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FOOD SAFETY IN MALTING AND ‘DUE DILIGENCE’

FOOD SAFETY is an area that attracts increasing attention in today’s health conscious world. It is a subject that food manufacturers have to properly address, and the MAGB helps UK maltsters in that task. We collate test results undertaken by individual members, arrange industry-wide sampling and testing regimes, and undertake industry-wide reviews.

DUE DILIGENCE is the approach that any responsible company should follow looking at areas of potential risk, having controls in place to prevent problems occurring and demonstrating their effectiveness. To help demonstrate this members of the MAGB have a collaborative survey organised, that each company contributes samples to and then receives the results from the entire survey. A wider picture of the barley crop can be drawn than by each individual company acting alone. The sample schedule for the survey is agreed following a written risk assessment by an independent expert.

Should analysis of any contaminant be a cause for concern, then the MAGB will promptly initiate investigations, any further sampling and testing and communicate the findings, lessons learnt and corrective actions taken. This is shared amongst all members. In addition, in each crop year the MAGB organises samples of barley and malt made from the same barley, to be drawn for due diligence testing at FERA for a further range of potential contaminants. This survey is collaborative with the National Association of British and Irish Millers (nabim), who provide wheat samples, and with the Agricultural Industries Confederation (AIC), who provide feed grain samples. A more comprehensive profile of the UK cereal crop can be seen from this work funded by AHDB Cereals & Oilseeds as part of the task of checking that food safety controls are operating correctly for each crop year in UK grown cereals.

The most recent published report of this information is the AHDB Food safety review of UK cereals grain for use in malting, milling and animal feed with results for crop year 2019.

An ASSURANCE value is given to Malt produced under such a protocol, because it gives security to companies who use it in their foods and drinks helping protect brands and demonstrate due diligence has been applied in sourcing and manufacture.

The MAGB has assisted in such an approach on a range of substances, some that have been controlled for several years, and some that have only recently had maximum limits set for them. New control limits tend to come into operation as methods of analysis allow ever-smaller amounts of substances to be measured. Care must be taken that limits are only set that reflect a true assessment of risk, not simply the lowest level measurable and the MAGB inputs into the setting of regulatory limits. There can be naturally occurring levels of some substances in food raw materials, which cannot be reduced.

RISK ASSESSMENT. The MAGB has drawn up a Hazard Analysis Critical Control Point Guide which is based on expert assessment of potential food safety risks, and their safe control during the malting process, to ensure food safety requirements are always met for UK malt.

Many food businesses have implemented systematic evaluations of threats and vulnerabilities to protect their businesses from fraudulent practices and malicious attacks. This is something which has been developed following the horse meat scandal in 2013 and it is now an important consideration in the brewing and distilling supply chains. The systems that have been developed are based on PAS 96:2017 ‘Guide to protecting food and drink from deliberate attack’ and are termed TACCP (Threat Analysis and Critical Control Point) and VACCP (Vulnerability Assessment and Critical Control Point). To help malting businesses, MAGB has developed guidance to assist malting companies with implementing these important standards

An example of what today’s testing is capable of, and the ever-lower limits being used is shown below:

Using Gas Chromatography to test for milligrams of substance per kilo of material (mg/kg) is equivalent to one corn of barley in a 50 kilogram sack full of grain

Simpsons
6th February 2019

Using HPLC to test for micrograms of substance per kilo of material (µg/kg) is equivalent to one corn of barley in 50 tonnes of grain

Using immuno-techniques for nanograms of substance per kilo of material (ng/kg) is equivalent to one corn of barley in 50,000 tonnes of grain.

CONTROL OF SUBSTANCES THAT COULD BE FOUND IN MALT
AGROCHEMICALS & PESTICIDES

Pesticides cannot be used on malt, but a very narrow range of pesticides is acceptable by brewers and distillers for use on the growing cereals and the stored grain. Other pesticides are accepted only for use on storage areas. Only pesticides listed on the BBPA Approved Agrochemicals list can be used on barley, and the list shows which pesticides are approved for what purpose, as well as the maximum residual levels of the chemical that can remain in the grain. Campden-BRI has been testing agro-chemicals that might be used by malting barley growers and storers for many years. UK maltsters specify that only products that have been accepted by BBPA/Campden-BRI can be used on grain sold to them.

Every load of grain supplied to UK maltings has to carry its own “pesticide passport” to declare if pesticide has been used on any stage of the grain post harvest, and if it has, what type, the application rate, and when it was applied. No grain is accepted without this declaration.

Spot loads are then tested at intake to the maltsters store, to ensure that the information given on the pesticide passport is correct, and that the maximum residual level of pesticide (if it is found to be present) is not exceeded. MAGB has also had carried out a few spot tests for a very wide range of pesticides, most of which were not approved for use on malting barley in the UK. Excellent results showing nil or very low residual levels of permitted pesticides have been found, and there has been no detection of the use of excluded pesticides.

