If process adaptation or replacement of machinery fails to rule out potential contamination entirely, the question of ‘what to do now?’ arises. Up to this point there are laws giving the answers to this type of question (such as EU regulation 1935/2004 which sets the framework for direct contact materials such as plastics for containers, cutting boards, etc.) but once the hazard ‘unavoidable incidental lubricant ingress’ has been identified, the plant owner is left with recommended daily intakes which the consumer can tolerate. But these amounts refer to cumulative intake from every source the consumer is exposed to. Therefore these recommendations are of very little help when it comes to choosing a lubricant (especially since the plant owner does not know the lubricant’s ingredients). Luckily the United States’ national legislation takes a more specific approach to this problem.
The United States Code of Federal Regulations (CFR, more specifically Title 21, §178.3570) explicitly states which ingredients lubricants with incidental food contact may contain. These ingredients are screened and added or removed by the US Food and Drug Administration (FDA). The CFR also states fixed limits for each approved component thereby giving the lubricant producer a clearly defined target to be met. Depending on what the application is, the unavoidable (incidental!) ingress of a lubricant or other material can vary greatly which makes choosing the right product all the more important.
Food Grade lubricants categories and applications Because the concrete definition of allowable substances in a lubricant for incidental food contact was (and still is) defined by US national legislation, the official recognition of such a lubricant was up to a US government authority. This meant that up until 1998, all lubricants for incidental food contact had to be submitted to the United States Department of Agriculture (USDA) which checked the components against the ingredients list of the CFR. After this check of a product was complete, it was categorised according to a system which defined it as an H1, H2 or H3 product. This lead to our current term ‘H1 lubricant’ for a lubricant approved for incidental food contact. Interestingly enough, H2 products are actually not allowed to
have food contact and this has lead to many a misunderstanding when it comes to which product to use for a food application. This misunderstanding is currently the basis for debate in the lubricant world since key lubricant producers and at least one registration company are opposing the use of H2 registrations entirely. This also leads us to the current state of affairs post 1998.
After the USDA discontinued their work of registering and authorising H1 lubricants, this task was taken over by the NSF (formerly ‘National Sanitation Foundation’, based in the US) who stepped in so successfully that an H1 registration is often only called an ‘NSF approval’. But since the service which is offered is no longer a government privilege, at least one other private sector company has come into the market (InS in the UK) which offers to check the lubricant’s formulation against the CFR list and confirm that the product in question is in fact H1.
The USDA category codes (H1, H3, etc.) are often used to define what kind of lubricant is needed for a technical application because this is an easy way to compare requirements and the properties of a potential lubricant.
• An H1 lubricant (and these are the majority in this little portion of the lubricant business) may enter the food which is produced if the ingress is not planned, but unavoidable. This might be the case for an air compressor lubricant which is finely dispersed and can, on occasion, make its way through the entire system to finally settle on the product which is being transported, dried or otherwise handled by compressed air. A chain oil on an oven chain may, if not chosen correctly, lose volatile components which are then in the air with the goods being baked. It is also possible that a hydraulic system has a leak which then sprays large amounts of fluid throughout the area. If the spray lands on any food, the 10ppm amount is undoubtedly exceeded. But the H1 hydraulic fluid gives the operator the opportunity to disassemble and intensely purge only that part of the production floor which was directly affected without having to take apart the entire factory for fear of residues which might not even be visible to the naked eye.
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LUBE MAGAZINE NO.130 DECEMBER 2015
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