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  1. 3 points
    Back from the dead, nearly 10 years later.
  2. 2 points
    I assume you are referring to general distillery trade waste, not from the sinks and bathrooms. We operate in a rural area also and initially we had to truck all our trade waste off for external disposal, at great cost. We now treat the waste on-site. No septic, or air assisted bio-cycle system will cope with distillery trade waste for three reasons; The pH is way too low THE BOD is too high (typical of boiled waste) The amount of residual alcohol is often too high in 'small' distilleries (we often dump our stillage at 2% residual alcohol, as its too expensive to strip-out the remainder) We established an on-site treatment system FOR THE TRADE WASTE ONLY (all sink and bathroom effluent is treated in a standard AWT septic system) comprising of three 10kl concrete tanks. The waste is transfered on a batch basis from one to the other, and then finally sprayed out onto rural pastures. The tanks work as follows; Tank 1 takes the raw waste, and holds until we have about 10kl, we then pH adjust to 7.2 with Calcium Carbonate. Residual chlorine is resolved with H2O2. BOD is measured, as well as copper, lead and N2 levels (local EPA requirement). Calcium Carbonate dissolves very slowly so we need to recirculate this tank for about 24 hours Tank 2 has a pump over aeration system that fixes the BOD and dissolved O2 levels, this again takes about 24 hours of circulation. Bentonite is added in the last hour of aeration just before transfer to tank 3. Tank 3 is the settling tank, we settle the sludge for 24 hours, the clear water is then fed by pump to an open field for irrigation. The sludge is drained monthly, and dumped onto open compost mounds. This system has been working flawlessly for 2 years and has proved very cheap to operate.
  3. 1 point
    Hey Mosaic, Distillate tastes great. It is very neutral tasting, and if carbon filtered, tastes like a perfectly fine vodka. I am using 100% grain base. I could probably get a higher proof if I ran an additional distillation, but we don't sell vodka so I have never had the need.
  4. 1 point
    SlickFloss makes some good points. Having just got out of the brewing industry, going back to endless packaging days, and measuring dissolved oxygen levels isn't so appealing. Cleaning the residual flavors of cola, ginger beer, or other sweet syrupy mixers out of your packaging lines is going to be terrible as well.
  5. 1 point
    Something to keep in mind. Cocktails are a moment in time. Acidity, dilution, and oxidation all come together to form the evolving flavor of a cocktail. Packaging a stable form of that is much more difficult than many people would think. Sodas are canned with artificial ingredients because they're cheap but they're also stable in the presence of carbonic and citric acid. For instance: an old fashioned isn't just a whiskey bitters soda, ya know what I mean?
  6. 1 point
    I suppose, since they are one mash when combined. More problematic, what if you had two different beers after fermentation, then combined them. I would want to query a TTB officer on that!
  7. 1 point
    who said what now? see, what actually happened was I fermented some grain wort and said.. hey, I bet I could distill this.. and never did anything else.
  8. 1 point
    If you're using A. absinthium wormwood in a maceration without distilling it, it's going to be too bitter to be considered absinthe. When undistilled, wormwood is so bitter that it will easily overpower the other flavors. I'm curious which US brands you compared it to? That's why I pointed him to the historical section over at the Wormwood Society. We have the full Duplais and De Brevans manuals posted there (but now I see the link is bad, so I'll need to fix that today). Those recipes and processes are essentially definitive of the nature and characteristics of absinthe, along with the many surviving bottles that were made in the pre-ban (pre-1915) era. You can't go wrong using those recipes as a starting point.
  9. 1 point
    You guys are made of money to be using $12 a pound citric or gallons of Heinz 57. Damn, you probably even use the more expensive squeeze bottle versions too. Meanwhile, the rest of us are stuffing our pockets full at Burger King. I phone up my local chemical supply and walk out with a 50 pound bag of FCC/USP Grade Citric Acid for about $60. No sales tax on that either. Mash Acidification - Check Still Copper Rejuvenation - Check Tricking your 5 year daughter to stick her finger in and taste it - Priceless
  10. 1 point
    Variance of fill with a level filler is going to be impacted by the quality of your glass. Glass produced by a discount manufacturer is more likely to have higher variance in fill volumes than that of a higher quality producer. At least that has been my experience. The TTB does have a pretty wide allowable variance in fill volumes, and you need to test and record those tests every bottling. They want to see an approximately equal number of over and under fills. However the quality of a level filler may also affect the consistency of visual fill level. Our rotary monoblock has a 16 head filler, but every bottle is ran through the same leveler after being filled. This minimizes the variance of the visual fill levels, and our glass quality has shown us very consistent fill volumes when the fill levels are the same.
