Canadian SFCR Craft Brewery Compliance

SFCR requires manufacturers of alcoholic beverages, those containing 0.5% or more alcohol by volume, to have a traceability system in place by July 15, 2020. A quick search on Google using logical search words will show that the CFIA has these regulations and they are available on their website.

The SFCR document is very technical. We’re talking about a government document designed to drive processes and procedures that protect the health of humans, so it is very comprehensive. Keep reading this article and we’ll summarize in layman's terms what you need to know.

You should care about these new regulations if you:

• Produce beer, wine, spirits, kombucha, cider, mead, or ready-to-drink cocktails
• Trade inter provincially
• Import or export your product outside of Canada
• Sell your product at the retail level through a taproom, off-sales or delivery.

Ask yourself – what do you and your teams know about traceability, and are you compliant with the new regulations? How can you achieve this without disrupting your business, or adding significant cost and complexity in an increasingly competitive market environment? Also, is traceability only the responsibility of the producer?

What are the roles of ingredient suppliers and distribution partners in ensuring that the food chain is safe? This article won’t provide all of the answers, but hopefully can be a catalyst for discussion.

Let’s get started by defining traceability. Essentially, it means tracking the origin of your ingredients and the destination of your finished goods, as well as your in-house manufacturing steps.

Brew Ninja makes this process seamless and provides you with reports so that you can meet the SFCR requirements. With our BeerXML recipe import, Square POS integrations and capacity to track inventory across multiple facilities, this seemingly daunting task becomes relatively straightforward.

Larger breweries with automated control processes and enterprise resource planning systems can easily monitor the inventory process from start to finish, and get analytics with a few simple clicks.

In a brewery, when ingredients arrive, they are entered into a database and the lot numbers of each item is recorded. As batches of beer are produced, they are assigned batch numbers that stay with them throughout the process.

A programmable logic controller (PLC) processes the transaction and shares it with a database or, as is increasingly the case, directly with an enterprise resource planning application that manages other information such as locations and lot numbers. A work order may move through the facility following those ingredients.

We don’t need to belabour the point but you can see how this carries on through packaging, finished goods, order fulfillment, and shipping. Of course, mobility technology such as smartphones and tablets provide instant access and visibility to this data. Having access to all this technology is definitely an advantage when it comes to compliance.

It is possible that a smaller brewery with manual processes, limited information technology, and a small part-time staff could still be compliant like their larger automated competitor – but they will need to have solid procedures, a discipline for data collection and accurate record-keeping, and a commitment to quality above all else.

If you don’t have a bar code scanner to receive your ingredients, you will likely find the lot numbers on your recent invoices from your suppliers. These values must be recorded by an employee at time of receipt. Some brewing systems can automatically log these values and validate that they match what was purchased.

Accurate record-keeping and a commitment to quality are important for manual processes, such as packaging, finished goods, order fulfillment and shipping. But there are inherent pitfalls to manual processes.

Data entry errors are common and while they can be relatively easy to correct, spotting them can be difficult and extremely time-consuming.

The reality is that if you are a brewery in Canada and you are operating using spreadsheets - you need to make an upgrade - NOW. Tracking lots, managing spreadsheets, employee access and performing data entry would entail a full time job that has plenty of room for error.

What systems are available to make your life easier?

You guessed it - Brew Ninja makes meeting Canadian SFCR regulations quite easy.

If your team is using our system, the data necessary to meet regulations will already be available and you can simply run a report at any time.

Brew Ninja’s cloud based software can be available on any computer, tablet or smartphone. You and your employees will contribute data to the process during your regular work days and when you need to complete reporting requirements - simply run the report.

If an inspector should come calling and ask to see the brewery’s records, the conversation should be straightforward and compliance should be easy to prove.

What would happen if a government inspector entered your facility unannounced today, and asked to see your traceability records? How easy would it be to comply with that request?

Take it a step further. What would happen if you were forced to do recall right now?

What would happen if you receive a phone call because of yeast contamination in one brand of beer you produced? If a yeast contamination issue contaminated a month of production how easy would it be for you to identify and quarantine all the products from that lot? How easy would it be to identify the lot numbers for the ingredients used? How confident are you be that you could contain the risk to the public and your brand? Have you ever done a mock recall to test your existing systems?

If not, try it sometime and you’ll likely see how vulnerable you are. It might be a little uncomfortable, but it will do you good in the long run.

Our goal in writing this article isn’t to scare you, but to shine a light on the complexities of operating a brewery in Canada and how to address regulations.

It IS possible to use manual processes, but prone to errors, and the risk of having a recall isn’t an insignificant matter.

On the other hand, Large Scale ERP systems are incredibly expensive to implement and maintain.

Brew Ninja is an affordable, cloud based brewery management software that allows your whole team to participate in brewery operations. We hope you take the next step to see how our software can benefit your brewery.

Source: https://www.brewersjournal.ca/2019/08/30/beer-traceability-in-canada-are-you-ready

This article was originally published by the Brewer’s Journal Canada, and republished with their permission. Brew Ninja’s inventory system provides a simple easy way to do lot tracking, plus a lot more. Please reach out to ask us how we can help you.