[euge]

Cattle might get ill from eating spent grain I suppose.

[majorvices]

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.

[majorvices]

Yeah I just said all that crazy stuff but now a warning not to dive into politics. Pretty please. Thanks! 

[euge]

Beer politics or industry politics? Might be a topic for the BA. Still, I am certainly not surprised this is going on.

[Jimmy K]

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.

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[majorvices]

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.

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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.

[Thirsty_Monk]

Did not it say if I sell my spend grain.
Does it mean if I give it away for free I am fine?

[majorvices]

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???

[james]

I wonder if these rules are coming up because of the tainted dog food, treats, or whatever that was a few months back.

[Slowbrew]

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

[klickitat jim]

Hay is for horse. Well, that's what my mom used to tell me anyway.

[Jeff M]

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. 

[Jimmy K]

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.
 
 

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
 
But trust me, FDA is not reading this forum. Submit your comments here.
http://www.regulations.gov/#!submitComment;D=FDA-2011-N-0922-0019

[Jimmy K]

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.

[majorvices]

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.