Health Department Problems

[PMR]

Hi all--

I'm going through Health Department approval for a production brewery, and they are using the general standards of a "Food Processing Plant". Two of their comments struck me as being unusual to require of a brewery:

1. They want the 10 x 10 and 12 x 10 doors either closed up or somehow separated from the brewing area. Most production breweries I've been to leave these doors open most of the time, but Orange County doesn't have too many production breweries, so they may not understand why it's different from a typical food processing plant. I need to keep the access to receive grain / bottle deliveries. My thought is to write them about how a brewery works, in that it is a closed system for the most part, and when it isn't completely closed, there are boiling liquids and positive pressure involved.

2. They want all floors of the "food production area" to be of a surface which is cleanable and can withstand chemical cleaners. They are treating my 4,800 s.f. warehouse like the entire thing is the food production area, where my curbed, designated brewing area makes up only 800 s.f. Of course the 800 s.f. brewing area will be covered with troweled epoxy, but the rest will be just used for storage, so I don't see the need to epoxy the whole thing (especially at $3-$8/s.f.). How do I convince them that the epoxy isn't necessary?

I was also thinking of taking pictures of some local production breweries (unfortunately only two in my county, one of which is more of a brewpub) to show them how the floors in the storage areas are finished (typically concrete), how the brewing areas are seperated from the storage areas (curbed, or just sloped floors), and how large bay doors are open most of the time during business hours without any separation from the brewing areas. Do you think this would be helpful, or just piss them off? Any other suggestions? Thanks!

[edm1077]

I am going through a very similar thing right now and I am looking forward to seeing other responses. The one thing that popped in my head to which I felt I can comment is regarding the floors. Did they specifically say the floors have to have epoxy? You might want to check and see if it follows code to just have the remaining concrete area sealed. This is something you would probably want to consider anyways and if this is all they want then that should eliminate that problem. The head of the health department here said that would work, but I know things vary from state to state or city to city.

Some of the things that hacked me off, was being told that I have to have some sort of wash down/wipe down ceiling in the production area (meaning my rafter type ceiling is not good enough) and that all of the walls in the entire facility have to be "sheet rock smooth" (meaning it doesn't have to be sheet rock but it has to be smooth enough to be wiped down with a cloth everywhere including storage areas!). I am in a similar situation in the sense that there have not been any other production breweries in my city/county, so I think a lot of people are just making up an answer to my questions and sticking with them whether they are right or not!

Good luck and if anyone out there has any creative ideas to my two problems I would love to hear them too.

Thanks-
Eric

[PMR]

Thanks Eric for the response. You're right about the sealed concrete-- that will work. For some reason I thought "sealed concrete" meant epoxy or some type of expensive floor covering.

The health department is requiring me to use semi-gloss paint in the entire warehouse. I was going to paint anyway, so not a big deal. As for the ceilings, they haven't brought that up yet. I'm hoping my foil insulative ceilings are considered a washable surface!

Good luck!

[northstarbrew]

I think I commented on your zoning question and again wasnt trying to make you nervous...

Anyhow, on the health department... Our County health department came in and the ONLY THINGS THEY INSPECTED:

1. Did we have a 3 basin sink in our tasting room for washing glasses
2. Was the water above 120 when each basin was filled
3. Did we have a hand wash sink/towel/soap dispenser near the taps, so we can wash our hands prior to serving
4. Did the bathroom have a toilet, sink, soap dispenser and towels.

We are a microbrewery not a brewpub (no restaurant). Just a 3,200 square foot steel building with concrete floors.

The County health department had absolutely no interest in the brewery, besides "wow, this is cool".

We have a neighbor in the industrial park that is a USDA licensed food producer. He has a "ready to eat" meat plant. In other words, he produces deli meats, sausages, etc., he processes and cooks everything on site then packages and sells through distribution... When we were building the brewery he gave me a tip... He told the County health department that they had absolutely no jurisdication in the meat plant because they are federally regulated/licensed by the USDA.

When I told the health department that we are regulated by TTB and ABC (Trade and Tax Bureau & Alcohol Beverage Control) it seemed like they had no interest in the brewery at all.

I mean really, prior to knock out the beer should almost never touch the atmosphere, nor touch anything that is not sanitised because it is not going to taste so good.

It is so interesting how from city to city, county to county, state to state, things can be so different.

Good luck and I hopy everything works out with no problems!!!!
Shawn
North Star Craft Brewery

[Beersmith]

PMR,

When we first opened our brewery, the local health dept. expressed some very similar concerns. If they are licensing you as a food manufacturer, then those are the standards they want to apply, regardless of your process. It didn't really help me to tell them how other breweries do it.

Their issue with your doors being open is understandable from a health dept. viewpoint - they are concerned about insects and rodents. In order to get our local agency to sign off, we had to agree to a "schedule" when our freight doors were open to receive freight and we weren't supposed to do any food processing while they were open.

They do generally want all surfaces in a food processing area to be smooth and cleanable. Any area of your warehouse being used for processing should be clearly marked on your site plan, and any other "non-food" storage areas the same. You should only have to seal the floor in the processing area. From our experience, you can seal the floor with just about anything to pass the inspection - they just don't want to see bare, pitted concrete in a processing area. They did grumble about our beam/foil insulation ceiling, but eventually let it go after showing them the enclosed nature of the process.

It will definitely help to be friendly with the inspector, explain the process to them, emphasizing your sanitation program and the non-perishable nature of beer (as compared to other more sickness causing prone foodstuffs). Don't be afraid to ask their advice on something (especially something that you know you can "fix" easily). It will score huge points with the inspector.

Sanitarians tend to be stricter with a start-up operation. Once your facility is licensed, they normally only inspect the routine. Also, our health dept only inspects us annually, as opposed to every 6 months for perishable food processors (restaurants, etc.).

I believe no matter how perfect your facility is, they will always find an issue - just make sure your issues are easily correctable and are not non-compliance items. Once they get to know your operation and see that you do things right, their scrutiny of your operation will greatly diminish. They see enough really ugly food service operations every day to make a brewery look pretty damn sanitary.

Our local sanitarian became so comfortable with our operation that they asked us to host an informational tour for the state association of sanitarians so they could better understand the differences between a brewery and other food processors.

Sorry for the wordy post, I hope it helps.

[PMR]

Thanks BeerSmith and Northstarbrew!

I'll try the 'schedule' approach for opening and closing the ground loading doors, and see how that flies (no pun intended). I'll also just show them how other production breweries in the area are doing their business, and perhaps a few technical articles on beer and spoilage (no pathogens, spoiled beer won't sell to we'll dispose of it, except the beers I'm spoiling intentionally with wild yeast/lacto/pedio).

[PMR]

Here's an update-- I sent the health department plan checker a letter about why I didn't think it was necessary to enclose the brewery from the cargo doors. I think I made good arguments (enclosed process, non potentially hazardous product, every other production brewery in the region doesn't have this, pictures of other breweries and the lack of a enclosure), and it didn't fly. I'll be meeting with the plan checker this week, and we'll try to figure out something that will work for the both of us. I'll try for the 'schedule' first, as it's definitely the easiest way to go about it. If that doesn't work, perhaps a vinyl slatted entrance over the cargo doors (sort of like a cold box would have)?

Anyway, any further advice would be great. Thanks!