But if you don't have a proper procedure in place, there's nothing stop a container that *did* contain beef byproducts to be reused to carry the grain waste as cow feed.
Too bad the regulation is all about processing the grain before it gets picked up and says nothing about how it's handled once it is picked up. I'm pretty sure no brewer is using beef byproducts in their wort. So let the regulation read that the grain may not come into contact with a container that hauled beef byproducts. BAM, done, because nobody does that anyway. No need to spend millions.
I suppose there's the risk they might unwisely decide to pack it into a cannon and shoot it in the general direction of their ranch too (even though nobody's tried that yet), shall we consult BATF? And the state department, you never know, they might find a way to violate the nuclear arms treaties.
In other words, I'm complaining about this because it has never been a problem AND there is no plausible mechanism where it becomes a problem.
On the other hand, I very much agree that mold should not be growing on 'sterile' equipment meant to package medicine to be injected into the spine. I have a hard time imagining that not to be a problem. The mechanism where it causes a problem is obvious (lo and behold, it is a problem). It's been a regulation for quite a while, they're just too busy dreaming of how to expand their domain to actually enforce the regulations that actually make sense.