FDA and spend grain

There is more to it but:

"
Would there be any exemptions?

Yes, as proposed, very small businesses, which could include local and craft brewers, would be exempt from the written food safety plan requirement. FDA sought comment on three possible definitions of very small businesses, ranging from having less than $500,000 of total annual sales of animal food to less than $2.5 million of total annual sales of animal food. Because the exemption is based on sales, companies that donate a byproduct rather than sell it likely would qualify for the very small business exemption."

http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm394991.htm?source=govdelivery&utm_medium=email&utm_source=govdelivery

So if they take a bad rule based upon inaccurate and incomplete science and say they are going to inflict it upon only those that have a minimum income level based upon sales, does that make it a good rule?  I think not.

Looks like the FDA is NOT going to require more than they do today:

http://blogs.fda.gov/fdavoice/index.php/2014/04/getting-it-right-on-spent-grains

Yeah, last I heard they had backed down, at least for now. It was always a solution looking for a problem. As was mentioned on the NPR article I heard on way to brewery the other day, farmers and brewers have had this symbiotic relationship for 100s of years. And if the FDA pushed through with this they were going to put a whole lot of viable businesses out of business and raise the price on beer and beef to boot.