EC 691 January 1996

HACCPAND

MICROBREWERIES

PRACTICAL GUIDELINES OF FOOD SAFETY FOR

MICROBREWERIES , BREWPUBS AND THE

BEER INDUSTRY

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TABLE OF CONTENTS

I. Purpose of this publication .............................................................................................. 3

II. Introduction .................................................................................................................... 3

III. Beer Safety and HACCP .............................................................................................. 4

IV. The Basics of HACCP.................................................................................................. 4

V. HACCP Terminology and Definitions .......................................................................... 5

VI. Steps to Develop a HACCP Plan ................................................................................. 5

a) Apply Principle 1................................................................................................ 6b) Apply Principle 2 ............................................................................................... 6c) Apply Principle 3................................................................................................ 7d) Apply Principle 4 ............................................................................................... 7e) Apply Principle 5................................................................................................ 7f) Apply Principle 6 ................................................................................................ 7g) Apply Principle 7 ............................................................................................... 7

VII. HACCP and SOPs....................................................................................................... 8

Figures and Tables

Table 1. Explanation of a Typical Critical Control Point in Microbreweries ........ 9Figure 1. General Flow Diagram of a Brewing Process ....................................... 10Figure 2. CCP Decision Tree................................................................................ 11Appendix .............................................................................................................. 12

Prepared by Felix H. Barron, Ph.D.Extension Food Scientist and Assistant Professor of Food Science

Special thanks go to Paul Sadoski for his contributions to this publication.

The Clemson University Cooperative Extension Serviceoffers its programs to people of all ages, regardless of race, color, sex, religion, national origin, or disability and is an equal opportunity employer.

Clemson University Cooperating with U.S. Department of Agriculture, South Carolina Counties. Issued in Furtherance of Cooperative Extension Work inAgriculture and Home Economics, Acts of May 8 and June 30, 1914

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I. PURPOSE OF THIS PUBLICATION

The purpose of this publication is to assistmicrobrewers, inspectors and interested persons inunderstanding the food safety aspects related to themicrobrewing process to make beer. A major issuerelated to any food or beverage is the control ofpotential hazards to reduce the risks of food-borneillnesses in consumers. The Hazard AnalysisCritical Control Points (HACCP) approach isapplied for the analysis of potential hazards duringthe microbrewing process. Many food safetyaspects remain to be presented and understood.This publication may be considered as the basis tobuild future knowledge in the food safety aspect ofthe increasingly growing industry of brew pubs andmicrobreweries.

II. INTRODUCTION

Beer is considered a safe beverage; however, itsdegree of safety may be comparable to many otherfood products. Many hazardous situations mayarise during the production of beer. It is uncommonto hear about a beer contaminated with a pathogensuch as E. Coli, or the presence of glass fragmentsin bottled beer, or contaminating mycotoxins in afreshly brewed beer. Although unusual, thesehazards may occur and the processor should beready to prevent these situations.

Beer is a fermented beverage made in several stepsfrom cereal grains such as malted barley. Other

grains such as corn and rice are being used to aid inthe final texture and flavor of the product. Theprimary ingredients in making beer are: maltedbarley, water, hops, and yeast. Water generallyconstitutes more than 90% of the finished product.The final alcohol content may vary from 0.5% to15% and the pH is typically 4.5 or less. These twofactors, along with the low nutritional value, makebeer a fairly safe product without considering thetoxicity of alcohol consumption and abuse.

Each ingredient has its own function. Barleyprovides the starch which is converted to maltoseand other sugars, and finally to alcohol and carbondioxide. Color, flavor and body are other importantfunctions of barley and are dependent on its roast-ing method. Different degrees of roasting result in arange of colored beers from very light to very dark.

• Hops are flowers used as such orprocessed to obtain an extract to pro-vide flavor, aroma and preservativeeffects to beer.

• Yeast are microscopic fungi used toconvert sugars into alcohol and carbondioxide.

• Minor ingredients may include herbs,spices, fruit, adjuncts and additives.

