Why is machine lubrication becoming an integral part of mandated food safety?
The European Food Safety Authority (EFSA) published a paper on 28 August 2013 which reported the latest findings of research on Mineral Oils in the food chain. The report detailed the likely levels, by product manufactured, of human exposure to hydrocarbons through processes of modern manufacturing and maintenance techniques. http://www.efsa.europa.eu/en/search/doc/2704.pdf
The report identified numerous sources for the occurrence of Mineral Oil Hydrocarbons (MOH) in food used in the normal manufacturing process. This article focuses on machinery lubrication.
As knowledge increases through such research it is likely that regulatory authorities like the United States FDA/USDA and the United Kingdom's FSA will continue to raise standards in terms of food-safety compliance and control so as to minimise the human consumption of MOH. For example prior to 1998 to gain USDA approval, lubricant manufacturers had to prove that all of the ingredients in their formulations were allowable substances in accordance with the Guidelines of Security Code of Federal Regulations (CFR). This did not include lubricant testing; rather, the approval was based primarily on a review of the formulation ingredients of the lubricant.
Starting February 1998, the USDA significantly altered its program requiring the manufacturer to assess risk at each point in the operation where contamination might occur. In essence, the manufacturer became responsible for reviewing and approving the chemical compositions of lubricants to decide whether they were safe as food-grade lubricants. Currently, in the United States as well as in other countries, the National Sanitation Foundation (NSF) manages a lubricant evaluation program that essentially mirrors the USDA plan. Each component in the formulation is submitted to NSF by the lubricant manufacturer along with other supporting documentation. This is then reviewed to verify it is within the FDA list of permitted substances.
NSF’s Web site www.nsf.org provides food processing manufacturers with a continually updated list of approved lubricants at www.nsfwhitebook.org NSF’s Web site also provides lubricant requirements for food-grade products and gives a free access listing of certified food-grade lubricants at www.nsf.org/usda/psnclistings.asp
Understanding the differences between food-safe synthetic and mineral lubricants and making the proper lubricant selection critical to food safety and machine reliability is clearly very important. However, in our experience as the largest provider of lubrication management services to the UK food & beverage sector, managing a reliability centred lubrication program is paramount as without contamination control, effective storage/handling, stock control, spill management, sealing, categorisation and lubrication-related KPIs then you may be wasting your time and money.
What information/resources are available to a Food & Beverage Company to help with regards to compliant and effective lubrication?
The lubricant manufacturers are clearly being driven and controlled by governmental bodies so the decision of “which oil to use” from a compliance point may seem relatively straight-forward. However, it is a complex area that needs careful consideration when choosing the correct lubricant. Seeking advice from a lubrication services company and/or lubricant OEMs will help in this respect, as well as reading ISO-21469 – Safety of Machinery Lubricants with Incidental Product Contact.
You will already be aware of course of the HACCP process (Hazard Analysis Critical Control Point), methods and principles of food safety management relating to machinery lubrication including correct choice of the appropriate NSF category lubricant. But HACCP it is not a regulation and the approaches to effective management of lubrication activities much more challenging as industry and corporations increasingly mandate HACCP rules and ISO Standards develop further.
Additional resources include the BRC (British Retail Consortium), which set standards for food grade manufacturing for plant audit purposes and mentions lubricants, HACCP, chemicals, workshop/maintenance practices but does not specify detailed lubrication management / lubricants to the a degree that would be of much use to a busy maintenance manager. And AIB (American Institute of Bakers) similarly drive food-safety standards on sites through audits but leave the detail to manufacturers in terms of maintenance regimes and lubricant grades.
Associations such as the International Council of Machinery Lubrication (ICML) and Noria promote lubrication best practice. Such best practice combined with regulatory standards have been integrated over the last 10 years by AVT Reliability into their “Lubrication Assessment” program; a proactive benchmarking approach which objectively compares a food manufacturers lubrication management practices against standards and best-practice to help companies achieve positive change.
A pragmatic approach to reliability centred lubrication that addresses common challenges and opportunities relating to food safety and machine reliability:
This article is based on a summary of over 100 food & beverage site audits carried out by AVT mainly throughout Europe and Africa since 2005, and focuses on the “lower quartile” performers, i.e. where we have seen the largest opportunities for improvements.
AVT’s resident tribologist, Mark Needham, carried out the analysis and confirms that “…the results are a common representation of a typical site where lubrication has not been considered as being critical”. The output of our research is a Lubrication Management Top Five Tips provided to help food & beverage companies focus on the most likely areas for improvement, of both machinery reliability and food-safety compliance.
1. People & Skills
There are no defined responsibilities and/or personnel specifically around lubrication. The importance of lubrication standards relating to food safety and/or machine reliability are therefore not understood.
Personnel are not trained in lubrication and do not therefore understand the effects of poor lubrication on machine reliability.
