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General Category => General Homebrew Discussion => Topic started by: dkfick on February 04, 2014, 11:43:45 AM

Title: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: dkfick on February 04, 2014, 11:43:45 AM
http://www.craftbrewingbusiness.com/news/fda-rule-regulates-spent-grain-sold-animal-feed/
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Slowbrew on February 04, 2014, 01:22:41 PM
It is possible this is the first step a new wave of action by the macro-brewing industry to make life difficult for small brewers.  Lord knows Big-Ag has been using the regulatory agencies for decades to shutdown family farms.

It may just be the FDA doing their job but it seems close to not passing the sniff test to me.  I apologize if my paranoia is showing.

Paul
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Jimmy K on February 04, 2014, 01:32:19 PM
Your paranoia is showing. FDA has been on a huge crusade to regulate every aspect of food production that impacts food safety in response to foodborne illness problems of recent years.
 
Don't worry, doesn't mean their not all after you. :)
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: morticaixavier on February 04, 2014, 01:36:56 PM
Does that mean they are going to start looking into the practice of feeding chickens to chickens and pigs to pigs and cement to steer at feedlots?

I'm all for food safety but there are so many places where our mass food production system is in need of attention before we should start worrying about whether the spent grain we send to the hog or chicken farm has too much bacteria in it.

I was reading about cheese making today and the author was talking about an effort by the FDA to ban all raw milk cheeses in the US. In response to these concerns the CDC did a study of all cheese related illnesses in the US between 1993 and 2005 and found ~70 cases in that time. Turns out nearly 50 of them were all tied to a single Queso Fresco factory in CA which was using Pasteurized milk anyway.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: euge on February 04, 2014, 02:50:21 PM
Yeah that raw milk thing is wack man...

Well spent grain makes great compost so that is one way of disposal. Or it can be dried and fed into the furnace firing the steam kettles for a brewery.

I've seen the neighborhood cats horking down my spent grain after dumping it on the compost-pile. They are still around. Mostly.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: HoosierBrew on February 04, 2014, 02:56:01 PM
Does that mean they are going to start looking into the practice of feeding chickens to chickens and pigs to pigs and cement to steer at feedlots?

I'm all for food safety but there are so many places where our mass food production system is in need of attention before we should start worrying about whether the spent grain we send to the hog or chicken farm has too much bacteria in it.



I agree. I would think they'd address that issue before worrying about spent grain.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: james on February 04, 2014, 03:45:45 PM
I'm not sure how many small breweries are selling their spent grain.  Everyone I know off gives it away for free (or gets occasional trades) or have to pay someone to take it. 

Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: HoosierBrew on February 04, 2014, 03:54:14 PM
I'm not sure how many small breweries are selling their spent grain.  Everyone I know off gives it away for free (or gets occasional trades) or have to pay someone to take it. 



Yeah, it's always been my understanding from brewers I've talked to that they give it away to farmers so that they won't have to pay to have it disposed of - a significant chunk o' change for small breweries.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Stevie on February 04, 2014, 03:55:21 PM
I've seen the neighborhood cats horking down my spent grain after dumping it on the compost-pile. They are still around. Mostly.

Please be careful if you mash hop. I have read that hops are as bad for cats as they are for dogs. If it is anything like chocolate, could be worse.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: james on February 04, 2014, 04:00:46 PM
I've seen the neighborhood cats horking down my spent grain after dumping it on the compost-pile. They are still around. Mostly.

Please be careful if you mash hop. I have read that hops are as bad for cats as they are for dogs. If it is anything like chocolate, could be worse.

Hmm, I might have to pull some old hops out of the freezer for my cat
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Joe Sr. on February 04, 2014, 04:07:39 PM
I've seen the neighborhood cats horking down my spent grain after dumping it on the compost-pile. They are still around. Mostly.

Please be careful if you mash hop. I have read that hops are as bad for cats as they are for dogs. If it is anything like chocolate, could be worse.

