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Monday, March 17, 2014

The FDA Finally Acts to Protect our Country's Livestock from the Dangerous Spent Grain from #Beer Mash

Or at least that must be how the FDA sees the world. Why else would the agency propose rules that "require that spent grain for animal feed be dried and prepackaged onsite in a manner that doesn't touch human hands." What is one source of spent grain - our country's breweries and distilleries. Instead of simply dumping the spent grain, most of these companies have established relationships with local farmers to provide the spend grain to supplement the diet of livestock. Scott Harris of Catoctin Creek Distilling Company explained how the cows that benefit from their spent grain rush the delivery truck when it arrives.  (See the 18 minute mark in this MyJoogTV video and video below.)  And not only does the spent grain supplement the diets, but it also hydrates the animals because the "wet" grain has soaked up the water.

Yet the FDA in their wisdom now wants breweries and distilleries to prepackage the feed, adding production costs to the operations for those companies that provide their left over grain to farmers. Instead of packaging the spent grain, they could also choose to just dump the spent grain, adding other costs in itself. The FDA also wants to force brewers to dry their grain, removing any hydration benefits that farmers prefer. Perfect. Another example of government bureaucrats creating a problem where one doesn't currently exist. In this case, just let the invisible hand of the marketplace do it's thing.

The Brewer's Association is on top of this situation and has posted these suggestions to brewers.
For BA members, we ask that you:
1. Communicate with your farmers that we will be looking for them to submit comments to FDA based on the draft farmer comments that we will circulate once final. Farmer comments should focus on the impact to their business of the proposed rules, the preference to receive grains "wet" from brewers, the lack of problems with receiving spent grains as currently in practice and the environmental issues related to a change in current practice.
2. Prepare your own set of comments to FDA based on the sample brewer comments, with an emphasis on how the current proposed rules will impact your business and any thoughts on how landfilling grains may not fit with sustainability efforts.
3. Sign up for the March 27 Power Hour and then send in comments after final revisions by the March 31 deadline.
Let's hope these comments to dissuade the FDA. Beer and spirits consumers should also contact your local representatives in the House of Representatives & Senate.


Update: another video describing farmers love for spent grain:

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