Brewers Association Responds to FDA’s Spent Grain Proposal

[Mongrel]

Please take the time to contact the FDA. This change to spent grain disposal would be horrible.

Brewers Association Responds to FDA’s Spent Grain Proposal

Brewers Association Responds to FDA’s Spent Grain Proposal
Posted 21 hours ago by David Eisenberg

Cows might not top the list of things that have benefitted from the rise of craft beer, but they certainly make the cut.

For years, smaller craft brewers have donated – or sold on the cheap – their spent grain to farmers to feed cows and other livestock. Rather than sending it to landfills, the handshake transaction between brewers and farmers has been lauded as mutually beneficial by many industry watchers and advocates.

Now, both parties are dealing with a different animal — the government. The two are fighting a proposal put forth by the Food and Drug Administration (FDA) that would make the transaction of spent grain more burdensome. Specifically, brewers would need to purchase expensive equipment and devote more time to properly packaging their spent grain before farmers could legally serve their animals, should the proposed changes be enacted.

Today, the Brewers Association issued the following statement regarding the FDA’s “Food Safety Modernization Act:”

“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.”

Gary Fish, the founder of Bend, Ore-based Deschutes Brewery issued somewhat of a rallying cry to brewers this week on an industry message board. Fish, who also serves as a chair on the BA’s Board of Directors, has called for brewers to communicate with their farmers and submit comments to the FDA. Their mission is to get the FDA to clarify in its proposal that brewers may provide spent grain for use as animal feed.

Brewers Association director Paul Gatza also issued a call to action last week, asking BA members to submit comments to the FDA in opposition to the proposed ruling.

Brewers have until March 31 to submit their comments. The complete rule can be viewed here.

 

[alane1]

farmers finding a cheap source of feed, can't have that.

 

[Weezy]

Solution without a problem.

 

[Yooper]

While I sympathize with the sentiments expressed, please remember that our rules specifically prohibit political talk in our forum.

This issue can be discussed, but please keep political comments and "wise"cracks out of the forum. If you cannot, please discuss this topic in the Debate Forum.

 

[fredmercer]

It is hard to find any quality to most things the government tries to "make better " by adding more complicated regulations . Why the FDA would feel the need to test and place grains in special packaging just to feed to animals is a mystery for sure . It would make sense if the grains could possibly get something in them that could harm the food chain but I doubt that is a concern based on any facts or residing in any reality .
It seems that the only thing to do is complain to the FDA which will probably not do any good but it is worth a try . Other wise get ready for higher beer , meat prices .

 

[pjj2ba]

It is hard to find any quality to most things the government tries to "make better " by adding more complicated regulations . Why the FDA would feel the need to test and place grains in special packaging just to feed to animals is a mystery for sure . It would make sense if the grains could possibly get something in them that could harm the food chain but I doubt that is a concern based on any facts or residing in any reality .
It seems that the only thing to do is complain to the FDA which will probably not do any good but it is worth a try . Other wise get ready for higher beer , meat prices .

I assume mycotoxins levels are behind this. Different animals have different sensitivities to the toxins, so depending what animal the grain is destined for, the allowable levels vary. Apparently if high enough (surprisingly low level), the animals will not eat it. All loads of grain (especially corn and wheat) are tested at the elevator for mycotoxin levels (not a perfect process). Some ethanol distillers have run into problems disposing of spent corn. They had not been testing for the toxin levels. Apparently the fungal toxins persist through the whole process and end up in the spent grain. The distillers have now caught on and are testing the grain beforehand.

Barley malt is different though, as it has been tested before the maltsters buy it. There is a possibility, (but unlikely) that the mycotoxin producing fungi could colonize the spent grain if not properly handled before feeding it to animals

 

[Hello]

I suppose with the influx of new breweries the FDA feels the need to meddle. I can understand the desire to test the grains but to make movement prior to stacking the evidence in their favor is foolish and it only harms farmers. I echo alane1's sentiment in his statement. I think if farmers can find a cheap source of feed that is actually beneficial to the animal then they should be able to without having to jump through hoops or added costs.

 

[jmp138]

This is the happiest day of the week for the guys in my pasture. Also, we knew that it was only a matter of time before this saw government regulation. If it can be bureaucratized it will be.



My man enjoying the leftovers from an Irish Red.

 

[Gar]

one of these days maybe just maybe people will wake up and pull there heads out of there rumps and think of the govt they elect and the groups they empower.

 

[GVH_Dan]

... Some ethanol distillers have run into problems disposing of spent corn...