• Adjuncts are unmalted grain such ascorn or rice added to enhance the flavorand body of beers.

• Additives are chemicals that may beadded to enhance the quality of beers,such as clarifiers, sulfur dioxide andsalts.

HACCPAND

MICROBREWERIES

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IV. THE BASICS OF HACCP

HACCP can be considered as a management tool. Itis a simple but specialized method designed toprevent health hazards resulting from the consump-tion of contaminated food and beverages.

Health hazards may originate at any point in aproduction process, including receipt of raw materi-als, food handling, storage, packaging and transpor-tation. The knowledge of the product formula andthe details of the process are basic tools necessaryto begin to apply the HACCP method.

A beer producer must also know certain factsincluding:

• The primary microorganisms and theirsources that may cause food-borneillness.

• The influence of temperature on micro-organisms (referred as pathogens fromnow on).

• Other types of contaminants fromchemical or physical sources.

HACCP simplifies the hazard analysis by focusingon 3 types of contaminants: microbiological (patho-gens), chemical (such as pesticides or antibiotics),and physical (such as metal fragments).

Once the details of a process are known, a flowdiagram is necessary. This initiates an analysis todetermine the critical areas presenting hazardoussituations that need to be controlled. The HACCPapproach applies the following seven principles atevery step in the selected process:

Principle 1: Assess the potential hazards (micro-biological, chemical, or physical) atevery step in the beer making process.

The major steps in producing beer include: malting,roasting, milling, mashing, boiling, fermenting,maturing, and keging or bottling.1

These steps, presented in a flow diagram, have tobe analyzed to effectively apply the HACCPmethod to control food safety. It is in the publicinterest that beer producers, especially at brewingpubs and microbreweries, develop and implementHACCP plans to ensure the safety of beer. This isparticularly true in brew pubs and microbrewerieswhere beer is not commonly pasteurized.

A brew pub has been described as an establishmentwhich brews and sells beer for consumption on thepremises such as in a restaurant.2 A microbreweryhas been identified as a brewery producing no morethan 15,000 barrels of beer annually. It is alsocritically important that federal, state, and localinspectors perform a HACCP-based auditing incooperation with the beer producer. This will helpto verify the safety of the process and the finishedproduct before it is consumed. Beer can be con-taminated with pathogenic microorganisms, chemi-cals, or physical particulates that are hazardous tothe health of consumers.

III. BEER SAFETY AND HACCP

The safety of any food and beverage, includingbeer can be managed and controlled by the HACCPconcept. This concept is already being used acrossthe food industry, especially in large food compa-nies where it may be a part of their quality manage-ment program. HACCP is not difficult to adopt forsmall processors which includes the microbrewingindustry. It is very important to remember thatHACCP is an analytical approach to food safety,focusing on critical points or areas of a food pro-cess which may present a hazardous situation inneed of control.

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5. HACCP system: The result of implemen-tation of a HACCP plan.

6. Hazard: Any biological, chemical, orphysical contaminant in the food that maycause an unacceptable health risk to theconsumer.

7. Monitoring: A planned sequence ofobservations or measurements of criticallimits to generate accurate records and tomaintain food safety.

8. Verification: Methods, procedures, andtests used to determine if the HACCPsystem is in compliance with the HACCPplan.

VI. STEPS TO DEVELOP A HACCP PLAN

The following are essential steps recommended tobuild a HACCP plan from scratch:

1. Select the product and the process to beanalyzed.

2. Describe the product.

This part is important for two main reasons. Thefirst is to obtain a general idea about potentialhazards that one has to be aware to be consideredfor the hazard analysis. The second reason is fordocumentation purposes. A well-described productwill convey the right information to interestedcustomers about the safety of the product.

3. Write a flow diagram as indicated in Figure 1.

This is a flow diagram representing a food processin a block format. Important information such asprocessing times and temperatures, storage tem-peratures, and critical direct handling operationsshould be indicated on either side of the blocks.

Principle 2: Determine the critical control points(CCPs) necessary to control thehazards. The definition of a CCP willbe provided later in this publication.

