INFORM March 2025

during pro Secondar material c Migration

Trash/Debris? Cross Contamination

24 • inform March 2025, Vol. 36 (3)

Hierarchy of Controls

secondary contamination involves the transfer of MOH from one source to another. At the estate level, fresh fruit bunches (FFB) exposed to environmental pollutants such as exhaust gases from machin ery, can contribute to MOH contamination. In palm oil mills, contamination is highly likely to occur during crude palm oil (CPO) extraction, where hydraulic gear oils as a potential source. Cross-contamination can also occur during transpor tation, especially when different types of oils with varying levels of MOH contamination are transported in the same containers. MITIGATION STRATEGIES Our company has implemented a comprehensive mitigation plan to address and prevent MOH contamination in its supply chain. The primary focus is on stopping and preventing leaks from machinery, equipment, or processes. Immediate correc tive actions are taken whenever potential sources of leakage or contaminants are identified. To ensure sustained effectiveness, the company contin uously monitors and governs this procedure. The mitigation process begins with detailed supply chain mapping to iden tify potential contamination sources, spanning from the estate to product delivery. A subsequent verification study clas sifies these sources by severity and criticality, aiding in risk prioritization. High-risk contamination points are addressed first, fol lowed by medium- and low-risk areas. A critical control point system for MOH contamination will be implemented, com plemented by a risk control plan based on the hierarchy of controls, including elimination, substitution, engineering, administrative measures, and secondary protective strategies. To sustain these efforts, we have revamped our production Standard Operating Procedure (SOPs) and improved lubricant management in all operation units. Additionally, we launched a cultural transformation program to enforce best practices, par ticularly in mill operations, with the goal of achieving Hazard Analysis and Critical Control Points (HACCP) certification across all mills. Risk management is guided by a robust strategy, with efforts focused on eliminating contamination sources, as out lined in the table below. For example, replacing hydraulic sys tems with pneumatic or electric alternatives reduces the risk of hydraulic oil contamination in food products.

Physically remove the risk e.g. relocate

Most effective

Elimination

Replacement e.g. Hydraulic vs Air Suspension

Substitution

Engineering Controls

Design e.g. Top vs side stirrer

Administrative Controls

SOP/WI to govern the new initiatives

PPE

2nd layer protection e.g. tray, absorbent

Least effective

Solutions to control contaminations. Source: Hierarchy of hazard controls-NIOSH

We have also considered substituting mineral oil-based hydraulic oils with food-grade lubricants. However, despite their safety benefits, some of these products still contain MOH, and fully eliminating MOH contamination from lubri cants remains a challenge. Our team has implemented other measures, like new gearbox designs with double sealing and bearing isolators to prevent lubricant contact with products. We have also established comprehensive cleaning and preventive mainte nance schedules. We installed secondary safeguards, like tray absorbents to catch potential lubricant leaks, while high-risk equipment, such as gearboxes, are relocated to reduce con tamination risks. For instance, relocating gearboxes away from conveyor systems significantly lowers the chance of mineral oil lubri cants contaminating fresh fruit bunches or loose fruits. These mitigation efforts have resulted in a marked reduction in both MOSH and MOAH levels in crude palm oil. Currently, 21 out of 30 of our mills in Malaysia are HACCP certified. Additionally, our team has deployed two MOH analytical workstations to enhance monitoring and analysis capabilities. Unstable MOSH/MOAH level MOSH limit MOSH, ppm 30 25 20 15 10 5 0

MOSH/MOAH Moni

M

The equipment or components that pose potential contamination risks and the corresponding risk management strategies.

Risk Management

Engineering control

Second Layer Protection

Risk/equipment

Elimination

Substitution

Administrative control 1. HACCP 2. Lubricant management system 3. Preventive maintenance plan 4. Cleaning schedule

Gearbox

Food grade lubricants Double sealing separation

Absorbent % tray

Hydraulics

Lubricants free system

Food grade lubricants

Absorbent % tray

Bearings

Separation

Absorbent % tray