EC 691 January 1996

HACCP
AND
MICROBREWERIES

PRACTICAL GUIDELINES OF FOOD SAFETY FOR

MICROBREWERIES, BREWPUBS AND THE
BEER INDUSTRY
 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 ................................................................................................ 6

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

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

Figures and Tables

Table 1. Explanation of a Typical Critical Control Point in Microbreweries ........ 9

Figure 1. General Flow Diagram of a Brewing Process ....................................... 10
Figure 2. CCP Decision Tree ................................................................................ 11
Appendix .............................................................................................................. 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 Service

offers 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 in
Agriculture and Home Economics, Acts of May 8 and June 30, 1914

2
 HACCP
AND
MICROBREWERIES
I. PURPOSE OF THIS PUBLICATION grains such as corn and rice are being used to aid in
the final texture and flavor of the product. The
The purpose of this publication is to assist primary ingredients in making beer are: malted
microbrewers, inspectors and interested persons in barley, water, hops, and yeast. Water generally
understanding the food safety aspects related to the constitutes more than 90% of the finished product.
microbrewing process to make beer. A major issue The final alcohol content may vary from 0.5% to
related to any food or beverage is the control of 15% and the pH is typically 4.5 or less. These two
potential hazards to reduce the risks of food-borne factors, along with the low nutritional value, make
illnesses in consumers. The Hazard Analysis beer a fairly safe product without considering the
Critical Control Points (HACCP) approach is toxicity of alcohol consumption and abuse.
applied for the analysis of potential hazards during
the microbrewing process. Many food safety Each ingredient has its own function. Barley
aspects remain to be presented and understood. provides the starch which is converted to maltose
This publication may be considered as the basis to and other sugars, and finally to alcohol and carbon
build future knowledge in the food safety aspect of dioxide. Color, flavor and body are other important
the increasingly growing industry of brew pubs and functions of barley and are dependent on its roast-
microbreweries. ing method. Different degrees of roasting result in a
range of colored beers from very light to very dark.

II. INTRODUCTION • Hops are flowers used as such or

processed to obtain an extract to pro-
Beer is considered a safe beverage; however, its vide flavor, aroma and preservative
degree of safety may be comparable to many other effects to beer.
food products. Many hazardous situations may • Yeast are microscopic fungi used to
arise during the production of beer. It is uncommon convert sugars into alcohol and carbon
to hear about a beer contaminated with a pathogen dioxide.
such as E. Coli, or the presence of glass fragments • Minor ingredients may include herbs,
in bottled beer, or contaminating mycotoxins in a spices, fruit, adjuncts and additives.
freshly brewed beer. Although unusual, these • Adjuncts are unmalted grain such as
hazards may occur and the processor should be corn or rice added to enhance the flavor
ready to prevent these situations. and body of beers.
• Additives are chemicals that may be
Beer is a fermented beverage made in several steps added to enhance the quality of beers,
from cereal grains such as malted barley. Other such as clarifiers, sulfur dioxide and
salts.
3
The major steps in producing beer include: malting, IV. THE BASICS OF HACCP
roasting, milling, mashing, boiling, fermenting,
maturing, and keging or bottling.1 HACCP can be considered as a management tool. It
is a simple but specialized method designed to
These steps, presented in a flow diagram, have to prevent health hazards resulting from the consump-
be analyzed to effectively apply the HACCP tion of contaminated food and beverages.
method to control food safety. It is in the public
interest that beer producers, especially at brewing Health hazards may originate at any point in a
pubs and microbreweries, develop and implement production process, including receipt of raw materi-
HACCP plans to ensure the safety of beer. This is als, food handling, storage, packaging and transpor-
particularly true in brew pubs and microbreweries tation. The knowledge of the product formula and
where beer is not commonly pasteurized. the details of the process are basic tools necessary
to begin to apply the HACCP method.
A brew pub has been described as an establishment
which brews and sells beer for consumption on the A beer producer must also know certain facts
premises such as in a restaurant.2 A microbrewery including:
has been identified as a brewery producing no more
than 15,000 barrels of beer annually. It is also
critically important that federal, state, and local • The primary microorganisms and their
inspectors perform a HACCP-based auditing in sources that may cause food-borne
cooperation with the beer producer. This will help illness.
to verify the safety of the process and the finished • The influence of temperature on micro-
product before it is consumed. Beer can be con- organisms (referred as pathogens from
taminated with pathogenic microorganisms, chemi- now on).
cals, or physical particulates that are hazardous to • Other types of contaminants from
the health of consumers. chemical or physical sources.