Principle 3: Establish the critical limits (CLs) foreach CCP.

Principle 4: Establish procedures to monitor eachCCP and their critical limits.

Principle 5: Establish corrective actions that needto be taken any time a deviation fromcritical limits occurs.

Principle 6: Establish an effective record keepingsystem to document the HACCP plan.

Principle 7: Establish procedures to verify that theHACCP system is working effec-tively.

V. HACCP TERMINOLOGYAND DEFINITIONS

1. Critical control point: Any point orprocedure in a food process where loss ofcontrol may result in an unacceptablehealth risk.

2. Critical limit: Prescribed tolerancesestablished to control potential or actualhazards identified in a critical controlpoint.

3. HACCP: Hazard Analysis CriticalControl Points

4. HACCP plan: The written documentdescribing the procedures to control foodsafety to be followed based on theHACCP principles.

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Every step should be identified with the name ofthe unit operation such as pasteurization, cooling,cooking, freezing. These names should be usedthroughout the whole HACCP plan and HACCPsystem for proper reference.

4. Validate the flow diagram.

This means to actually confirm that every step inthe diagram is accurately representing the desiredprocess. A walk through the facility and visualexamination of every step in the process is essentialto validate the diagram. The seven principles ofHACCP can be applied more effectively when theflow diagram has been validated.

5. Application of the Seven Principles of HACCP.

An example of a HACCP plan is shown in Table 1,representing a model HACCP plan for one step in abeer making process. Notice that the heading inevery column accommodates each one of the sevenHACCP principles. You will need to work on eachcolumn one at a time until completing the wholechart or HACCP plan as follows:

a) Apply Principle 1 at every step in the process.

To do this, you will need the flow diagram toperform the hazard analysis at every step in theprocess that has been identified. You begin withlisting ALL potential hazards (microbiological,chemical, and physical) for every step. This is bestdone with a HACCP team formed by a group ofpeople within the company coming from represen-tative areas such as quality control, production,sanitation, maintenance, management, distribution,etc.

At this point, ALL potential hazards should belisted, regardless of how important they may be.The next thing to do is to select those potential

hazards that the team considers significant. Thesewill be subjected to further analysis to determinehow critical they might be in the HACCP plan tobecome CCPs. The remaining hazards should bekept as records and part of the HACCP plan.

You also need to indicate any preventive measuresalready implemented to prevent the occurrence ofthe hazard.

At this point, use Form 1 in the Appendix to list theidentified hazards with the corresponding process-ing steps and preventive measures.

b) Apply Principle 2.

You need to determine what steps in the process arecritical control points (CCP). This means that allsignificant potential hazards have to be controlledat some point in the process. You can determinewhich point is a CCP as follows:

• By using the preventive measuresalready implemented to preventhazardous situations.

• Common sense.• Your own experience and knowledge.• The assistance of the CCP Decision

Tree (Figure 2).• The definition of a CCP.

One important thing to remember is that it is essen-tial to exercise control over a point to be consideredas a CCP. If you cannot control a point or step, youcan not call it a CCP.

At this point, use Form 1 in the Appendix to iden-tify the CCPs by number in the first column, underthe processing step. In column 4, describe thecontrol parameter such as temperature, concentra-tion of a chemical, size of a screen, time, etc.

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c) Apply Principle 3.

For each CCP that has been identified, you need toestablish its critical limits (CL) also. The purposeof CLs is to provide allowed tolerances to effec-tively control the identified hazards. These limitsshould be flexible enough to insure food safety,taking into consideration factors such as equipmentvariability and other commercial limitations.

Examples of CLs are: temperature, pH, wateractivity, relative humidity, concentration of preser-vatives, etc. It is important to remember that theselimits have to be respected at all times and thateffective records are to be generated as evidence forauditing and compliance purposes.

At this point, use Form 2 in the appendix to recordyour critical limits in the second column.

d) Apply Principle 4.