HEAVY METALS (Lead, Cadmium)

The MAGB has also tested for heavy metals levels in its raw materials for several years. Such substances are only likely to be found in the finished malt if they come in with the raw material, malting barley. The heavy metals tested for have included zinc, copper, lead and cadmium. Lead and cadmium can be found in some soil, and hence could be taken up into the growing barley crop. The MAGB survey work shows that this has not been a problem for UK malting barley, and that there are no problems of heavy metal contamination in malt made in the UK.

NDMA (Nitrosodimethylamine)

Following the discovery in the 1970s of NDMA in beer, MAGB members have implemented a voluntary code to monitor and report on levels in malt, as well as developing best practice to reduce the formation of the compounds during kilning.

NDMA is formed as a result of nitrosylation by NOx gases of amino-acids on the surface of malted grain. Control may be achieved by reduction of NOx levels in drying gases, often by indirect firing or the use of low-NOx burners, or by reducing the pH of the grain surface.

Malts are regularly tested by malting companies for NDMA formation, and the MAGB collates their members’ thousands of test results over the years to demonstrate due diligence action. View below the chart showing a 10-year trend and table showing full results of MAGB NDMA testing carried out on malts made from the 2000 crop barley onwards.

MYCOTOXINS (In particular Ochratoxin A)

Recently attention has turned to the ability of some fungi on food raw materials to produce mycotoxins, which can be toxic to humans if consumed in significant quantities. Harmonised European legislation is being introduced to limit the level of mycotoxins in foods.

There are two types of fungi/mould that can infect cereal crops, one is field fungi on the growing crops in the field, and the other is storage fungi.

Field fungi are easily avoided by the maltsters; they can be visually detected, which leads to an automatic rejection of the grain as not being suitable for malting. Fusarium moulds are common field fungi on growing cereal crops and do little damage to the plants themselves. However, under certain conditions they can also produce a range of toxins.

Storage fungi are less likely be present on grain at intake to maltings, unless the grain has been held for some period under poor stored conditions. Storage mould or fungi can develop if the grain is poorly stored above 14.5% moisture over an extended period of time, particularly if the grain temperature is high. Damp, badly aerated grain is a high-risk area for fungi growth, with the subsequent risk of toxin production. If storage moulds are present in grain at 17.0% moisture or above, then there is a risk that the combination of time, temperature and moisture could be sufficient for the mould to start producing toxins. A limit of 5 parts per billion in barley has been set by the EU legislators for the storage mould toxin, Ochratoxin A.

Storage fungi information

Ochratoxin A is the mycotoxin most likely to be produced by Aspergillus and Penicillium fungi on grain grown in Europe. This is less toxic than Aflatoxin, which may occur on maize, sorghum and other cereals in sub-tropical and tropical parts of the world.

The UK system of taking barley from the harvest field and drying it before storage has always been used to keep grain “sweet” and protect its germinative capacity.  Long-term grain storage in the UK is usually at around 12% moisture content in the grain, as it has been proved by experts at CSL that in order to protect the germ in long term grain storage to 98% capacity and above the grain moisture should not exceed 13%.  These two factors in UK malting operations also prevent the development of any mould, and hence any mycotoxin.  The importance of avoiding long term storage of grain above 14.5% has only recently been signalled, but the MAGB has been testing UK barley for Ochratoxin A since 1994.  As long ago as 1885 Mr H Stopes was urging UK maltsters only to buy barley with its own clean, identifiable odour, and to avoid all other smells on the grain. Excellent practical advice, long before the potential problem of mycotoxins was known!

UK tests results over the years have shown that Mr Stopes’ advice, and UK maltsters’ storage practices have ensured that grain free from mould infection has been used, and that there is no mycotoxin risk from using malt produced in the UK.

Field Fungi information
Although maltsters barley intake procedures should avoid the intake of grain infected with field fungi, the MAGB has tested for the toxins deoxynivalenol (DON), nivalenol (NIV) and zearaleone (ZEA) that can be produced by field fungi, to show maltsters diligence in this matter.  The tests were done on malts to ensure that the finished product met the likely limits that the EU is considering introducing.  Only very small traces of these compounds were detected, well below the EU proposed action levels, and substantially less than has been reported in the growing barley crop.

For more information on due diligence work on mycotoxins Click Here

There will be a continual increase in the knowledge of what makes food safe, and there will be an ever-greater emphasis placed on what makes certain foods more beneficial in the diet than was previously realised.  The MAGB will continue its important task of helping UK maltsters show how diligent they are in meeting food safety requirements.

The AHDB Cereals & Oilseeds Food Safety and Due Diligence work, carried out by crop year, on Malting Barley and UK made Malt is an important part of the industries coverage of Food Safety and Due Diligence. The MAGB and AHDB Cereals & Oilseeds work closely together on issues that are of interest for Food Safety of UK Malt made from UK Malting Barley. For more information on AHDB Cereals & Oilseeds click on the logo below.