Successful lubrication management programs are vital to food and feed safety.

In any manufacturing environment, lubrication is critical to equipment functionality and longevity. In food and feed facilities, it is imperative that lubricants do not contaminate your product and pose a health hazard. Understanding how to safely utilize lubricants in your food and feed facility is vital to consumer health and your company’s success. 

Product adulteration due to non-approved or toxic lubricants results in recalls. Products such as sliced turkey, smoked hams, infant formula and milk powder have been recalled because of lubricant contamination.1 Consumers reported that these products tasted bad, smelled like tar, caused intestinal discomfort and burning in the throat for up to three hours.1

Implement a successful lubrication management program to help your company minimize the likelihood of products contaminated with lubricant.

Current Good Manufacturing Practices (CGMPs)

The CGMPs are the basis of food safety.2 They state that food is adulterated when it is manufactured under conditions that make it unfit for consumption or when it has been prepared, packed or held under unsanitary conditions where it may have become contaminated or hazardous to health.3

All third-party audits look at chemical control programs, which include lubricants. The CGMPs specifically address chemicals and lubricants in terms of maintaining sanitary operations.4 Further, the CGMPs explain that the design, construction and use of equipment and utensils can help prevent the adulteration of food with lubricants and other contaminants.5 Learn more about these regulations in 21 CFR § 110.35, 110.40 on the US Code of Federal Regulations (CFR) website .

What is a food-grade lubricant?

Food-grade lubricants are similar to other lubricants, except they must also:

  • Resist degradation from food products, chemicals, water and steam
  • Exhibit neutral behavior when in contact with plastics and elastomers, such as rubber
  • Be physiologically inert, odorless, tasteless, nontoxic and harmless
  • Comply with the food safety regulations found in 21 CFR § 178, specifically part 178.3570 6,7

The US Food and Drug Administration (FDA) regulates the substances used to prepare lubricants, ingredients that are generally recognized as safe, as well as concentration limitations of each substance in the lubricant.6,8 Learn more on the US CFR website.

US Department of Agriculture (USDA) food-grade designations

The USDA created the original food-grade designations, which became the industry standard. The USDA would evaluate the manufacturer’s lubricant formulation to ensure they were allowable substances.9

The original USDA food-grade designations are:

  • H1: Food-grade lubricants used in food processing environments where incidental contact with food, feed or ingredients is possible
  • H2: Food-grade lubricants used on equipment and machine parts in locations where contact with food, feed or ingredients is not possible
  • H3: Food-grade lubricants, typically edible oils, used to prevent rust on hooks, trolleys and similar equipment
  • HT1: Used as heat transfer fluid in primary and secondary heating and cooling systems9

Note: H1 and H2 are considered nonfood compounds. They are not intended for direct food contact or to become a food component. H1 was created for the possibility of incidental contact.6

Unfortunately, this program was discontinued in 1998 due to a lack of funding.9 Registrations granted prior to this date are still effective and you will continue to see H1 and H2 on many lubricants.10

National Sanitation Foundation (NSF) International registration

Lubricant manufacturers now submit a file for review by the NSF, which manages the Nonfood Compounds Registration Program.6

Upon successful completion of the review, the NSF issues a registration letter. They also post the registration letter in The White Book, which contains the listings of thousands of NSF-registered lubricants from hundreds of companies around the globe.6

Registration is complete when the registration number, category code and NSF registration mark appear on the product.6

Develop a lubricant management program

A lubricant management program should be a component of your preventive maintenance and chemical control programs. It is important to identify and account for all lubricants utilized in your facility and ensure all responsible personnel are aware of their intended use. Take the steps below to follow industry best practices in your lubrication management program.

Step 1: Reduce the number of lubricants in your facility

Make a list of all lubricants in your facility and organize it by type – H1, H2, H3 and HT1. Keep the following documents on file for each lubricant: The Safety Data Sheet and the registration letter detailing the lubricant’s intended purpose.

After doing this, companies often realize they have accumulated a large number of lubricants – many accomplishing the same purpose. This may be due to changing suppliers or having received free samples from salespeople.

Set a goal to minimize this list and work with your maintenance manager and supplier to determine which lubricants are necessary. Many companies are able to reduce to 5-10 lubricants instead of 20-30.

Step 2: Organize and label your storage areas

Organize your primary and secondary storage areas. Remember, many third-party audits request secured storage areas that limit chemical access to authorized personnel.

Lubricants are usually stored in the chemical storage area of the maintenance shop and should be segregated from other chemicals. All H1 lubricants should be further segregated from other lubricants to help prevent cross-contamination.

Industry best practices typically segregate H1 lubricants by designating and clearly identifying a shelf or cabinet for their storage. If they are kept in the same cabinet, H1 lubricants should be stored on shelves above other lubricants.

Additionally, secondary storage areas, such as chemical cabinets or maintenance carts, should be organized and all lubricants properly identified. Poorly maintained storage areas create easy opportunities for mistakes.

Lubricants transferred to secondary containers, such as grease guns, must be properly labeled to identify the lubricant type. Labeling may be done by color coding, engraving, tagging or another means that is legible and will not fade or smear with use.

