Food Grade Lubricants

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Food Grade Lubricants Certification Is Better
than Registration
Dr R Pinchin Shell International For the NSF
International Steering Committee. 2004
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USDA Approved ?
Food Grade ?
USDA H1 ?
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Non Toxic ?
FDA ?
Food Safe ?
NSF H1 ?
CONFUSED CUSTOMER ?
How can I trust them ?
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Currently, NSF International provides Food and
Beverage Manufacturers with a NSF H1 Registered
Service. Users can check which products are
registered on an up-to-date web site and find out
more information
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They will also be able to find out that the
registration process involves a detailed check on
the suppliers declared formulation vs. the
technical standards agreed by the industry
(based on the previous USDA H1 system and now
moving towards an ISO Standard) But is this
Enough Reassurance ?
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Remember in 1993 Ford and GM were concerned
about engine oil quality in the USA. They bought
samples from the market, analysed them and also
subjected them to tests (ASTM Sequence tests,
such as the III-D and V-D). They found many oils
purporting to be API SF and SG did not meet the
technical/functional requirements. Even worse,
some oil were effectively additive-free, and
would provide very little protection against
sludge and wear in modern engines. Why? Possibly
because some oil blenders were careless with
the amount of additive in the formulation. As a
consequence A more stringent API performance
qualification procedure was implemented with an
Aftermarket Audit Program..
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Now, 10 years later API Audit One in Five Motor
Oils Off-Spec
Quote More than one out of five API-licensed
engine oils was off-spec last year, according to
the American Petroleum Institutes 2001 worldwide
engine oil quality audit. API collected and
tested more than 600 samples of licensed engine
oils, including both bulk and bottle samples.
Sixteen percent were found to have marginal
deviations, and 5 percent (30 oils) had
significant deviations. According to API,
significant deviations are so far outside
compliance limits that they could potentially
raise short-term or long-term engine operability
concerns.
Report by David McFall in Lubes-n-Greases Wednesda
y, June 12, 2002 VOLUME 2 ISSUE
24 http//www.imakenews.com/lng/e_article000076081
.cfm
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Is this relevant to FLGs ? I suggest the answer
is YES !
I wonder how many of you have come across oils
where you suspect the H1 claim isnt justified ?
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Really Food Grade ?
Sometimes supply and production constraints are a
driving force for the use of alternative
materials in oil formulations. Such changes are
NOT permitted under the H1 technical standard
without re-registration of the new
formulation. So, registration of a confidential
formulation (on paper), does not guarantee that
the same formulation is always, or ever, used in
actual production, although a declaration is
required to this effect. But WHO REALLY KNOWS
for Sure ?
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Thats what I read on the label !
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The answer is to extend the quality assurance
from Registration to Full Certification.
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• To achieve this, we need to consider
• Audit of the oil manufacturers production
  process (to an agreed standard)
• Verification of records that the H1 oils really
  are being blended according to the registered
  formulation
• Ensure adequate quality control processes are in
  place.
• And, samples of the H1 oils should be withdrawn
  from the marketplace and compared analytically
  with samples of the genuine article from the
  suppliers plant or laboratory.

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The oil manufacturer and his products would then
have Certified Status This is an OPTIONAL
ADDITION to H1 Registration
Any deviation from declared quality, would lead
to the need for immediate corrective action..
..with the sanction that failure to comply
would result in the supplier losing certification
status
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Relaxed and confident customer !
Food and Beverage manufacturers who have a
concern about the quality of products used in
their production lines could turn to this system
for a higher degree of assurance.
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How can our customers benefit ? Today we hope
they check the NSF web site to validate H1
Registered claims made for products In future
they could check which products are, in addition,
Certified. This would give them peace of mind
that they can really trust the supplier and his
products
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The costs, to be determined, must be
controlled Initial estimates indicate costs
should be similar to those currently incurred for
the registration service (see appendix) Supplier
s would recoup costs mainly through gain in
market share
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WHO present here today would support such a
program ? If there is sufficient interest, would
NSF consider being a provider of the program
? (is there a minimum No. of users ?)
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Appendix
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• What is needed to make this work ?
• Interest from the user group (food and beverage
  companies)
• Interest from the supplier group (e.g. in this
  room)
• Agreed scope of the Certification Scheme
• Technical standards (for products and production)
• Promotion of the scheme, and a suitable logo
• Process and Costs

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• What is needed to make this work ?
• 2. Interest from the supplier group (e.g. in this
  room)
• A show of hands today could start this project
  rolling
• A small team would then be set up now to assist
  NSF to design a suitable service

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• What is needed to make this work ?
• 3. Agreed scope of the Certification Scheme
• Plant Audits ?
• Determine frequency of regular audits and method
  for random checks
• Samples ?
• Determine scheme to collect samples
• Marketing ?
• Position this carefully as a extra option on top
  of product registration.

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• What is needed to make this work ?
• 4a. Technical standards
• The composition of H1 products ready
• Good Manufacturing Practice most of the
  elements already exist in the EHEDG Guideline No
  23. These could easily be evolved into the
  standard for the plant audits
• 4b. Sample analysis
• It would be very easy for the certification body
  to set up an archive of analytical data e.g.
  infra-red spectra, on certified products
• A process to obtain and check market samples
  would be required

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What is needed to make this work ? 5. Promotion
and Penalties Adoption of this scheme by several
companies will seed the programme. Certified
products must be easily recognised and
positioned as the gold standard for food grade
lubricants - retain H1 but in a different
form A powerful penalty is announcement to
end-users of suspension from previous certified
status. (Name and Shame) But before such a
drastic step is taken, the supplier who is found
in breach of the certification scheme would be
given time to take corrective action
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What is needed to make this work ? 5. Promotion
and Penalties Users (e.g. FB Companies) could
register their interest in news on H1 products
and receive a free newsletter / update about
companies and products which are certified. This
can be used to promote the program -
worldwide The newsletter could also be used to
announce the loss or suspension of certification
should such an event occur (a very powerful
motive for supplier companies to comply with the
scheme)
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What is needed to make this work ? 6. Process
and Costs Major consideration is Plant
Audits Suggestion Plant audit cycle every 5
years, with intermediate spot-check audit on a
random basis for 10 of the plants If each audit
costs 5000, Average annual fee 1100 Note a
plant which supplies several marketers needs one
audit only, each marketer shares the
benefit. What is important to the customer is the
PRODUCT is Certified (this implies the plant is
audited and the products are included in the
sample check process)
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What is needed to make this work ? 6. Process
and Costs Secondary cost is for sample checking.
e.g. If 5 of all certified products are
sampled and checked every year, this cost would
be shared by all participating suppliers and the
cost per supplier may be only 1-200. The
overall program cost per supplier is similar to
that currently arising from the registration
process. It is important that the costs are FAIR
and kept to a minimum
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Can this work with a sample check only ? (no
plant audit) The Registration Body would hold
samples of genuine formulations of each
certified product (maybe make samples under
laboratory conditions) Samples of products would
be drawn, at random, from the market and checked
for compliance (by spectral analysis) Web
publication of certified products and penalties
for non-compliance (as before) This would
demonstrate the correct formulations are being
used within the limitations of the analytical
techniques but may not detect
cross-contamination in the production
process. It would be lower cost