Machines that make food need grease and oil, and some of it can reach the food: a mixer's bowl lift, a filler's valve, an extruder's gearbox seal. FDA's rule for lubricants with incidental food contact says what those lubricants can be made from, limits some ingredients, such as 10 parts per million of certain substances in the food, and says to use the minimum amount needed. Suppliers sell lubricants made to that rule as H1, registered for incidental contact; H2 lubricants are for points where food can't be reached. The practical job is a list of every lubrication point, which ones can touch food, and an H1 lubricant on each of those. In the example below, a Kansas pasta maker gets ready for a buyer's audit.
The short version
- Lubricants that can reach food must meet FDA's incidental contact rule.
- Suppliers sell them as H1; H2 is for points food can't reach.
- Use the minimum amount that does the job.
- List every lubrication point and whether food can reach it.
- Store lubricants apart from ingredients, labeled.
- Keep a lubrication log: point, product, date.
- TaroStack keeps lubricants and supplies counted, with lots. More below.
H1 or H2
| Point | Can food reach it? | Lubricant |
|---|---|---|
| Mixer bowl lift and hook shaft | Yes, drips can fall into the bowl | H1 |
| Extruder gearbox seal at the screw | Yes | H1 |
| Extruder gearbox, sealed housing | No | H2 allowed; many use H1 everywhere |
| Conveyor chain over open product | Yes | H1 |
| Motor bearings behind a guard | No | H2 allowed |
Using H1 on every point avoids the wrong grease in the wrong gun. Lubricant drips are one of the hazards in foreign material control program, and the equipment rules sit with the rest of the good manufacturing practices in 21 cfr 117 subpart b.
The rules
| Rule | Where |
|---|---|
| What it can be made of | Listed substances, generally recognized as safe substances or prior-sanctioned ones, with limits on some (21 CFR 178.3570(a)) |
| How it's used | As an antirust film, a release agent on gaskets and seals, or a lubricant where the part is exposed to food, in the minimum amount (178.3570(b)) |
| Equipment | Designed, built and used so lubricants and fuel don't get into food (21 CFR 117.40(a)(2)) |
This is general information, not legal advice.
An example: a pasta maker's lubrication points
Prairie Mill Pasta, the made-up pasta maker in Lawrence, Kansas, I use in these examples, listed every point its maintenance tech greases before a grocery buyer's audit:
| Machine and point | Food can reach it? | Was | Now |
|---|---|---|---|
| Spiral mixer, bowl lift | Yes | General-purpose grease | H1 grease |
| Extruder, gearbox seal | Yes | H1 oil | No change |
| Extruder, gearbox housing | No | H2 gear oil | H1 gear oil, one less product to stock |
| Sheeter, roller bearings | Yes | H1 grease | No change |
| Conveyor drive chain | Yes, over open pasta | General-purpose chain oil | H1 chain oil |
Two points had general-purpose products where pasta could be reached; both changed to H1, and the shop switched the gearbox to H1 too, so only H1 products are on the shelf. The lubricants are kept in a locked cabinet away from the semolina, labeled, and each greasing is logged. How the pasta is made is in pasta production process.
Get the checker
Download the lubrication log. One sheet: each machine and point, whether food can reach it, the lubricant and whether it's H1, how often it's greased and when it last was; whether it needs an H1 product and when it's due fill in. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
The log covers the points on paper. A new conveyor, a contractor with his own grease gun, or a case of the wrong grease received by mistake are how an H2 product ends up over the dough.
How TaroStack does it
TaroStack keeps lubricants and supplies counted, received with their lots like any other item.
Supplies as items. Lubricants, sanitizers and parts can be items too, received with their supplier and lot.
Counts and reorders. They're counted with everything else, and come up on the reorder list in days of cover.
Batches with checklists. A production batch can carry a custom checklist, so a pre-start check that the guards and seals are clean is recorded on the batch.
| The job | Notebook | In TaroStack |
|---|---|---|
| Which grease is on the shelf | A look in the cabinet | Stock by item and lot |
| When to reorder H1 grease | When it runs out | The reorder list |
| Pre-start checks | A clipboard | A checklist on the batch |
Receiving, counts and checklists are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.