12 replies to this topic

[aaronlee]

Hi all,

This is my first post so any help is of great help.

We have a number of pieces of redundant equipment that is being 'made ready' for full production by our engineers and NPD staff. Without the benefit of any engineering training myself how can I be certain that the commisioning is sufficient to produce safe food?

Thanks in advance

[GMO]

I think you have to have some trust in the engineers. I don't mean "leave them to it" but talk to them, ask them to break it down for you, open doors, ask questions "what is that made of", "what grade of stainless steel is that?" "is that belt certified safe for food contact?" "Are you using food safe lubricants?"

Obviously it depends on the machinery but lots of food contact things tend to also be the high replace items so it might be possible to fully replace the food contact areas; belts etc to ones you know are safe for food contact and new.

Might sound odd but your cleaning chemical supplier might be a good source of information. They will have seen all kinds of machines of all ages and are likely to know 'typical' issues with machinery that you're bringing back in.

I work in a company where it is not atypical to buy a second hand machine. I suspect even larger manufacturers will be looking increasingly at adapting, refurbishing and repairing. There's nothing wrong with that there were just obviously different standards some years ago. My real bugbear is painted machinery. Some of ours is so old that stainless steel as the casing was not the norm. It is a right pain in the butt but we even cope with that.

[shea quay]

As you have used the word "engineer" in your question it would be impossible for anyone to answer that query. Engineers think differently to most of the rest of us. This is mostly because their hearts have been replaced with rocks which pump a viscous, oily-like substance around their veins. Your engineer will guarentee that that your "new" equipment will never really be ready and will break down frequently. And don't even get me started on NPD. I hope this helps in coming to grasp with this issue.
However if you insist on trying to do your job properly, ensure all lubricants used are food grade, do up a risk analysis that shows you have considered all possible physical, chemical, microbiological and intrinsic hazards related to the machine (is it mobile / hard to clean / does it have hidden corners where product might lodge, are refrigeration gas pipes running through it etc etc). If it's your job, do the same for health and safety. Remove your engineer's cigarette butts and empty coke cans from inside the machine, clean down, swab internally (if available) and externally. Run a trial. Send trial product for microbiological testing. Add machinery to glass and hard plastics register. Do up a cleaning schedule. Validate cleaning schedule. Write up a factory procedure. Train staff how to use machinery. Add machine to regular maintenance schedule. Not a whole heap you can really do after that I reckon.
And before all you engineers on the site start jumping up and down shouting and dragging those knuckles of yours along the ground - my sister is an engineer, so I know what I'm talking about.

[GMO]

Oh Shea. Even I'm not that cynical... I've had great friendships and support from engineers in the past. They're not all that bad.

[Charles.C]

Dear shea quay,

ensure all lubricants used are food grade

As a basic requirement, i think this is not quite correct. It's also a question of likelihood of contact, or risk analysis as you mentioned.

Based on experience and previous threads in this forum I doubt that many QA staff, never mind "engineers", appreciate the subtleties of what food grade actually means in practical chemical contexts. Similar to GMO's comment, the use of mild steel has (is?) been so entrenched in machinery design that IMEX it is almost certain to be encountered, particularly in certain industries, like it or not. Not to forget plastic conveyor systems with their painfully evident broken (but engineer smoothed) corners and edges. I hv seen many auditors wince at encountering such ugliness but no further comment, it's the name of the (not) game.

I guess it depends on the specific backup abilities / degree of rebuilding / sensitivity of equipment but in drastic cases, maybe better to stick to the professionals and get a meaningful certificate with it.

Rgds / Charles.C

[shea quay]

I find the subtle difference between food grade and non-food grade lubricants to be approximately 2 euro extra a tube myself, but I accept your point Charles. It just seems that I've been asked "are the lubricants foodgrade?" in every audit I've ever had, and I respond yes and produced my certificate. If we're to go to town on this altogether and consider having food grade and non-food grade grease in the same factory, I presume we would be entering the murky world of chemical control, locked storerooms, colour coded greaseguns and, gulp, training of engineers?!?!? That would be a world that I would pay two euro extra a tube to avoid myself!
As for the 316 stainless steel, "I'm almost certain that all of our equipment was once food grade stainless steel but we had to paint over it some time in the 80's as it had started staining". Now THAT's a quote to make an auditor really wince!

[GMO]

Having started up a factory from scratch, I know there are machines and parts which are greased with non food grade lubricants. Sometimes this can be a one off and they're always far away from food contact but it's worth having an open conversation with your engineers. They may well be using some and just not telling you. I agree that auditors are a bit blind to all this though.

There is a pragmatic approach to be had based on risk. Don't get me wrong, where there is a food safe option I will chose it but I have in the past permitted non food grade for specified purposes. After all, I would rather the machinery doesn't break causing a foreign body issue either. And yes, we managed to train engineers to only use the correct lubricant for a job.

