Is Your Spent Grain Consumed By Animals? 5 FSMA Requirements You Need To Know.
No matter your brewery’s size, you are now officially required to comply with a set of FDA regulations defined by the Food Safety Modernization Act (FSMA). One important set of these regulations (21 CFR 117.95) deals with properly storing, labeling, and tracking the removal of spent grain. FDA audits are currently happening and increasing – here’s what you need to know if your spent grain is being sold/given to farmers for animal consumption:
- Spent grain must be held in a manner that prevents contamination (containers should be designed, constructed of appropriate material, cleaned as necessary, and maintained in a way that protects against the physical, chemical, or biological contamination of human food byproducts for use as animal food)
- Stored spent grain must be protected from trash
- Stored spent grain must be identified (labelled with its common name)
- Shipping containers/bulk vehicles used to remove spent grain must be examined prior to loading to protect against being sources of contamination
- If spent grains are transferred from a silo, that needs to be indicated on the bill of lading
These FSMA rules support the Sanitary Facilities and Controls section under Good Manufacturing Practices (GMPs), or in the craft brewery business, Good Brewing Practices (GBPs). These controls encourage paying attention to spent grain storage – where, how and the duration of storage – because spent grain is a major attractant to small and large pests.
Another level of protection for you that is not required, but recommended, is having a contract with your farmer specifying what the spent grain is being used for, eg. livestock. Also note that if your spent grain is being used for fertilizer or compost, no FDA/FSMA rules apply.
Safety Plan Scenarios
There are two spent grain uses where rules go beyond FSMA and Hazard Analysis and Critical Control Points (HACCP) food safety plans are also required:
- Spent grain used for human food (eg. spent grain bread)
- If processing spent grain (pelletizing) for animal food
If these uses pertain to your brewery, be sure to investigate the requirements surrounding these scenarios. This link is a good place to start https://www.fda.gov/food/guidanceregulation/fsma/ucm366510.htm .
How Union Jack Can Help
Union Jack provides FDA-compliant bins to help make sure you meet spent grain compliance rules. Our Spent Grain Bins are food safe, sturdy, color-coded and easy to clean. They come with optional lids to keep trash, pests, chemicals and other foreign materials out of stored spent grain. With two different runner options, they are easy to transport via pallet jack or forklift, and can be dumped with the proper forklift equipment. Let us be your partner in compliance!
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