MOSH/MOAH and JAX Food Grade Lubricants. How to reduce the risk of mineral oil contamination in a food processing plant?

Introduction

Food safety less and less frequently ends with the control of raw materials and finished products. In a modern food processing plant, the entire production chain is analyzed: from deliveries, through packaging, the production environment, maintenance, to the technical means used with machinery. One of the topics that has particularly strongly returned to industry discussion in recent years is MOSH and MOAH, which are mineral oil hydrocarbons.

MOSH, or mineral oil saturated hydrocarbons, are saturated mineral oil hydrocarbons. MOAH, or mineral oil aromatic hydrocarbons, are aromatic mineral oil hydrocarbons. Both groups can appear in food from various sources: packaging, raw materials, the environment, technological processes, transport, feed, and—in certain cases—from improperly selected or improperly used lubricants.

In industrial practice, the most important question is not "are there lubricants in the plant?", because they have been, are, and will be in every production plant. A machine without lubricant is like a bearing without a race—theoretically you can talk about it, but it won't work for long. The key question is: what lubricants are used, at what points, in what quantity, with what documentation, and do they meet the requirements for food production.

In this context, JAX food grade lubricants, from the American lubricant manufacturer, which has been developing products for the food, beverage, bakery, dairy, meat, poultry, fish, fruit and vegetable, and packaging industries for many years, are particularly important.

Why are MOSH/MOAH important for the food industry?

The increasing requirements for MOSH/MOAH stem from a broader approach to food safety. Today, it is not enough to demonstrate that the final product meets organoleptic and microbiological requirements. Chemical contamination, migration of substances from packaging, contact with auxiliary materials, and the risk of cross-contamination are becoming increasingly important.

MOSH and MOAH hydrocarbons can enter food from many sources. One frequently analyzed source is packaging, especially that made from recycled paper and cardboard. Other sources can include the environment, auxiliary agents, harvesting processes, storage, transport, feed, technological additives, or elements of the production process.

Lubricants are only one potential source. Therefore, one should not automatically assume that every presence of MOSH/MOAH in a food sample originates from lubricant. However, in a well-managed maintenance facility, lubrication must be treated as one of the risk assessment areas. This is a classic industrial principle: we do not guess, we identify the source, document it, and eliminate the risk at its root.

New requirements and MOSH/MOAH monitoring

The requirements for MOAH being drafted and discussed in the European Union foresee a gradual regulation of permissible levels in various food categories. For vegetable fats and oils, such as rapeseed or sunflower oil, the anticipated maximum value is 2.0 mg/kg. For some oils, such as argan, coconut, or peanut oil, higher levels are temporarily permitted, which are to be gradually reduced to 2.0 mg/kg by 2030.

For spices, dried herbs, and instant teas, the draft foresees a value of 10.0 mg/kg from 2027, reduced to 5.0 mg/kg by 2030. Traditional dried tea and herbal teas are generally treated differently if they are not instant products or food ingredients, because the transfer of MOAH to the infusion is limited.

For dietary supplements, the proposed value is 10.0 mg/kg from 2027, and then 5.0 mg/kg by 2030. For processed and composite foods, general fat content-based limit values are to apply from 2030.

Parallel to this, monitoring of MOSH/MOAH is expected between 2026 and 2029. Indicative levels, referred to as ILs, do not automatically ban the sale of a product. Their role is to trigger an investigation into the source of contamination. In practice, this means the necessity of checking the entire process: from raw materials and packaging, through storage, to the technical agents used in production.

Food-grade lubricants and incidental food contact

In food processing plants, ordinary industrial lubricants are not used where there is a possibility of contact with food. For such locations, NSF H1 class lubricants are intended, which are products approved for incidental food contact. However, it must be very clearly emphasized: H1 does not mean that the lubricant is a food ingredient. H1 means that the product can be used where accidental, technically unavoidable contact with food is possible.

According to the FDA and NSF approach, an H1 lubricant should only be used in the minimum amount necessary to perform its technical function. In practice, this means proper application, dosage control, elimination of leaks, securing lubrication points, and proper documentation.

In the food industry, three elements are therefore of fundamental importance:

• selecting the correct lubricant for the operating point,
• limiting the risk of lubricant migration into the product,
• documenting the use of a product compliant with food production requirements.
• This is where the role of JAX food-grade lubricants begins.

