SECTOR FOCUS: REGULATION
Clouds on the food grade lubricants horizon?
Andreas Adam, Fragol
The lubricant industry is currently encountering a wide range of concerning difficulties. Disruptions in supply, pricing fluctuations and above all a public sentiment against the sector are all among the considerations facing the industry. For lubricants and greases used in the mechanised food production there could be additional and more troubling concerns in the future that so far have been widely overlooked.
The main reason that little attention has been given to these is due to the way the various sectors work in their own circles. In the lube industry attention is given on product performance, availability, quality and development. Our users move in different circles and the have concerns around efficient production, marketing and meeting pressures from consumer organisations and legislators. Occasionally, as with the Mineral Oil Aromatic Hydrocarbons (MOAH) discussion, when these questions reach us, the lube industry moves together. Supplying high-performing products that support safe, good and efficient production.
The EU member states are engaged in ongoing work on initiatives to make our food safer. That is by itself recommendable, but if due care and attention is not paid, it comes with major implications for the future. Recently we have seen how increased scrutiny
18 LUBE MAGAZINE NO.170 AUGUST 2022
has led to greater regulation of Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) and Titanium Dioxide and many manufacturers and marketers were caught by surprise.
Our food production is widely impacted by the EU plastics regulation 10/2011. Under the plastics regulation several materials are regulated such as plastics, coatings, rubber, adhesives, ink and other contact materials. Lubricants are not contact materials and cannot and will not qualify as such. In the USA lubricants (for incidental food contact H1) are covered under the Code of Federal Regulations 21CFR178.3570 but that does not apply in Europe. In Europe, lubricants are not acceptable in food. The plastics regulation has a description for this; NIAS or non-intended added substances. The foodstuff producers need to meet a considerable number of demands in limiting, quantifying and establishing the toxicological safety of these components. The cost of the tox screening is very expensive and goes well beyond the cost of a single component required under EU REACH.
Lubricants and greases contain many components, from a selection of base oils to various soaps and multiple additives. Yet the volume of food grade lubricants used in production is small in comparison
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