According to Tyler Housel, vice president of the Lexolube Division of Inolex Inc., The food industry focuses primarily on the safety and quality of food ingredients themselves. Although food processing lubricants receive less attention, food lubricant suppliers must hold food safety above all other concerns.

In a presentation at the OilDoc Conference in Rosenheim, Germany, in January, he emphasized that lubricant manufacturers should work together to define best practices and ensure that food processing lubricants are properly manufactured and applied. He then reviewed the status of industry and government efforts globally.

A current debate exists regarding ingredients with GRAS status, Housel said. The United States Food and Drug Administration states that any compound that is Generally Recognized as Safe for food is an acceptable ingredient for incidental food contact lubricants.

However, since 1997, the FDA has allowed ingredient companies to make their own GRAS determination without sharing safety data or alerting federal authorities when a new ingredient will be used in the food chain. As a result, the Natural Resources Defense Council found that 275 ingredients used in food today do not have adequate information available for review. This could potentially allow wide latitude in selecting lubricant ingredients, Housel cautioned.

In February, the public interest group Center for Food Safety filed a lawsuit against the FDA to require federal oversight of this process. At present, the courts have not settled the lawsuit. Meanwhile, the Grocery Manufacturer’s Association is working toward an industry sponsored set of guidelines to determine when materials can be considered GRAS.

In Europe, the European Hygienic Engineering and Design Group issues guidance documents that cover various aspects of food safety, Housel said. Lubricants are covered in Guideline 23, which embraces Hazard Analysis and Critical Control Point principles and confirms the groups insistence on the use of H1 category lubricants in all areas comprising a contamination risk.

Housel explained, European regulations for food contact materials are described in Framework Regulation EC 1935/2004, which requires that any food contact materials not affect the safety or quality of food. It also describes appropriate traceability and labeling. This standard does not cover lubricants directly but provides a framework that applies to anything that may contact food.

The European Food Safety Agency is another resource that issues scientific opinions on topics related to food safety, Housel added. The European Commission asked EFSA to consider the most recent data and deliver an opinion on the health effects of mineral oil in food. The report shows that mineral oils are a complex mixture of linear and branched alkanes, cycloalkanes and aromatic compounds…. Toxicity varies widely among the different components, so it is impossible to assess exposure limits without specific knowledge of the composition, said Housel.

The report mentions several potential sources of mineral oil in foods, including packaging, printing inks and adhesives. If H1 lubricants are limited to 10 parts per million, it is likely that exposure from lubricants would be relatively small, he noted.

The U.S. Congress passed the Food Safety Modernization Act in 2011 with the goal of allowing the government to focus on preventing contamination rather than responding to incidents that have already occurred. FSMA mandates prevention-based controls across the food supply chain and requires government inspections to ensure industry compliance, said Housel. The Act reaches beyond U.S. borders to oversee the 15 percent of foods that are imported.

FSMA [also] gives the FDA mandatory recall authority when deemed necessary for public health, Housel continued. While promising a significant overhaul of the food industry, there has been ongoing debate about the appropriate interpretation of some sections and concerns about the costs.

The Global Food Safety Initiative is an industry driven initiative providing guidance on food safety management systems. The focus of GFSI is to harmonize food safety requirements globally, reducing redundancy and improving efficiency, Housel said. The main goal is a single certification that would be accepted globally.

GFSI schemes address the entire production process and do not mandate lubricants per se. However, schemes specifying that processes use H1 products for incidental contact lubricants gain from the de facto global recognition of H1 certification.

Finally, many papers, articles and presentations have addressed food grade lubricants, Housel noted. For example, NSF International hosts an annual Nonfood Compounds’ Steering Committee Meeting in Ann Arbor, Michigan, U.S. Also, ICIS sponsored a conference in Berlin in November focused on food grade lubricants. These resources give lubricant suppliers and food manufacturers the opportunity to become familiar with the requirements of food processing lubricants, explained Housel.

Other industry forums are food grade working groups sponsored by the European Lubricating Grease Institute and the National Lubricating Grease Institute. The working groups give lubricant suppliers an opportunity to … establish recommended practices, said Housel. Developing a consensus position will allow the industry to build on government safety initiatives while using the expertise of its members to provide safe and effective lubricants.

The groups are currently discussing an industry code of conduct for food grade lubricants, so that lubricant manufacturers can have a single point of industry-wide reference. One of the key points to address is minimizing confusion around the various H categories.

As these groups build a consensus on the code of conduct, the next step is to educate the supply chain on proper use and practices to ensure that best practices make their way to the shop floor, Housel said. Regulations and documents are useless if they are locked in a book or on a website somewhere. The people working in the factory must understand and follow best practices.