FDA regulating feed

Gravytrain · #21 03/22/14, 04:44 PM

Quote:

Originally Posted by highlands

There's no need for the FDA to get involved between us and the local beer brewer we get spent barley mash from nor the farmer we get apples from nor the cheese maker we get whey from. None of those things are coming in from China. We are working directly together and have for decades in many cases. No problems. This is too much government interference. They're creating problems.

Yes, but you see the bureaucrats do not like this. A peer to peer, business to business, farm to business symbiotic relationship in which the government doesn't have control, is dangerous to society (err...them). Additionally, taking another entities' waste and using it for your production takes government taxes, fees, and licenses out of the equation.

**highlands** · #22 03/22/14, 05:34 PM

Quote:

Originally Posted by Gravytrain

Yes, but you see the bureaucrats do not like this. A peer to peer, business to business, farm to business symbiotic relationship in which the government doesn't have control, is dangerous to society (err...them). Additionally, taking another entities' waste and using it for your production takes government taxes, fees, and licenses out of the equation.

This is true. We are failing to do our part to drive the Gross and Disgusting Production (GDP) which fuels the coffers of our beloved learless feeders. Most genuine apologies and abject groveling before the all mighty bureaucracy.

haypoint · #23 03/22/14, 05:40 PM

Quote:

Originally Posted by highlands

The exemption is meaningless. It is extremely easy to break the $500K mark and these are NOT feed dealers. These are breweries. The spent barley mash is a byproduct they need to get rid of. Putting it in the land fill is bad. Putting it in compost is not as good as feeding it to the animals as it is further down the chaos slope.

The government needs to keep their greedy noses out of things like this. They are not solving any problems. They are making problems.

Specifically, what part of the proposed regulation do you object to, specifically?

Seems logical to split for a brewery business and separate the sale of brewery waste/feed business from the production of alcoholic products. If a business is marketing just spent brewer's grain and grosses over $500,000, I think we can agree that they should be prevented from selling filth, chemical contamination and other toxins. You disagree?

Seems you'd applaud a plan that regulates the big players and lets the little guy to go unregulated.

**highlands** · #24 03/22/14, 05:48 PM

Specifically? Just about all of it as it relates to farming. Start with the link I provided before. Here it is again:

http://brewers.informz.net/Brewers/a...e_3146038.html

You are failing to read things. You are making statements which are false and don't have anything to do with me or what I have said. I don't have a brewery. This was not about animal feed dealers.

Please actually read the comments you are responding to and quoting and read the links rather than just ranting.

haypoint · #25 03/22/14, 06:45 PM

Quote:

Originally Posted by highlands

Specifically? Just about all of it as it relates to farming. Start with the link I provided before. Here it is again:

http://brewers.informz.net/Brewers/a...e_3146038.html

You are failing to read things. You are making statements which are false and don't have anything to do with me or what I have said. I don't have a brewery. This was not about animal feed dealers.

Please actually read the comments you are responding to and quoting and read the links rather than just ranting.

I thought we were still talking about mash/brewers spent grains and the worry that this resource would be lost. If breweries market over $500,000 in livestock feed.
Other than the breweries grains you feed your pastured hogs, I fail to see how inspections of large scale livestock feed producers impacts you.
Seems GRAS would exclude wet brewers grain from regulation.

**highlands** · #26 03/22/14, 06:53 PM

Quote:

Originally Posted by haypoint

I thought we were still talking about mash/brewers spent grains and the worry that this resource would be lost. If breweries market over $500,000 in livestock feed.

No, the way the FSMA is worded is if the total sales of the business is over $500K then they are regulated by the FDA under FSMA. It is not the sales of the mash, it is the total gross sales. Even a very small restaurant with a brew pub can exceed that easily. $500K / 365 days = $1,369 in sales per day which is pitifully small for a restaurant. If they only served 100 customers a day that would be a mere $14/tab - the restaurant would die. It couldn't support a brew pub. $500K is a very low gross sales for a even a small business.

Besides, the brewers are not selling the mash, they're giving it away so it should not be regulated but the FDA is trying to take control anyways.