III. BEER SAFETY AND HACCP

HACCP simplifies the hazard analysis by focusing
The safety of any food and beverage, including on 3 types of contaminants: microbiological (patho-
beer can be managed and controlled by the HACCP gens), chemical (such as pesticides or antibiotics),
concept. This concept is already being used across and physical (such as metal fragments).
the food industry, especially in large food compa-
nies where it may be a part of their quality manage- Once the details of a process are known, a flow
ment program. HACCP is not difficult to adopt for diagram is necessary. This initiates an analysis to
small processors which includes the microbrewing determine the critical areas presenting hazardous
industry. It is very important to remember that situations that need to be controlled. The HACCP
HACCP is an analytical approach to food safety, approach applies the following seven principles at
focusing on critical points or areas of a food pro- every step in the selected process:
cess which may present a hazardous situation in
need of control. Principle 1: Assess the potential hazards (micro-
biological, chemical, or physical) at
every step in the beer making process.

4
Principle 2: Determine the critical control points 5. HACCP system: The result of implemen-
(CCPs) necessary to control the tation of a HACCP plan.
hazards. The definition of a CCP will
be provided later in this publication. 6. Hazard: Any biological, chemical, or
physical contaminant in the food that may
Principle 3: Establish the critical limits (CLs) for cause an unacceptable health risk to the
each CCP. consumer.

Principle 4: Establish procedures to monitor each 7. Monitoring: A planned sequence of

CCP and their critical limits. observations or measurements of critical
limits to generate accurate records and to
Principle 5: Establish corrective actions that need maintain food safety.
to be taken any time a deviation from
critical limits occurs. 8. Verification: Methods, procedures, and
tests used to determine if the HACCP
Principle 6: Establish an effective record keeping system is in compliance with the HACCP
system to document the HACCP plan. plan.

Principle 7: Establish procedures to verify that the

HACCP system is working effec- VI. STEPS TO DEVELOP
tively. A HACCP PLAN

The following are essential steps recommended to

V. HACCP TERMINOLOGY build a HACCP plan from scratch:
AND DEFINITIONS
1. Select the product and the process to be
1. Critical control point: Any point or analyzed.
procedure in a food process where loss of
control may result in an unacceptable 2. Describe the product.
health risk.
This part is important for two main reasons. The
2. Critical limit: Prescribed tolerances first is to obtain a general idea about potential
established to control potential or actual hazards that one has to be aware to be considered
hazards identified in a critical control for the hazard analysis. The second reason is for
point. documentation purposes. A well-described product
will convey the right information to interested
3. HACCP: Hazard Analysis Critical customers about the safety of the product.
Control Points
3. Write a flow diagram as indicated in Figure 1.
4. HACCP plan: The written document
describing the procedures to control food This is a flow diagram representing a food process
safety to be followed based on the in a block format. Important information such as
HACCP principles. processing times and temperatures, storage tem-
peratures, and critical direct handling operations
should be indicated on either side of the blocks.
5
Every step should be identified with the name of hazards that the team considers significant. These
the unit operation such as pasteurization, cooling, will be subjected to further analysis to determine
cooking, freezing. These names should be used how critical they might be in the HACCP plan to
throughout the whole HACCP plan and HACCP become CCPs. The remaining hazards should be
system for proper reference. kept as records and part of the HACCP plan.

4. Validate the flow diagram. You also need to indicate any preventive measures
already implemented to prevent the occurrence of
This means to actually confirm that every step in the hazard.
the diagram is accurately representing the desired
process. A walk through the facility and visual At this point, use Form 1 in the Appendix to list the
examination of every step in the process is essential identified hazards with the corresponding process-
to validate the diagram. The seven principles of ing steps and preventive measures.
HACCP can be applied more effectively when the
flow diagram has been validated. b) Apply Principle 2.

