BRC clause 4.7.5, What constitutes "indirect contact"?

My read of that requirement is that the BRC wants everyone to use Food Grade lubricating oils and greases, and if they can't, demonstrate (Validate) that it cannot enter the food. 

as per my opnion ,it must be food grade.rather it touched or not.When you are using lubricant for processing machine it must be food grade.and when you are buying asked to vendor to provide its food grade certificate.

BRC requires to use Food Grade materials only thus this is also in effect for lubricants

You must use food grade grease/lubricant and also need to get food grade certificate along with allergen status coz most of the food grade grease based on soya.

What constitutes "indirect contact"?  Our process is nearly 100% closed.  So if I have machinery with lubrication requirements and their is no chance for the lubrication to come into contact with the product does it still have to be FG?  Is just using FG grease better to er on the side of caution?

 

Indirect would be "possible even if unlikely" - for example, we have some closed processes and things like lubricants for pumps, gasket seals in certain areas etc are not intended to come into direct contact with food, but there is a possibility that they may do so. As such, these are required to be food grade to ensure that there is no risk of product contamination.

This is a very easy area to pick up non-conformances ;)

As others have mentioned, you'll want food grade declarations for all components that are, or may come into, contact with food, and also allergen declarations for lubricants.

The easy answer is to use food grade for everything but that's naive. I bet your engineers tell you they only use food grade right? What is lubricating those sealed bearings... What is that chain oil (can be food grade but often isn't).

The best idea is to work with and train your engineers. Then give some really clear guidance (with visual management ideally) on where non food safe oils can be used. Capture all of this in a risk assessment.

 

BRC clause 4.7.5 states "Materials and parts used for equipment and plant maintenance shall be of an appropriate grade or quality.

Those materials (such as lubricating oil) that pose a risk by direct or indirect contact with raw materials

(including primary packaging), intermediate products and finished products shall be food grade and of a

known allergen status."

 

What constitutes "indirect contact"?  Our process is nearly 100% closed.  So if I have machinery with lubrication requirements and their is no chance for the lubrication to come into contact with the product does it still have to be FG?  Is just using FG grease better to er on the side of caution?

 

Thank you

 

Ben

 

 

Hi Ben,

 

It's a popular topic.

 

IIRC the semantic subtleties when discussing the meaning of "food-grade lubricants" (eg H1 etc etc) as required/applied in the Food Industry are defined/quantified within documentation issued by bodies such as USDA/NSF.

 

The interpretive aspects are also extensively detailed/explained within various Manufacturer's product Publications, some of which are previously quoted/linked on this Forum (somewhere)