DaYooper wrote:
When I first posted I figured it was all about the money, but now that you have pointed out some of the actual wording it is obvious it is. If they were concerned about health issues it would be across the board. Now that I see they are targetting only breweries that SELL their grains (after all, cant tax free) and making over $500k (less than that it costs more in paperwork than they will recover) it is pretty obvious. About time for another Boston tea party.
I would tend to agree with you as well, especially the way they set up the thresholds and as I read it ONLY target those breweries that sell their spent grain and have yearly sales of over $500,000. Then yes, it seems it really is all about the money and not the "health issues" as they would try to spin it. It seems they don't care too much about the health issues when you give it away or have sales less than $500,000 annually.
Section 116 of the FSMA makes exemptions for the raw ingredients to make alcohol and the production of it, under the FDA’s interpretation, “a brewery that sells its spent grains as animal feed may be manufacturing beer and animal feed simultaneously for at least part of the brewing process.” This statement makes me believe they are only targeting those that sell their grain.
But my question is and remains, why are they only concerned on this issue if the brewery is selling it (I say fully knowing it's about the tax money)? Would the concern also not be there if breweries were giving it away as well? I guess sold spent grain carries a higher health risk than free spent grain ... Who knew?
The problem I have with it is in line with what the Brewers Association has said as well. Many breweries that operate throughout the United States provide spent grain to local farms for use as animal feed at no cost. The proposed FDA rules on animal feed could lead to significantly increased costs and disruption in the handling of spent grain. Brewers of all sizes will either have to adhere to new processes, testing requirements, recordkeeping and other regulatory requirements or send their spent grain to landfills, wasting a reliable food source for farm animals and triggering a significant economic and environmental cost.
Without any form of non-partial risk assessment conducted by the FDA to prove that spent grain to animals is harmful to their health, this point and proposed regulations is almost mute. Spent grain has been a source of food for animals for centuries and it seemed to work out fine for all involved. So now I am supposed to believe their is a health risk involved, but only from those who sell their spent grain?
And what of the farmers involved in this as well? We tend to look at it from a brewing stand point (obviously) though some of these farmers are not mega operations and count on this spent grain at times to help reduce their costs which in turn reduce the overall cost of their products sold. If this were to be taken away, their cost go up, our cost go up ... It's not just a one industry burden at that point. It effects countless other industries and lives for that matter.
<<< Steps off his soapbox for now >>>
