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ARMORTHANE PROTECTING YOUR WORLD

PROTECTING YOUR WORLD

ARMORTHANE PROTECTING YOUR WORLD

Food Grade Coating:
What the Label
Really Means

Which rule covers tank linings, drinking water, floors and walls, the extraction tests behind a compliance letter, and the documents your auditor will ask to see.
Food plant projects

Coating a tank, wall or processing floor?

Tell us what the surface touches and how it gets cleaned. We will match an ArmorThane product with the right documents and connect you with a certified applicator near you.

  • Surface: tank, bin, wall, curb or floor
  • Food or liquid it contacts
  • Washdown temperature and sanitizers
  • Area in square feet or tank gallons
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Step 1 of 3
175.300
FDA rule (21 CFR) for resin coatings that touch food
Direct contact linings
18 mg
Max extractives per sq in for repeat-use coatings
Chloroform-soluble, per 175.300
1997
Year USDA FSIS dropped prior approval of plant materials
62 FR 45016
3/8 in
Minimum cove radius many health departments require
Running at least 4 in up the wall

Food grade coating is a phrase printed on a lot of data sheets, and it promises less than most buyers think. There is no single federal food grade stamp. What counts is where the coating sits in relation to the food, and which rule covers that spot.

Quick answer

A food grade coating is one that meets the rule for where it touches food. Linings for tanks, bins and equipment in direct contact must comply with FDA 21 CFR 175.300. Drinking water tanks need an NSF/ANSI/CAN 61 listing. Floors, walls and ceilings only need to be durable, impervious and easy to clean under USDA 9 CFR 416.2 and the FDA Food Code.

What's in this guide
  1. 1The four contact levels
  2. 2Coating types compared
  3. 3Contact and test checker
  4. 4Paperwork to ask for
  5. 5Floors, walls and cove
  6. 6Questions
Definitions

What makes a food grade coating compliant

Inspectors and auditors sort every surface in a plant into one of four buckets. The bucket picks the rule, and the rule decides what paperwork you need from the coating maker. Get the bucket wrong and you either pay for a lab-tested lining on a wall no food will ever touch, or you put an ordinary floor epoxy inside a syrup tank.

Direct contact

Tank, bin and equipment linings

Food sits against the coating. FDA 21 CFR 175.300 applies: listed raw materials, plus extraction tests in water, heptane or 8% alcohol depending on the food.

Drinking water

Potable water tanks and lines

Covered by NSF/ANSI/CAN 61, which most states and utilities require. The listing names the smallest tank and the cure schedule the lining was tested at.

Incidental

Floors, walls, ceilings, splash zones

Food may drip or splash but is never stored there. USDA wants materials that are durable and impervious to moisture; the Food Code adds smooth, easily cleanable and nonabsorbent.

Non-contact

Docks, dry warehouse, exteriors

Normal industrial coatings are fine. Choose for forklifts, salt, UV and chemicals rather than for food rules.

There is no "FDA approved" coatingFDA does not approve or certify coatings. The resin maker determines that its formula complies with 175.300 and states it in a signed letter. USDA ended its prior-approval program for plant materials in 1997 and has kept no approved list since. When a data sheet says "USDA approved," ask exactly what it means and get the answer in writing.
Coating families

Food plant coatings side by side

A slicer blade and a meat room floor both need a food-safe surface, yet the two coatings have nothing in common. Film thickness alone runs from a couple of mils to more than a quarter inch. Here is how the common families line up.

CoatingTypical film (mils)Where it fitsContact levelWatch for
PTFE / fluoropolymer1–3Slicers, chutes, molds, bake pansDirect (21 CFR 177.1550 resins)Shop-baked only; scratches through under abrasion
Powder coat2–4Racks, frames, guards, cartsIncidental; some grades directChips at impact, then rusts underneath
Polyaspartic floor system10–25 (system)Dry storage, packing, retail and light wet areasIncidentalHot water and steam on thin film
100% solids epoxy lining15–40Wine, juice, syrup and grain tanksDirect (175.300 grades)Slow cure in cold tanks; limited thermal shock
Pure spray polyurea40–100Water tanks, bins, hoppers, splash walls, curbsDirect or potable for listed productsMust be the documented formula, fully cured
Urethane cement188–375 (3/16–3/8 in)Meat, dairy and bakery floors with hot washdownIncidentalNeeds a trowel crew and a dry, sound slab
Typical industry ranges. The compliance letter and the product data sheet decide what a specific product can do. Tap a column heading to sort.

Our take after a lot of tank and plant work: polyurea earns its spot on tank and bin linings, block walls, curbs, containment and floors that stay dry or cool, because it cures in seconds, builds thick in one visit and bridges hairline cracks. On a kill floor or a dairy slab that gets blasted with 180°F water every shift, we would put urethane cement on the floor and polyurea on the walls and curbs around it.

ArmorThane products with food or water documents on their pages: AquaSafe pure polyurea for drinking water storage and HighLine 510 pure polyurea, listed as meeting USDA and Canadian agriculture criteria. For germ control, see antimicrobial polyurea coatings.

Contact checker

Which rule covers your surface?

Pick the surface, then the food and how it is filled or stored. The checker returns the contact class, the rule, the extraction test a lab runs under 21 CFR 175.300 Table 2, and the pass mark you should see in writing.

Compliance check

Food contact class and test finder

Direct-contact tests follow 21 CFR 175.300: water for watery foods, heptane for fatty foods (result divided by 5), 8% ethanol for alcoholic drinks, at the time and temperature set by the condition of use. Repeat-use coatings may not exceed 18 mg/sq in of chloroform-soluble extractives. Potable water follows NSF/ANSI/CAN 61; floors and walls follow 9 CFR 416.2 and the FDA Food Code.

