In The Industry: Food Safety with BSG’s Brandon Pierce
Do you have a food safety plan in place? In 2011 the Food Modernization Safety Act was signed into law, and reshaped the way the food and beverage industry worked their products. Last week we sat down with Brandon Pierce, the Quality Assurance and Compliance Manager at BSG and formerly of Dogfish Head Brewery, to discuss food safety in the craftbrewing, winemaking, and distilling industries, and how developed programs and regulations in food safety have become in the last few years.
What’s the Golden Rule of food safety in the brewing industry?
My golden rule of quality and food safety is that issues are best prevented or corrected as far upstream in the supply chain or process as possible. Complexity and cost of resolving and controlling issues always increases the further an issue is allowed to proceed through the supply chain/process. When an issue, or potential issue, is identified, STOP, gather your team, and determine how to proceed. Things you don’t know about could get out of control, so it’s important to prevent and control things before they happen. Work with your suppliers to keep up to date and know what’s happening on all sides of the process.
What food safety objectives should breweries be targeting?
I would encourage brewers, distiller and wine makers to use their industry trade organization to better understand what part of food safety government regulation they are and aren’t subject to. The Master Brewers Association of the America, for example, is a great resource for breweries to find information on what food safety laws breweries are and are not subject to. I would also encourage folks to develop a HACCP or Food Safety Plan for their organization even if they aren’t required by law. The benefit of HACCP and Food Safety Plans are that they required a cross-functional team to formally evaluate the inputs to their product, and processing steps at pre-determined intervals and when changes are made. These exercises break down management silos that can develop over time. HACCP and Food Safety Plans are self-imposed requirements to gather accounting, purchasing, logistics, manufacturing, maintenance, warehousing and HR staff to discuss how each functional area affects the end product.
How do standards shift if a brewery takes on other fields, like food, distilling, winemaking, etc.?
Again I would encourage an organization that is looking to expand their operations to new types of products find industry professional organizations that can provide resources regarding the food safety regulatory requirements of that product type. Breweries, for example, are exempt from certain parts of FSMA that a maple producer is subject to. So, if I’m currently making a New England IPA and wish to supplement my brand with a line of maple syrup, I might find that I need to learn how maple syrup is regulated. There many general food safety professional organizations out there as well as product specific organizations that have food safety resources.
What advice do you give new brewers?
If you have questions, ask them. Ask anyone and everyone you think might know the answers. There’s a lot to know out there, and the more you ask the more you will start to find out who you can count on for different subjects. BSG has a particularly large bench of folks to draw information from, if you have a question we likely have someone that can help answer or point you in the right direction.
What are some starting blocks for developing a food safety plan?
The MBAA is going to be a great place for brewers to start gathering some knowledge and resources regarding food safety for beer specifically.
What are some of the biggest differences in food safety rules between breweries, wineries, and distilleries?
In general breweries, wineries and distilleries are regulated very similarly in regards to food safety in the US. The big differences we see at BSG is when products are marketed for international trade. It is important to understand the regulatory requirements of the markets you’re selling into. One prime example is allergen declaration; in the US wheat is one of the major allergens that requires product labelling where in other places wheat is lumped together with other grains into the category of “Cereals containing gluten”.
How do food safety processes work with international suppliers?
We have a supply chain team that manages supplier approval and verification. In our case the team uses some very handy software to help with the task since we are sourcing ingredients from so many different suppliers and areas of the world. The fundamentals still apply though, assess the hazards and ensure they’re being controlled.
What are some day-to-day tasks you focus on as a Quality Assurance and Compliance Manager?
My job is making sure people are trained and supported. In our case it means orientation training in food safety, ensuring key individuals responsible for food safety have more in-depth training and they have a well-developed food safety management system. Folks need to be supported with robust training, appropriate equipment, well organized facilities, clear policies, thorough procedures and efficient record keeping tools in order to meet our food safety goals AND to do the job of distributing ingredients.
What’s the hardest part of your job?
Reacting to customer expectations as they change and evolve with the times. Food safety is still new to this industry, and BSG was required to be compliant to FSMA back in 2017, just two years ago. When I started working, just out of college at a large craft brewery on the east coast, the idea was “well, we’re regulated by the ATF, as long as we know how much booze is in the bottle we’re good”, but that’s changed a lot. People now realize that all beverage areas are regulated by the FDA. FSMA has been a reset button for our customers as well as the entire US food industry.
How do breweries handle the new FSMA requirements?
Some facilities may be exempt from the preventive controls requirements but all facilities should meet GMP requirements. However, if you don’t perform a hazard analysis then you’re not stopping to ask if an ingredient item or food is safe or not. I’ve seen articles about invasive aquatic species used as ingredients to raise awareness about lake cleanliness and even spirits infused with leather, concrete and rusty iron; none of which are GRAS. Hazard analyses aren’t required, but they can help you stop and think, “is this really a safe food ingredient?” There’s a lot to learn, and a lot of things that new breweries don’t know that they don’t know. A great first step is to reach out to industry resources and begin to get familiar with the regulations that apply to your facility.