Food Grade Lubricant Registration 101

Tuesday, September 19th, 2017

What is there to look for when sourcing chemicals for use in your food processing or production operations? Sometimes this can be confusing, but here’s a quick 101 guide to help manufacturers understand food grade lubricants and the registration process. By Ashlee Breitner, business unit manager, Nonfood Compounds, NSF International

Ask yourself, are the lubricants you are using in your food facility safe? As you source chemicals such as lubricants for use in the production process of food, do you ever find yourself asking “Is this really appropriate for me to be using near food?” or “Is there a risk associated with using this product around food?”

For manufacturers, understanding the basic elements of what to look for when sourcing chemicals for use in a food processing or production facility can sometimes be confusing. The following article will help to explain what product registration is, the prominent lubricant categories and their end-use applications, how product registration works and why it is an important component of a food safety program.

Who Seeks And Grants Registration?

Whether in food processing, manufacturing or food service, the handling, preparation, processing and packaging of food products of all types inevitably involves the use of equipment and machinery with lubricated moving parts that come into contact with the foodstuffs.

Just think for a minute about all the chemical products used prior to, during and after processing. The potential for nonfood materials to have incidental contact with a food product is a hazardous cross-contamination risk and must be controlled as part of the facility’s overall hazard analysis critical control point (HACCP) approach.

A prerequisite approach to a risk-reduction plan is the use of registered nonfood compounds and more specifically food grade lubricants. ‘Nonfood compound’ is an industry term used to describe lubricants, greases and other chemicals used in and around food processing areas. With the potential for contamination of the foodstuff, it is vital that these compounds and substances adhere to strict standards of safety and quality.

The US Department of Agriculture (USDA) formerly reviewed and authorised nonfood compounds acceptable for use in food processing and handling facilities. In 1999, NSF International, a not-for-profit public health organisation took over the responsibility of evaluating food grade lubricants and other food processing substances.

Working with the USDA, the organisation captured all previous review requirements and launched a third-party registration and listing program for these nonfood compounds represented by category codes developed based on the particular intended end use of the product. Today, this registration has a global reach with products produced in over 50 countries (including China, Hong Kong, Japan, Korea, Malaysia, Singapore and Taiwan) and continues to grow as food safety becomes more and more of a concern to consumers, producers and regulators.

What Are The Registration Categories?

Product registration category codes have been developed to ensure that all products intended for specific applications are reviewed equally against the necessary criteria for that product’s intended end-use application. The criteria are often based on regulations in place for a particular product, ingredient or material type and also take into consideration key aspects of the process used to manufacture the product. While being applied in a production process, something as simple as a letter grading may not seem extremely important, but the impact of using the incorrect product could lead to a significant risk potential and possible food contamination.

Let us use lubricants as an example. There are two main product categories for lubricants used in the food industry, which designate the different intended end-use applications for a particular product. The most well-known is the H1 lubricant category.

An H1 lubricant is intended for use in applications where there is only potential for incidental food contact, as in the case of anti-rust agents or release agents for gaskets or seals of tank closures. Although this category implies the possibility of incidental food contact, the use of the minimum amount of lubricant in order for it to be effective for its purpose is recommended; overuse can transfer the material onto food or build up residual lubricant, which are genuine risks.

The second category of lubricants is the H2 category. H2 commonly gets confused with H1, though the two are very different. In fact, H2 categorised lubricants are not intended to be in contact with foodstuff at any time, not even incidentally. As such they are not food-grade products.

H2 lubricants are intended to be used on equipment where there is no possibility of food contact or residual cross-contamination and should not be applied in a production process at any point where there is a recognisable or incidental cross-contamination control point.

As such, these two product categories are approved for very different uses. Understanding product categories is therefore critical in the sourcing and use of these products in your production facilities.

