Trouble Brewing in Proposed FDA Regulations

Pigs are my favorite animals. While I loved all the animals at Wyebrook, they stood out from the rest. I think I like them because I can relate to their personalities. They are curious, stubborn, goofy, and completely adorable. Just like me, right? They should be your favorite, too. Why?  They are one of the most sustainable animals out there. They take compost – scrap food that would otherwise end up in landfills – and turn it into bacon and sausage. What more could you ask for from an animal?

At Wyebrook the pigs got all the non-pork kitchen scraps. (It’s important not to feed animals waste product from their own species. Think mad cow.) They also eat spoiled cheese and excess whey donated by Doe Run Farm, a nearby dairy farm. It’s a great partnership: Doe Run has a sustainable way to dispose of byproducts that would otherwise be thrown out and Wyebrook gets free food for the pigs. And the pigs get to eat really delicious cheese. Everyone wins. Small-scale farmers often form these types of relationships with local restaurants, grocery stores and food producers to offset costs and minimize waste.

One of the biggest cross-industry relationships exists between brewers and animal farmers. Beer brewing is pretty simple (in theory). You mash up some water, grains, hops, and yeast and let them ferment for a bit. The yeast converts the sugars in the grains into alcohol. Once all the sugars are converted you strain out the grains and you’ve got beer. More or less. Don’t try this at home based on these instructions.

Anyway, after the filtering process brewers end up with what is called spent grain. The spent grain is useless to the brewers and they need a way to dispose of it. They could pay to have it hauled off to a landfill, but luckily for them, pigs love spent grain. Since the dawn of beer, brewers have been feeding their spent grains to pigs (and cows and chickens). Like Wyebrook’s relationship with Doe Run, everyone wins. Brewers. Farmers. Pigs.

Unfortunately, the FDA has decided to get involved in the process. They’ve proposed new regulations governing the processing and handling of animal feed as part of the Food Safety Modernization Act (FSMA). FSMA, by the FDA’s own admission, was crafted for a globalized food economy: “FSMA embraces preventing food safety problems as the foundation of a modern food safety system and recognizes the need for a global approach to food and feed safety.” (Emphasis added.) Unfortunately, these regulations are being applied across the board, from global producers like Tyson down to little guys like Wyebrook, and they are being drafted by folks who have little experience with or regard for small-scale food production.

The proposed rules implement “Current Good Manufacturing Practices” to regulate what gets fed to animals and how those products are handled. They cover hygiene and training for people handling the products, facilities, equipment, processing, record keeping, storage and distribution. For multinationals like Smithfield and Anheuser Busch complying with such regulations is pocket change, but for craft brewers and small farms, these regulations are incredibly burdensome. Rather than encouraging sustainability and waste minimization, the new rules make it more economical for brewers to send their spent grains to landfills instead of farms. Farmers will be forced to buy feed to make up for the loss of spent grains. This added cost will either cut into their already narrow profits or force them to increase the prices of their products.

While brewers have been the focus of the debate, these proposed regulations would affect dairies, restaurants, grocery stores and any other food processor who provides food scraps to farms as animal feed. Like much of the FDA’s work, these proposals may seem reasonable on the surface, but once you start to consider how they will affect real farms and businesses, the absurdity becomes clears.

If you want to know more about the proposed regulations, visit the FDA website. Also, the regulations are still open for comments (they close on March 31st and 11:59 p.m.). You can share your thoughts with the FDA here.

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