Hmm, I might have to pull some old hops out of the freezer for my cat

Or pull some old cats out of the freezer for your hops...
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: euge on February 04, 2014, 04:33:42 PM
I don't mash hop and hardly think it is a common practice.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: klickitat jim on February 04, 2014, 05:07:32 PM
Cats love hops except for Citra. They just spray on Citra.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 04, 2014, 05:30:46 PM
Yeah, knew this was coming. Very unfortunate. Totally the FDA searching for a problem that doesn't exist. That said ... I have seen my dog get deathly ill from eating several day old spent grain. But I hardly see where this could affect the human food chain.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: HoosierBrew on February 04, 2014, 05:32:33 PM
Yeah, trying to picture that too. I'm no expert.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: euge on February 04, 2014, 06:24:32 PM
Cattle might get ill from eating spent grain I suppose.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 04, 2014, 06:40:02 PM
Cattle might get ill from eating spent grain I suppose.

But why is the FDA protecting the farmer? I need evidence on how a sick cow can affect me when I eat it.

Spent grain is a challenge to mget rid of without the farmers. I'm with the poster who said this may be a big brewery ploy to throw a wrench in the small craft brewery machine. I mean, I don't want to go all twilight zone here - but it really is a cut throat business. Think Founder's and New Belgium are the good guys? You couldn't be further from the truth. They want to move in and take all the local taps they can. And BMC wants to stop their declining sales.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 04, 2014, 06:41:41 PM
Yeah I just said all that crazy stuff but now a warning not to dive into politics. Pretty please. Thanks!  :D
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: euge on February 04, 2014, 06:44:41 PM
Beer politics or industry politics? Might be a topic for the BA. Still, I am certainly not surprised this is going on.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Jimmy K on February 04, 2014, 08:18:07 PM
They would be more concerned with contamination caused by feed produced in an industrial setting. There are plenty of things in a brewery that cows should not eat.

Sent from my XT1030 using Tapatalk

Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 04, 2014, 08:27:26 PM
They would be more concerned with contamination caused by feed produced in an industrial setting. There are plenty of things in a brewery that cows should not eat.

Sent from my XT1030 using Tapatalk

So, I give grain away to farmers nearly every day. Give me an example what you are talking about that could be potentially harmful to cows, let alone humans.

I watch the stuff get hauled away nearly every day and I can't fathom a reason why this should be regulated.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Thirsty_Monk on February 04, 2014, 08:33:52 PM
Did not it say if I sell my spend grain.
Does it mean if I give it away for free I am fine?
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 04, 2014, 08:40:08 PM
Curious to know if hay is regulated the way they are talking about regulating spent grain. Maybe it is? I see farmers bale this stuff up all over. It sits a rots near, and past, mid winter and yet cows still eat it. What about pesticides used on hay? Fertilizer? Potential contaminants? Hay and corn that is grown strictly for feed is under looser regulations than that grown for human consumption, is it not? And what about all the antibiotics that are given to cattle? Hormones? Steroids? Those are fine ...

But spent grain is regulated? Whaaa???
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: james on February 04, 2014, 09:41:43 PM
I wonder if these rules are coming up because of the tainted dog food, treats, or whatever that was a few months back.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Slowbrew on February 05, 2014, 05:33:00 AM
Curious to know if hay is regulated the way they are talking about regulating spent grain. Maybe it is? I see farmers bale this stuff up all over. It sits a rots near, and past, mid winter and yet cows still eat it. What about pesticides used on hay? Fertilizer? Potential contaminants? Hay and corn that is grown strictly for feed is under looser regulations than that grown for human consumption, is it not? And what about all the antibiotics that are given to cattle? Hormones? Steroids? Those are fine ...

But spent grain is regulated? Whaaa???
Hay is sold as a commodity.  As far as I know, it is not considered a "manufactured" food product and has only minimal, market controlled, restrictions.  You can feed your own rotten hay to your cattle but you won't be able to sell it (unless the market is really, really tight on supply).  Hay actually goes through a natural fermentation process that makes it more easily digested than raw hay would be.  The heat from this fermentation is what burns down barns when the bales aren't stacked correctly (i.e. too much air in the stack and not enough through the barn).

The funny thing about cattle is they will not eat things that are bad for them normally.  They love spent grain because it is like candy to them.  Too much might make walking behind them inadvisable but it won't hurt the product they produce for us.

Farmers have hundreds of thousands of $$ invested in their herds and are, generally speaking, pretty smart folks.  IMHO the FDA is creating a problem so they can look like they have fixed something for reasons beyond my knowledge base.

