HACCP for Craft Breweries: A Complete EU Compliance Guide

Introduction

Many craft breweries face a common issue: inadequate CIP verification records. Without proper documentation on caustic concentration, temperature, and contact time, you're leaving the door open for spoilage organisms that could ruin your product.

What You'll Learn

• How to identify and control unique CCPs for brewing safety.
• Best practices for supplier checks to prevent mycotoxin contamination.
• Staff training protocols that reduce risks in production and packaging.

What Auditors Check First

• CIP Verification Records:
  • Ensure you have documented proof of caustic concentration, temperature, and contact time.
• Grain and Malt Storage Conditions:
  • Check for damp storage areas that increase mycotoxin risks.
• Glass Breakage Policy:
  • Confirm you have a protocol in place for handling glass in the taproom and packaging area.

Hazards Specific to Craft Breweries

Biological Hazards:

• Key organisms include Brettanomyces, Lactobacillus, and Pediococcus, which can spoil beer but are not food safety pathogens.

On a busy Saturday when fermentation temperatures rise due to increased ambient heat, yeast may exceed its tolerance, leading to off-flavours and incomplete attenuation. Maintain fermentation temperatures below the yeast's tolerance level, ideally between 18-22°C.

Monitor fermentation pH; it must drop below 4.5 within 48 hours of pitching yeast. If it doesn't, investigate immediately for stuck fermentation.

Chemical Hazards:

• Mycotoxins, specifically ochratoxin A, can be present in contaminated malt or grain.

When receiving malt on a humid day, if the grain is stored in damp conditions, the risk of ochratoxin A contamination increases significantly. Store grains in a dry environment with moisture levels below 14%.

Request mycotoxin testing certificates from suppliers to verify safety before use.

Physical Hazards:

• Glass breakage and foreign objects (metal, plastic) pose risks in packaging and taproom areas.

During a busy evening service, if a glass bottle breaks on the packaging line, shards can contaminate adjacent containers, leading to safety issues. Implement a glass-in-glass breakage policy that requires immediate cessation of operations in the affected zone.

Conduct regular inspections of glass bottles upon receipt, checking for chips or cracks to prevent potential hazards.

Seasonal Considerations

In summer, fermentation temperature control is critical. Ambient heat can push fermentation temperatures above yeast tolerance, creating off-flavours and incomplete attenuation.

During festival season, temporary bars and cask service increase contamination risks. Ensure clean lines and maintain cellar temperatures between 11-13°C for cask ale to mitigate spoilage risks.

Critical Control Points

• Wort Boiling
  • Measure:
    • Start time, duration (60-90 minutes), and vigorous boil confirmation.
  • Monitor:
    • Use a timer and temperature gauge during each boil batch. Record data in a log after each boil.
  • Corrective Action:
    • If the boil is less than 60 minutes, extend the boil time to meet the requirement and document the adjustment.
• Fermentation pH
  • Measure:
    • pH must drop below 4.5 within 48 hours of pitching yeast.
  • Monitor:
    • Use a calibrated pH meter to check pH levels at 24 hours and 48 hours post-pitching.
  • Corrective Action:
    • If pH is above 4.5 at 48 hours, investigate for stuck fermentation and consider re-pitching yeast or adjusting fermentation conditions.
• CIP Validation
  • Measure:
    • Caustic concentration (2-3% NaOH at 75°C), rinse completeness (pH neutral), and sanitiser contact time (minimum 10 minutes).
  • Monitor:
    • Use test strips for caustic concentration, a thermometer for temperature, and a pH meter for rinsing. Record results after each CIP cycle.
  • Corrective Action:
    • If concentration or temperature is out of specification, re-run the CIP cycle and document the corrective steps taken.
• Dissolved Oxygen
  • Measure:
    • Dissolved oxygen levels must be less than 50ppb post-fermentation.
  • Monitor:
    • Use a dissolved oxygen meter to test levels immediately after fermentation.
  • Corrective Action:
    • If levels exceed 50ppb, investigate sources of oxygen ingress and take corrective measures, such as adjusting transfer methods.

