For many years, breweries have leaned on the assertion that there are no known pathogens (bacteria, viruses or other microorganisms that can cause disease) that can survive in beer. Brewers have often used this as justification for not implementing the same control measures found in other food manufacturing facilities.
While many studies have shown beer to be an inhospitable environment for many microorganisms, it is important to understand that potential food safety hazards are not limited to pathogens. Potential threats include chemical and physical hazards which could harm a consumer. It is the responsibility of the brewer to ensure that they have taken all necessary measures to identify and prevent all potential hazards.
Good Manufacturing Practices
With the introduction of the Food Safety Modernization Act (FSMA), there has been increased recognition that beer is food. For the first time, alcoholic beverages are regulated as food products, which now fall under U.S. Food and Drug Administration (FDA) jurisdiction. There is an increased focus on the concepts of good manufacturing practices (GMPs) and food safety plans, which can include hazard analysis and critical control points (HACCP), or FSMA-related concepts such as preventive controls.
GMPs are designed to create a suitable processing environment so that products are considered to be safe and suitable for human consumption. Preventive control programs like HACCP build on GMPs, and involve the brewer taking a deeper dive into their products, raw materials, ingredients and processes, with the goal of identifying specific opportunities where controls can be applied in a preventive manner. GMPs and HACCP are both general concepts created to suit a wide range of food production settings. There have historically been limited resources that specifically address how these concepts can be implemented in a craft brewery.
Food Safety Plan & Hazard Templates
Food Safety Plan Resources
In 2016, the Brewers Association Quality subcommittee released Good Manufacturing Practices for Craft Brewers (GMPCBs), which provides guidance for developing GMPs in a craft brewery. The Food Safety Plan for Craft Brewers (see Resources box) is intended to be an extension of GMPCBs, and provides guidance for craft breweries to design and implement a food safety program.
These resources are intended to identify some of the food safety hazards that can exist in craft breweries, but is not intended to be all-inclusive. The templates are intentionally customizable. Each template focuses on a particular type of hazard and includes some control measures that can be implemented. Hazards will vary from brewery to brewery, so it is important to audit your processes and tailor this resource accordingly.
While this document is not HACCP specific, it does pull from HACCP theory. Standard HACCP guidance is general and does not typically provide specific advice for brewery settings. In addition, HACCP is not currently required for brewery settings in the U.S. However, after implementing a basic food safety and preventive control program, we strongly encourage brewers to investigate the steps that are required to implement HACCP and become HACCP certified. The Master Brewers Association of the Americas (MBAA) offers resources for breweries interested in seeking HACCP certification.