Paul
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: klickitat jim on February 05, 2014, 06:13:19 AM
Hay is for horse. Well, that's what my mom used to tell me anyway.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Jeff M on February 05, 2014, 07:36:02 AM
This is an interesting issue.  Im surprised this didnt happen earlier in the craft brewing revolution.  Personally, if i have the money when i set up my brewery id put a garden on the roof and compost all of the spent grain.  It is of course a pipe dream but it is a great way to reuse that energy and some of the waste water from the brewery.  IF any brewer has the land to do this id highly suggest it, imagine the amazing vegetables you could pull out of the all organic garden of your brewery.  Awesomeness. 
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Jimmy K on February 05, 2014, 07:55:51 AM
They would be more concerned with contamination caused by feed produced in an industrial setting. There are plenty of things in a brewery that cows should not eat.

 Give me an example what you are talking about that could be potentially harmful to cows, let alone humans.

Caustic cleaners, acids, glycol - all not good to eat. Dogfish Head was evacuated last year because of a leaking 300 gallon tank of nitric acid. Are these likely to contaminate spent grains? Certainly not in most cases, but FDA's business is preventing rare events.
 
Mostly, the rule will require breweries to have a written hazards analysis for spent grain. They'll have to document how they handle and store grain between brewing and delivery to the farmer, what possible hazards exist that could contaminate grain, how they will prevent contamination, and what their procedure will be if contamination occurs.
 
This regulation covers all manufactured animal food, not just spend grain. Spent grain is a very small blip in the radar of a set of new FDA regulations that cover human food, animal food, produce, and food importers.
 
 
Quote
FDA’s proposed rule on Current Good Manufacturing Practices (CGMPs) and preventive controls for food for animals focuses on preventing problems in order to improve the safety of these products. The preventive controls provisions of the proposed rule, which are required by the FDA Food Safety Modernization Act, would apply to domestic and imported animal food, including pet food, animal feed, and raw materials and ingredients. Facilities producing animal food would be required 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 would also establish certain Current Good Manufacturing Practices (CGMPs) that specifically address animal food.
 
...
 
The proposed rule would establish for the first time Current Good Manufacturing Practices that specifically address the manufacturing, processing, packing, and holding of animal food. FDA considered it important to establish CGMPs for animal food as prerequisite requirements to ensure that these products are manufactured under conditions and practices that protect against contamination. The proposed rule also would establish Hazard Analysis and Risk-based Preventive Controls for Food for Animals to implement the provisions in section 103 of the FDA Food Safety Modernization Act. The new requirements would be called “Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals.”

You can read all about it for yourself.
http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm366510.htm (http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm366510.htm)
 
But trust me, FDA is not reading this forum. Submit your comments here.
http://www.regulations.gov/#!submitComment;D=FDA-2011-N-0922-0019 (http://www.regulations.gov/#!submitComment;D=FDA-2011-N-0922-0019)
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Jimmy K on February 05, 2014, 08:06:57 AM
Did not it say if I sell my spend grain.
Does it mean if I give it away for free I am fine?

The proposed rules include reduced requirements for small operations (<$500,000 in animal feed sales), but the government is generally hip to that jive. No exemption if you give it away.
 
I wonder if these rules are coming up because of the tainted dog food, treats, or whatever that was a few months back.
Yes and no. These changes have been in the works for years, so not specifically the ones a few months back. But yes, these rules are due to many food contamination problems in the past decade - pet food, produce, meat, peanut butter, etc.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 05, 2014, 08:12:23 AM
And how or why would the caustic get into the grain? I can't imagine a scenario where this would happen.

In a similar scenario, I can't imagine someone racking the beer onto caustic, packaging it, and shipping it to be consumed. But that is a far greater possibility than caustic getting into the grain.

Maybe there are sloppy practices at larger breweries like DFH that I am not aware of, but at most small breweries I have been around the grain gets dumped into a bin and removed from the brewery immediately. There is no time where any foreign chemicals could get into the grain, any more than it could the beer. Our farmers come and get it that day or the next. I realize that some breweries dry the grain and store it, but for small breweries doing what we and most other microbreweries across the country I can assure you this is needly regulation and it further taxes small business struggling to succeed.

Just can't understand why this should be regulated. What about the grass the cows eat naturally and oil in the sides of the roads than runs off into the pasture?