Common Mistakes

• Mistake:
  • No CIP verification records → Fix: Maintain detailed logs of concentration, temperature, and contact time for each CIP cycle.
• Mistake:
  • Grain/malt storage in damp conditions → Fix: Store grains in a dry environment with moisture levels below 14% and use mycotoxin testing certificates from suppliers.
• Mistake:
  • No foreign body protocol for the packaging line → Fix: Implement a clear protocol for inspecting packaging for glass, metal, and plastic contaminants before use.

Supplier management is key to maintaining quality in your craft brewery. Conducting thorough checks upon receiving ingredients helps prevent spoilage and contamination. Each delivery should meet strict criteria to ensure your brewing process remains safe and efficient.

Delivery Acceptance Checklist

• Malt/Grain:
  • Request mycotoxin testing certificates; store in dry conditions (<14% moisture).
• Yeast:
  • Verify viability and purity from the supplier; maintain in-house propagation logs.
• Hops:
  • Check for vacuum-sealed packaging; store cold (<5°C) to prevent oxidation.
• Packaging:
  • Inspect glass bottles for chips/cracks upon receipt; check cans for dents.

When to Reject a Delivery

• Any malt or grain showing signs of dampness or mold.
• Yeast with viability below 80% as verified by your tests.
• Hops that are not vacuum-sealed or have visible signs of oxidation.
• Packaging materials with visible defects that could compromise product safety.

Daily Monitoring Checklist

• Verify wort boiling:
  • log start time, duration (60-90 min), and vigorous boil confirmation.
• Check fermentation pH:
  • ensure it drops below 4.5 within 48 hours of pitching.
• CIP validation:
  • confirm caustic concentration (2-3% NaOH at 75°C) and rinse completeness (pH neutral).
• Measure dissolved oxygen:
  • ensure levels are <50ppb post-fermentation.
• Inspect grain/malt storage conditions:
  • confirm storage is dry (<14% moisture).

What Records Auditors Expect

• CIP verification records:
  • document concentration, temperature, and contact time.
• Fermentation logs:
  • record pH measurements and timestamps for each batch.
• Mycotoxin testing certificates from malt/grain suppliers.
• Glass breakage log:
  • document incidents and corrective actions taken.
• Training records:
  • maintain logs of staff training sessions and topics covered.

Staff Training Requirements

Brewers must be trained on the entire CIP procedure, focusing on verification steps, not just running the cycle. In the packaging team, ensure all members know the glass breakage protocol: stop the line, exclude the zone, and inspect adjacent containers.

Taproom staff require training on the line cleaning schedule, which must occur every 7 days minimum, along with glass hygiene practices to prevent contamination. Regularly review these training sessions to keep staff updated on best practices.

Conclusion

The regulatory landscape for craft breweries in the EU/UK mandates compliance with EC 852/2004 Annex II Ch. II for premises requirements, Annex II Ch. V for equipment validation, and EC 178/2002 Art. 18 for traceability from grain to glass. These regulations ensure that your brewing process maintains high standards, reducing the risk of spoilage organisms and mycotoxins.

By adhering to these requirements, you safeguard both your product and your business reputation.

Quick-Start Action Plan

1. Review your CIP verification records for concentration, temperature, and contact time.
2. Check grain/malt storage conditions and ensure they are dry (<14% moisture).
3. Implement a glass-in-glass breakage policy for your taproom and packaging area.
4. Verify that your fermentation pH drops below 4.5 within 48 hours of pitching.
5. Train your staff on specific procedures for CIP and glass breakage protocols.

Generate your free Craft Breweries HACCP plan at ilovehaccp.com/builder - it takes under 10 minutes and covers all the points in this guide.

For practical implementation, review monitoring-corrective-actions-and-verification-explained and haccp-records-what-to-keep-and-for-how-long before finalizing your HACCP records.