5. Application of the Seven Principles of You need to determine what steps in the process are
HACCP. critical control points (CCP). This means that all
significant potential hazards have to be controlled
An example of a HACCP plan is shown in Table 1, at some point in the process. You can determine
representing a model HACCP plan for one step in a which point is a CCP as follows:
beer making process. Notice that the heading in
every column accommodates each one of the seven
HACCP principles. You will need to work on each • By using the preventive measures
column one at a time until completing the whole already implemented to prevent
chart or HACCP plan as follows: hazardous situations.
• Common sense.
a) Apply Principle 1 at every step in the process. • Your own experience and knowledge.
• The assistance of the CCP Decision
To do this, you will need the flow diagram to Tree (Figure 2).
perform the hazard analysis at every step in the • The definition of a CCP.
process that has been identified. You begin with
listing ALL potential hazards (microbiological,
chemical, and physical) for every step. This is best
done with a HACCP team formed by a group of One important thing to remember is that it is essen-
people within the company coming from represen- tial to exercise control over a point to be considered
tative areas such as quality control, production, as a CCP. If you cannot control a point or step, you
sanitation, maintenance, management, distribution, can not call it a CCP.
etc.
At this point, use Form 1 in the Appendix to iden-
At this point, ALL potential hazards should be tify the CCPs by number in the first column, under
listed, regardless of how important they may be. the processing step. In column 4, describe the
The next thing to do is to select those potential control parameter such as temperature, concentra-
tion of a chemical, size of a screen, time, etc.

6
c) Apply Principle 3. e) Apply Principle 5.

For each CCP that has been identified, you need to The purpose of establishing corrective actions for
establish its critical limits (CL) also. The purpose every deviation of critical limits is to eliminate the
of CLs is to provide allowed tolerances to effec- actual or potential hazard created by each deviation.
tively control the identified hazards. These limits Each action must be written. Demonstrate that the
should be flexible enough to insure food safety, CCP has been brought under control. Some actions
taking into consideration factors such as equipment may be as drastic as stopping the process if neces-
variability and other commercial limitations. sary, or placing the product on hold for further
investigation.
Examples of CLs are: temperature, pH, water
activity, relative humidity, concentration of preser- At this point, continue to use Form 2 to write
vatives, etc. It is important to remember that these corrective actions in the fifth column. Also, you
limits have to be respected at all times and that may want to include the name of the person respon-
effective records are to be generated as evidence for sible for the monitoring.
auditing and compliance purposes.
f) Apply Principle 6.
At this point, use Form 2 in the appendix to record
your critical limits in the second column. Developing an effective record keeping system is
essential for the implementation of HACCP in any
d) Apply Principle 4. food processing facility, including beer making.
Examples of record keeping are: the HACCP plan
Establish monitoring procedures at this time. itself; forms to show monitoring and corrective
Chemical and physical monitoring is preferred to actions activities; documents indicating chemical
microbiological monitoring due to rapidity in and microbiological reports; time-temperature logs;
obtaining results. At this point, microbiological and charts, etc. Record maintenance is fundamental
monitoring is very much limited for monitoring to a HACCP system and it would be critical to
purposes. However, microbiological testing can be regulators, who may have the right to ask for copies
used for verification procedures. of any records related to HACCP. Also depending
on laws and regulations, HACCP records may have
All monitoring procedures are to be recorded and to be kept on site for at least one year, and for 2
signed. Examples of monitoring include tempera- additional years on site or at another known loca-
ture done with thermometers, time with clocks, tion.
water activity with hygrometers, pH with pH-
meters, etc. The frequency of monitoring is deter- At this point, use Form 3 in the Appendix to indi-
mined by experience, laws and regulations, and cate ways for record keeping in the second column.
common sense to control food safety. “As often as
necessary” should be the rule. g) Apply Principle 7.

At this point, continue to use Form 2 to record Verification procedures are an important part of the
monitoring procedures in the third column. HACCP plan to verify that the HACCP system is
effectively working and fulfilling its purpose in
controlling food safety. Verification may include
several activities such as microbiological, chemical,

