When Are Food-grade Lubricants Required?

Noria Corporation

"Which types of machinery require food-grade lubricants?"

There is not a specific type of equipment that requires food-grade lubricants. Instead, the requirement is based on the application. Any application in which there is a possibility of incidental contact or intentional direct contact with food would require the use of food-grade lubricants.

Most people who work in and around food manufacturing, processing and packaging are aware of the H1, H2 and H3 designations. These designations were established by the United States Department of Agriculture (USDA) and represent the various categories of food-grade lubricants.

H1 lubricants are identified as being food-grade lubricants used in food-processing environments where there is the possibility of incidental food contact. H2 lubricants are food-grade lubricants used on equipment and machine parts in locations where there is no possibility of contact. H3 lubricants are food-grade lubricants, typically edible oils, used to prevent rust on hooks, trolleys and similar equipment.

The relatively new Food Safety Modernization Act (FSMA) of 2011 has changed the way companies treat lubricants for their food-related plants. The term "food-related" would include the paper plant that makes the box in which your cereal is packaged, the plastic manufacturer that makes the wrapper on your candy bar, and the stamping facility that makes the can for your soda. Along with imported food, this legislation also covers the manufacturing, packaging and shipping of pet food as well.

When the FSMA was introduced, it was the first legislative mandate to the Food and Drug Administration (FDA) to require controls across the food supply. It also established registration fees. More importantly, under the FSMA there is the potential for criminal charges and/or fines for the "responsible" individuals when a violation occurs. These individuals can be anyone from the lubrication technician all the way to the company president and CEO. If the violation results in a death, the fines can be as much as $500,000 with up to three years in prison.

While this legislation was signed into law in 2011, there are windows of implementation based on the size of the plant or company. However, many of the deadlines have already passed. Also, keep in mind that there are considerable documentation requirements. Therefore, it is imperative to research the requirements to ensure you are in compliance.

The FDA's website provides additional information regarding the changes in this legislation. Several organizations also offer training specifically related to the FSMA, its potential impact, and the steps you can take to safeguard yourself and your organization from criminal liability.

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