It’s official. Beer is food. That’s effectively what the Government of Canada and the Canadian Food Inspection Agency (CFIA) said on January 15, 2019 when introducing new Safe Food for Canadians Regulations (SFCR) for Canadians, explains Steve Grundy from McRae Integration.
With this comes new requirements for manufacturers of alcoholic beverages, those containing 0.5% or more alcohol by volume, to have a traceability system in place by July 15, 2020. Google the topic using a logical set of search words and you will quickly find these new regulations on the CFIA website and through a variety of other government sources.
Prepare yourself though, the SFCR document isn’t a light read. We’re talking about a government document designed to drive processes and procedures that protect the health of humans, so it is very comprehensive.
You should care about these new regulations if you:• Produce beer, wine, spirits, kombucha, cider, mead, or ready-to-drink cocktails• Trade interprovincially• Import or export your product outside of Canada• Sell your product at the retail level
By the time this article is published, it will already be 6 months since the CFIA made its announcement and you will have roughly 12 months to get your act together. If you are a breweryowner or a manager in this space, the big question is what do you need to do between now and next July to be ready?
Ask yourself – what do you and your teams know about traceabilityand what is required to be compliant with the new regulations? How can you achieve this without disrupting your business and adding significant cost and complexity in an increasingly competitive market environment? Also, is traceability only the responsibility of the producer?
What role do ingredient suppliers and distribution partners play to ensure the entire food chain is safe for consumers? This article won’t provide the answers to all of these questions, but hopefully we can stimulate a positive discussion and generate action toward solutions that drive compliance and safe food for everyone.
Let’s start by defining traceability. Basically, it comes down to lot tracking of where your ingredients come from (one step back) and where you provid your finished product (one step forward). The following infographic paints a simple picture of a batch manufacturing process with lot tracking of inputs, work in progress (WIP – not required for CFIA compliance), and finished goods. Depending on the nature of your operation, this may be familiar to you.
Figure – Lot Controlled Batch Manufacturing Process
Source – https://www.batchmaster.com/tracking-compliance/lot-traceability/
Many larger breweries with automated process controls and enterprise resource planning (ERP) systems have the ability to automatically collect this data, manage and track inventory from start to finish, and get reports and analytics with a few simple mouse clicks. How does that happen? Ingredients such as malt, hops, and yeast arrive at the brewery and are received by an operator who scans a barcode on the container with the lot number and quantity. A programable logic controller (PLC) processes the transaction and shares it with a database or, as is increasingly the case, directly with the ERP which then provides a location and internal lot tracking number that follows those ingredients through the facility. Internal work orders move the ingredients through the manufacturing process and the resulting batches of beer and other beverages are given unique batch records, a birth certificate of sorts, containing the quantities and lot numbers of the ingredients used. We don’t need to belabor the point but you can see how this carries on through packaging, finished goods, order fulfillment, and shipping. Of course, mobility technology such as smart phones and tablets provideinstant access and visibility to this data. Having access to all this technology is definitely an advantage when it comes to compliance. If an inspector should come calling and ask to see the brewery’s records, the conversation should be straightforward and compliance should be easy to prove.
Now consider the opposite end of the spectrum. Suppose you own a smaller brewery with manual processes, limited information technology, and a small part-time staff. It doesn’t mean you can’t be compliant like your larger automated competitor – but you will need to have solid procedures, a discipline for data collection and accurate record keeping, and a commitment to quality above all else. You might not have a bar code scanner to receive your ingredients, but if you check your most recent invoices from your suppliers, you will likely find the lot numbers for what you purchased. Someone needs to record that data at the time of receipt. If you don’t have an automated brewing system with instrumentation to measure and validate the quantity and lot number of the ingredients used, you will need to include these fields in manual brew sheets and the brewer will need to record these values every time. The same manual data collection process continues through packaging, finished goods, order fulfillment, and shipping. It comes down to accurate record keeping and a commitment to quality – but there are inherent pitfalls to manual processes. Data entry errors are common and while they can be relatively easy to correct, spotting them can be difficult and extremely time consuming.
What would happen if today a government inspector were to show up unannounced at your facility and ask to see your traceability records? How easy would it be to comply with that request? Take it a step further. What would happen if you were forced to do a recall right now? Imagine you get a phone call from a distributor because a consumer complained of an “odd” aroma from a beer you just released. Upon further investigation, you discover that a significant portion of last month’s production is contaminated due to a yeast issue. How easy would it be for you to identify and quarantine all the product from that lot? How easy would it be to identify the lot numbers for the ingredients used? How confident are you be that you could contain the risk to the public and your brand? Have you ever done a mock recall to test your existing systems? If not, try it sometime and see how vulnerable you are. It might be a little uncomfortable, but it will reveal your blind spots and benefit you in the long run.
There is no step-by-step guide to traceability compliance, but there are plenty of great examples in other segments of the food industry where traceability has long been a requirement. There are people with years of industry experience that can help make your journey toward traceability compliance more efficient and effective. As you might expect, there are software packages available on the market that are designed for food and beverage batch processes. They use electronic procedures that allow manufacturing teams to gather the required data with minimal errors and make reporting simple and consistent.
To help prepare brewers for the new CFIA requirements, Beer Canada has put together an industry working group tasked with creating a template that brewers can use to implement a traceability system into their operations in advance of the July 15, 2020 deadline.
Members of the Beer Canada Working Group are currently touring breweries of different sizes to get a picture of how ingredients flow into and throughout the brewery before the finished product exits the brewery and enters the market. The Working Group is aiming to have the excel-based template available for brewers to use by the end of summer 2019.
“The ability for brewers to trace their ingredients back to the supplier and their finished products to the retailer is not only a requirement under the Safe Food for Canadians Regulations, but also a commitment to quality. A greater emphasis has been put on the importance of traceability in recent years and Beer Canada is taking a leadership role by ensuring that breweries of different sizes have the tools needed to seamlessly implement traceability principles into their brewing processes.” – Luke Chapman, Director, Federal Affairs, Beer Canada
This initiative by Beer Canada will provide breweries and other alcoholic beverage companies almost a full year to examine the template against their existing tools and procedures, figure out where they have gaps, and make changes if necessary to ensure compliance with the new CFIA regulations. Some may use this as an opportunity to up their manufacturing technology game and take advantage of the efficiencies and operational insights that follow. Others will do the bare minimum because that’s what they can afford and that’s OK. End of the day, this is going to shine a big light on how things are done in breweries and has the real potential to give a substantial lift to quality across the industry. As spirits, wine, and other beverages continue to put pressure on the beer industry, perhaps this couldn’t have come at a better time.
End of the day, it comes down to having a solid strategy built around a combination of people, processes, and technology to ensure the quality and safety of your products. Are you ready?