7
and physical testing, usually performed on a spo- VII. HACCP AND SOPs
radic or distanced time basis. Auditing and inspec-
tion activities every 3 or 6 months, reviewing of all Proper sanitation procedures are important in the
HACCP related records, sampling of finished production of safe food and beverages. Pathogens
products, etc. are also verification procedures. can grow and reach contamination levels in a food
processing facility because of improper sanitation,
At this point, continue to use Form 3 in the Appen- poor handling procedures, and inadequate equip-
dix to write verification procedures in the third ment.
column. You may want to use the fourth column to
identify the number of the SOP (Standard Operat- Standard operating procedures are detailed proce-
ing Procedures) related to the control of the corre- dures indicating step by step how to do a job.
sponding CCP in this row of the chart. These procedures should be written in such a way
as to assist in the training of new employees so
By applying all seven principles at every step, your they know what is expected of them. Standard
HACCP plan should be ready for implementation.3 operating procedures can be written to perform any
Even if your plan is not perfect at this time, it is job, including sanitation and HACCP related jobs.
recommended that you use it in this form and to In the first case they are called sanitation SOPs and
modify the plan as necessary while implementing in the latter HACCP SOPs.
it.
The purpose of sanitation and HACCP SOPs is to
A HACCP plan should include the names of per- prevent direct contamination of food products
sons responsible for any HACCP-related activities before and during operations. Written SOPs are
such as monitoring and taking corrective actions as evidence reflecting the commitment by an estab-
necessary. Also the development and use of stan- lishment to control food safety and the consumer’s
dard operating procedures (SOPs) to take total health.
control of every CCP is strongly recommended.
Examples of activities that can be written in SOP
format are: cleaning procedures and tests to verify
their efficacy; hand washing sanitation and disin-
fection of equipment prior to start up; calibration of
thermometers; and preparation of preservative
solutions, 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). Practical
Guidelines for Food Processors. Extension Circular 685. Food Science Department, Clemson University,
Clemson, South Carolina.

8
 TABLE 1 - EXPLANATION OF A TYPICAL CRITICAL CONTROL POINT

This is the description of the These are instructions on what to do and how Specific records for each
hazard itself or a factor related often monitoring of CCPs occurs. It could be potential hazard in a CCP.
to the control of the hazard. batch or continuous monitoring. Records may be legal evidence.

Process Potential Description Critical Monitoring Person Corrective Records Verification

Conditioning Chemical Concentration Less or Weight of Preparation Dilute batch Batch • Review records
of sulfur equal to 50 sulfur operator to correct records for • Collect 3 samples
dioxide ppm dioxide per concentration amount used per year for external
batch testing
• Collect 3 samples
every 6 months for
in house testing

Undeclared Labels All labels Check all Labeler Reject Batch • Collect 25
food allergen indicating declaring labels for unlabelled production containers/week
presence of sulfur dioxide declaration containers of all Persons responsible
9

sulfur dioxide containers for doing the

monitoring

These are the Persons

identified These are the limits responsible
potential established to control all for doing the
hazards. hazards. Laws and monitoring.
Actual and
Regulations, as well as These may be
This is a step in realistic action
previous experience may sporadic or
the process where to be taken to
dictate these limits. distanced activities
a CCP exists, correct a
to verify that
based on an deviation from
potential hazards
analysis including critical limits.
are kept under
the use of the control. Notice that
CCP decision NOTE: Standard operating procedures (SOPs) need to be written to indicate how to verification is
tree. monitor CCPs, how to take corrective actions and how to do verifications. not monitoring.
SOPs should be written in a very simple and clear way. Without SOPs it
would be difficult to implement HACCP plans.
Figure 1. General Flow Diagram of a Brewing Process

Milled grain

Liquor
Mashing Cereal Adjuncts
(hot water)

Hops Boiling

Yeast Fermenting Flavors, spices

Process aids
Filtration (sulfur dioxide)

Consumption Keging Conditioning Bottling Distribution

(refrigeration)

Consumption

10
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?

Modify step, process, or product.

Yes No

Is control at this step necessary for safety? Yes

No Not a CCP Stop

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

No Yes

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

or could these increase to unacceptable level(s)?

Yes No Not a CCP Stop

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

occurrence to an acceptable level?
Critical
control
Yes Not a CCP Stop* No point

* Proceed to next step in the described process.

Federal Register, Vol. 60, No.23

11
 Appendix

Form 1

Identification of Hazards, Preventive Measures and Critical Control Points

Product _________________________ Plant _______________________ Date __________________

Processing Step/ CCP Potential Preventive Critical Control

Number Hazard Measure Point Description

12
Form 2

Critical Limits, Monitoring Procedures, and Corrective Actions

Product ___________________________ Plant _____________________ Date __________________

Processing Step/ Critical Monitoring Person Corrective

CCP Number Limit Responsible Action

13
Form 3

Record Keeping and Verification

Product _________________________ Plant ______________________ Date __________________

Processing Step/ Records/Measurement Verification SOP Number

CCP Number

14