There has long existed a symbiotic relationship between brewers and farmers in which spent grains, a byproduct of the brewing process, are given or sold to farmers for use as food for livestock. A proposed rule regarding preventive controls for pet and animal food as required under the Food Safety Modernization Act (FSMA) is causing a commotion among brewers over the effect it may have on this relationship.

In late October, the Food and Drug Administration (FDA) issued a proposed rule that would require facilities producing animal food to have written plans that identify hazards, specify the steps that will be put in place to minimize or prevent those hazards, identify monitoring procedures and record monitoring results, and specify what actions would be taken to correct problems that arise. The proposed rule also would establish certain Current Good Manufacturing Practices (CGMPs) that specifically address animal food. According to the proposed rule, brewery operations that sell their spent grain as animal feed could fall within the scope of the rule requirements. Accordingly, this rule could potentially have a significant impact on operations, handling procedures, record keeping and other food safety processes within the brewery setting.

According to an April 17 Food Safety News article, the major concern among brewers, as well as some members of Congress, is that the additional regulations on the spent grain, which would require that it be treated in the same way as commercial animal feed, would make it cost-prohibitive for brewers to continue to supply spent grain to farmers. In addition, brewers argue that the rule would offer no further safety assurances. The brewing industry submitted extensive comments to the proposed rulemaking during the extended comment period which ended in March 2014.

The FDA is currently revising the proposed rule to clarify exactly what will be expected of the byproducts of brewing. The agency intends to issue a re-release of the revised proposed rule some time during the summer.

I will continue to following the proposed rule change and  report on FSMA developments as they relate to the alcoholic beverages industry.