  11. 1 point
    no expert, but from my point of view when bottles look to be filled to the same point nobody will speak up and tip off the TTB to a potential problem That said, I took the TTB chart and filled five bottles by weight for the given proof and they were all within 1mm of each other. So we just fill to the same point for each bottle.
  12. 1 point
    I love the folks that come in and ask what spirits we have that are gluten free. I tell them all our spirits including the whiskey is gluten free; they tell me it cant be because its made from grains; I explain gluten is a protein that cant pass through the distillation process and hence all our products are gluten free; they tell me it cant be because its made from grains. I suggest they read the information from the FDA, Canadian Celiac Association or National Institute of Health that explain why all distilled spirits are gluten free; they tell me it cant be because its made from grains; I tell them the world is round; they tell me it cant be because its made from grains; I tell them to buy the vodka or gin because they are made from corn.
  13. 1 point
    Pardon my skepticism, but I cant help notice that you have no other posts on this forum and that your account was created less than two weeks ago. This leads me to think that your post may not be entirely truthful and that you may be part of the scammers running this site. Feel free to prove me wrong.
  14. 0 points
    How about ... how about we do a 4-day gin workshop in the USA? You come in with ideas, we train you, we make extracts, concentrates and then translate your ideas to an actual recipe? Next step is that we run that recipe, all the students taste it and give feedback ... and we run it again maybe with a few last tweaks to make it gin perfect? You basically walk in with the wish to make a great gin. Four days later you walk out with the actual recipe, herbs bill, and distilling procedure to make that gin in your own craft distillery? Let me know if that would be of interest to you! Sales@iStillmail.com. If this is helping you, we'll organize it! Regards, Odin.
  15. 0 points
    Yes, and thanks to all for that. This post is meant to aggregate peoples' experience and preference for one type of condenser, not to be antagonistic or assert that one is superior. I have personally found that coils are safer, but there are compelling arguments to be made for both styles and I want to hear them. In most of the comments above, the superiority of one style over the other has to do with the traditional materials used; copper vs. stainless. Eliminating that variable we get: Tube in Shell Pros: Compact size Less surface area contact time (also a Con for certain spirit types such as Cognac or Scotch when a longer temp gradient is desirable) Less chance of occlusion or blockage (though, as I mentioned earlier, occlusion of the condenser should never be an issue) Coil Pros: Better control of thermal gradient, especially important when using a reactive material such as copper. Safety. Totally anecdotal, I admit. I haven't seen this topic addressed on these forums before and want to understand all of the subtleties at hand. Thanks again for everyone's input.
  16. 0 points
    Off-time is generally the time after lunch service but before dinner service, it's a pretty narrow window usually, in my parts about 2-3, maybe a little wider. Before lunch service, you generally miss the beverage manager, don't even attempt coming in during service as you'll be ignored, and things are generally pretty busy leading up to dinner service starting, 4-5. You tend to have a little bit more leeway if it's a restaurant that doesn't open for lunch. Weekends are usually always off the table.
