I need support on some ideas on how to create a risk analysis for food grade lubricants. Currently, we have a tea blending production, we do not carry any allergens, but we do have documented procedures for the control and prevention of any possible allergens. We had a Pre-Assessment back in June 2014 and the auditor stated to create a risk analysis for food grade lubricants.
Any feedback will be truly appreciate it.
As per yr last post, I anticipate that the auditor query was propelled by a specific requirement in the SQF Code. The latter's allergenic requirements have been previously (inter alia) discussed here a few times (eg (2014)) -
(the above thread shd prob.hv been in SQF forum)
(eg see attachment val4, sec. 184.108.40.206)
As per the rather nice, random, official lubricant spec.brochure attached below, Spurs Girl's approach looks logical and a, not in the least unreasonable, request. Personally, i would be tempted to define the "absence" as a prerequisite (within the lub. oil purchasing set-up) and therefore negligible risk. Hopefully the classification system in USA may have done that for you.
Whether USA has also implemented any official directives as (apparently) done by EC in above example, no idea. I daresay the problem has long ago been bounced to organizations like NSF, eg
PS - in truth, calling oil lubricant "food-grade" is IMO a semantic corruption. One of my sales-reps genuinely believed it to be true and gave impressive demonstrations of the edibility. Shortly replaced.