Incorporating Food Safety Responsibilities into a Quality Program 11/9/2018
Links to all resources covered: Quality Priority Pyramid Good Manufacturing Practices for Craft Brewers Food Safety Plan for Craft Brewers Voluntary Market Withdrawals and Recalls FSMA FAQs
Quality Subcommittee Formed in 2014
Quality • Jason Perkins, Allagash Brewing Subcommittee • Alastair Pringle, Pringle-Scott LLC Members • Jamie Floyd, Ninkasi Brewing • Larry Horwitz, Four String Brewing • Neil Witte, Brewers Association • Phil Leinhart, Ommegang • Rob Christiansen, New Belgium Brewing • Tom Flores, Brewer's Alley • Tom Shellhammer, Oregon State • John Mallett, Bell’s Brewing • Ken Grossman, Sierra Nevada
Vision: Our vision is a membership that consistently produces beer of high quality. Foundational documents for the Quality Beer: A beer that is responsibly produced using BA Quality wholesome ingredients, consistent Subcommittee brewing techniques and good manufacturing practices, which exhibits flavor characteristics that are consistently aligned with both the brewer’s and beer drinker’s expectations.
Quality We seek to continue the advancement of quality Subcommittee within the craft brewing community through: Mission • Fostering a sense of shared responsibility in all Statement: breweries for the importance of quality in craft beer • Motivating all BA members to invest in issues that improve and maintain quality, without compromising their focus on creativity and flavor • Educating all BA members about existing quality resources and best practices for ingredient selection, process control
The Quality Priority Pyramid Alastair Pringle – Pringle-Scott LLC
History of the Pyramid Originated from early discussions about quality by the Beer Quality Sub-group Provides: • A road map for the development of materials addressing the different aspects of quality • An effective way of communicating priorities for addressing quality Has evolved with changes in regulations and as the subcommittee's thinking evolved
What it does: Summarizes the elements of a quality program Provides a means for brewers to prioritize their efforts • e.g. GMPs should be first item you tackle so you are ready for an FDA audit
What it isn’t: It is not a strict, step by step process. You can work on other areas at the same.
Version 2.0: GMPs • Good Manufacturing Practices for Craft Brewers • Check-lists available on BA website • Being used by some states for audits
Version 2.0: Food Safety HACCP • Currently not required by FDA • Methodology can help prevent recalls • There is a resource for this on the BA website Preventive Controls • Currently not required by FDA • A modification of HACCP that focuses on prevention • Required for facilities producing non-alcoholic drinks • Resource on this coming soon
Version 2.0: Process Controls Consistent beer flavor, color, alcohol content, etc. can be achieved through: • Identification of quality control points (QCPs) • Then, control of the QCPs
Version 2.0: Standards Develop standards for: • Finished beer • Beer production processes Includes establishing SOPs for: • Process procedures • Cleaning and sanitation procedures • Laboratory procedures
Version 2.0: Analysis Perform chemical, physical, and sensory analyses to routinely to verify: • Process control • Product parameters are within set standards • Product shelf life and stability
Version 2.0: Continuous Improvement • Continually look for ways to improve the product and the process Preventative maintenance • Reduce down time • Improve product quality
Good Manufacturing Practices (GMPs) for Craft Brewers (GMPCBs) Phil Leinhart – Brewery Ommegang
• The Food Safety Modernization Act (FSMA) was signed into law in 2011. • FSMA specifically defined alcoholic beverages as food and for the first time brought alcoholic beverage producers under direct FDA Background of regulation, without affecting TTB authority. • Alcoholic beverage producers are exempt from The Food several portions of FSMA but do need to comply with other portions regardless of size. Safety • Compliance with Good Manufacturing Practices (GMP’s) is one of those portions. Modernization • GMP’s have historically applied to the Food Industry such as Dairies and Meat Processing Act ( FSMA)… facilities. • Current FDA regulations require all breweries to have an active GMP program in place. Failure to meet this requirement could result in several disciplinary actions.
