3 Things Every Brewer should Know about Hops and Food Safety
Small scale regional hop production has exploded over the last 5 years providing many eager folks with a chance to grab a piece of the craft beer scene.
However many small growers are clueless about food safety guidelines meaning brewers bear the responsibility.
Here are 3 questions to ask when purchasing hops from small-scale growers.
1. Ask for chemical application log and licenses
Hops fall under pesticide regulations like all crops and require that the grower possess a pesticide applicator’s license and a logbook recording all chemical applications. Each state has its own list of approved chemicals and it is too much to expect a brewer to understand what these things are and how they should be used.
Simply asking to see such records sends a powerful signal to growers that you are in-the-know about crop chemicals and that growers should be ready to provide records. If the grower cannot or will not produce the records then think twice about those hops, especially if using them for wet-hop brews.
2. Ask to inspect their hop harvesting and drying facility
Hops fall under the 2011 Food Safety and Modernization Act (FSMA) and require ALL growers with a farm gate value of more than $25,000 to register and comply with FSMA regulations. Farm food safety covers sanitary practices, worker hygiene, harvest and drying facility cleanliness, pest exclusion, everything you’d want to see if you were buying produce from a CSA for example.
Again, many small growers either are unaware/unwilling to comply or fall below the minimum threshold ($25K) value to be covered. Regardless a quick tour can reveal any potential issues that a brewer should be concerned with, for instance:
Storing chemicals and farm equipment in the same building as harvest and drying
Signs of pests (bird nests, rodent activity, etc) in the harvesting/drying area
Harvesting/drying/packaging taking place outside or on gravel/dirt floor
Dry hops being stored loose (no baling) or without environmental controls (temperate and relative humidity)
Noticeably diseased, discolored, or malformed hop plants/cones
Even the very smallest grower can comply with these simplest of food safety measures so do not be afraid or embarrassed to point out things that make you uncomfortable. For more information on FSMA and hop harvesting please see USA Hops website.
3. Ask for evidence of Food Processing Certification
For brewers using regional pellets, demand evidence of a food processing license from your state. If your state does not include hops on their list of processed foods the FDA regulations apply at the least.
All hop processors must comply with FSMA but there is a grace period for processors to ease into the program. Still there are small processors who believe they are exempt from such regulations and therefore do not have the appropriate control in place to ensure a safe processed hop pellet.
10 years ago there were very few manufacturers offering equipment for hop processing. Now there are several companies (domestic and foreign) who have modified (somewhat) small pellet systems intended for wood and animal feed for use with hops.
Here are a few questions to quiz your small processor:
Ask for evidence that these systems meet FDA requirements
Ask whether or not the processor has a recall plan in effect (they must if they are licensed)
Inquire about a HAACP and whether or not it applies to them
How do they generate and store lot numbers? How are you notified if there is ever a problem with contaminates?
How does the processor handle hops from various growers? If there is a problem from a blended batch how does the processor find the source of the issue?
Ask about the acceptation/rejection criteria for incoming raw hops
Don’t be surprised if you receive a lot of blank stares and mumbling.
Hops are a food product.
Period. End of Story.
If you would like help navigating the food safety requirements for hop please do not hesitate to contact us at Gorst Valley Hops at this address: firstname.lastname@example.org