Farmers too can very easily get over this threshold. $500K is GROSS sales of everything from the business/farm. If we sell timber that gets included in the sales. Everything gets included in those gross sales figures. That is one of the many of the fundamental flaws in FSMA. People like you read $500K in sales and think that is profits or that is sales of one item but your wrong. This makes a lot of small farms and businesses covered which don't need regulating.

Awnry Abe · #27 03/22/14, 07:22 PM

Quote:

Originally Posted by haypoint

I thought we were still talking about mash/brewers spent grains and the worry that this resource would be lost. If breweries market over $500,000 in livestock feed.
Other than the breweries grains you feed your pastured hogs, I fail to see how inspections of large scale livestock feed producers impacts you.
Seems GRAS would exclude wet brewers grain from regulation.

Yes, but I want to open a feed store and have revenue of $500K and 1 penny. But I won't. Ever. Because of sucky, stupid, arbitrary, capricious, bureaucracy. But why do I waste my time talking about it. Everyone seems to like this sucky version of America. Stop worshipping this beast of a government ,that is a figment of our imagination.

skidsareforkids · #28 03/22/14, 08:50 PM

More Government regulation is never the best option.

haypoint · #29 03/22/14, 10:04 PM

If you read the proposal, further down, it discusses the exemption for businesses under $500,000 annual sales of ANIMAL feed. Seems that a brewery would be fairly large if they sold a half million dollars worth of "waste product".

**highlands** · #30 03/22/14, 10:40 PM

If you read the rest of the regulations for the Food Safety Modernization Act (FSMA) it talks about $500K gross sales being the total sales of all products from a business being the trigger for regulatory oversight by the FDA. There is no need for government regulation of this. This is not human food and should not be part of the FSMA.

I'm curious as to why you defend the government so much. It's not about being right - You're wrong. We have a situation here where the government is clearly reaching too far. The FDA is having a second comment period because they themselves recognized the concerns about the FSMA and that there may be problems. Time to speak up to the FDA on the comments and work out the problems. No need to defend errors in government.

PricklyThistle · #31 03/22/14, 10:52 PM

I get brewers grains for my goats. It's cheap, it's healthy for them and it's almost twice the protein as regular grain. Why do I have the sneaking suspicion that it's just one more thing that's good for something and affordable that the government doesn't want us to get our hands on?

PasturedPork · #32 03/22/14, 11:32 PM

Overall I think this aspect of the FSMA will be a benefit to small farmers and homesteaders. The rule would prevent very big distillers from putting dangerous waste in the good byproducts usable for feed.

It wouldn't regulate businesses that gave the byproducts away.

The government is made up of some people who ARE idiots or want to take away rights. There are govt employes who are working to make the world better. I think the FSMA is a good example of this - some of the rules are burdensome but others will be really positive for consumers and small farmers.

arabian knight · #33 03/23/14, 12:26 AM

Yes and this is one example of the good they do for all concerned.

ChocolateMouse · #34 03/23/14, 12:30 AM

Or they could just generically say that people distributing spent grain pay a minimal yearly inspection fee that even small businesses can afford and anyone found putting waste products in feed gets a giant fine that would crush their company and will be required to face criminal charges... Then if you don't put waste products in your feed, what is the problem? And if you do the company has a huge scandal on their hands. You pay a guy $25 to come conduct a 1/2 hour inspection 1-2 times a year. It's not like the FDA runs tests on every product, like actual chemical identification or bacterial culture tests, before releasing it for public human consumption....

haypoint · #35 03/23/14, 07:58 AM

Quote:

Originally Posted by highlands

If you read the rest of the regulations for the Food Safety Modernization Act (FSMA) it talks about $500K gross sales being the total sales of all products from a business being the trigger for regulatory oversight by the FDA. There is no need for government regulation of this. This is not human food and should not be part of the FSMA.

I'm curious as to why you defend the government so much. It's not about being right - You're wrong. We have a situation here where the government is clearly reaching too far. The FDA is having a second comment period because they themselves recognized the concerns about the FSMA and that there may be problems. Time to speak up to the FDA on the comments and work out the problems. No need to defend errors in government.

