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There are few certainties in life, but one of them is that lubricants leak. Regardless of how much effort is made to guard against leakage, it still occurs. In many industries, this isn’t necessarily an issue. In food-related industries, it is more of a concern, as lubricant cross-contamination in food would be a bad thing. For this reason, a special category of lubricants has been developed - food-grade lubricants. These lubricants must perform all the same functions as ordinary lubricants as well as be inert, tasteless, odorless and internationally approved.
The four categories of food-grade lubricants are classified based on the risk of contact with food, feed or pharmaceuticals. The original designations were H1, H2, H3 and P1. H2-designated lubricants were to be used in areas where no contact with food, feed or pharmaceuticals would be possible. H3 lubricants were used in applications where direct contact would occur, such as a rust preventative on a meat hook. P1 lubricants were to be used in accordance with the conditions set forth in the United States Department of Agriculture’s letter of acceptance and not in a food or beverage processing plant. The H1 designation is the most critical, as this category is for incidental contact.
A widespread misconception is that “food grade” indicates that it is acceptable for these lubricants to come in contact with food products or pharmaceuticals. H1 lubricants are for incidental contact, meaning that they are not intended to come in contact with food products or pharmaceuticals but are to be used in instances where contact may occur.
Prior to Sept. 30, 1998, the United States Department of Agriculture’s Food Safety and Inspection Service Division (USDA/FSIS) served as the governing body for food-grade lubricants. It granted approval based primarily on a lubricant’s formulation ingredients. Registrations approved before Sept. 30, 1998, remain in effect, with USDA H1 and H2 still standing as recognized approval for food and drug suitability.
After the USDA/FSIS ceased to be the watchdog for food-grade lubricants, three organizations stepped up to take a leadership role. These organizations were NSF International, Underwriters Laboratory (UL) and a working group from three lubricant industry professional associations: the National Lubricating Grease Institute (NLGI), the European Lubricating Grease Institute (ELGI) and the European Hygienic Equipment Design Group (EHEDG). Of these three groups, the Underwriters Laboratory has not been very aggressive in outlining its lubricant and chemical authorization program. The NLGI, ELGI and EHEDG group has been active in defining its version of the authorization program. Much like the NSF, their program mirrors the requirements of the former USDA/FSIS program.
A new standard relating to the definitions and requirements for food-grade lubricants was soon developed and submitted to the International Organization for Standardization (ISO) for consideration. In 2006 the ISO standard 21469-2006 was adopted. It is intended to be a step above the USDA requirements.
H1 - Lubricants used in applications where they might touch food, such as equipment over a food line.
H2 - Lubricants used in locations where there is no possibility that the lubricant or lubricated surface contacts food, e.g., equipment under a food line. Standard industrial lubricants may qualify as H2 lubricants as long as they do not include heavy metals such as detergent and anti-wear/extreme-pressure additives or compounds identified as carcinogens, mutagens, teratogens and mineral acids.
H3 - Water-soluble and typically edible lubricants used to control rust. An example would be a meat hook or a trolley.
P1 - Lubricants used in accordance with the USDA’s letter of acceptance and not in a food or beverage processing plant.
The scope of ISO 21469-2006 specifies the hygiene requirements for the formulation, manufacture, use and handling of lubricants that may come into incidental contact through heat transfer, load transmission, lubrication or corrosion protection of machinery with products and packaging used in food, food-processing, cosmetics, pharmaceutical, tobacco or animal-feeding-stuffs industries.
The hazards covered by this standard are associated with incidental product contact including biological, chemical and physical factors. Basic machine hygiene measures should be selected in accordance with ISO 12100-2010. Lubricants are classified in accordance with ISO 6743-99:2002 and are deemed safe for product or incidental product contact by any of the following: the Food and Agriculture Organization of the United Nations, the World Health Organization, the European Parliament and Council Directive 95/2/EC, and the U.S. Code of Federal Regulations (CFR) 21, Part 178.3570.
|56%||of lubrication professionals use food-grade lubricants at their plant, based on a recent poll at MachineryLubrication.com|
All of this falls under the larger umbrella of the Hazard Analysis and Critical Control Point (HACCP) system, which includes several different applicable standards such as the ISO 22000 series covering food-safety management. Sadly, there is not much oversight in this area, and compliance is voluntary for the most part. It is promising that several nations are working together to develop policies on food quality, labeling and recall processes.
The future of food-grade lubricants appears bright. As with most anything, education is critical. Currently, there is a large volume of conflicting and confusing information out there. Hopefully, this article will help to dispel a few of these myths and clear up some of the confusion.