Ask the Experts: How food-grade lubrication certification is shaping industry standards

Key takeaways

• Food-grade lubricants are crucial to public health, requiring stringent regulatory compliance in sectors like food and pharma.
• The FPL certification helps professionals address unique lubrication challenges in highly regulated environments, enhancing industry-wide safety.
• Knowledge of regulations like FDA’s 21 CFR 178.3570 is vital for selecting compliant lubricants and ensuring safety in food and pharma operations.
• The FPL certification benefits practitioners by offering internationally recognized credentials, valuable for career mobility in food processing industries.

Food and pharma lubrication practitioners face unique challenges with their machine lubricants and lubrication programs. They must contend with numerous regulations, priorities, and practices that are simply not common or necessary in other environments.

The International Council for Machinery Lubrication (ICML) offers a specialty certification badge for Food Processing Lubrication (FPL), developed by a remarkable, multi-national team of industry professionals. To provide some insight into the background, development, and relevance of the FPL badge—even in sectors outside of direct food & pharma manufacturing—I connected with several members of ICML’s development committee.

Joining the discussion were:

• Mohamed Ibrahim, Senior Mechanical Engineer, QatarEnergy
• Roberto Trujillo, Senior Technical Consultant, Noria Latin America
• Michael Holloway, President, 5th Order Industry
• Garrett FitzGerald, Senior Principal Engineer – Maintenance & Reliability, Eli Lilly and Company
• Rich Wurzbach, President, MRG Laboratories

What followed was an insightful and in-depth "Ask The Experts" exchange about the unique challenges, regulatory demands, and evolving best practices in this specialized field.

This article covers Part 1 of the conversation, and centers on why food-grade lubrication is a valid topic for certification due to its direct impact on public health, strict regulatory oversight, and widespread relevance across industries like food processing and pharmaceuticals. It was also noted that the personal ownership of FPL specialty badges is practical for practitioners in an industry well-known for worker mobility.

(Part 2 of this conversation is forthcoming soon, and centers on emerging technologies that will impact food-grade lubrication practices, as well as the job roles and industries will be most positively impacted by certifying practitioners with the FPL badge.)

Question 1: Why was the topic of food-grade lubrication selected to be among the first specialty badges produced by ICML? Are food-grade challenges extraordinarily commonplace with your clients or within your own facilities?

Ibrahim: The selection of food-grade lubrication as one of the initial specialty badges by ICML was guided by the industry's recognition of its critical relevance and urgency. The safety and quality of lubricants used in food processing directly impact public health, making it an essential facet of industrial operations. Challenges related to maintaining food-grade standards are pervasive across various sectors, so as consumers become increasingly discerning about the products they consume, ensuring the highest standards of food-grade lubrication has become a shared priority. This badge serves as a proactive measure to address these challenges systematically, setting a benchmark for competency and safety in the industry.

Trujillo: The FPL badge is [very] relevant for the industry. There are too many products manufactured without following best practices and demands, even as penalties have increased in the last years.

Holloway: Unlike other industries in the U.S., products used in and around food processing equipment are heavily regulated and have specific requirements. The regulation was established by the U.S. Food and Drug Administration (FDA) with NSF International acting as the product certification body.  In no other industry is there a direct consideration or influence of product chemistry in terms of safety. While certain manufacturing plants may adopt rules for non-flammable product or biodegradable chemistry, the products in the U.S. must be formulated in accordance with a special code, Title 21 Code of Federal Regulations (21 CFR) 178.3570, and the formulation ingredients in the product must be listed as safe. This code is strict, and acceptable products such as oils, grease, antioxidants, and surfactants must comply. These requirements can make product development very challenging. There are only so many raw materials that are generally regarded as safe.

Meanwhile, food processing plants present all the operational challenges as many other industries, as well as the additional hurdles to clear such as extreme temperature variations (from freezers at -35 °C to >100 °C) and contamination from the products themselves (proteins, fat oils, organic and inorganic particulate from grain dust to spices, and sugar or salt), and the regular washdowns with acidic or caustic solutions. Other countries address these concerns, as well. For instance, the European Union has the European Food Safety Authority (EFSA). However, there is no formal EU regulation for lubricants like there is in the U.S., the H1 requirements are accepted in the EU. In Canada they have the Canadian Food Inspection Agency (CFIA), which is similar to the NSF program in the U.S. yet only applies to meat processing. Australia has the Australian Quarantine and Inspection Service (AQIS) that mimics Canada for product review and is very close to the U.S. criteria which are termed Type A. While many parts of Asia do not have such regulations, China has the Chinese food safety authority known as the Food Hygiene Law of the People’s Republic of China that ensures food hygiene and protects food products from contamination by harmful substances. However, it doesn’t cover products themselves but instead covers the processing facilities and environments where products are made. The focus is on the potential of harmful substances’ being added into the food product.

FitzGerald: I work in the biopharma sector. So, all lubricants that have the potential for incidental contact are heavily regulated. As such, all of the subject matter in this FPL badge is directly related to day-to-day roles. Every maintenance intervention we make, in terms of lubrication, is made with the consideration for impact to product. Therefore, selection of suitable products—technically suited to the challenge at hand, but also appropriately formulated and certified—is critical.