FYI: The glycol is food safe so, while it would not be good to ingest it would not kill you.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Jimmy K on February 05, 2014, 08:45:14 AM
For the record, I'm addressing the 'This is a big-beer move' and trying to provide context, not defending FDA's desire to regulate spent grain. Your concerns sound very similar to the concerns I've heard from small animal and produce farms. Chance of contamination is extremely low and production is overseen by people very knowledgeable about the process who'd quickly recognize a problem and know how to correct it. 
 
Anyone know if the Brewers Association is submitting a comment?
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: dkfick on February 05, 2014, 08:58:36 AM
Yeah I think they just look at the worst case scenario.  Still seems like it will create a definite additional burden for small businesses.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: kylekohlmorgen on February 05, 2014, 09:08:53 AM
Does that mean they are going to start looking into the practice of feeding chickens to chickens and pigs to pigs and cement to steer at feedlots?

Hell no! That would require 'action' as opposed to 'motion'. (*steps of soapbox*)

As for the original topic, I'm afraid this is another step in the FDA's mission to takeover alcohol industry regulation.

Brewers are used to paperwork & red tape, but FDA reg's are a whole new ballgame.

I have nightmares about the booklet labels that would be required on my 'wild' beer bottles...
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: reverseapachemaster on February 05, 2014, 09:17:20 AM
Brewers are getting swept up in these proposed rules because there have been widespread problems with animal feed. Brewers are selling spent grain for animal feed which earns inclusion under the rule. The way I read it, all that is required for compliance is to develop and implement a QA plan. In terms of FDA compliance that is a very low threshold to meet.

The BA should draft comments that address the low probability of harm. IMO the comments would be better off requesting lowering the bar for brewers rather than trying to win complete exclusion from the rule. It's hard to get the FDA to grant exclusions when they want sweeping authority. Easier to win relaxed rules where the level of authority matches the level of risk.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Jimmy K on February 05, 2014, 09:45:32 AM
The BA should draft comments that address the low probability of harm. IMO the comments would be better off requesting lowering the bar for brewers rather than trying to win complete exclusion from the rule. It's hard to get the FDA to grant exclusions when they want sweeping authority. Easier to win relaxed rules where the level of authority matches the level of risk.

I think BA could make a good argument for spent grains being very low risk. There is minimal processing (it's just grain mixed with hot water then drained), it's entirely food grade for human consumption already, and nothing is being added to the spent grain to enhance its value as an animal food.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 05, 2014, 10:00:23 AM
Hey, now we are starting to makes sense!
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: james on February 05, 2014, 10:04:51 AM
I think BA could make a good argument for spent grains being very low risk. There is minimal processing (it's just grain mixed with hot water then drained), it's entirely food grade for human consumption already, and nothing is being added to the spent grain to enhance its value as an animal food.

Trub, yeast, and hops are often added to spent grain for disposal.  So I wouldn't say nothing is being added.  Finings and anything else that gets added could come along with it.

It's mostly self regulating though, I know one place that used to dump hops/trub with their grain and the farmer requested they stop because the cows would just eat around those clumps. 
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 05, 2014, 10:12:59 AM
Yeast shouldn't be harmful. Hops, maybe another story, but still - as slowbrew states (and my farmer has confirmed) cows won't eat it if it is bad for them.

Finings maybe something I hadn't considered, not sure if that would be harmeful. We just give our farmers 100% grain. And the farmers say the cows love it.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: klickitat jim on February 05, 2014, 10:39:17 AM
Well, I grew up on the neighborhood dairy products, and their cows ate Luck Lager malt. I think I turned out ok. A series of single data points should be all they need.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Jeff M on February 05, 2014, 10:42:34 AM
Finings maybe something I hadn't considered, not sure if that would be harmeful. We just give our farmers 100% grain. And the farmers say the cows love it.

It does make you wonder what some breweries with unscrupulous people might be giving to the local farmers. 
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Jimmy K on February 05, 2014, 10:43:26 AM
Cows won't eat it if it is bad for them.
Cows may not like hops and trub, but if that statement were true cows would never get sick from feed.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: euge on February 05, 2014, 11:10:37 AM
And what are cows? Fermenters on four legs.

I don't think it will end until every aspect of life is governed by some rule, legislation or protocol.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: reverseapachemaster on February 06, 2014, 08:49:35 AM
Finings maybe something I hadn't considered, not sure if that would be harmeful. We just give our farmers 100% grain. And the farmers say the cows love it.

