How it popped up on the Food and Drug Administrations radar, I do not know, but sometime around last November, the FDA decided it was time to work on regulating what brewers did with their spent grain from the brewing process. Specifically with regards to brewers giving or selling their spent grains to farmers for use as animal feed.
Now bear in mind, this symbiotic relationship has been going on for many, many years. In the vast majority of cases, brewers freely give their spent grains to farmers for use as feed, and in a much smaller percentage of circumstances, they sell it to farmers for next to nothing. There are multiple benefits to this arrangement. Brewers do not have to pay costly fees to have their spent grain hauled off to a landfill or composting facility, and farmers do not have to pay high prices for feed for their animals. The brewers get rid of what quickly becomes a nuisance byproduct of the brewing process and farmers gain a highly nutricious feed for their animals that is also a good source of hydration.
For reasons that are not completely clear to me, the FDA has felt the need to insert themselves in to this process. They feel that there should be much more stringent controls in effect with regards to how this source of animal feed is handled and processed. Now I for one, totally understand the need to make sure that something harmful is not introduced into the food supply, but this particular feed source has the potential for few ill effects by the time the end result hits the supermarket shelves, or much more likely with most brewer/brewpub/farmer arrangements, your plate at your your favorite brewery. There are also no documented cases of spent grain used as feed causing any sort of contamination in the end product consumed by humans. You can’t say the same thing for spinach, lettuce, or mass produced ground beef which has been the source numerous times for E. Coli outbreaks.
You see, most animals that are fed from this food source, have a gastrointestinal tract in which a small nuclear device could detonate, and there would be little chance of an ill effect reaching your plate (this is of course hyperbole, but you get the idea). In most cases, spent grain is fed to cattle, pigs or chickens. All of which have fantastic digestive systems which can handle this food source with no problem. If you have every seen what some of these animals are normally fed (my mother’s side of the family comes from a farm tradition in Eastern Oklahoma) then you would most certainly choose meat fed on this food source than some of the usual things that find their way in to commercial farming to include GMO grains, animal by products (think canibalism, although the animals don’t know it), and other manufactured feed and food sources.
Imposing regulations on farmers and brewers with regards to spent grain has the potential to impose onerous costs on both, as well as depriving brewers of a cheap if not free way to dispose of unusable biomass and depriving farmers of a cheap if not free food source for their animals.
While the comment period for the FDA expires tonight, please use your muscle as a citizen to voice your concern for the effects this will have the economy for both brewers and farmers.
Statement from the Brewers Association on FDA Proposed Rulemaking on Spent Grain
Boulder, CO • March 28, 2014–As part of the Food Safety Modernization Act (FSMA), the FDA has proposed extensive regulations governing use of spent grain for animal feed. Because grain used in the brewing process is frequently donated or sold at low cost to farmers for animal feed, the FDA proposal would affect hundreds of brewers across the country. The Brewers Association, the not-for-profit trade association dedicated to small and independent American craft brewers, issued the following statement on the FDA animal feed proposal:
The current rule proposal represents an unwarranted burden for all brewers. Many of the more than 2,700 small and independent craft breweries that operate throughout the United States provide spent grain to local farms for use as animal feed. The proposed FDA rules on animal feed could lead to significantly increased costs and disruption in the handling of spent grain. Brewers of all sizes must either adhere to new processes, testing requirements, recordkeeping and other regulatory requirements or send their spent grain to landfills, wasting a reliable food source for farm animals and triggering a significant economic and environmental cost.
Absent evidence that breweries’ spent grains as currently handled cause any hazards to animals or humans, the proposed rules create new and onerous burdens for brewers and for farmers who may no longer receive spent grain and will have to purchase additional feed. Farmers also appreciate the ‘wet’ grains from breweries because it helps provide hydration for the animals.
Brewers’ grains have been used as cattle feed for centuries, and the practice is generally considered safe. We ask the FDA to conduct a risk assessment of the use of spent brewers’ grain by farmers prior to imposing expensive new regulations and controls.
Contact: Abby Berman (on behalf of the Brewers Association), 646.695.7044
Beer Institute Urges FDA to Exempt American Brewers from Costly Regulation
WASHINGTON, DC – Today, the Beer Institute filed joint comments with the American Malting Barley Association in order to protect a centuries-old and environmentally-conscious practice of brewers marketing their brewers’ grain to local animal producers. Please click here to view the comments, filed today.
The Beer Institute has been working for more than a year with Members of Congress, regulators and allied organizations from dairy farmers to agriculture scientists in order to present a strong economic and scientific argument proving that it is completely unnecessary for the Food and Drug Administration (FDA) to add additional regulation to brewers’ spent grain and other by-products of brewing. The Beer Institute is the national trade association representing brewers of all sizes, beer importers and industry suppliers like hops farmers and can and bottle manufacturers.
The National Milk Producers Federation also filed comments that expressly reference and include support for the Beer Institute’s comments.
Brewers’ spent grain exist as a natural and necessary result of the brewing process. For centuries, brewers, large and small, have disposed on their spent grain by giving or selling them to farmers and ranchers. This recycling process supports community green initiatives, but could end if this FDA rule is upheld. Instead, some brewers will be forced to throw away this valuable feed, a cheaper option than complying with the costly proposed regulations, which the Beer Institute estimates may cost a single brewery more than $13 million in one-time and reoccurring costs.
Chris Thorne, Beer Institute Vice President of Communications said: “This regulation is onerous and expensive, but really it’s just unnecessary. There has never been a single reported negative incidence with spent grain.” Thorne added, “We have had very positive conversations with the FDA and other concerned stakeholders making us cautiously optimistic.”
This letter was filed in response to the Food and Drug Administration’s (FDA) proposed rule on “Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals” under the Food Safety Modernization Act (FSMA) [Docket No.: FDA-2011-N-0922] RIN: 0910-AG10.
In November of 2013, the Beer Institute filed two additional comments with the FDA regarding proposed FSMA regulations. The first comment, filed jointly with the Brewers Association, asked the FDA to add hops to the list of produce that is exempt from regulation under FSMA because hops are not consumed raw and are quite safe.
The American Malting Barley Association again joined the BI in our second letter last November – asking the FDA to exempt brewers’ spent grain from FSMA regulation for human food because they are safe and merely the byproduct of brewing.
The Beer Institute will continue following all developments with the FSMA and any proposed regulations that may impact U.S. brewers.
The Beer Institute is the national trade association for the American brewing industry, representing both large and small brewers, as well as importers and industry suppliers. First founded in 1863 as the U.S. Brewers Association, the Beer Institute is committed today to the development of sound public policy and to the values of civic duty and personal responsibility: www.BeerInstitute.org. Connect with us @BeerInstitute and on Facebook.
– See more at: http://www.beerinstitute.org/bi/media-center/press-releases/beer-institute-urges-fda-to-exempt-american-brewers-from-costly-regulation#sthash.aj7ONrcU.dpuf