Step 3: Identify areas of lubricant use

Identify all areas of lubricant use – on machinery and throughout the facility – and incorporate them into your Preventive Maintenance (PM) program. Assign a work instruction to each PM task. The work instruction should detail how to complete the task, including which lubricant to use, how much to apply and how often it is needed.

Accurate lubrication application is critical for food safety and preventing accidental equipment damage. Help ensure that maintenance technicians apply the right lubricant to the right lubrication point by labeling or engraving lubrication points or using color coded caps that match the correct lubricant type.

You may want to assign a code to each lubricant instead of listing the manufacturer name. You could utilize a master list detailing the manufacturers that correlate with each code. The advantage to this practice is that you can simply update the master list to reflect changes in supplier or lubricant types instead of updating the work instruction at each machine and facility location where it is used.

Step 4: Train maintenance technicians and lubricators

Train and educate your maintenance technicians or lubricators. You may have dedicated lubricators or multiple people assigned to lubrication tasks. Either way, it is imperative that these employees fully understand lubricant type designations and their intended uses.

One of the biggest misconceptions in the food industry is that substances labeled “food-grade” are safe and acceptable if they get into the food product. Food grade lubricants are not intended for direct food contact or to become a component of the food. H1 was created for the possibility of incidental contact.

Instruct your maintenance technicians or lubricators to thoroughly clean up any excess oil or grease to prevent accidental contamination of food or food-contact surfaces.

Step 5: Maintain lubricant inventory and usage logs

Maintain lubricant inventory and usage logs to track the amount of lubricants in your facility. Inventory and usage logs serve a variety of purposes such as ordering and meeting third-party audit requirements.

It may seem overwhelming at first, but the goal is not to track lubricants to an overly specific amount. The purpose is to have an overall idea of the quantity present.

Bulk liquids can be tracked on a log located at the container as individual quantities are removed. Containers, such as aerosol cans or grease cartridges, can be tracked as individual containers are removed from storage. General chemical inventory logs can serve these purposes.

Step 6: Use preventive devices and sanitary design

Evaluate lubricant points of use, such as bearings and gearboxes. If they are located where lubricant may leak or drip onto food or a food-contact surface, you must properly install a catch pan, deflector plate or another means of containing all of the lubricant or preventing contact.

The work instructions for PM tasks should require the maintenance technician to evaluate the condition and cleanliness of the catch pan or deflector plate. List these devices on your master cleaning schedule for periodic cleaning and/or sanitizing. Remember, catch pans and deflector plates are preventive devices, not an excuse for poor lubrication practices or leaking equipment.

Consider sanitary design of equipment and systems for future installations. Whenever possible, design and install gearboxes and bearings so lubricant will not leak onto food or food-contact surfaces.

Establish a lubricant management program

Food-grade lubricants are necessary to produce a safe product in any food or feed facility and ensure proper equipment function. Establish a well-developed lubricant management program that provides essential lubricant control and helps prevent product contamination. Train and educate all personnel who are involved in carrying out this program.

Contact your Nationwide risk management consultant to learn how our team of food safety experts can help you create a safer workplace.

[1] Judge, Diana. “Switching to Food-Grade Lubricants – Provides Safety Solution. ” Machinery Lubrication, a Noria Publication. July 2005.
[2] 21 CFR § 110. “Current Good Manufacturing Practices. ” US Food and Drug Administration. Note: In September 2018, the CGMPs will become 21 CFR § 117 per the Food Safety Modernization Act.<<br/> [3] 21 CFR § 110.5. “Current Good Manufacturing Practices – General Provisions. ” US Food and Drug Administration. Note: In September 2018, the CGMPs will become 21 CFR § 117 per the Food Safety Modernization Act, making this citation 21 CFR § 117.5.
[4] 21 CFR § 110.35. “Current Good Manufacturing Practices – Sanitary Operations. ” US Food and Drug Administration. Note: In September 2018, the CGMPs will become 21 CFR § 117 per the Food Safety Modernization Act, making this citation 21 CFR § 117.35.
[5] 21 CFR § 110.40. “Current Good Manufacturing Practices - Equipment and Utensils. ” US Food and Drug Administration. Note: In September 2018, the CGMPs will become 21 CFR § 117 per the Food Safety Modernization Act, making this citation 21 CFR § 117.40.
[6] Turner, David. “Food-Grade Greases. ” Machinery Lubrication, a Noria Publication. November 2007.
[7] 21 CFR § 178.3570. “Lubricants with Incidental Food Contact. ” US Food and Drug Administration.
[8] 21 CFR § Part 178. “Indirect Food Additives: Adjuvants, Production Aids and Sanitizers. ” US Food and Drug Administration.
[9] Lawate, Saurabh. “What You Need to Know About Food-Grade Lubricants. ” Machinery Lubrication, a Noria Publication. July 2007.
[10] Williamson, Martin. “Understanding Food-Grade Lubricants. ” Machinery Lubrication, a Noria Publication. January 2003.
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