We recently learned that some breweries may be using non-food grade polyvinyl chloride (PVC) piping in grain conveyance equipment, sometimes in conjunction with augers to move the grain. Using non-food grade PVC does not comply with FDA regulations, and we urge member breweries to examine their PVC piping and, if necessary, act to bring their brewery into compliance with FDA regulations.

FDA regulates food-contact materials as “indirect food additives.” The relevant FDA regulations do not regulate PVC as a finished product. Instead, they regulate chemical substances and polymer formulations that may safely contact food. In the case of PVC, this means the resin formulation complies with applicable 21 CFR Part 177 provisions, the extractables/leachables are at acceptable levels, and the material does not adulterate the product and consists of substances authorized for food-contact use.

Key points:

• A brewer must be able to show that material used is suitable for food contact under normal use in accordance with FDA regulations.
• In the case of PVC, the designation NSF 51 denotes that the piping’s material formulation complies with applicable FDA food-contact requirements.
• Other options for grain conveyance include stainless steel, other food-grade plastics, and mild steel fully sealed with FDA-approved coatings. When in doubt, the supplier of brewery equipment should be able to provide documentation that its equipment meets FDA requirements for use in food production.

One misconception worth addressing: because brewing kills pathogens — sometimes called a “kill step” — some brewers assume FDA requirements don’t apply to surfaces that contact ingredients before brewing. They do. FDA food safety requirements are designed to control hazards beyond pathogens, and apply to any materials that come into contact with brewing ingredients at the brewery, including prior to the brew itself.

The following resources can help breweries understand and meet their food safety obligations:

Good Manufacturing Practices for Craft Brewers: These easy to understand and execute standards allow companies to operate confident that their facility is acting in good faith to satisfy requirements from any regulatory body that may come and inspect the facility.

Food Safety Planning for Craft Brewers: Familiarize yourself with the requirements of the Food Safety Modernization Act (FSMA) and learn practical guidance on implementing FSMA requirements.

Food Safety Plan for Craft Brewers: provides guidance for craft breweries to design and implement a food safety program.

Here’s How Traditional Brewing Processes Keep Beer Safe To Drink: Every brewer should leverage these five things to keep beer safe from food-borne pathogens, and you’re probably already doing them.

21 CFR 117.3 Definitions: Food-contact surfaces are those surfaces that contact human food and those surfaces from which drainage, or other transfer, onto the food or onto surfaces that contact the food ordinarily occurs during the normal course of operations.

21 CFR 117.40 Equipment and Utensils: Equipment and utensils must be designed, constructed, and used appropriately to avoid the adulteration of food with lubricants, fuel, metal fragments, contaminated water, or any other contaminants. “All plant equipment and utensils shall be so designed and of such material and workmanship as to be adequately cleanable and shall be properly maintained …” and “shall not adulterate food.”

21 CFR 177.1980 Vinyl chloride-propylene copolymers