Wurzbach: As an instructor that teaches to the ICML certification exams, I happen to work in a region that has a very high concentration of food production manufacturers. Hershey, for example, is very close to my office. In fact, the number one industry in the state of Pennsylvania is the agriculture and food production industry. I have engaged several of these food production manufacturers, and they have requested to expand the knowledge of lubrication best practices among their production and maintenance staff. So, we have developed short courses to support these industries and got the participation and attendance of over 20 companies, so there is an interest and a demand for improving the knowledge and competency of their working professionals in the area of lubrication. And it became clear to me that when ICML’s badge process came along, it could be an ideal way to satisfy this industry’s desire to train people.

This all enabled me to create some of the early outlines for what the FPL badge would cover and what the demand would be, and who would be the customers for this badge, because that's always important, right?

We also found that professionals working in this industry, since there are so many companies working in food production in this region, there tends to be mobility among these professionals, moving from location to location and company to company. And the idea that an international certification could be obtained by someone in that industry, and then be recognized and honored and utilized as they move to another location and bring that knowledge and competency with them through the FPL badge certification, would be a great benefit.

Question 2a: How did the committee determine the Body of Knowledge (BoK) for this badge? Key areas include regulatory compliance, contamination prevention, and lubricant performance, with a focus on balancing broad applicability with specific food-grade challenges. Is there any particular area that you see as most important/relevant when it comes to the competency of food-grade practitioners?

Holloway: The committee was composed of seasoned professionals with extensive knowledge of the requirements of the certification objective. The content deemed appropriate is from peer reviewed publications and manuscripts from legitimate publication houses which do not have an agenda. The topic is extensive, however, when applied with other ICML certifications, and it becomes essential for anyone who services the food processing industry or for the maintenance and reliability teams within the food processing facilities.

It’s a delicate balance; you can't be too general nor can you be too defined. You have to understand and select the appropriate balance of content that addresses the wide range of components and processes and still be applicable in the U.S. as well as abroad.

Ibrahim: The committee approached the determination of the BoK with meticulous attention to the unique challenges and intricacies of lubrication practices in the food industry. By engaging in in-depth discussions, leveraging the collective expertise of committee members, and staying abreast of evolving regulatory landscapes, we formulated a comprehensive framework. Each component of the BoK was carefully crafted to address the multifaceted aspects of food-grade lubrication, with particular emphasis on regulatory compliance, contamination prevention, and the judicious selection and application of food-grade lubricants. The competency of food-grade practitioners hinges on a nuanced understanding of these key areas.

Question 2b: Which came first: developing the domain of knowledge (i.e., DoK, the published resources from which you would derive exam questions), or developing the body of knowledge (i.e., the allocation of the topical areas to be covered by the exam)?

Wurzbach: The BoK came first because, with this preexisting desire [for] and delivery of content, the process was all about the outcomes and focus areas that the manufacturers were looking to address. My company’s workshop outlines and course outlines [were already] in place, so when we started to talk about a badge, then it became important to base these knowledge areas and competency areas within the written record that's out there: written materials, books, articles, etc. So, they were [selected to] fit into this overall outline of knowledge that one might call the body of knowledge. 

Regarding relevance of BOK topics, I think it's built around the governmental regulations, because generally it is not the technician in the field that is pushing for this, saying, “Doggone it, I wish I had a badge to go for.” Rather, it is typically the management of these facilities that says, “We are bound by these regulations and therefore we want to make sure that our employees are trained properly and understand how to work within that framework.”

[Consider] the significance of FSMA, which was a law put in under the Obama administration that changed the liabilities of the food industry, placing it upon the management of the companies that produce the food. So now there are criminal penalties that can be directed at plant managers and CEOs for their failure to protect the food supply. And this [drives] some of the motivation that says, “We better make sure that our people know what they're doing, because ignorance is no longer a defendable position.”

Question 3: Speaking of the Domain of Knowledge (DoK), what were the challenges to finding and vetting suitable resources to be included?

Trujillo: Many of the concepts in lubricants are of general use, meaning they are not exclusive for FPL. Their domains of knowledge are too wide to cover lubrication fundamentals, so we [focused on] a limited source of technical articles and bibliographies specifically suited to food-grade lubricants.

Wurzbach: In this industry there are regulations that can include FDA regulations, the provisions of the Physician Act, the Food Safety Modernization Act (FSMA). So, when you have them as a starting point and then you start to think about creating a domain of knowledge and test questions for a badge, those documents are some of the obvious DoK candidates. Then we looked for other authoritative documents, many of which turned out to be articles rather than independent books, as it were, or perhaps subsections of books where you would find some of these [topics]. But, certainly, in a highly regulated environment such as food production, those regulations become a natural starting point for a domain of knowledge.

Holloway: It's always a challenge to find an unbiased source that doesn't have a commercial agenda, be it product technology or services such as consulting, training, or processes. But isn’t that always the challenge? 

FitzGerald: There is plenty of information available online, but finding suitable detailed information beyond the superficial can be a challenge. Additionally, the need to balance appropriate technical depth in terms of the lubricant itself against the necessary regulatory requirement meant two separate streams of research had to be completed: (1) lubricants have to be technically capable to adequately do the jobs required of them, and (2) lubricants have to be appropriately formulated and certified as such to meet the stringent requirements of the sector.

Ibrahim: The process of identifying and vetting suitable DoK resources presented challenges intrinsic to the dynamic nature of the food industry. Rigorous scrutiny was necessary to ensure that selected resources were not only current but also comprehensive and universally applicable across diverse food processing scenarios. Collaborating with subject matter experts and relying on established standards proved crucial in navigating these challenges. The committee's commitment to providing practitioners with the most robust and relevant resources played a pivotal role in overcoming these hurdles, reinforcing the credibility and comprehensiveness of the FPL badge.