[Charles.C]

Dear shea quay,

Re: lubricants. Getting bit OT but it’s an interesting topic. I hv tried to look at both sides of the “argument”.

I suppose the most logical (ironic?) response to a BRC auditor would be to refer to risk assessment (ie BRC para 4.7.5). However I can understand yr preference to take a conservative option and avoid argument. The cost differential IMEX can be substantial (but so can the avoidance also, eg see 1st link below). The actual degree of safety obtained also tends to be rather glossed over IMEX, and not only by Engineers (see “Other issues” end of 1st link).

I once attended a sales pitch by a company promoting their food-grade grease for conveyor bearings. One engineer in the audience asked what the “food-grade” actually meant. The salesman replied that he was only too happy to demonstrate his product’s safety as stated in the brochure. He then took out a tablespoon from his travelling “kit”, dug into his large can of white ickyness and cheerfully digested a spoonful. Some of the audience covered their eyes but no apparent after-effects. Shortly after, the demo (and the sales rep.) changed. Maybe unconnected (fake contents?) but again refer end 1st link. My Chief Engineer immediately signed up for a sample but I never saw any Engineer verify the edibility claim. Still wondering.

Not sure about exact situation in UK/EC/Ireland but it seems the Americans did the ground-breaking theoretical and developmental work on this topic and their standards are still the primary global reference. The links below are presumably current. Note the (interpreted) BRC satisfier in 1st attachment.

http://www.machinery...bricants-basics

http://www.machinery...rade-lubricants

http://www.indlub.co...elubricant.aspx

http://lubricants.pe...oducts/283.aspx

 lubricants info sheet - UK food safety and legislation.pdf   81.24KB   69 downloads

 example implementation food-grade grease, undated.pdf   914.52KB   85 downloads
(example only, not an endorsement)

Rgds / Charles.C

[GMO]

Thanks! Interesting post!

I always took food safe to mean that mineral oils were excluded and food grade oils were used. I suspect that some items are "food safe" only as incidental small levels of contamination.

I remember in chocolate they even had a word for old chocolate debris mixed with lubricant oil as it occurred so often.

[shea quay]

Thanks for that Charles, though you do realise you have condemned my next auditor to a world of pain when they ask "are your lubricants food grade"! I think after I start my answer with the phrase "well, you are really asking a number of questions there......" it should send them running!
Having read my original post though, the last thing I expected was an admittedly fascinating in-depth analysis of food grade greases. I was only looking to vent after another altercation with our engineer!

Apologies to aaron if his question has been slightly dragged off topic, but possibly the bottom line re-enforces GMO and Charles' comments of getting informed input from all sources to properly risk assess new equipment. I appreciate the oxymoron of "informed" and "engineer" though!

[bibi]

Thanks for that Charles, though you do realise you have condemned my next auditor to a world of pain when they ask "are your lubricants food grade"! I think after I start my answer with the phrase "well, you are really asking a number of questions there......" it should send them running!
Having read my original post though, the last thing I expected was an admittedly fascinating in-depth analysis of food grade greases. I was only looking to vent after another altercation with our engineer!

Apologies to aaron if his question has been slightly dragged off topic, but possibly the bottom line re-enforces GMO and Charles' comments of getting informed input from all sources to properly risk assess new equipment. I appreciate the oxymoron of "informed" and "engineer" though!

Hi
last year we want to buy new machine for more input production(old still doing well)
well my first question was when the engineer came for comissioning,by inviting the operators to show the mantling and dismantling of the machine.
we found the dismantling process for cleaning took nearly double the time .Plus the components parts were more and too complicated. Imagine the operators faces .
We found the new input was 1100pieces/hour, the old 1000p/h.The price was 3times more.
By the end we stick to our old machine but we extended the working hours.
may be our story could have other angle to your question.
bibi

[Intlft96]

I've been helped out so many times through this website so, here is my 'giving back.' You would essentially treat the redundant equipment as you would new equipment. I will attach a list (several in one page, actually) that I think may be of help to you as to what to look for. And, yes, I've met some helpful Engineers, too, through the years. You may also check out the AMI's (American Meat Institute)check list for new equipment. Best of luck and I hope this helps!  Sanitary Validation.docx   15.82KB   101 downloads

[Charles.C]

Dear aaronlee,

Since the last post has nicely reverted to yr original query ( ) I can make one more suggestion. Assuming you hv a budget, it is also possible to request 3rd party experts to vet yr commissioned equipment, both during and after the activity. Many service operators will happily do this for you at varying levels of documented certification although yr own engineers may not be too happy about it of course.

If there is no budget, I'm afraid you may be faced with a "dilemma", revolving around earlier mentioned options, eg as in

http://en.wikipedia....Hobson's_choice

Again, the exact nature/function of the (unknown) commissioned items may be critical.

Rgds / Charles.C