What documentation should I keep for FSSAI audits?

Maintain: (1) NSF certification certificates for each food-grade product used, (2) safety data sheets (SDS), (3) supplier authorization letters confirming you are buying through an authorized channel, (4) a lubrication chart showing which product is used at each food-contact point, (5) batch-level chain-of-custody records linking each delivery to the specific machines/areas where it's used, (6) operator training records confirming food-grade discipline.

Can I use the same Castrol Optileb across all my equipment?

Optileb covers gears, bearings, chains and hydraulics in food-contact zones. The specific Optileb grade depends on the application — Optileb GR for grease points, Optileb GT for gearboxes, Optileb HY for hydraulics. For non-contact equipment (away from food zones), conventional industrial lubricants are acceptable but most plants standardise on food-grade plant-wide to eliminate cross-contamination risk.

By Vineeth Polisetti, Director · Published 2026-04-28 · 9 min read

FSSAI Compliance for Food-Grade Lubricants in India: Aligning NSF H1 with FSSAI Audits

Q: Does FSSAI specify which lubricants can be used in food plants?

FSSAI's Food Safety and Standards (Licensing and Registration) Regulations 2011 require Food Business Operators to use food-grade lubricants in equipment with incidental food contact. FSSAI does not publish its own lubricant specification — it accepts internationally-recognised food-grade certifications, primarily NSF H1 (lubricants with possible incidental contact), NSF H2 (no contact possible) and NSF 3H (release agents).

Quick Answer

FSSAI does not publish its own lubricant specification — instead it requires food business operators to use lubricants with internationally-recognised food-grade certifications (primarily NSF H1, NSF H2, NSF 3H). For Indian food, beverage and pharma plants, the practical compliance discipline is: standardise on NSF H1 products like Castrol's Optileb range for any equipment that could have incidental food contact, maintain NSF certification documents and supplier authorization letters in your audit file, and operate a chain-of-custody log linking each lubricant delivery to specific machines and dates.

FSSAI auditors don't typically hand you a list of "approved lubricants." They ask: where could lubricant contact food, what are you using there, and can you prove it's food-grade? The audit-ready answer is a documentary chain that ties NSF H1 certifications, supplier records, and your internal lubrication map together. This article walks through how Indian food and pharma plants actually pass that audit.

What FSSAI actually requires

The Food Safety and Standards (Licensing and Registration) Regulations 2011 require Food Business Operators (FBOs) to maintain hygienic processing conditions including the use of safe materials in any place where food can be contaminated. Lubricants used on equipment with food-contact potential must be of "food-grade" standard. FSSAI does not specify a particular standard but accepts internationally-recognised certifications — with NSF (National Sanitation Foundation, USA) being the global benchmark.

The three NSF categories most relevant for Indian plants:

NSF H1Lubricants for incidental food contact. Maximum 10 ppm in food permitted. Used on equipment where the lubricant could possibly — but should not normally — contact food. This is the workhorse category for food and pharma plants.
NSF H2Lubricants for use in equipment where there is NO POSSIBILITY of food contact. Used in environments where the lubricant cannot reach food zones (e.g. enclosed gearboxes in non-contact areas).
NSF 3HRelease agents and lubricants applied directly onto food-contact surfaces (e.g. mineral oil applied to a baking sheet). Direct food contact is permitted.

Where to use H1 vs H2 in a real plant

The mapping discipline:

Use NSF H1 for: bearings on overhead conveyors above food zones, gear oil in reducers near or above food production lines, hydraulic oil in any cylinder positioned over food, chain lubricant on conveyor chains in production areas, grease for any motor or drive that could leak into food zones.

Use NSF H2 for: equipment in clearly non-contact zones (e.g. compressor room far from production), administrative-area HVAC equipment, packaging-room machinery if positioned away from open food. Note: most plants STILL choose H1 plant-wide to eliminate the risk of accidentally placing H2-only product near food after a maintenance reorganisation.

Use NSF 3H for: explicit release-agent applications. Not common in industrial lubrication; mostly used in baking and confectionery.

