All too often when engineering and compliance attempt to uniformly convert plants to food grade they are met with resistance resulting in the conversion process being a mystery. Many food grade lubricant marketers are willing to assist in this process but converting should not be viewed as a mystery it is a simple step-by-step process.
a. Identify and document all current hazard analysis critical control points
b. Identify and document all lubricants currently in use and in what application they are used
c. Identify and document the current method and frequency of lubrication
d. Identify and document the lubricant handling and storage practices
e. Gather all OEM lubricant standards and recommendations
2. With the information gathered the conversion plan should be created and include the following:
a. A lubricants cross reference list indicating the food grade product which will replace the non food grade product (look to consolidate when possible)
b. Written conversion procedures which outline flushing and purging procedures for all applications (Your lubricant provider should be able to provide this information)
c. A lubrication manual which pairs each application with the corresponding lubricant also the method and frequency of re-lubrication should be noted
d. A storage and handling manual which outlines the following:
i. What area will be designated for lubricants storage this area should be caged to reduce risk of contamination
ii. How will lubricants be transferred and dispensed throughout the plant (Color coding the lubricant, transfer container and machine is very helpful and minimizes risk of contamination and or misapplication it also leads to consistency)
iii. How will used oil be stored, contained and disposed of
e. A spill and contamination control plan must be in place (This plan should already exist)
f. The HACCP plan should be updated to reflect the use of food grade lubricants
g. All staff maintenance and production should be abreast of all the hazard analysis critical control points throughout the plant it should be emphasized that any lubricant contamination of the finished product should be reported immediately and if the rate of contamination exceeds 10 milligrams per kilogram of foodstuff.
3. Now the implementation plan must be created it should include the following:
a. Oil samples must be collected from all applications prior to the conversion through oil analysis any preexisting problems can be identified and rectified before the conversion takes place
b. The quantity of lubricant inventory needed to fully convert the entire plant this should included cleaning agents and flush oils
c. A timeline which includes a complete list of all change outs and conversion activities preferably the time period chosen should coincide with a period of planned downtime
d. A QA/QC check list must be created and someone independent of maintenance should be responsible for verifying that all conversions are complete also in critical areas it is a good idea to pull oil samples post conversion and have them analyzed this will ensure that cross contamination has not occurred during the conversion process
If this method is followed the conversion to food grade is now complete. It is evident that the conversion process required time, money and the use of many resources while on the surface there is little to no savings. During the conversion process another activity should be taking place at the same time which is optimization of the lubrication maintenance program.