Never before has the food industry been under such close watch. With consumers, special interest groups and regulatory bodies alike weighing in on every stage of food production from farm to fork, it has never been more important or complex for food processing manufacturers to stay on top of regulatory environment and quality assurance standards. The choice of lubricants plays a major role in this equation.
This scrutiny comes at a time when processing facilities are challenged to produce more, lower costs and keep plants running 24/7 in extreme operating conditions.
These challenges have led many food processing manufacturers to ask: how can I manage the requirements of the evolving food environment while still running my operation efficiently and effectively?
H1 & H2
Michael Choi, Ontario, Canada
When considering lubricant implications throughout food facilities, it is important to start with the basics, and that means truly understanding the differences between H1 and H2 food grade lubricants.
Despite the increasing number of food processing and food packaging facilities now using food grade lubricants, a surprising level of confusion exists around the use, labelling and regulations pertaining to these specialty lubricants.
H1 lubricants are used in areas of production where there may be the possibility of incidental contact with food. Therefore, these lubricants can only be composed of acceptable base oils and additives.
By contrast, H2 lubricants may be used in areas of a food processing plant where there can be no chance of contact, direct or indirect, with the food product. H2 lubricants are allowed in equipment and processes away from any possible points of contamination.
As the risk of contact is at least believed to be eliminated, H2 lubricants do not have a defined list of acceptable ingredients, but they do have restrictions on the use of compounds such as heavy metals and carcinogens.
More Regulatory Layers
Other certifications and programs that are important to consider, whether or not they have yet to be made mandatory, are the use of Hazard Analysis and Critical Control Point (HACCP) plans and the International Organization for Standardization (ISO) Certification, ISO 21469:2006 [E]—Safety of Machinery—Lubricants with Incidental Product Contact.
The use of HACCP plans are being written into food safety legislation that governs essentially all food production. While HACCP was brought to life in the 1960s in order to test food made for NASA, it has grown by leaps and bounds over recent decades. HACCP plans also serve as the basis of all food safety programs under the Global Food Safety Initiative (GFSI).
A safety standard that is growing in importance for manufacturers of food grade lubricants is ISO 21469. This credential specifies the hygiene requirements for the formulation, manufacture, use and handling of lubricants that may come into incidental contact with food during processing.
What is the difference between ISO 21469 Certification and NSF H1 Registration?
In addition to the formulation and label review requirements for H1 registration, ISO 21469 Certification also requires that a full risk assessment be carried out on the lubricant manufacturing plant; that the plant be audited by an independent third party to ensure that all certification procedures and requirements are met; and annual sampling, testing and re-auditing take place to verify that the food grade lubricants continue to use only FDA-approved additives to the originally submitted formulation—a significant point of difference for a lubricant supplier.
This standard does not replace the globally recognised NSF H1 registration for incidental contact, but rather, complements it. Certifications like ISO 21469 may not currently be mandatory but they do go a long way toward providing operations managers and even concerned customers added confidence and peace of mind.
Serving Market Needs
Though contamination and food safety regulations are top concerns, various cultural and dietary attributes are becoming major considerations for food processing manufacturers, especially given the realities of globalisation.
Attributes such as having Halal, Kosher and Pareve certifications, and being ‘free’ from recognised allergens, are on their way to becoming table stakes for many manufacturers. To be Halal, Kosher and Pareve certified, there must be no contamination with a substance prohibited by Islamic or Jewish law during the preparation, production or storage of the product.
Though these standards are not needed across all facilities, those that do cater to unique consumer demands are faced yet again with additional considerations when it comes to finding food safe lubricants that meet all of their product and equipment demands.
Managing Lubricant Complexity
Steven Depolo, Miami, US
Seth and Alexa Andrzejewski, California, US
A major challenge we hear from today’s operations managers is simply managing the segregation of lubricant products within the same facility. It takes tough lubricants to stand up to the conditions found within food processing facilities and not all conditions are the same for every facility, every machine or every product.
From climate and cleaning methods to the increased complexity and non-stop operations encountered during everyday processing activities, these lubricants face a variety of intense challenges.
The common method used to combat these challenges, along with mixed regulatory demands, is to build an inventory of products made to address each individual issue. And in some cases, this means using both H1 and H2 products in plants.
However, although H2 lubricants are acceptable for use in food plants where there is no possibility of food contact, the strict guidelines for usage outside of contamination points do not entirely mitigate the fear of contamination for plant operators—yet another layer of complexity for operations managers.
Not to mention, with this collection of various lubricants comes the task of ensuring that all frontline workers are aware of the different requirements and registrations for different pieces of equipment and/or products.
How can operations managers avoid the confusion while still creating a more efficient operation?
To avoid the headache of managing a large inventory and remove any issues of possible contamination from H2 products, many of the more food-safety-conscious producers are turning to food grade, food safe lubricants in every area of their facilities, from their release agents to the hydraulic systems in their forklifts.
This helps facilities create an inventory of fewer products to address multiple issues while still meeting, and often exceeding, industry standards. Essentially, this means creating a program with high performing, certified, and multifunctional H1 products.
These responsible producers often take their cue from agencies such as the GFSI that provide a benchmarking tool from which producers can gather their food safety requirements for the food supply chain to ensure greater protection and transparency for consumers.
The risk of H2 contamination has many advocacy groups lobbying for a recommendation that only H1 lubricants be used throughout food processing plants and machinery to eliminate accidental grease or oil contaminations that can lead to food safety issues.
With high quality H1 lubricants available for today’s food processing plants, why take the risk?
Meeting Demands Without Compromise
Though it is essential to follow regulations, food processors always need to ensure that their lubricants are serving their fundamental purpose in properly protecting their machinery.
Thankfully, today’s processors do not have to sacrifice one for the other. Food grade lubricants have come a long way. With the right food safe, plant tough lubricant solution, food processing manufacturers can now employ food grade lubricants across their full facilities, with the confidence of knowing those products are tough enough to stand up to the job.
Start From The Beginning
A complete plant survey is the perfect place for operations to start when considering a food grade lubricant switch. It can help to uncover needs of the plant and how to best service the equipment that is used each and every day—which means better results and better value for the manufacturer.
For example, a plant had previously inventoried a total of 60 food grade lubricants from eight different suppliers. A complete plant survey uncovered that they were able to consolidate their use of 60 lubricants into only 12 food grade lubricants across their facility. This helped to ensure that an incorrect product was not used and also helped to save them time, money and even space that once housed their growing inventory.
While the decision surrounding which food grade lubricants to choose may not affect the bulk of an operations manager’s budget, the ramifications of choosing the wrong product or supplier can be huge, especially if a case of incidental contact occurs between the food and anything other than a food grade, food safe lubricant.
Recalls are damaging to a manufacturer’s production and reputation—and the thought of such issues can keep food producers and operations managers up at night. The right products and the right supplier-to-producer partnership are integral to the success of the manufacturer.