The Castrol Optileb range — what it covers

Castrol's Optileb family is the food-grade range certified to NSF H1, ISO 21469 (more demanding than NSF H1 alone) and Halal/Kosher where required. The grades that matter:

Optileb GT (gear oils)NSF H1 industrial gear oils across viscosity grades 100-680 for enclosed reducers in food and pharma plants. ISO 12925-1 CKC performance.
Optileb GR (greases)NSF H1 aluminium-complex greases NLGI 1, 2 for bearings, chains and pivot points in food-contact zones. Working temperature -20 to +150°C.
Optileb HY (hydraulic oils)NSF H1 hydraulic oils for hydraulic systems on food-processing machinery. Anti-wear, anti-foam properties matched to typical food-plant duty.
Optileb compressor oils, chain oils, slideway oilsSpecialist NSF H1 grades for specific applications.

What FSSAI auditors actually check

From feedback by FSSAI-audited Indian food and pharma plants, auditors typically work through this checklist:

"Show me the lubrication map." A schematic or list of every lubrication point in the plant, the product used, and the food-contact classification (H1/H2/non-contact). If you don't have this, you fail this audit point immediately.

"Show me certifications." NSF certification certificates for each food-grade product used. These should be the original NSF documents (downloadable from info.nsf.org) or supplier-provided copies. Castrol India provides these on request through your authorized distributor.

"Show me the supplier authorization." A letter from Castrol India (or via your authorized distributor) confirming you are an authorized buyer. This is to verify the lubricant didn't enter the plant through a parallel-import or refilled drum.

"Show me the chain of custody." Records linking each delivery to the specific machines or areas where the lubricant was used. Date, drum/batch number, dispense location. Most plants implement this through a simple log book or ERP record.

"Show me operator training." Records that operators handling food-grade lubricant know the H1/H2 discipline, segregation rules, and what to do if non-food-grade product is accidentally introduced into a food zone.

Common compliance failures (and how to avoid them)

Mixed storage. Storing H1 and non-H1 lubricants on the same rack without physical segregation is the most common failure. Fix: dedicate one rack or shelf area for food-grade only, with bright signage. Use coloured drum bands.

Shared dispensing equipment. Using the same grease gun or oil can for both H1 and non-H1 products. Fix: dedicated colour-coded equipment per category. Operators trained to never cross-use.

Expired NSF certifications. NSF certifications are typically valid 1 year and renewed annually. Old certificates in the audit file fail compliance. Fix: a yearly diary reminder to download fresh certs from NSF and refresh the audit file.

Out-of-scope NSF marking. Some plants accept any drum showing "NSF" without verifying the H1 vs H2 classification. Fix: read the NSF label fully. The NSF mark itself is not enough — the category (H1, H2, 3H) must be present.

Loss of supplier traceability. Buying through a non-authorized cheap-source dealer leaves you without a verifiable supplier authorization letter. Fix: only buy through Castrol's authorized distributor network. The discount you save on grey-market product isn't worth losing FSSAI compliance.

The audit-ready folder

Maintain a single lever-arch file (or its digital equivalent) called "Food-Grade Lubrication Compliance" with these tabbed sections:

Tab 1: Lubrication map — current plant schematic with every lubrication point classified.

Tab 2: NSF certificates — one per product currently in use, refreshed annually.

Tab 3: Supplier authorization letters — from Castrol India / your authorized distributor.

Tab 4: Safety Data Sheets (SDS) — for each product.

Tab 5: Chain of custody log — receipt date, batch, dispense location and date for each lubricant entering the plant.

Tab 6: Training records — signed acknowledgements from each operator who handles or maintains food-grade equipment.

Tab 7: Internal audit reports — quarterly self-audits of the above, dated and signed by your QA lead.

Pulling this folder out at an FSSAI audit visit is the cleanest possible response. Most auditors close out the lubrication-related audit point in 10 minutes when this file is presented organised.

Need help building an FSSAI-ready lubrication compliance system?

Our technical team works with food and pharma plants to build the lubrication map, supply NSF H1-certified Castrol Optileb products with full chain-of-custody documentation, and train operators on segregation discipline. Available pan-India through Vasundhara Group.