I'm not interested in defending the FDA. But I think that broad brushing this as government intrusion is overly simplistic.
We have people that bemoan the government's inability to prevent a jar of peanut butter, a melon, a strawberry or ground beef from reaching a grocery store with any sort of contamination. Some resist any effort to develop a method to get to the source of disease, infection or contamination.
If we want to get our government to operate the way we want, we need to be able to focus on real issues.
I have been unable to get you to pick a specific problem, beyond "everything". The closest you have gotten is the part of this proposal that excludes most small operations. When I read that the operations that sell under a half million dollars in animal feed, it seems clear to me that most brewery's would be exempt. While this proposal is to protect all sorts of food and feed manufactures, we have been focusing on the waste product of the manufacture of alcohol. But that is just a tiny slice of it. It is mostly to protect people and animals, following recent problems with contamination from pesticides, diseases, fungus, bacteria and just plain filth. I don't want to fight to protect businesses that do that.
If you want to complain about this proposal, go ahead. Just make sure you are focused on something that really exists in the proposal.

Steve in PA · #36 03/23/14, 09:18 AM

Quote:

Originally Posted by haypoint

If we want to get our government to operate the way we want...

Respectfully, right there is the rub. How I want the government to operate may be different from how you, my neighbors, or the guy 7 states away may want it to operate yet there is a group of about 500 people in a city located on the east coast that feels quite comfortable regulating very basic elements of the lives for roughly 300 million people.

ChocolateMouse · #37 03/23/14, 09:22 AM

People we didn't elect, mind. None of us voted for them... Nobody voted for them. There wasn't even a vote.

Gravytrain · #38 03/23/14, 09:52 AM

Quote:

Originally Posted by Steve in PA

Respectfully, right there is the rub. How I want the government to operate may be different from how you, my neighbors, or the guy 7 states away may want it to operate yet there is a group of about 500 people in a city located on the east coast that feels quite comfortable regulating very basic elements of the lives for roughly 300 million people.

This is why regulation at the federal level is almost always a boondoggle and an overreach. Regulation at the state level can be emulated if successful and rejected when it's a failure. Regulations at the federal level, even if disastrous, rarely go away.

Yet, the sheep always seem to clamor for more control to be exerted over their lives. BAHHHHH! Those regulations are strangling us! BAHHHH! We need more regulations then! BAHHHHHHH!

**highlands** · #39 03/23/14, 10:31 AM

This isn't about animal feed dealers. This overly broad regulation is being applied where there is no need by bureaucrats who have no concept of what they're doing. They are city people trying to micromanage the lives of rural people who are not part of their commerce. The FDA has unfortunately been given overly broad powers to deal with things that have nothing to do with human food. The government's trying to say that the spent barley has to be up to human standards. This is utter nonsense. Pigs live out in the pastures.

The $500K exemption is an absurd threshold and it applies quite specifically to ALL sales by the business, not just sales of animal feed. The FDA has been very explicit about this issue. If you sell $499,999 in things the FDA has no control over and you sell $2 of anything the FDA has control over such as produce or "animal feed" then the FSMA kicks in. That's absurd. This is not about animal feed sales. In fact, if the brew pub sells $500,001 in beer, their main product and they give away any animal feed (the spent barley) then they get included under FSMA for the barley which they should not be. Virtually any brew pub / restaurant exceeds that threshold. That's only about $1,400 in sales per day. That's a very tiny pub or restaurant. Ten times that is still very, very small.

Furthermore, the FDA should not have any control over this. This is a USDA matter because it is dealing with livestock.

There are a LOT of other problems with the FSMA. I have not raised them on this discussion thread because this thread is focused on this issue.

PricklyThistle · #40 03/23/14, 11:49 AM

I'm going to say something downright crazy (at least I'm sure it's considered so these days). I don't want the government to protect me from Anything. I don't believe they have any true interest in doing so and quite frankly, I've outgrown the need for a nanny.

I've never feared a terrorist nor a glass of raw milk nor a sack of brewers grain and I'm not going to start today. In my experience, government creates the fears that it then tries to make you feel you need their protection from.

Human beings need to remember that they are human beings, I think, with a mind to make choices and take risk if they see fit. Only cattle get told where to go, what to eat and are guarded from their own stupid choices.