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Craft Brewing Business

FDA rule regulates spent grain sold as animal feed

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UPDATE September 2014: Spent grain is NOT going to be regulated by new animal feed rules, says FDA

Entrepreneurial, eco-conscious craft brewers across the country have found a side business of selling or just giving the spent grain from their production process to local farms to feed livestock. It’s a great practice, but one that might be more complicated soon.

Back in October 2013, the Food and Drug Administration (FDA) proposed a rule to establish best practices for manufacturing animal feed. Under this definition, craft breweries would be labeled animal feed manufacturers and be regulated as such by the FDA. In fact, breweries are specifically called out within a subsection:

“For example, FDA understands that many breweries and distilleries sell spent grains, such as brewers dried grains and distillers dried grains, as animal food. Because those spent grains are not alcoholic beverages themselves, and they are not in a prepackaged form that prevents any direct human contact with the food, the Agency tentatively concludes that subpart C of this proposed rule would apply to them.”

Each facility would be required to prepare and implement a written food safety plan, which is essentially a long list of checks and balances and re-checks and re-balances. They are in the rule as follows:

Hazard analysis — This would identify and evaluate known or reasonably foreseeable hazards for each type of animal food manufactured, processed, packed or held at the facility.

Preventive controls — These are to provide assurances that hazards that reasonably likely to occur would be significantly minimized or prevented. These would address, for example, animal food processing, prevention of cross-contamination and sanitation affecting animal food safety. A recall plan would also be required.

Monitoring — Procedures that would provide assurance that preventive controls are consistently performed and records to document the monitoring.

Corrective actions — Facilities would be required to correct problems and minimize the likelihood of reoccurrence, evaluate the animal food for safety and prevent affected animal food from entering commerce.

Verification — Activities that ensure preventive controls are consistently implemented are effective. These might include records review of monitoring, correction actions or instrument calibration. Preventive controls would also be required to be validated to ensure they are effective in controlling the hazard. In addition, the food safety plan must be reassessed at least every three years.

Recordkeeping — Firms would be required to keep a written food safety plan, including hazard analysis. They would be required to keep records of preventive controls, monitoring, corrective actions and verification procedures.

There is a potential small business exception on the table that would exclude companies that fall within a $500,000 to $2.5 million sales window. Craft breweries should keep an eye on this, dig into the rule if they wish, and perhaps make a comment by the Feb. 26 deadline.

Do you give away or sell your spent grain, currently? Would new rules prevent you from doing so in the future?

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