JAX position on MOSH/MOAH

In a letter dated September 10, 2021, JAX INC., located at W134 N5373 Campbell Drive, Menomonee Falls, WI 53051, addressed the growing concerns regarding MOSH and MOAH levels in mineral lubricants approved for food contact.

JAX confirms that the mineral oil bases used in JAX food-grade products undergo intensive refining to achieve a very high level of purity. According to the company's statement, they meet the requirements of the U.S. Pharmacopeia, the National Formulary, the U.S. FDA 21 CFR 172.878, and are NSF 3H certified for direct food contact.

JAX also refers to analytical data on MOSH and MOAH provided by mineral oil suppliers. According to this information, the MOAH content for hydrocarbons below C16 was not detectable at 20,000 mg/kg, and for the C16–C25 and C16–C35 ranges, it was not detectable at 10,000 mg/kg. These data are significant because in industry discussions, MOAH is precisely the fraction considered to require particular attention.

Based on the provided data, JAX INC. confirms that the MOSH and MOAH content in JAX products does not pose a problem for mineral oils used in the production of lubricants for food contact.

However, this position should be interpreted in a technical and responsible manner. The manufacturer's declaration does not relieve the plant of the obligation to properly use lubricants, maintain hygiene procedures, control dosing, and keep documentation. Even the best food-grade lubricant should be used as intended. The old maintenance rule still applies: a good product helps, but a good procedure ensures the result.

What does the MOSH/MOAH study teach us?

The technical study on MOSH/MOAH challenges in the food industry highlighted several important issues that should be considered when evaluating lubricants.

First, industrial lubricants usually consist of 90-99% mineral or synthetic base oil. The remaining part consists of performance additives. Base oils are divided into Groups I-V depending on the processing technology and final properties. Groups I-III include various types of mineral oils, while Group IV includes polyalphaolefins, or PAOs, and Group V includes other specialized synthetic bases.

Secondly, lubricants used in food machinery must meet safety requirements for incidental food contact. In practice, this means compliance with FDA 21 CFR 178.3570 and registration of components as NSF HX-1 or the finished lubricant as NSF H1.

Thirdly, the study indicates that the BfR test was primarily developed to detect MOSH and MOAH in food or food contact materials, such as packaging. It is not a test specifically designed for lubricants. However, the method can be used in the lubricant industry to generate technical data and answer end-user questions.

Fourthly, a very important conclusion is that the BfR test does not always differentiate whether the detected structures originate from mineral oil or from specific synthetic bases. In practice, this means that the mere use of a synthetic lubricant does not automatically guarantee that a MOSH or MOAH signal will not appear in the analysis. Therefore, risk management cannot be based solely on the slogan "synthetic," but on a full assessment of the product, NSF H1 registration, documentation, application control, and plant procedures.

MOSH vs. MOAH – why shouldn't we lump everything together?

In practical plant operations, a common shortcut is often taken: "MOSH/MOAH = lubricant problem." This oversimplification can lead to incorrect conclusions.

MOSH and MOAH are detected by various analytical methods, and their presence can result from numerous sources. MOSH can appear in both mineral products and certain synthetic systems, as the analytical method may identify specific hydrocarbon structures without simply distinguishing their origin. MOAH, on the other hand, is a fraction that raises greater toxicological and regulatory concerns.

For this reason, the selection of lubricants should not be based on a single marketing slogan, but on a full set of criteria:

• is the product registered as NSF H1,
• does the manufacturer have technical documentation,
• is the product intended for a specific operating point,
• is there a possibility of food contact,
• is the application controlled,
• is the amount of lubricant minimal and technically justified,
• are the lubrication points included in the maintenance plan,
• does the personnel know where to use a given product.

JAX in food processing plants

JAX food-grade lubricants can be part of a strategy to reduce the risk of MOSH/MOAH in a food processing plant, as they enable the selection of products designed for use in food production environments. JAX offers lubricants for various industry segments: baking, dairy, meat and poultry processing, beverage production, fish, fruit and vegetable processing, pet food production, confectionery, and packaging production.

In practice, the following areas are of greatest importance: