All food producing companies must provide documentation of the production and supply chain.
The ability for a product to be traced from raw materials to the consumer is both a compliance issue regulated by the U.S. Food and Drug Administration (FDA) and a commitment to quality. As the craft beer industry continues to grow, quality management programs are receiving more attention since companies have realized the value in improving the overall quality of their products. Quality is also a consideration for a brewery’s business strategy in order to be competitive against the ever increasing competition of new breweries opening and existing breweries expanding.
The ability for a product to be traced from raw materials to the consumer is both a compliance issue regulated by the U.S. Food and Drug Administration (FDA) and a commitment to quality. As the craft beer industry continues to grow, quality management programs are receiving more attention since companies have realized the value in improving the overall quality of their products. Quality is also a consideration for a brewery’s business strategy in order to be competitive against the ever increasing competition of new breweries opening and existing breweries expanding.
The FDA requires companies producing food (which includes breweries) to register with them as a requirement of the Food Safety and Modernization Act (FSMA). The FSMA in conjunction with the Bioterrorism Act also requires companies to provide documentation of the production chain and supply chain in order to trace products from suppliers, or finished goods to distributors. To register, visit their site where you may complete the process online. Another requirement of the FSMA is that breweries must be able to demonstrate they have a system in place that can trace raw materials (malt, hops, adjuncts) from initial delivery to when they are turned into finished goods and delivered to customers.
Creating a system with traceability enables a brewery to more accurately recall products as needed, instead of every product on the shelf, which can save an enormous amount of time and resources. One doesn’t have to look far in current events to realize the importance of traceability. For example, within the past few years Ten Barrel Brewing had to issue a recall for two beers due to issues with a manufacturing process. The important part is how the brewery handled the issue and subsequent recall. First, the source of the issue was identified. Next, consumers were informed as to how to safely handle the beer, that it did not pose a health risk, and how to apply for a refund. Breweries using a response such as this can help restore consumer confidence by being transparent, ethical, and seeking out the best method to serve the consumer. Having systems in place to handle issues with products is also an important part of a quality program.
Since quality management is my primary responsibility, I have some insights on what has worked and why. A good first step to creating a quality management program is to start with an audit. I began by reviewing operating procedures, especially those involving cleaning. Next, I worked with the brewery staff to create standard operating procedures (SOP’s) based on best practices, or in the field of quality management known as good manufacturing practices (GMP’s). This first step was also crucial in creating open lines of communication, which was extremely helpful in gathering information, generating solutions to issues, and ultimately getting “buy in” from staff.
Another issue that was resolved was consistently date coding bottles. Some issues were due to setting expectations with vendors and others required changing processes. Regarding the process change, through communication with customers we were able to determine there were issues with reading the date codes on bottles. Further discussion revealed a simple solution, change the color of the ink from black (which is difficult to read on a brown bottle or dark label) to yellow. The end result is it will now be easier for our customers to read the date codes, which will help ensure better product rotation and overall customer satisfaction. Of course, other solutions exist such using laser etching on bottles, which is used by Allagash Brewing. The end result is it will now be easier for our customers to read the date codes, which will help ensure better product rotation and overall customer satisfaction.
Ultimately, traceability is an integral part of a quality management system that should be in place to address both compliance requirements and product quality. Whether your brewery makes 500 or 500,000 bbls start with compliance and register with the FDA. Work with your vendors to ensure traceability exists throughout your supply chain. So, choose your vendors wisely and hold them accountable with a vendor requirements letter stating what you expect of them. Finally, remember that creating a quality management system requires time and resources so set goals and allocate resources to help determine the scope of your quality program.
If you liked reading this article, you may also like: Building Your First Craft Brewery Quality Control Lab.