It does make you wonder what some breweries with unscrupulous people might be giving to the local farmers.

That's exactly why you have regulations like this.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 06, 2014, 09:36:39 AM
This is getting to be a sticky topic so I won't push it any further but let me just say most of you have no idea just how over regulated the brewing industry already - much of it unnecessary. Having worked in this industry for going on 4 years now I can't understand this regulation. But so be it.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: pinnah on February 06, 2014, 10:34:10 AM
Yeah I just said all that crazy stuff but  :D
I lol'ed at that. ;D

So, to be clear, if you give away your spent grain, are you still under these new rules?
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: euge on February 06, 2014, 10:39:42 AM
This topic is going to be a sticky? :(
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Slowbrew on February 06, 2014, 01:25:31 PM
Yeah I just said all that crazy stuff but  :D
I lol'ed at that. ;D

So, to be clear, if you give away your spent grain, are you still under these new rules?

These kinds of regulations are usually about the production of a product and not the distribution of the product.  The fact a brewery produces a product that is fed to livestock is what is being regulated, not the fact they sell it.

Paul
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: anthony on February 06, 2014, 07:54:24 PM
...
In a similar scenario, I can't imagine someone racking the beer onto caustic, packaging it, and shipping it to be consumed. But that is a far greater possibility than caustic getting into the grain.
...

This is the exact reason that all breweries are already regulated by the FDA.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 07, 2014, 05:59:50 AM
...
In a similar scenario, I can't imagine someone racking the beer onto caustic, packaging it, and shipping it to be consumed. But that is a far greater possibility than caustic getting into the grain.
...

This is the exact reason that all breweries are already regulated by the FDA.

You think we would be but we are not. We are required to register with FDA but I've not had an FDA inspection once. Been unfortunate enough to be subjected to not one but two grueling TTB inspections, been through several health department inspections, fire marshal has popped in once, but this far no dealings with FDA.

I suspect that's about to change.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: reverseapachemaster on February 07, 2014, 08:56:45 AM
...
In a similar scenario, I can't imagine someone racking the beer onto caustic, packaging it, and shipping it to be consumed. But that is a far greater possibility than caustic getting into the grain.
...

This is the exact reason that all breweries are already regulated by the FDA.

You think we would be but we are not. We are required to register with FDA but I've not had an FDA inspection once. Been unfortunate enough to be subjected to not one but two grueling TTB inspections, been through several health department inspections, fire marshal has popped in once, but this far no dealings with FDA.

I suspect that's about to change.

That is in part because the TTB already allocates resources and processes to inspect and review your products before they go out for sale.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 07, 2014, 09:35:21 AM
...
In a similar scenario, I can't imagine someone racking the beer onto caustic, packaging it, and shipping it to be consumed. But that is a far greater possibility than caustic getting into the grain.
...

This is the exact reason that all breweries are already regulated by the FDA.

You think we would be but we are not. We are required to register with FDA but I've not had an FDA inspection once. Been unfortunate enough to be subjected to not one but two grueling TTB inspections, been through several health department inspections, fire marshal has popped in once, but this far no dealings with FDA.

I suspect that's about to change.

That is in part because the TTB already allocates resources and processes to inspect and review your products before they go out for sale.

Again, not really 100% true. The only recipes that require approval are those with special ingredients or those that could increase abv. (like fruit/spices) or bbl aging in bbls that previously held liquor. As long as you're going with malt/adjucts/hops/water/yeast - no recipe approval necessary.

Now, the do want a layout of your brewery and you are supposed to provide one every time you upgrade. But aside from that all they care about is if you are paying your taxes or not.

Oh, yeah, and they want to approve names and they go a little over board with their power there. They also want to make sure you have the SURGEON GENERAL'S WARNING in correct font (with SURGEON GENERAL'S WARNING" bold  ::) and they want to make sure you have "ALE" or "BEER" somewhere on the label for some inane reason.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: anthony on February 07, 2014, 11:19:34 AM
I guess we can argue semantics until we're both blue, but what I mean is, you're expected to register with the FDA for a reason... ultimately I guess I assumed we were registering so that eventually we would have another government master to make happy.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 07, 2014, 11:37:07 AM
I guess we can argue semantics until we're both blue, but what I mean is, you're expected to register with the FDA for a reason... ultimately I guess I assumed we were registering so that eventually we would have another government master to make happy.

