Update, April 4, 2014:
There is now a White House petition asking that this new regulation be reconsidered. The petition can be found here.
The other day I posted a story about a proposed FDA regulation that promises to negatively impact craft breweries and the farmers who use the spent grain from those breweries. This is a follow up to that post. My hope is that this helps to quantify the issue.
Without going into details and mentioning names, I want to tell you about one local farm that relies on spent grain as part of its business. Instead of creating a narrative, I will simply give you a list of facts. Anyone who needs to know my source, or needs to know the exact farm about which I’m talking, should contact me directly.
- Collects 3 to 4 million pounds of spent grain and trube each month from local brewers and distillers.
- Is a third-generation, family-owned farm.
- Is located in King County, has 1,000 milking Holstein dairy cattle, and supplies 7,500 gallons of Grade A milk to a well-known dairy supplier every day.
- Collects spent grain and trube (a similar brewing byproduct) from 11 local breweries and four local distilleries.
- Has invested a lot of money into trucks, trailers and other equipment for this part of its business.
- Uses containers that insure nothing leaks onto streets and into waterways.
- Uses containers and methods to insure the grain is not contaminated before or during transport.
- Uses containers and methods to insure the grain is not odorous or otherwise problematic.
- Inspects the grain to make sure it is safe to feed to cattle.
- Tracks and records everything: what it collects and when, what it feeds to cattle and when.
- Produces milk for well-known dairy supplier, which tests the milk for contamination and to make sure it contains no antibiotics.
The information above tells the story of just one farm. They collect grain from 11 breweries and a few distilleries. There are more than 200 breweries in Washington alone, about 3,000 in the nation, and every single one of them produces spent grain. The amount of spent grain potentially headed to our landfills is staggering.
And that is just stupid.
How stupid? Georgetown Brewing estimates that this regulation would leave it looking for a way to dispose of 160 tons of grain each month.
Drying and bagging the spent grain, as this regulation would require breweries to do, would not be an option for most breweries. The space required to do so simply does not exist. Also, complying with the regulations would create a new set of requirements and procedures which are simply not economically feasible. The cost of doing it would be prohibitive compared to the cost of shipping the grain to the landfill. Craft breweries are small businesses that operate on tight budgets and it is unrealistic to believe they can just find a way to absorb an expense like this.
I don’t know about farming, but I know about brewing. Craft beer and sustainability go together like peas and carrots. Just about every brewery I’ve talk to about the subject is actively seeking ways to be more sustainable. The brewery-farmer relationship is an age-old sustainable practice that should be protected.
I understand what the FDA is trying to prevent. I know they want to make sure our milk, beef, pork, and so on, is free from contamination. I recognize that they want to protect America’s food chain from evildoers of all types. I do not begrudge their efforts.
I do not believe that the FDA’s intention is to destroy the brewery-farmer relationship. It is an unintended consequence that has now been identified and should be avoided.
The FDA is welcoming comments on this issue. Farmers, brewers and anyone with a stake in this issue is encouraged to comment. See our previous post to find out how you can make comments.