Allergen Risk Analysis for Food Grade Lubricants

Hello everyone,

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.

Gracias! :-)

AB 

The way I approach this is to get a specification for each lubricant from the manufacturer - it should provide allergen informaiton if it is classed as food grade. I also send an allergen form to the manufacturer which basically asks do they handle any food allergens in the manufacturing plant - if so which ones and are they on the same line as the lubricant supplied and how do they control allergen contamination

I then risk out as high, medium risk, low risk, no risk

High risk - allergen present  in lubricant

Medium risk -no allergen in lubricant, allergen used on site and no allergen control

Low risk - no allergen in lubricant, allergen used on site but good allergen control

No risk - no allergen in lubricant and no allergens used on site.

Hope that helps!

S

I sure will look into that.

Thanks so much for your guidance, definitely a great start! 

AB 

AB,

May I ask the nature of the pre-assessment? Was it to some specific standard for the purpose of implementing HACCP or GMP certification or one of the GFSI bench marked standards e.g., BRC, SQF, etc.? IFSQN members may be able to assist you better if you provide more specific background and goal information.

Regards

Sure... We are looking forward to obtain SQF Certification. The day of the pre-assessment this was given a minor due to not all ingredients with allergen were not recorded ( in this case, food grade lubricants) under clause 2.8.2.1 Allergen Management. 

Thanks, 

AB 

AB,

Attached are a couple articles on constructing a risk matrix very much along the lines of Spurs Girl 's. Also, a whitepaper on risk assessment and an SQF allergen guidance doc. IMO a risk matrix and assessmentfor food safety ought to have a logical connection to the established criteria and verbiage for class 1, 2, 3 recalls, an in-house (never-left-your-control) event and a non-event.

Hello everyone,

 

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.

 

Gracias! :-)

AB 

ana-baron

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)) -

http://www.ifsqn.com...-documentation/

(the above thread shd prob.hv been in SQF forum)

(eg see attachment val4, sec. 2.8.2.1)

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.

 shell_cassida_food_grade_brochure.pdf   2.89MB   428 downloads

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

http://www.foodsafet...ade-lubricants/

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. 

Dear,

BRC does not require the risk assessed document, only the evidence of known allergen status for lubricant. Some declaration doc from supplier/manufacturer is enough. You should challenge to your auditor. Do not over interpreted.

KK