Establish monitoring procedures at this time.Chemical and physical monitoring is preferred tomicrobiological monitoring due to rapidity inobtaining results. At this point, microbiologicalmonitoring is very much limited for monitoringpurposes. However, microbiological testing can beused for verification procedures.

All monitoring procedures are to be recorded andsigned. Examples of monitoring include tempera-ture done with thermometers, time with clocks,water activity with hygrometers, pH with pH-meters, etc. The frequency of monitoring is deter-mined by experience, laws and regulations, andcommon sense to control food safety. “As often asnecessary” should be the rule.

At this point, continue to use Form 2 to recordmonitoring procedures in the third column.

e) Apply Principle 5.

The purpose of establishing corrective actions forevery deviation of critical limits is to eliminate theactual or potential hazard created by each deviation.Each action must be written. Demonstrate that theCCP has been brought under control. Some actionsmay be as drastic as stopping the process if neces-sary, or placing the product on hold for furtherinvestigation.

At this point, continue to use Form 2 to writecorrective actions in the fifth column. Also, youmay want to include the name of the person respon-sible for the monitoring.

f) Apply Principle 6.

Developing an effective record keeping system isessential for the implementation of HACCP in anyfood processing facility, including beer making.Examples of record keeping are: the HACCP planitself; forms to show monitoring and correctiveactions activities; documents indicating chemicaland microbiological reports; time-temperature logs;and charts, etc. Record maintenance is fundamentalto a HACCP system and it would be critical toregulators, who may have the right to ask for copiesof any records related to HACCP. Also dependingon laws and regulations, HACCP records may haveto be kept on site for at least one year, and for 2additional years on site or at another known loca-tion.

At this point, use Form 3 in the Appendix to indi-cate ways for record keeping in the second column.

g) Apply Principle 7.

Verification procedures are an important part of theHACCP plan to verify that the HACCP system iseffectively working and fulfilling its purpose incontrolling food safety. Verification may includeseveral activities such as microbiological, chemical,

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and physical testing, usually performed on a spo-radic or distanced time basis. Auditing and inspec-tion activities every 3 or 6 months, reviewing of allHACCP related records, sampling of finishedproducts, etc. are also verification procedures.

At this point, continue to use Form 3 in the Appen-dix to write verification procedures in the thirdcolumn. You may want to use the fourth column toidentify the number of the SOP (Standard Operat-ing Procedures) related to the control of the corre-sponding CCP in this row of the chart.

By applying all seven principles at every step, yourHACCP plan should be ready for implementation.3

Even if your plan is not perfect at this time, it isrecommended that you use it in this form and tomodify the plan as necessary while implementingit.

A HACCP plan should include the names of per-sons responsible for any HACCP-related activitiessuch as monitoring and taking corrective actions asnecessary. Also the development and use of stan-dard operating procedures (SOPs) to take totalcontrol of every CCP is strongly recommended.

VII. HACCP AND SOPs

Proper sanitation procedures are important in theproduction of safe food and beverages. Pathogenscan grow and reach contamination levels in a foodprocessing facility because of improper sanitation,poor handling procedures, and inadequate equip-ment.

Standard operating procedures are detailed proce-dures indicating step by step how to do a job.These procedures should be written in such a wayas to assist in the training of new employees sothey know what is expected of them. Standardoperating procedures can be written to perform anyjob, including sanitation and HACCP related jobs.In the first case they are called sanitation SOPs andin the latter HACCP SOPs.

The purpose of sanitation and HACCP SOPs is toprevent direct contamination of food productsbefore and during operations. Written SOPs areevidence reflecting the commitment by an estab-lishment to control food safety and the consumer’shealth.

Examples of activities that can be written in SOPformat are: cleaning procedures and tests to verifytheir efficacy; hand washing sanitation and disin-fection of equipment prior to start up; calibration ofthermometers; and preparation of preservativesolutions, etc.

1 M. J. Lewis and T. W. Young. 1995. Brewing. Chapman and Hall, London, UK.

2 S. Johnson, 1994. On Tap New England, The beer connoisseur’s guide to brewpubs, restaurant breweries,craft breweries, cottage breweries, and brewery inns. WBR Publications, Clemson, South Carolina.

