Author Topic: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.  (Read 1829 times)

Online mtnrockhopper

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #30 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?
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Offline dkfick

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #31 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.
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Offline kylekohlmorgen

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #32 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...
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Offline reverseapachemaster

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #33 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.
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Online mtnrockhopper

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #34 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.
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Offline majorvices

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #35 on: February 05, 2014, 10:00:23 AM »
Hey, now we are starting to makes sense!
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Offline james

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #36 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. 

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #37 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.
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Offline klickitat jim

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #38 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.

Offline Jeff M

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #39 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. 
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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #40 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.
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Offline euge

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #41 on: February 05, 2014, 11:10:37 AM »
And what are cows? Fermenters on four legs.

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Offline reverseapachemaster

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #42 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.
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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #43 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.
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Offline pinnah

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Re: New FDA Rules For Breweries Selling Spent Grains For Animal Feed.
« Reply #44 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?