The Food Safety Modernization Act is changing how ethanol producers do business, and it’s shifting focus on just being fuel producers that incidentally make a feed coproduct, to being fuel—and food—producers. “Feed is food,” said Matt Gibson, ICM Inc.’s vice president of feed.

Gibson, who spoke at the Fuel Ethanol Workshop & Expo in Indianapolis, directed anyone in the audience who wishes to learn more about the FSMA to search Public Law 111-353, a regulation that contains 41 sections and four titles, two of which are critically important to the ethanol industry.

The main points of the new regulation are to improve the capacity of ethanol producers to prevent problems, and to detect and respond to problems.

“It’s not just about recalls or inspections,” Gibson said. It’s about a prevention mandate, and those who are noncompliant will be held accountable, he added.

Gibson joked that since more than four agencies, including the Food and Drug Administration, the USDA and the U.S. EPA, are involved, he’s confident that implementation of the act will be “very smoothly and efficiently run.”

Ethanol producers must register under the act beginning in 2012, and every other year thereafter. Gibson said having a Hazard Analysis and Critical Control Point plan “is a big part of this,” and it needs to be implemented by July 4, 2012.

The FDA “shall assess and collect” for re-inspections, he emphasized. The frequency of facility inspections are based on risk, higher or lower, and Gibson noted that feed producers like ethanol plants are considered lower risk, but cooperation with the FDA is paramount.

“There is whistleblower protection clearly in the law,” he added.

“What does all this mean for me?” he asked. “In my opinion, you and me, and everybody, must be proactive. There’s a big liability associated with this. Compliance must become SOP (standard operating procedure).” He advised to be on the lookout for new rules, and cautioned ethanol producers that all inputs must be feed grade or better. “Assistance is available,” he concluded.

Tara Vigil, a chemical process engineer with Katzen International, who spoke on the same panel as Gibson, also uttered those same words: “Feed is food.” She said “too many chemicals in your plant can destroy your coproduct,” and rallied the audience of ethanol producers to “make a better feed that ultimately ends up on your table.” Vigil’s presentation covered how plant design and operations can ultimately affect quality of distillers grains produced.

“Coproducts make the margin,” she said, meaning a plant’s profitability—or lack thereof—is often determined by the distillers grains sales.

Vigil highlighted the often discussed drawbacks of distillers grains: inconsistency in moisture, fiber, grain size, fat content, sulfur and more. “There’s room for improvement,” she said. “The standard deviation is very great, and it can land on either side of the average, making a huge range.”

What is done upstream affects what results downstream. “You get out what put in,” she said, “or better yet, you don’t get out what you don’t put in.” She also reminded the audience that, just like feedstock, chemicals and yeast, “operations is another input.”

She detailed how design of an ethanol plant’s milling, piping, equipment, automation, cooling, dryer designs and DDG handling all have profound effects on distillers grains quality.

Milling is important as it determines particle distribution in the plant and the size of material in DDGS, so a plant needs the right hammers, screens and so forth to optimize particle size.

The right piping can minimize chemical inputs, reduce or eliminate sulfur and minimize caustic consumption. “No dead legs,” she said, meaning a plant shouldn’t have any areas in its configuration of piping where mash sits and doesn’t move, for that only leads to a place where bacteria and sugar concentrate, which have to be mitigated with chemicals. This can all be avoided, or at least greatly minimized, with no dead legs.

Also, Vigil pointed out that something as simple as pipe welds can have a big impact on bacteria growth. “Smooth welds give no place for bacteria to grow,” as opposed to jagged welds with pockets for bacteria infiltration.

She said heat exchangers should be designed with biology in mind so they can be easily drained.

Higher temperature cooking can help kill bacteria that would otherwise get recycled through the backset, and if the bacteria is minimized or eliminated through high-temperature cooking, so too is the need for antibiotics.

Automation can greatly increase a plant’s consistency.

Plants also must consider dryer capacity, and a plant may require spare capacity in order to run consistently on a day-to-day basis. “Size matters,” she said, referring to dryer capacity. Dryers become bottlenecks, so when the drying temperature is raised” to push more product through, this adversely affects lysine levels, dropping the presence of the critical amino acid. It also increases VOC emissions.

Another point to think about, Vigil told the audience, is that improper cooling leads to product bridging.

Backset is good because it decreases the amount of fresh water needed to make ethanol, but it increases viscosity and enzyme usage, and it increases the potential for contamination as well as produces more nonfermentable solids circling around the plant.

“We harp on no shortcuts in sanitation,” she said.

Regarding operations, Vigil cautioned managers to maintain consistent operator schedules. “The importance of shift uniformity is key, especially if the plant is not automated.”

Finally, Vigil noted that the very most important thing to monitor in an ethanol plant is fermentation.