We often hear from technicians for example when asked what lubricant they use, how often and why “…we’ve always just used that grease in everything…” with no comprehension as to why or whether it’s correct or what markings such as EP2, NLG 2 or whatever actually mean.
- Making someone responsible for lubrication and empowering them to develop and own an improvement program will raise the profile of lubrication on site and deliver tangible results very quickly.
- Raising the awareness of lubrication basics for all of your maintenance team and operators will assist with the improvement program; this can be done quite easily through training programs which can include short briefing sessions up to ICML training courses for nominated personnel.
2. Assets & Machines
Many Food & Beverage companies do not consider effective lubrication requirements when installing or changing processing equipment. Leading to lubrication related failures and/or the need for shutdowns to carry out lubrication.
Challenges associated with regular “Wash-downs” are often not considered with regards to bearing water-ingress or lubrication routines. One of the most common failure modes we witness on our lubrication contracts and regular advice coming from our condition monitoring teams relate to premature bearing failure due to lack of lubrication and corrosion created by wash-downs and unprotected bearings (as well as the wrong or insufficient lubrication of course!).
- Add lubrication requirements to the engineering design specification to consider;
- Fitting remote lubrication points / central lubrication systems.
- Ensure lubrication activities are not hindered through guarding (including when guards are modified in operation).
- Fitment site glasses/level gauges & breathers (after assessing the environmental conditions).
- Fit bearing protectors such as “labtecta” on critical equipment where water ingress through cleaning is likely.
Storage if often not maintained, there is no clear ownership and is not suitably located. This can lead to contamination from airborne debris (dust, dirt, moisture), “dumping ground” mentality and a general lack of control.
The opposite of course is a well-managed lubricant store is defined as having:
- Dedicated storage area.
- Clean, Enclosed & secure.
- Environmentally (e.g. temperature controlled).
- Owned and with well understood rules.
- Well organised, segregated product with colour-coding to avoid cross-contamination.
- Don’t assume the stores that you have are OK and that stock is well managed; it will not take long to carry out an audit and follow a 5S approach to identify improvements which can have a significant and immediate positive impact:
4. Lubrication Routines
Often lubrication activities are included in other maintenance activities, or not planned at all. Even with those we found with routine lubrication, the majority do not include capturing data relating to lubrication (like amount of lubricant used).
Also guidelines often do not exist for what lubricant should be used, in what quantity and when, just statements like “lubricate”.
- Define a specific schedule for lubrication activities.
- Capture data to enable usage & schedule compliance reporting.
- Set-up routes logically, in a “walking order” so as to make the most of the time available.
5. Continuous Improvement
Combining here results from the sections “Lubricant Analysis” and “Goals and Metrics” as topics for moving into Reliability Centred Lubrication:
Lubricant Analysis is often not carried out though there are some important opportunities open to the Food & Beverage Sector. For example, a major chocolate manufacture in the UK was changing oil in it’s high-pressure hydraulic presses every three years at a cost of £36,000 per time. We implemented proactive oil condition monitoring combined with filtration of the oil in use and extended the oil life to eleven years, saving over £100,000!
Highly critical large gearboxes which are difficult to maintain/replace are ideal for wear-debris and contamination tracking through oil analysis; giving essential information which will help avoid downtime due to unpredicted failure.
It is very rare for us to see lubrication metrics such as % lube-routes completed on time, quantity of lubricant used tracking, waste tracking, root cause analysis and so on.
- Carry out a criticality analysis to identify machinery where oil analysis is appropriate.
- Define the correct oil analysis test suites to match the likely failure mode and for example make sure that ISO cleanliness codes are included.
- Consider and include lubrication related Key Performance Indicators relative to your challenges and the maturity of your lubrication program, for example;
- Ad-hoc lubrication versus scheduled lubrication % (highlights opportunities to amend routines).
- Route Compliance % (highlights where lubrication schedules are not being followed).
- Lubricant quantity used monthly tracking (identifies increases and enables focused actions).
- Record faults/failures by reason which includes “lubrication bad actors” and measure the % of lube-related issues monthly (drive the trend down!)
To summarise; more than half of the food & beverage manufacturers’ sites that we have benchmarked have significantly benefitted by addressing the opportunities above. We have seen OEE rise by 8% on a dairy due to the reduction of lubrication related failures and costs savings of hundreds of thousands of pounds by eradicating failures through implementing reliability centred lubrication.
So if any of the 5 areas above sound like your operation then we know that the top-tips will save you money, improve machine reliability and availability. Also, uniquely in the Food & Beverage sector, provide you with some practical food safety & maintenance improvement initiatives!
A final note on lubricant products; AVT Reliability have key alliances with all the leading Food-Safe Oil Manufacturers such as Petro-Canada, Total and Kluber and equipment providers such as Trico and Lube-Safe. We will only deal with such quality lubrication product suppliers, we find that an approach which may combine different manufacturers has the best effect on machinery availability/reliability when delivered through a reliability centred lubrication program, but that is the key – effective lubrication management!