From the article, "New registration and record keeping requirements for wineries under FSMA impose important changes. Wineries must now renew their FDA registration every two years.." Wineries must also comply with GMP requirements, including the need to have documented employee training. These firms are exempt from the the risk based preventive controls (Subpart C) and the supply chain program (Subpart G).
Wine kills pathogens and there is no history of food safety issues in wineries. Pathogens are not sustainable in beer also. Forcing food based GMP's (Government Manufacturing Practices)(nothing Good about them pertaining to alcoholic beverages) is ridiculous. Especially anyone looking at their craft holistically with microbial diversity being a goal. This crazy nonsense somehow got skipped in the exemptions in sec 116 in the FSMA. Almost makes the exemptions moot. This is ridiculous unnecessary over regulation.
ReplyDelete