There are currently over 90 product categories used to identify an end use in which a particular product is registered. Below is a list of just a few of the more prominent categories; note the differences in the end-use applications:

Prominent Product Registration Categories
Category Designation Category Code Acceptable End Use
H: Lubricants H1: General – Incidental
food contact
Lubricant with incidental food contact for use in and around food processing areas.
Such compounds may be used on food processing equipment as a protective anti-rust film,
as a release agent on gaskets or seals of tank closures, and as a lubricant for
machine parts and equipment.
A: Cleaning Products A1: General cleaners General cleaner on all surfaces in and around food processing areas, where its use
is not intended for direct food contact.
C: Non-Processing Area Products C1: General For use in inedible product processing areas, non-processing areas and/or exterior
areas of food processing establishments provided that it is not used to mask odours
resulting from unsanitary conditions, and that any characteristic odour or fragrance does
not penetrate into an edible product area.
G: Water Treatment Products G5: Cooling and retort
water treatment products—
all food processing areas
This product is acceptable for treatment of cooling and retort water in and around
food processing areas.
G6: Boiler treatment products—all food
processing areas/food contact
This product is acceptable for treating boilers or steam lines where steam produced
may contact edible products and/or cooling systems where the treated water
may not contact edible products in and around food processing areas.

How Are Lubricants Registered?

In order to register a lubricant, the formulation (including ingredients and percent composition) must be submitted to the registration body. This formulation will then go through an independent review against the requirements and must be formulated in compliance with 21 CFR, Section 178.3570 or other applicable sections.

In addition to the formulary requirements, the finished product label must also be submitted for review. The labelling must be accurate with no misleading claims and include appropriate end-use instructions. Product labels must also be traceable to the registered company and bear the registration mark, including the category code and unique product registration number.

For registered products, this label review should provide end users with the added reassurance that the claims made on the label are accurate and the suggestions for end-use application are appropriate.

Nonfood Compounds Registration In Asia

From products that should have no food contact such as cleaners and degreasers to antifoaming agents that are intended for direct food contact, these chemicals are present in almost all parts of the production process.

Over the past five to ten years, product registrations for nonfood compounds used in food processing facilities have grown consistently, as food safety and risk mitigation have become increasingly important in the food industry. Asia is a growing region for the production of these petro chemicals and key players in the region, such as Lubricant Company Sinopec Corp and Apex Grease Company, are making the region competitive in the food-grade lubricant sector.

China has become the leader in the Asian market in terms of its focus on strengthening food safety regulations by expanding laws to include various aspects of food manufacture and packaging, including processing compounds that could potentially contact food. In addition, China is a fast-growing market for the manufacture and purchase of registered release agents (3H). These products are used on food contact surfaces, such as grills and chopping boards, to prevent food from adhering during processing.

The Food Hygiene Law of the People’s Republic of China sets forth the standards and requirements for ensuring food hygiene and protecting food products from contamination with harmful substances. The law is applicable to all parties engaging in food production or marketing food products within the territory of the People’s Republic of China.

It also applies to all foods and food additives as well as containers, packaging, utensils and equipment used for food, detergents and disinfectants. In addition, it covers the premises, facilities and environment associated with food production or marketing.

While the law does not specifically call for hygiene standards for food-grade lubricants, it clearly states that harmful substances must not be introduced into processing environments. Today, demand for food-grade lubricants is increasing in China, driven largely by rising awareness within the local food processing community and the desire to export food products to Europe and North America.

The Importance Of Using Registered Lubricants

As today’s food manufacturers realise the importance of identifying contamination risks, the use of correctly registered products for the different applications in facilities provides a reliable prerequisite approach to complement a HACCP plan. While HACCP plans tend to focus on the handling of the actual ingredients and products, manufacturers now also need to consider seemingly peripheral aspects such as the lubricant on a chain. What may seem to be a minor issue could have a massive impact on a product, a company’s reputation and public health.

The use of registered H1 lubricants as part of a strong HACCP plan that looks at both the chemical and physical risks associated with food processing is an important and critical step toward completing certification to the Global Food Safety Initiative (GFSI) benchmarked standards.

In addition, the use of registered products is important, not just at the food manufacturer level, but even before that, at that of the manufacturer’s ingredient suppliers. Using registered products and ingredients is a critical link in the supply chain and one that can influence the success of achieving certification to a GFSI benchmarked standard.

The market for registered food-grade lubricants is growing fast, both because of the proliferation of new product development and, more importantly, because of the rapidly increasing demand for third-party registered products by food processors. Understanding what the product categories are, the value of sourcing and how to appropriately apply registered products are critical elements of a production facility’s quality plan and should be considered very closely by those responsible.