• Good Manufacturing Practices for Craft Brewers (GMPCB’s) were adapted from GMP’s but apply more specifically to conditions and operations inside a …and it’s brewery. • GMPCB’s are essentially a set of application to standards used to determine if a brewery is maintaining practices set by federal, alcoholic state and county regulations. • They are the foundation for all quality, food beverage safety and organizational initiatives in any brewery. • producers… They establish clear guidelines for the hygiene and cleanliness of the workers and the brewery. • They dramatically decrease food safety risks for the brewery’s customers . • They are easy to execute and maintain.
• Compliance with the Standards are addressed through a series of checklists addressing the following topics: …including • Plants and Grounds breweries. • Equipment and Utensils • Sanitary Facilities and Controls • Sanitary Operations • Processes and Controls • Personnel
Food Safety Plan for Craft Brewers Jamie Floyd – Ninkasi Brewing Co.
What is the document? The Quality Subcommittee created this document which provides templates that focus on a particular type of hazard and includes some control measures that can be implemented.
Where is the document? https://www.brewersassociation.org/best-practices/quality/food-safety-plan-for- craft-brewers/
The templates are customizable to fit each brewery’s complexity. The Food Safety Plan for Craft Brewers is meant to be an Each template addresses a extension of the GMPs for different kind of hazard and Craft Brewers with a focus on includes control measures that can preventative controls through be implemented. Hazard Assessment throughout the brewery. Though not HACCP specific, these pull from HACCP theory
• Allergenic Ingredients • Chemical Inclusion • Hazardous Object Templates Inclusion cover: • Package Explosion • Toxicants • Revision Log
Suggestions from Tatiana Lorca of Ecolab: Beer is food and food is regulated by the U.S. Food & Drug Administration. High level points about FSMA from Breweries are not exempt from Tatiana Lorca PHD protecting their customers and meeting food safety requirements. of Ecolab. She has extensive HACCP Whether you have to comply with FSMA and Food Safety depends on who your customer is. background
You will be inspected. The inspector may come from the FDA, the Health Department, the Department of Agriculture or it may be your customer or a designate Tatiana and Doug The different Rules within FSMA will tell Hindman did an you what the minimum requirements are awesome talk at the which apply to your business. 2018 CBC on FSMA The MBAA Food Safety Committee is and what it means putting together their plan to teach 3 district to brewers. level HACCP for Brewers courses in 2019. The
Suggestion from Doug Hindman Elliott Bay Brewing Keep exterior doors closed (pest What Audits are management) finding at Keep glassware and food out of areas where product is handled breweries from Hair restraint (caps/beard nets) use Doug Hindman, when ingredients/processing aids/product is exposed Brewery Ops Properly store, label, and track removal Manager at Elliott of spent grain Bay Brewing, SOPs clearly spelled out and signed off after training MBAA District NW Validate CIPs and maintain supporting Vice President document trail No cats in the brewery substituting for "real" pest control
Voluntary Market Withdrawals and Recalls Guidance for Craft Brewers Larry Horwitz – Four String Brewing Co.
But what if we made an error and think we need to recall? We strive to Mistakes can and do occur make the It is the brewer’s responsibility to ensure removal of the product best, safest from the market before harm is caused to the consumer. beer possible Withdrawal MAY be for non- safety reasons
FSMA/GMP • FDA, under the mandate of FSMA, is responsible for the regulation and food safety standards for most of the U.S. food supply. • FDA has authority to force a recall and shut down operations at breweries if there is a significant threat to public health. • Recalls are classified according to their potential seriousness.
Contamination Adulteration Misbranding Major Major Reasons f easons for or • Misbranded or mislabeled beer • Foreign object inclusion: plastic, Recall or ecall or glass or metal fragments. Etc. • Chemical contamination Withdr ithdraw awal al • Allergens or other toxins in the beer • Package over-pressurization
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