My first thought was that this was targeted at ethanol and breweries just got swept along for the ride. Is that the case or where is this coming from?

 

[Biergarden]

I assume mycotoxins levels are behind this. Different animals have different sensitivities to the toxins, so depending what animal the grain is destined for, the allowable levels vary. Apparently if high enough (surprisingly low level), the animals will not eat it. All loads of grain (especially corn and wheat) are tested at the elevator for mycotoxin levels (not a perfect process). Some ethanol distillers have run into problems disposing of spent corn. They had not been testing for the toxin levels. Apparently the fungal toxins persist through the whole process and end up in the spent grain. The distillers have now caught on and are testing the grain beforehand.

Barley malt is different though, as it has been tested before the maltsters buy it. There is a possibility, (but unlikely) that the mycotoxin producing fungi could colonize the spent grain if not properly handled before feeding it to animals

If those problems really existed, then farmers would have shied away from spent grains centuries ago as the livestock got sick. Being a brewer here in SE Alaska the only farmers that benefit from my spent grains are a few chickens and the occasional black bear. Otherwise it goes to a landfill.
One interesting this is what the Alaskan Brewing CO did. They took a grant to dry and pelletize their spent grains. Once that is done, the spent grains are used as fuel to heat water and boil the wort. Pretty clever if you ask me.

 

[pjj2ba]

My first thought was that this was targeted at ethanol and breweries just got swept along for the ride. Is that the case or where is this coming from?

This is my suspicion

 

[fuzzy2133]

My first thought was that this was targeted at ethanol and breweries just got swept along for the ride. Is that the case or where is this coming from?

This is my suspicion

Yep if it is a problem in one division why bother testing the next, it is easy to just handcuff them both.

I could understand periodic testing before feeding (if the spent grain sat for a week) but packaging would be an extra waste of resources.

 

[masteraviator]

Hmm... This is likely why Oskar Blues has their own farm to rid themselves of their spent grain. I know I don't package mine to feed it to my horses... and they love it!

 

[pjj2ba]

If those problems really existed, then farmers would have shied away from spent grains centuries ago as the livestock got sick.

The problem with mycotoxins in cereal grain does exist. The problem paid my salary last year (not working on it now). This is more of an issue with corn and wheat, than with barley. Some years are worse than others, depends on the weather. Huge monocultures don't help with this. It can partially be controlled with fungicides, but that is expensive and the timing is critical. Often times the farmers will just roll the dice and hope for the best.

Way back ago, plenty of animals, not to mention people, got sick from eating contaminated grain. They didn't always understand the cause. One theory states that the Salem witch trials came about from people eating grain infected with ergot (which makes an LSD like compound) and basically tripping out, and since they didn't know any better, figured it must have been witches. That particular incident may or may not be true, but other folks certainly have experienced ergot poisoning.

I assume the concerns now are aflatoxin (carcinogenic), and fumonisins (commonly called vomitoxins) produced by a few (different) kinds of fungi. They keep lowering the amounts allowable in grain, which varies with the end fate of the grain. Pigs are quite sensitive, chickens not so much. The more fumonisins in your grain, the less money you will get for it.

I suspect the concerns are a spillover from the ethanol distilleries. They produce a lot of spent grain, and until recently, hadn't been testing the grain they were buying. I don't think farmers are worried about contamination of spent grain from craft brewers, but they certainly are concerned about it in the crops they harvest.

 

[fuzzy2133]

The problem with mycotoxins in cereal grain does exist. The problem paid my salary last year (not working on it now). This is more of an issue with corn and wheat, than with barley. Some years are worse than others, depends on the weather. Huge monocultures don't help with this. It can partially be controlled with fungicides, but that is expensive and the timing is critical. Often times the farmers will just roll the dice and hope for the best.

Way back ago, plenty of animals, not to mention people, got sick from eating contaminated grain. They didn't always understand the cause. One theory states that the Salem witch trials came about from people eating grain infected with ergot (which makes an LSD like compound) and basically tripping out, and since they didn't know any better, figured it must have been witches. That particular incident may or may not be true, but other folks certainly have experienced ergot poisoning.

I assume the concerns now are aflatoxin (carcinogenic), and fumonisins (commonly called vomitoxins) produced by a few (different) kinds of fungi. They keep lowering the amounts allowable in grain, which varies with the end fate of the grain. Pigs are quite sensitive, chickens not so much. The more fumonisins in your grain, the less money you will get for it.