Not trying to argue petty semantics. Just trying to explain what actual regulations. Apologies if it seemed that way.

I have had 0 dealings with FDA up till now. Has nothing to do with semantics. Wasn't even required to register until last year that I know of.

As I said, looks like
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: majorvices on February 07, 2014, 11:37:24 AM
I guess we can argue semantics until we're both blue, but what I mean is, you're expected to register with the FDA for a reason... ultimately I guess I assumed we were registering so that eventually we would have another government master to make happy.

Not trying to argue petty semantics. Just trying to explain what actual regulations. Apologies if it seemed that way.

I have had 0 dealings with FDA up till now. Has nothing to do with semantics. Wasn't even required to register until last year that I know of.

As I said, looks like that's going to change.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: Thirsty_Monk on February 07, 2014, 02:24:02 PM
I guess we can argue semantics until we're both blue, but what I mean is, you're expected to register with the FDA for a reason... ultimately I guess I assumed we were registering so that eventually we would have another government master to make happy.

Not trying to argue petty semantics. Just trying to explain what actual regulations. Apologies if it seemed that way.

I have had 0 dealings with FDA up till now. Has nothing to do with semantics. Wasn't even required to register until last year that I know of.

As I said, looks like
Registering brewery with FDA is due bioterrorism act that was passed to law after 9/11.
It has Nothing to do about product safety.

In my state product safety is regulated with agg dept because I am a food processor.
I am supposed to have recall process and all kind of fun stuff.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: anthony on February 08, 2014, 06:50:24 PM
I am talking about Food Safety Modernization Act (FSMA) requirements and specifically an event on the Reportable Food Registry (RFR).

I was replying to the scenario where a beer was racked on to caustic, packaged, and distributed. If this happened and touched more than one US state, the amount of regulatory authority the FDA has over breweries would become very obvious very quickly.

When I was at CBC this past year, one of the talks was FDA involvement/regulation of breweries, I will try and pull up the presentation and put it somewhere online.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: anthony on February 08, 2014, 07:17:13 PM
Here is the PDF: https://www.dropbox.com/s/kuctqjo6jmka3ib/preparing-for-an-fda-audit.pdf

There were also some folks there discussing what had happened to them when the FDA decided to pay them a visit, truly some comical stuff... "Why isn't your grain refrigerated!?"
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: reverseapachemaster on February 09, 2014, 08:48:23 AM
Again, not really 100% true. The only recipes that require approval are those with special ingredients or those that could increase abv. (like fruit/spices) or bbl aging in bbls that previously held liquor. As long as you're going with malt/adjucts/hops/water/yeast - no recipe approval necessary.

Which is why I said "in part". The TTB regs enumerate ingredients that do not require recipe approval. Everything else does, if the beer will be shipped out of state. By the time you add TTB, state ABC, state public safety regs and state/local health regs together, there is not much left for the FDA that isn't already regulated through one of those other channels regarding your manufacturing. Their resources are better used on industries that do not have as much oversight duplicating their own. 
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: MDixon on March 26, 2014, 05:13:25 AM
There is still time to comment on the FDA site about the rules.
http://mashbang.wordpress.com/2014/03/26/fda-rules-and-brewery-spent-grain/
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: reverseapachemaster on March 26, 2014, 06:59:48 AM
Judging by the comments I've seen around the intertubes about this issue, I almost feel bad for the FDA folks who are going to have to sift through comments from beer drinkers about how this is going to ruin beer for everybody.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: kramerog on March 26, 2014, 07:51:08 AM
Yeah, knew this was coming. Very unfortunate. Totally the FDA searching for a problem that doesn't exist. That said ... I have seen my dog get deathly ill from eating several day old spent grain. But I hardly see where this could affect the human food chain.

Obviously you've never eaten dog.  Neither have I.
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: dkfick on April 04, 2014, 05:23:57 AM
Saw this hit the news earlier today... Apparently they are revising the proposed new rules...

http://www.pressdemocrat.com/article/20140403/articles/140409816
Title: Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
Post by: tschmidlin on April 04, 2014, 10:40:53 AM
Saw this hit the news earlier today... Apparently they are revising the proposed new rules...

http://www.pressdemocrat.com/article/20140403/articles/140409816
That's potentially good news, but I am confident they will manage to screw it up somehow.