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Resource Papers
3-A Requirements for Rubber Materials
This paper describes the general requirements for multiple-use
rubber and rubber-like materials in 3-A Sanitary Standards. Readers should
obtain a copy of the complete current standard for details or consult
with a qualified laboratory authority on the testing protocol. To obtain
this standard, go the 3-A SSI web site home page, click on ’Purchase
3-A Sanitary Standards and 3-A Accepted Practices’ and follow to
purchase information for 3-A Sanitary Standard
#18- , 3-A Sanitary
Standards for Multiple-Use Rubber and Rubber-Like Materials Used as Product
Contact Surfaces in Dairy Equipment.
What does this standard cover?
This standard pertains to the material and serviceability requirements
of rubber and rubber-like materials used as product contact surfaces.
The primary uses of these materials in typical dairy and food processing
operations are for liquid product hoses, food conveyor belts, and gaskets
for pipelines and equipment.
This standard specifically excludes hard rubber and provides
a definition for the composition of these materials. In addition, the
standard specifically excludes room-temperature-vulcanized (RTV) silicone
adhesives or sealants. They are considered suitable only for certain nonproduct
contact sealing applications.
Why a 3-A Sanitary Standard for
rubber materials? Isn’t FDA
food grade testing sufficient?
Compliance with FDA regulations in CFR Title 21, Part 177.2600 is a primary
requisite of the 3-A Standard. FDA specifies the permitted "ingredients"
for food grade rubbers, that is, the natural and/or synthetic polymers
and the adjuvant substances (e.g. vulcanization materials, antioxidants,
plasticizers, fillers, colorants, etc.). The 3-A Sanitary Standard specifies
additional performance requirements to establish acceptance for these
applications. Specifically, the materials must meet requirements for compatibility
with cleaning and sanitizing agents under accelerated use-simulating conditions.
These tests are intended to evaluate the rubber physical properties and
to assess performance of the rubber under accelerated simulated dairy
product contact and cleaning conditions. The specified laboratory testing
concerns milk fat absorption, air aging stability, and tests for compatibility
with cleaning and sanitizing agents.
Is there one best or "ideal"
formulation of rubber for dairy and food uses?
No, the wide variety and composition of dairy and food products, together
with the diverse requirements of the processing equipment, necessitate
a wide range of rubber formulations.
The standard does establish four classes of rubber mainly
delineated by the expected temperature of exposure to product or sterilization.
For instance a Class III rubber is considered suitable for exposure to
product up to 120°F (49°C), and temperature of exposure to chemical
solution used in cleaning and bactericidal treatment up to 180°F (82°C).
Although meeting the 3-A Sanitary Standard, such a Class III rubber would
not be considered suitable for a Class I use involving exposure to temperatures
up to 300°F (149°C).
Is a rubber material that meets
all four classes suitable for the manufacture of any equipment covered
by a 3-A standard?
Technically, yes, but it wouldn't be a good idea. For satisfactory service,
rubber material should be compounded to meet the performance criteria
for its intended use. The 3-A Sanitary Standard covers only some of the
sanitary aspects. Tests for other performance properties that may be desirable
for a given application may be measured by established ASTM tests.
Once a rubber formulation or compound
is tested and found to conform to the requirements of a given class(es),
How often is subsequent testing required?
Re-testing of the compound is required only if the formulation is changed,
at which time, the compound number should also be changed.
Is there any color preference for
dairy rubber materials?
No. The color of rubber materials will vary depending on the ingredients
and formulation, but the color of the final product has no sanitary significance.
If colorants are used, they must conform to the FDA food color additive
regulations.
Is there a list of sources of rubber
compounds that meet the 3-A Sanitary Standard?
To our knowledge, there is no such list. Previously, 3-A SSI maintained
such a list for plastics, but discontinued the list. It was not possible
for the limited staff to keep the list current.
Who should do the required laboratory testing—the rubber
manufacturer, the rubber parts manufacturer, or the user?
The standard does not address this matter, but only the rubber manufacturer
can attest to compliance with the basic FDA requirements. In fact, the
Appendix of the standard includes
Example of a Rubber Certification
Form, which shows combined wording that certifies compliance
with both FDA and 3-A test requirements. However, this would not rule
out situations where the rubber parts manufacturer or user could 1) obtain
a FDA compliance certification from the rubber manufacturer, 2) perform
or underwrite the required 3-A laboratory testing, and 3) prepare the
standard’s sample or similar certification form. In the latter case
of course, the certifier should have an understanding with the rubber
manufacturer requiring notification of any changes in the formulation.
How can I find a list of companies
that make “food grade” rubber?
You may consult the industry trade association, the Rubber Manufacturers
Association. The RMA web site has a directory of RMA members at
www.rma.org,
but it does not break out the “food grade” rubber manufacturers.
Is there a list of laboratories that specialize in
testing rubbers or that are capable of performing the required 3-A tests?
To locate such a laboratory, try the following sources:
ASTM International at www.astm.org.
American Council of Independent Laboratories at www.acil.org.
American Association for Laboratory Accreditation at www.a2la.org.
Is it a big job to run these 3-A rubber tests?
Performing these tests successfully does require specialized laboratory
equipment and knowledge of proper laboratory procedures. Five ASTM Standards
are referenced and the rubber samples must be prepared and tested according
to carefully prescribed procedures.