3 F. H. Barron, 1994. Food Safety and Hazard Analysis and Critical Control Points (HACCP). PracticalGuidelines for Food Processors. Extension Circular 685. Food Science Department, Clemson University,Clemson, South Carolina.

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TABLE 1 - EXPLANATION OF A TYPICAL CRITICAL CONTROL POINT

PersonCritical Corrective

Less orequal to 50ppm

Weight ofsulfurdioxide perbatch

Preparationoperator

Dilute batchto correctconcentration

Labeler Rejectunlabelledcontainers

Check alllabels fordeclaration

All labelsdeclaringsulfur dioxide

Process

Conditioning

Potential Description

Concentrationof sulfurdioxide

Labelsindicatingpresence ofsulfur dioxide

Records

Batchrecords foramount used

Batchproductionof allcontainers

Verification

• Review records• Collect 3 samplesper year for externaltesting• Collect 3 samplesevery 6 months forin house testing

• Collect 25containers/weekPersons responsiblefor doing themonitoring

Undeclaredfood allergen

Chemical

This is a step inthe process wherea CCP exists,based on ananalysis includingthe use of theCCP decisiontree.

These are the limitsestablished to control allhazards. Laws andRegulations, as well asprevious experience maydictate these limits.

NOTE: Standard operating procedures (SOPs) need to be written to indicate how tomonitor CCPs, how to take corrective actions and how to do verifications.SOPs should be written in a very simple and clear way. Without SOPs itwould be difficult to implement HACCP plans.

These may besporadic ordistanced activitiesto verify thatpotential hazardsare kept undercontrol. Notice thatverification isnot monitoring.

Actual andrealistic actionto be taken tocorrect adeviation fromcritical limits.

These are theidentifiedpotentialhazards.

Personsresponsiblefor doing themonitoring.

Specific records for eachpotential hazard in a CCP.Records may be legal evidence.

This is the description of thehazard itself or a factor relatedto the control of the hazard.

Monitoring

These are instructions on what to do and howoften monitoring of CCPs occurs. It could bebatch or continuous monitoring.

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Figure 1. General Flow Diagram of a Brewing Process

Bottling

Fermenting

Boiling

Milled grain

Mashing Cereal AdjunctsLiquor(hot water)

Hops

Yeast Flavors, spices

FiltrationProcess aids(sulfur dioxide)

DistributionConditioning(refrigeration)

KegingConsumption

Consumption

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Figure 2. CCP Decision Tree (apply at each step of the process with an identified hazard)

Q 1. Do preventive measures exist for the identified hazard?

No

Is control at this step necessary for safety?

No Yes

Yes No Not a CCP Stop

Stop* No

CriticalcontrolpointNot a CCPYes

* Proceed to next step in the described process.

Federal Register, Vol. 60, No.23

Q 2. Does this eliminate or reduce the likely occurence of a hazard to an acceptable level?

Q 3. Could contamination with identified hazard(s) occur in excess of acceptable level(s)

or could these increase to unacceptable level(s)?

Q 4. Will a subsequent step eliminate identified hazard(s) or reduce the likely

occurrence to an acceptable level?

Yes

No Not a CCP

Yes

Modify step, process, or product.

Stop

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Appendix

Form 1

Identification of Hazards, Preventive Measures and Critical Control Points

Product _________________________ Plant _______________________ Date __________________

Processing Step/ CCPNumber

PotentialHazard

PreventiveMeasure

Critical ControlPoint Description

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Form 2

Critical Limits, Monitoring Procedures, and Corrective Actions

Product ___________________________ Plant _____________________ Date __________________

Processing Step/CCP Number

CriticalLimit

Monitoring PersonResponsible

CorrectiveAction

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Form 3

Record Keeping and Verification

Product _________________________ Plant ______________________ Date __________________

Records/Measurement VerificationProcessing Step/CCP Number

SOP Number