—
Contact class
—
Rule that applies
—
Test or check
—
Pass mark

Documentation

The paperwork to ask for

No auditor is going to scrape your tank and send the chips to a lab. They ask for documents. Collect these before the crew shows up, file them with the food safety plan, and an SQF or BRCGS audit becomes a five-minute conversation about coatings instead of an hour.

  1. Letter of guarantee on letterhead

    Signed by the manufacturer, naming the exact product and the regulation it meets, such as 21 CFR 175.300. A line on a data sheet is not a guarantee.

  2. Extraction report or third-party listing

    For direct contact, a lab report at your food type and condition of use. For drinking water, the NSF/ANSI/CAN 61 listing, checked against your tank size.

  3. Cure schedule before contact

    The hours at a given temperature before the surface may touch food or water. Polyurea gels in seconds, but full cure still takes time, and a cold tank stretches it.

  4. The applicator's job record

    Batch numbers, mixing ratio checks, surface and air temperatures, mil readings and, on linings, holiday (spark) test results showing no pinholes.

  5. Cleaning chemical compatibility

    Match the chemical resistance chart against what your sanitation crew really runs: caustic, chlorine, quats, peracetic acid, acid descalers.

Full cure firstA compliant formula that is mixed off ratio or put into service early can leave unreacted material at the surface. That is why ratio checks and the cure log matter as much as the letter from the manufacturer. If the job record is missing, the compliance letter covers a product, not your tank.
Floors and walls

Floors, walls and cove base

Most of the square footage in a food plant is incidental contact. The bar there is physical, not chemical. The surface has to shed water, survive the sanitation crew and leave bacteria nowhere to hide.

  • Integral cove: many health departments, Los Angeles County among them, want a cove of at least 3/8 inch radius running 4 inches or more up the wall. Vinyl top-set base is usually turned down.
  • Slope to drains: 1:50, roughly 1/4 inch per foot, is a common requirement anywhere floors get hosed.
  • No open joints: cracks, saw cuts and old tile grout get filled and coated over, or they become the dirtiest inch in the room.
  • Texture to match the wet: broadcast aggregate adds grip but makes scrubbing harder. Spec it for how wet the floor really gets.
  • Thermal shock: hot washdown on a cold slab works the bond line every shift. Ask for the system's thermal shock rating in writing.
Good fit for polyurea

Walls, curbs, tanks, dry and cold rooms

Back in service in hours, thick crack-bridging film and no seams. Strong on block walls, curbs, pits, coolers and freezer floors where washdown water stays moderate.

Pick something else

Hot, wet, steel-wheel floors

Constant hot water, steam and loaded steel-wheel carts call for a 1/4 inch class urethane cement. A thin coating there is a repair schedule, not a floor.

Prep decides all of it. A food grade coating over a slab soaked with fat and cleaning residue will lift no matter what the paperwork says; read our surface preparation guide before anyone opens a drum.

Related: foodservice and healthcare coatings, commercial kitchen flooring, walk-in cooler insulation and chemical resistant coatings.

Food plant work

Lined, cured and documented.

A certified ArmorThane applicator can line tanks and coat walls, curbs and floors with products backed by the documents your auditor will ask for.

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FAQ

Food grade coating questions

What is a food grade coating?

It is a coating that meets the rule for its level of food contact: FDA 21 CFR 175.300 for direct-contact linings, NSF/ANSI/CAN 61 for drinking water, and durable, impervious, cleanable surfaces under USDA and Food Code rules for floors and walls. No single federal label exists.

Is polyurea food safe?

Some formulations are. Pure polyurea products made for potable water or food handling can carry the needed documents, and ArmorThane's AquaSafe was developed for drinking water storage. Not every polyurea qualifies, so ask for the letter of guarantee or listing for the exact product.

Is there an FDA approved paint or coating?

No. FDA does not approve paints or coatings. Manufacturers formulate to 21 CFR 175.300 or another Part 175 to 178 rule and state compliance in a signed letter. "FDA approved" on a can usually means FDA-listed ingredients, so get the letter.

Is epoxy food grade?

Some epoxy tank linings comply with 21 CFR 175.300 once fully cured, and many epoxy floors are fine for incidental contact. Craft and tabletop epoxies are a different market. Check that the product names the regulation and the cure time before food contact.

Does USDA approve floor coatings?

No. USDA FSIS ended prior approval of plant materials in 1997. Under 9 CFR 416.2, floors must be durable, impervious to moisture and kept sanitary, and inspectors judge them by condition, not by a product list.

How long before a coated tank can hold food?

Follow the cure schedule in the compliance letter or NSF listing, which ties a minimum time to a temperature. Cold tanks take longer. Many owners also rinse the tank and run a taste and odor check on a small first batch.

AT
Written by the ArmorThane technical team. We have manufactured polyurea, polyurethane and polyaspartic coatings and plural component spray equipment in Springfield, Missouri since 1989. Ranges here are typical; always follow the product's compliance documents and your own food safety plan.

Sources

  1. eCFR, 21 CFR 175.300 Resinous and polymeric coatings. ecfr.gov/current/title-21/section-175.300
  2. eCFR, 9 CFR 416.2 Establishment grounds and facilities. ecfr.gov/current/title-9/section-416.2
  3. Federal Register, Elimination of Prior Approval Requirements for Establishment Drawings and Specifications, Equipment (62 FR 45016, 1997). federalregister.gov/documents/1997/08/25/97-21882
  4. Food Engineering, Coating and lining considerations for FDA and USDA regulated food and beverage plants. foodengineeringmag.com/articles/99826
  5. Los Angeles County Public Health, Construction Requirements for Retail Food Facilities. publichealth.lacounty.gov/eh/inspection

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