I suspect the concerns are a spillover from the ethanol distilleries. They produce a lot of spent grain, and until recently, hadn't been testing the grain they were buying. I don't think farmers are worried about contamination of spent grain from craft brewers, but they certainly are concerned about it in the crops they harvest.

So is this a situation where stopping it at harvest will keep it from being a problem further down the chain?

 

[pjj2ba]

So is this a situation where stopping it at harvest will keep it from being a problem further down the chain?

Depends. Again, for barely, not likely an issue, at least not the barley destined for malting. Bigger issue for corn. If the corn is not handled properly after harvest (properly dried), the fungus could continue to grow in storage and produce more toxins after harvest. If not dry enough at harvest time, some farmers will put it into their own driers. sometimes they don't work. Once it goes to the processor, it is likely fully dried, or they'll ding you for it and then make sure it is dry. After that, toxin levels likely won't change. Once it gets to the processor, it is checked (not fool proof). And again, depending on the end use, different levels of contamination are allowed (wheat flour is lowest). Probably every grain load has a little bit, just like bug parts, rocks, etc. that are also in there.

With all plant diseases, the best course of action is prevention. Do what you can to minimize things that promote the pathogen's growth (variety selection is a biggie). Good farm sanitation practices. Effective use of crop rotation.

Side note. One of these pathogens is also responsible for some gushing in beer. The fungus produces a protein that makes it all the way through the brewing process and can cause gushing in an otherwise properly carbonated, uncontaminated beer.

 

[krackin]

I don't see where this could be anymore problematic than ensilage and most likely less as I would think the spent grain spends little if any time in storage because that adds another expense to the feedlot or farm. I would think that it is collect and fed out. In the least, there should be a consideration for this type of handling. No matter what, it will cost the consumer more.

It looks like more of another way to create a revenue stream through a regulated buisness.

 

[krackin]

I'm also wondering if the FDA is overstepping their jurisdiction again. Once those grains are sparged and intended as feed it is more likely USDA territory. More than once FDA has tried stepping in where they don't belong and were not welcome.

 

[soccerdad]

Wait til they find out about silage! Farmers gonna need fermenting licenses.

 

[Mongrel]

I'm glad to see Sen. Mark Udall is getting involved. CO Craft Breweries Enlist Vulnerable U.S. Senator in Pushback on Spent Grains

 

[fearwig]

I'm also wondering if the FDA is overstepping their jurisdiction again. Once those grains are sparged and intended as feed it is more likely USDA territory. More than once FDA has tried stepping in where they don't belong and were not welcome.

Maybe. The FDA/FSIS jurisdictional divisions are notoriously weird. Of course you could avoid a lot of red tape, duplication, and underinformed decision making in these regulations by combining those agencies, as has often been proposed, but since that might actually result in some enforcement you're going to get the ire of the same don't-tread-on-me crowd that clamors about red tape (not to mention opposition from people with a profit stake in overlooking hazards).

It would also get FSIS out from under a department that is tasked with both regulating and promoting an industry (funny how we have so many of those).

If the measure would actually require "packaging" and other weird and pointless measures it obviously shouldn't be adopted, as many rule proposals aren't.

 

[fearwig]

Here's the FDA's bit on animal food, anyway: http://www.fda.gov/AnimalVeterinary/Products/AnimalFoodFeeds/ucm050223.htm

 

[HomebrewCraig]

TBH, spent grains should never end up in a landfill anyways.. Composting them, or even throwing them under your bushes or into the lawn is better than having them squished down by one of those tractors that remove the air in the garbage. I feed them to my 10,000 pets.

 

[fearwig]

Plan is to lay them out to dry and see if they work as cat litter. Could go very wrong, but I'm gonna try.

 

[fuzzy2133]

All the nutrition that is left makes me sad if it goes to a land fill. Bread, dog treats (if not hop contaminated) chicken feed...

 

[krackin]

Here's the FDA's bit on animal food, anyway: http://www.fda.gov/AnimalVeterinary/Products/AnimalFoodFeeds/ucm050223.htm

I did a quick speed read on that and it seems like they maybe stretching a bit much.

The spent grains, when fed out directly can't be classified as an additive or supplement, no issue, no say. If the spent grains are picked up in the equipment used to feed out the grain in an arbitrary time period under reasonable handling and storage conditions (which is not not specified by the FDA) then the FDA has no say at all.

Granted, some spent grain is used in mixed and processed feed which is another issue entirely and falls under this FDA rule. It seems that the FDA wants to lump it all together but that isn't what their rule says.

Again, I just did a tired quick read.