[AIB ICE Chips] Answers to Your Toughest QA Questions

Q. We have an audit scheduled soon and were told that non-food grade grease cannot be used in a production area. Some of our equipment specifications require a specific lubricant that we cannot find as food grade. Will we automatically fail the audit?

A. Some equipment manufacturers do not accept a food-grade lubricant as a substitute for a non-food grade material. There is debate between manufacturers on this topic.

As it relates to food safety and the AIB Audit Program, if there is a possibility that the lubricant may come in contact with the product or product contact surface, then a food-grade lubricant labeled for incidental contact is expected.

However, there are some rare instances where, due to high temperature or other performance issues, a non-food grade lubricant may be suggested for use. If this is the case, then there should be a design feature or control program that provides isolation of this lubricant from potential product contact.

There are some issues with older equipment designs that did not factor in lubricant types when they were manufactured. This provides a significant challenge, both for plants and auditors. However, due to the age of the equipment, it is not likely that there would be a concern for voiding the warrantee on the equipment if a food-grade lubricant is used.

In most cases, the design issues would encourage the use of a food-grade lubricant, since it would be difficult to have 100 percent confidence that you could keep all of the lubricant out of the product zone despite rigid programs. As long as the risk is present, the use of food grade material is encouraged and expected.

But to answer your question about whether or not you would fail the AIB audit: If you have a well-developed lubrication program that includes proper labeling, segregation and use of lubricants in your facility you would not fail the audit on this issue.

However, if the auditor observes an application or use of a lubricant not in compliance with your program and there is a potential for product contamination, you would fail.

As you can see, it is all a matter of how you control your program.