Mosh Moah Free Lubricants | The EFSA Regulation on Food Safety

Published: 02 September 2021

Mosh Moah Free: the future of Food Processing Industries is above Haccp

Mosh and Moah Definition

Moh (Mineral Oil Hydrocarbons) are mineral based hydrocarbons obtained from crude oil, coal, gas or biomass that can potentially contaminate food production undermining food safety. Moh can be divided into two main categories:

  • Mosh, acronym of Mineral Oil Saturated Hydrocarbons. Mosh tend to accumulate with toxic effects on organs, especially on liver and lymph nodes. 
  • Moah, acronym of Mineral Oil Aromatic Hydrocarbons. Moah are considered more toxic than Mosh and they are suspected to be carcinogenic.

The real challenge of this last years has been to establish a detection methodology to fix the ADI (Acceptable Daily Intake) value, which is the acceptable daily ingestion tolerance for humans. Generally speaking experts think that Moah percentage (ref. 3-7 PAC) settles at 15-35% of total Moh. Although a step forward has been made in detection methodology it is still hard to imagine long-term implications, especially regarding liver deposits.

Food Safety: Moh Contamination Sources

Apart from detection methodology it is still very difficult to establish the effective source of a Mosh Moah food contamination. Main potential occasions might occur from:

  • Environmental contamination: leaks of industrial lubricants, gasoline, bitumen and rubbish parts coming from agricultural machines during harvesting;
  • Process contamination: coming from A) process industrial lubricants made for direct or accidental contact with food, B) food additives, C) processing aids like lubricants and release agents during baking and/or packaging;  
  • Transfer contamination: coming from direct contact of food with packaging, adhesives or inks particularly in case of recycled paper and board.

Take into account that hydrocarbons and light mineral oils are extremely volatile. Even if there's no direct contact, hydrocarbons can evaporate and later on re-condense on food. 

Why including a Mosh Moah Free Lubricant in the Haccp plan

NSF International registered lubricants

Like we mentioned before among Mosh Moah contamination sources there are also industrial lubricants and greases used in food and beverage industries. Choosing to include a Mosh-Free and Moah-Free lubricant is an important statement towards food safety. NSF H1, H2, H3 registration of the Food and Drug Administration (FDA) ruling this discipline is a good starting point in the right direction but having a specific declaration from the lubricant producer regarding Moh levels in the products is strongly advised. 

Foodgrade lubricants: Pakelo Non Tox M Series

Pakelo Non Tox M series was born with the specific aim to help food and beverage industries to enhance food safety in view of a future stricter regulation on Mosh and Moah limits. This series is made of three key products which are both NSF compliant and Mosh Moah Free:

  • Pakelo Non Tox Oil M is a range of fully synthetic lubricants specific for food processing and packaging. It is available in the following viscosities: ISO 15, ISO 32, ISO 46, ISO 68, ISO 150, ISO 220, ISO 320, ISO 460.
  • Pakelo Non Tox Oil M DP is a release agent granting the correct release of food from moulds or from cooking surfaces. It is suitable also for not loaded plants and for direct contact with food (NSF H3 and 3H levels). 
  • Pakelo Non Tox Grease M CA NLGI 2 is a fully synthetic grease thickened with anhydrous calcium granting high water-repellency which is necessary because of the frequent washings operated in this field. This industrial grease is specific for the lubrication of machineries used in food processing and packaging. 

Pakelo products of Pakelo Non Tox M range are also: allergen-free, OGM-free and Halal-compliant.

Tribological test on Pakelo Foodgrade Lubricants

Pakelo tested its whole range of non-toxic lubricants to understand if the formulation changes to create Mosh and Moah free lubricants could affect their performance. In the graphic below we confronted friction coefficients of a standard mineral-based foodgrade lubricant (green line), a standard synthetic-based foodgrade lubricant (yellow line) and a product of the new Mosh and Moah free series Non Tox Oil M ISO 46 (blue line). Under the same viscosity, friction coefficient test reveals a -20% for Non Tox Oil M ISO 46 compared with other products. It means that this product is as good for food safety as it is for the good functioning and performance of mechanical organs.

Regulations: Mosh Moah Limits

European Insights: Food Safety Regulations

The first concern of food processing industries is rightly food safety. Hot topics like food hygiene and food contamination have an impact both on consumers' health and on the producer's reputation. Having a good Haccp (Hazard Analysis Critical Control Points) in compliance with legislative decree 197/2007 is the norm, but maybe it is not enough. Today European Food Safety Authority (EFSA) is confronting more and more often with open concerns about Moh (Mineral Oil Hydrocarbons) presence in food. First concerns on the topic were raised by EFSA in 2010. This led to the formulation of an official EFSA scientific opinion in 2012 (Contam Panel) followed by a field test on powder milk in 2019 to better understand the risks connected with the presence of those substances in food. 

EFSA Position

You might rightly wonder if there is any Mosh and Moah limit fixed by law to respect. Like we mentioned in the premises at the beginning of 2021 EFSA has not established official parameters yet. In its "Scientific Opinion on Mineral Oil Hydrocarbons in Food" (Contam Panel) in 2012 EFSA affirmed that in absence of further studies ADI (Acceptable Daily Intake) thresholds will be those established by JECFA in 2002 (Joint Fao - Who Commitee on Food Additives). On low viscosity mineral group II and III oils the Commitee established a limit of: 10 milligrams per day per kilogram body weight referred to Mosh only. However, this limit has been suspended by Who itself in 2012 waiting for more accurate evaluations on the topic. 

The German Case History

German Federal Ministry of Food and Agriculture (BMEL in German) has already taken a position autonomously. German limits on Mosh and Moah presence on packagings are:

  • Mosh presence limit: 0,6 ppm of food
  • Moah migration limit: 0,15 ppm of food

We don't know when, but it is pretty obvious that both EFSA and the World Health Organization (Who) will also take a decision on this delicate matter in the next future.

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