By Lisa Tocci

One of the tastiest, most profitable niches in the industry – H1 lubricants sold to the food and beverage industry – is also one of the most closely scrutinized. As Andre Adam of the German lubricant company Fragol says, Food is emotion. We like it, we need it, we eat it (sometimes too much of it) and many people do not get enough of it. In all cases, it has our attention many times per day, every day.

Of course, food also has the attention of government regulators, suppliers of food processing machinery, standards organizations and food buyers and sellers. And some of these groups want to see lubricant manufacturers take a more active role in ensuring food safety.

The European Hygienic Engineering & Design Group, for example, is weighing a recommendation that only H1 lubricants be used throughout food-processing plants and machinery, so there is no way consumers could be sickened if the food were accidentally contaminated with a grease or oil. H1 lubricants are odorless, colorless and nontoxic, and designed for use wherever incidental contact with a foodstuff might occur. Suppliers must follow strict U.S. regulations covering their ingredients and appearance.

EHEDGs idea is to update its guidance on lubricants for the food industry (published as Document 23) and bluntly to declare that H2 lubricants – which are allowed in equipment and processes where no food contact can possibly occur – are not to be used anywhere in food processing plants. EHEDGs subgroup on lubricants has said that there are many cases where operators knowingly or unknowingly use H2 lubrication for production sites in which H1 products are required. Its previous position was that raising general awareness and customer training would prevent this, but the groups unease about the similarity of the two names has grown.

H2 lubricants are NOT safe for use in food production because they might be toxic! the lubricants subgroup strongly asserted in a January bulletin. EHEDG would welcome concerted action of the lubricants industry by combining its efforts in order to raise the awareness of food safety as a signal towards the market and politics, and by promoting a clear and undisputed policy regarding food grade lubricants.

Adam sees this as an unequivocal call to action. The food industry wants us to take leadership on this topic. If we dont do anything, eventually regulatory parties will come up with rules, or even a ban. Education would take confusion out of the equation.

Both H1 and H2 categories were established by the U.S. Dept. of Agriculture, but the agency stopped enforcing them in 1998. Ever since, products claiming to meet the categories have been self-certified by the maker or registered with an independent reviewer, such as NSF International or InS Services.

InS no longer accepts new products for H2 registration, viewing it as unnecessary. NSF has taken a different tack, and has been trying to educate users about the differences between these two classes of products. It stresses that H2 lubricants should never be called food-grade, and that images of food should not be displayed on H2 product labels, so as not to mislead buyers into thinking they are suitable for food machinery. But NSF is hesitant to do away with all oversight of the category – especially if it is actually useful for some stakeholders. And without some independent review in place, somewhere, a few players worry that abuse and mislabeling of H2 products would become rife.

Regulators are already becoming tougher in this area. Brazil for example – which is a food and agriculture giant – has promulgated new rules for the makers of food-machinery lubricants. The countrys National Petroleum Agency in April issued final rules that oblige suppliers of H1 lubricants and greases to have their manufacturing plants certified to ISO 21469, the international standard which outlines the hygiene requirements for formulating, producing and handling these lubricants.

Some companies involved in making H1 lubricants have embraced ISO 21469 certification as good practice, or at least good marketing, while others feel that it is overly burdensome, risks disclosure of their formulations, and is already addressed through their ISO 9001 certification. But Brazils move could force wider adoption of 21469, especially if other countries decide to follow its regulatory lead.

Many of these issues were debated recently by a joint working group of the European Lubricating Grease Institute and the National Lubricating Grease Institute. The groups focus is two-fold: on end users, and on lubricant manufacturers themselves.

Dick Burkhalter of Covenant Engineering Services in Branson, Mo., which designs and engineers lubricant and grease plants, notes that the first line of defense really begins at the lubricant manufacturing facility. He recently led an NLGI task force in drafting guidelines for making food-grade greases, from raw materials to blending to packaging to storage.

The draft is still under review, and he said that these are not mandatory, not required, theyre just guidelines. They emphasize the need for segregating the products and raw materials that go into them. And they emphasize the need to isolate the production process, to prevent any contamination. And once theyre made, they emphasize how to protect the products to keep them in compliance.

The idea is that the industry can be one step ahead of the regulators, so we dont have those who know nothing about making grease trying to tell us how to make it.

As Burkhalter explained to LubesnGreases, dedicated blending units are a must for making H1 lubes, since many industrial and automotive lubricants use ingredients, such as zinc-based antiwear additives, that are banned from any contact with food. Not only should these units be dedicated, but they ideally should be isolated from the rest of the lubricants plant.

If you are dumping sacks of additives into open tanks and your food-grade lube units are not totally protected from it, all that dust and material could easily blow around the lube plant and contaminate your food-grade lubes, Burkhalter reminded. And while some producers think they can make food-grade lubes with the same blending equipment as regular lubes, by simply flushing it out between batches, thats unlikely to work, he said.

Many of the additives used in conventional lubricants are highly surface-active on metals, and you cant easily flush them out of the blending tanks and fittings, he observed. Even in minute amounts, theyll contaminate your food-grade lubricants and make them unfit for use. You need to have dedicated process units for making food-grade lubes.

Taking things further, some voices in ELGI have begun calling for a code of conduct for producers and marketers of food-grade lubricants. It would cover the type of information, the size of logos, and the use of misleading promises in marketing these lubricants, Andre Adam told LubesnGreases.

Adam said a code of conduct would establish basic principle for those making these lubricants, such as giving complete and accurate information to customers, being clear on labels about their proper application, and refraining from false or overblown marketing claims. (His favorite example of such hyperbole is one manufacturers boast that its lubricant is so pure you can eat it.) The subsequent step would be to issue guidelines on how to label and promote H1 lubricants.

Not everyone is enthusiastic about having either manufacturing guidelines or a code of practice. This could have unexpected consequences, confided one grease manufacturer. He worries that a few vocal activists could be overreacting, or trying to steer things to favor their own commercial interests.

I think we should look at this carefully, and go slowly. It may not be needed, and meanwhile, it distracts us from far more important issues – like the fact that 60 to 80 percent of the worlds food plants still arent using H1 lubricants at all in areas where food contact is a real risk, this commenter said. Thats a far greater need, and Id like to see us paying more attention to educating these customers.

Others point out that a code of practice is only as good as the companies that adopt it; good companies already adhere to such practices, and those who are unethical will have no qualms about abusing it.

Meanwhile, NSF is prepared to rethink the H2 category, if that is what stakeholders in the food industry, government agencies and lubricants business want, said Ashlee Breitner, business manager of NSFs non-food-compounds registration program in Ann Arbor, Mich. She told NLGI that NSF will start by gathering information on the value of the H2 designation, creating a survey and putting it out to the stakeholders in the food and lubricants industries. It expects to have the surveys results available by late October, in time to report on the findings at its annual non-food-compounds stakeholders meeting.

More Opportunities to Learn

Stay abreast of developments regarding food-machinery lubricants, their manufacture and application at these upcoming meetings:

23-24 September.

ELGI/ICIS Food Grade Lubricants Conference, Berlin, Germany. Details: www.icisconference.com/foodgradelubricants or sarah.j.butler@rbi.co.uk

29 October.

NSF Internationals non-food-contact stakeholders meeting, Ann Arbor, Mich. Details: www.nsf.org or nonfood@nsf.org

17 or 18 November.

ELGI Working Group on Food-grade Lubricants, Amsterdam, Netherlands. Details: www.elgi.org or a.adam@fragol.de

Whats Allowed in H1?

U.S. federal regulations govern the ingredients that are acceptable for making H1 lubricants. Base fluids that are allowed include white mineral oil, polyalphaolefins, silicone fluids of viscosity greater than 300 centiStoke, PFPE, polybutenes, and certain grades of polyalkylene glycols.

To this list, the lubricants industry now can add a newcomer: On May 16, Dow Chemical received a favorable Food Contact Substance Notification from the U.S. Food and Drug Administration, allowing its oil soluble polyalkylene glycols to be used in lubricants for incidental food contact. Specifically, the FDA has approved the ISO 32, 46, 68, 150 and 220 viscosity grades of Dows OSP.

Acceptable grease-thickener chemistries for H1 include anhydrous calcium, aluminum complex, calcium sulfonate complex, calcium oleate, silica, PTFE and some clay and polyurea types. No lithium or lithium complex greases have been approved for this use to date.

Additive selections are quite limited, but do include several types of antioxidants, polymers, extreme-pressure agents, antiwear and corrosion inhibitors. No toxic or metal-based products can be used, such as zinc dithiophosphates, and the allowed volume of each additive is narrowly defined – often minute in fact.

The full list of FDAs acceptable ingredients for non-contact food-grade lubricants can be seen at http://www.fda.gov/Food/IngredientsPackagingLabeling/PackagingFCS/Notifications/default.htm.