While craft brewers strive to manufacture and ship the highest quality beer, which is in compliance with Alcohol and Tobacco Tax and Trade Bureau (TTB) and state regulations, it is possible for a product to enter the market that is mislabeled or could cause adverse health effects.
Brewers have the responsibility to consumers to protect their health and well-being. This is of utmost importance to Brewers Association (BA) membership. When there is potential for adverse health effects, brewers must take steps to ensure that consumers are kept safe. A voluntary market withdrawal or recall involves removing products from distributor inventories and store shelves and effectively notifying consumers of the risk.
Guidance for Craft Brewers
Good Manufacturing Practices (GMPs), Hazard Analysis and Critical Control Points (HACCP) plans, and food safety plans can be used to ensure quality and food safety during the manufacturing process; however, mistakes can and do occur. When such mistakes occur, it is the brewer’s responsibility to ensure removal of the product from the market before harm is caused to the consumer.
The U.S. Food and Drug Administration (FDA), under the mandate of the Food Safety Modernization Act (FSMA), is responsible for the regulation and food safety standards for most of the U.S. food supply. Recalls are classified according to their potential seriousness. The FDA now has authority to force a recall and shut down operations at breweries or other food-production plants if it deems that there is a significant threat to public health.
As the main regulating body in the beer industry, the TTB also has an interest in voluntary market withdrawals and recalls. Brewers must notify the TTB immediately if a voluntary market withdrawal or recall is imminent, and the FDA should be given a courtesy call. The TTB may also communicate with the FDA about beer recalls and market withdrawals, and either organization may notify the other about a given recall.
Contamination, adulteration and misbranding comprise the major reasons for which a brewer’s products can be recalled.
Some examples of these include:
• Misbranded or mislabeled beer
• Foreign object inclusion such as plastic, glass or metal fragments
• Chemical contamination
• Allergens or other toxins in the beer
• Package over-pressurization
Avoid the Expense and Stigma — Have a Recall Plan
Voluntary market withdrawals and recalls are expensive and can be stigmatizing for the affected brewery. It is in the brewer’s best interest to do everything possible to prevent them through good brewery management practices.
If a situation does arise where a voluntary market withdrawal or recall is warranted, a brewer should act quickly to maintain and regain consumer confidence during these types of events by communicating openly and honestly and working hard to remove product. The best practice to ensure this rapid and efficient recovery of out of specification or potentially harmful products is to have a recall plan in place and to practice the activity regularly.
Some things a brewery can do to make a voluntary market withdrawal of recall less painful:
Follow the Brewers Association’s Date and Lot Coding Best Practice.
• Keep a library of packaged beer and test them for flavor, pressure, pH, etc. after a period of time or over a period of time.
• Put together an internal consumer safety team to identify potential areas that could cause a voluntary market withdrawal or recall scenario.
• Reference the BA’s Food Safety Plan for Craft Brewers and Good Manufacturing Practices for Craft Brewers resources.
• Develop a recall plan and practice the plan with mock recalls.
At a minimum, implement a basic microbiological screening program