Questions for Pat Kennelly & his replies
pH: Are all parts of a winery considered a food processing area (fruit receiving areas, fruit processing areas, fermentation, barrel storage, tank farms, bottled good, public tasting room, analytical lab, business offices, etc)?
PK: No, the offices and analytical lab are not considered processing area, but they also must not contribute any contamination to the processing areas. The tasting room falls more closely under the retail food facilities law, and is not considered a processing area. Any area related to the storage of raw, in process or finished materials and any area where processing, bottling or labeling is occurring is subject to the GMP regulations.
pH; And just for the sake of drama in a presentation...as I plan to use the traditional "winery dog" as an example...what is the ramification of having a dog in processing plant, and what are the degrees of fine or citation or hand-slapping? Would it matter which area the dog was in?
PK: If there is evidence that the dog has contaminated equipment or product, embargoes can be placed on the effected materials. The worst case scenario is a $1,000 fine.
pH: The traditional argument/discussion with wines is the happy circumstance of (at least to date) not being able to harbor any human pathogens. What is the state's attitude towards non-toxic spoilage or other microbiological growths with respect to GMPs or contamination?
PK: Spoiled wines are still adulterated under the law, even though they may not harbor a pathogen. Wines must be protected from contamination, just as any other food.