OnTap Magazine

emember the listeriosis outbreak back in 2017? In case you’ve forgotten, this was the nationwide outbreak of Listeria monocytogenes that caused food poisoning from contaminated processed meats and lead to the untimely deaths of just over 200 people. At the time, some people joked on social media that the contamination had also been picked up at one of the big brewing companies. As brewers we all knew this was untrue because beer has intrinsic antimicrobial properties (presence of alcohol, CO2 and hops, low pH levels and an absence of oxygen) that protect against the growth of pathogens. Pathogens are microorganisms that cause diseases to humans such as E. coli, salmonella, clostridium and listeria. The only microorganisms that have been proven to survive and grow in beer are those known as “spoilage bacteria” such as lactobacillus, pediococcus and acetobacter). These microorganisms only spoil the beer, making it unpalatable but fortunately they do not kill or harm anyone. So, does that mean breweries do not have to concern themselves with compliance to food safety regulations? "Food safety" means the assurance that food will not cause harm to the consumer when it is prepared or eaten according to its intended use. Unfortunately, many breweries in South Africa believe that food safety is something that is only a concern for those who wish to get listed by a national retailer, or those that export. What many don’t understand is that basic plant hygiene, personal hygiene and good manufacturing practices are mandatory for all facilities that manufacture food products. The beer we make, whether in a small country brewpub or in a big factory, is made for human consumption. It is therefore our duty as brewers to ensure that these brews are produced in a manner that conforms to all food safety requirements. ADHERING TO THE ACT The National Department of Health requires that all foodstuffs should be safe for human consumption under the Foodstuffs, Cosmetics and Disinfectant Act (Act 54 of 1972). According to the FCD Act, “foodstuff” is any substance ordinarily eaten or drunk by a person or purporting to be suitable for human consumption. Based on this definition, beer is also classified as “foodstuff” and falls under the FCD Act and all the applicable regulations. There are many regulations within the Act, and it is important that those who own and run breweries familiarise themselves and comply with all applicable regulations irrespective of business size or turnover. Let’s unpack regulation R638 of the FCD Act, which governs the general hygiene requirements for food premises and the transport of food among other things. This regulation came into law in June 2019, meaning all breweries needed to re-apply for accreditation. The basis of the R638 regulations is good manufacturing practices, which ensure that food isn’t contaminated or spoiled during the manufacturing process. Here are some of the key points, relevant to brewers: CERTIFICATE OF ACCEPTABILITY This is a certificate issued to premises that are compliant with the R638 regulation. According to the regulation, no person may handle food within premises that have not been certified by the relevant local municipality. Application forms are available from your local municipality. I have to be honest, compared to liquor license application and excise tax application, applying for the certificate of acceptability is a walk in the park (once you start communicating with the relevant person within the municipality and you complete the right form that is…) Once your application has been submitted, the municipality will send out an inspector to audit your premises. If there are any gaps identified, they will issue a checklist and indicate a timeframe to ensure everything is up to scratch. Assuming the inspectors are happy with everything, they will recommend your facility for certification. A senior inspector will also come through for final inspection before giving the certificate. Key things to note about your certificate of acceptability • Like the liquor license, the R638 certification is linked to the premises inspected. Should you make any changes to your premises, you will need to submit a written request to the authority informing them of the changes and then expect another visit from the inspectors. • The certificate is not transferable from one person to another person or from one food premises to another. If one sells the brewery, the new owner will need to re-apply. • The certificate is only valid for what you applied for – if you indicated you would be manufacturing beer and later start making gin, you would need to apply for an updated certificate. • The certificate must be displayed where it is visible to the public. • The regulation also warrants that any delivery vehicle used to transport ingredients or finished products also needs to be issued with a certificate of acceptability against the R638 regulation. PREMISES According to the regulation, thepremises must be equipped and maintained in the condition for which they are intended. In the case of a brewery, this means that tanks must be made from the correct grade stainless steel that can handle routine CIP regimes. Pipework should be designed to avoid sharp bends and rather have smooth bends that are easy to clean and don’t allow for biofilm build up. All interior surfaces such as walls, ceilings, roofs and floors, must not have open joints or open seams and must be made of smooth, rust-free, non-toxic, cleanable and non-absorbent material that is dust-proof and water-resistant. The brewery should be effectively ventilated to facilitate adequate fresh air, especially with regard to steam produced during mashing and wort boiling, or CO2 produced during fermentation. The ventilation can either be achieved by natural means (windows or skylights) or by adequate artificial ventilation compliant to relevant building regulations. The brewery should also have adequate lighting. This can be through minimising obstruction of windows that would ordinarily admit daylight or of course through artificial illumination. The regulation requires illumination strength of at least 200 lux. Consult an accredited company to correctly measure your lux reading. When choosing the lights and bulbs, care should be taken to ensure the light fixtures could not introduce glass contamination into the product. This can be achieved by putting in covers on the glass lights so even if they were to break during production, the glass pieces would not end up in the final product thus creating a physical hazard that could harm the consumer. What is not allowed within the premises • No person should be allowed ontapmag.co.za | Autumn 2020 | 35