Brewer- Farmer Relationships Threatened

News about an FDA proposal to control animal feed is making small brewers and small farmers nervous.  Both would experience increased costs of operation if this proposal goes through.  Fortunately, it is open to public comment until March 31st. 

Brewing uses a lot of barley.  Barley is a cereal grain rich in protein and carbohydrate calories as well as a host of other important nutrients.  Brewers are most interested in the starches and sugars that are extracted through the mashing process.  Once those have been removed from the grain, the rest is considered waste to the brewer.  For as long as there have been brewers living near farmers, these wasted grains have ended up as animal feed.  A new effort from the FDA would severely threaten that relationship.

 

A new proposed rule would prevent breweries from passing off spent grain to farmers. The rule is meant to “ensure the safety of animal food for animals consuming the food and ensuring the safety of animal food for humans handling the food, particularly pet food…”

The rule essentially would require breweries to dry, analyze and package the grain before sending it to the brewers. All without any of it touching human hands. The process would be too time consuming and too costly for small craft brewers. The grain would have to be dumped. The farmers would be barred from picking it up. The free grain is a big help financially to the farmer, offsetting food costs for the animals.
— beerstreetjournal.com

Obviously there is a need to control the products farmers feed their livestock.  There is real danger to consumers of animal products if the feed used to raise them is unsafe.  Brewers' barley, however, does not fall into this category of dangerous products.  This barley has already been deemed safe enough to use as a principle ingredient in a beverage for human consumption.  The brewing process simply steeps the barley in 150+/- degree water for an hour or so.  If the farmers are utilizing the spent grains from brewers in a timely fashion, there is little risk for bacterial growth or any other spoilage that might affect the quality of the feed.  Any proposal should seek to regulate that part of the equation, if anything.  From a quick google search, I wasn't able to find any information to support a theory that brewers' grains pose any health risk to cattle.  Also, a study released by the National Institutes of Health in 1994 concluded the following:

Twenty lactating Jersey cows were offered diets containing 0, 15, or 30% wet brewers grains or 30% wet brewers grains plus liquid brewers’ yeast during hot, humid weather. The DMI was not different, even though diets with 30% wet brewers grains contained only 35.5% DM and approximately 50 versus 36.8% NDF for the control diet. Yields of milk and FCM did not differ for cows offered the control diet versus wet brewers grains or diets with 15 versus 30% wet brewers grains, but milk yield for diets with 30% wet brewers grains was greater with added liquid brewers’ yeast than without it. Milk fat percentage was not different, but milk protein percentage was lower, for diets with wet brewers grains than for controls and for 30% wet brewers grains than for 15% wet brewers grains. Serum urea N was lower for control cows than for cows receiving the diets with wet brewers grains. Feed cost per cow was lower for wet brewers grains versus the control diet, and income over feed cost was greater for diets with 30 versus 15% wet brewers grains. Large quantities of wet brewers grains can be added to the diet during hot weather without depressing DMI.
— National Insititute of Health

This only helps to reaffirm the argument that farmers strongly benefit from the use of brewer's grains as feed.  Also, many small brewers reap the benefit of free haul off and disposal of this waste product.  If small brewers were forced to pay for this waste to be removed, they would incur extra costs that would have to be passed on to the consumer.  No one benefits from losing this relationship.   

Please don't let small brewers and farmers get caught up in this proposal.  The comment period is open until March 31st.  Follow the link to make your opinion heard.  http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm247559.htm#pc_animal