Preparing a due diligence analysis plan for a brewery
By Gordon Jackson - 2 September 2014
A food safety analysis (due diligence) plan provides a risk-based approach to food safety analyses. It ensures that all analyses needed to prove legal compliance / safe products are included and minimises costs by targeting essential analyses. It also ensures regular checks and evidence of compliance to Regulations, industry guidelines and in-house specifications. This gives assurance to stakeholders and provides part of the defence for the company in case things go wrong. We can help you to design a suitable Due Diligence plan.
It is not possible to measure every potential food safety issue in every material or product. It is therefore essential to identify the main risks and where they occur. When preparing a Due Diligence plan it is important to correctly identify the risks and limits - especially for novel ingredients or products. For example the risk of occurrence of the mycotoxin fumonisin is high for maize and wheat, but is low for barley, rice and hops; hence, it is only necessary to check maize and wheat for fumonisin mycotoxins.
Regulatory requirements also need to be borne in mind. There is a limit in the EU for maize but not for malted barley. There is no legal limit for beer, but legally the concentration should not exceed that for maize, taking into account the proportion of maize used in the grist and the dilution factor during the brewing process. Hence maize should be analysed for fumonisins, but it is good practice that beer is also tested when maize is used as an adjunct.
Analyses can be done in-house or by a contract laboratory. To assure the quality of the data, the laboratory should meet the requirements of an external standard such as ISO17025 or ISO9001. The Limits of Detection can be included in the plan to ensure that it is clear what these are. For example, in the methods that we use, the LOD for fumonisins B1 and B2 is 5 µg/ kg of maize or 1 µg/litre of beer.
Correct interpretation of the results is important. Even when results are within limits, a lot of useful information can be gleaned by monitoring trends; this enables early action to be taken if values are increasing or highlights best practice if values are decreasing.
The actions to be taken by staff if the limits are exceeded can be defined in the plan. This could include, for example, repeating the analysis, contacting the supplier and quarantining existing stocks.
The due diligence plan should be reviewed based on the results obtained and also whenever raw materials, additives (or their sources) or product formulations are changed; additional risks may be identified or some risks can be removed from the plan. It should also be reviewed if there are changes in legislation and whenever food safety issues arise; it is therefore important to have systems in place to flag up changes in legislation and to identify emerging issues. Even if there are no obvious changes the plan should be reviewed on a scheduled basis to ensure that it is still valid and up to date
As well as performing the range of beer and ingredient analyses to satisfy due diligence plans, we can advise on the plans themselves, the legislation that needs to be considered, and interpretation of the analytical results. We will be at Europe's biggest trade show for the brewing industry at Brau in Nuremberg on 11-13 November - so come along to Stand 1-333 in Hall 1 to chat to us.