  17. 0 points
    Go early in the week and during off times. See if you can set up an appointment with the buyer/beverage manager/etc even if you have personal or professional connections with them. Be prepared to do a tasting at each place and have all of your "ducks in a row". This means drink(pour)- bottle- and case costs, any promotional material (sell sheet) or support you have, qty discounts, and ask when they prefer deliveries and try to be in the window when you do the deliveries. Don't hound them but you should expect to need to keep on them since all the other reps are doing the same for their brands. Take PaulNL's advice - it's right on target. [edit: also, don't forget that you'll still need to do and have all of these things when you sign with a distributor too]
  18. 0 points
    Question, when we do a cook, (lets call it "A") and bring our water to 190 and add our corn to start our cook and then drop temp, yada, yada, yada, finish around 1.060 we get a nice dry grain cap about 2 " thick and you dont see anything going on at all and will finish in 4 days with the cap dropping and end SG usually .998 yield is great. No problems. Been doing it this way for 5 years. Or, (lets call this one "B") we bring our water to 100 and then add our corn and continue raising the temp to 190 cook for the same time the rest of the cook is the same Yada, yada, yada, finish around 1.060 we get a wet creamy, very active bubbling for the 4 days a wet cap will come and go, finishes at .998 pretty much the same yield and flavor. So what i'm in search for info is what is actually happening with the grains during the cook???? cant figure it out. both great flavor, good yield, etc. "B" is a little shorter time. side note we use enzymes and do a sour mash, all added at the same time, temp, quantity between the two its winter here in Maine and l have some time to play around with things and just love learning more.......
  19. 0 points
    By way of an update, for those that are interested, we ended up with a 24-day ferment down to 1.002, which would have been awesome had it not taken so long. We felt we learned some things about nutrient additions and adding more yeast so we tried again with our new found knowledge. We started batch #2 on march 1 and went with roughly the same OG, feeling that the correct nutrient and yeast addition regimen would overcome...we were wrong. We started batch #3 on March 7 at a lower OG of 1.065 and followed the same yeast and nutrient regimen. They are both down to 1.03, but batch #3 has done it in half the time. That being said both have had issues of stalling and we are in the strong belief it has to do with pH. At one point the pH of batch #2 got down to 2.5. We have been working to keep the pH of both around 3.5 and the fermentation is visibly more active and the SG drops about 4 points a day instead of 1-2. So batch 4 is going to be the charm, with an OG around 1.065 and monitoring pH daily. Thanks again for all of your input and i hope our experience is helpful to someone else.
  20. 0 points
    All of the above is true, however many traditionalists will argue, particularly with Cognac, that a tube-in-bath or worm-tub type condenser leads to a slower step down in temperature (top of the bath is hotter than the bottom of the bath) and that the temperature of the distillate coming off the still will affect the flavor of the product. I believe, although am not certain, it is standard practice to watch both the temperature of the finished distillate and the proof, and it is easier to control that temperature with a worm-tub. We have both worm-tubs and a tube-in-shell. We use the worm-tub stills for brandy and mostly make American whiskey on the tube-in-shell, albeit not the only reason we use the stills for those products.
  21. 0 points
    So back to my original question. What, if any, specific and unique benefit does tube-in-jacket have over a coil designed with the same throughput rate? Higher efficiency - Countercurrent tube-in-shell heat exchangers will have a higher overall efficiency than tube-in-bath. Smaller Package - Tube-in-shell will be smaller, have more surface area, more efficient use of space. Safer design - Multiple vapor/liquid paths mean reduced risk of occluding the single-path design of tube-in-bath. Tube-in-bath designs are older, less-advanced designs, where the ability to create more efficient designs was not possible to to the manufacturing complexity involved. Fairly easy to make a crude tube-in-bath condenser with soft copper and any container you might have. Building a baffled tube-in-shell is going to require significant machining/welding. I am of the community that feels that you should not use copper on the downside vapor path, so for me, a copper worm would not represent a good option. The only advantage that a tube-in-bath/worm condenser has is that it can be easily/crudely made.
  22. 0 points
    (I hope this doesn't come off as snarky because I'm not trying to be) 1 Fernet on the rocks isn't a cocktail 2 You cannot can anything on the rocks the ice will melt (so maybe you need to look into how things are canned?) 3 the soda options you listed are possible in some respects, but they'll be bland, people will still need garnishes, and you won't be able to incorporate natural flavorings as easily as you think. You can't just add juice to shit and hope it works in a can for a few months. 4 Canning process requires high temps and pressure for extended periods of time for sanitation. This will cook off, degrade, etc most flavor compounds like juice, natural oils, etc. 5 You would want to engineer in dilution rates etc for your serving, which means selling a concentrated amount at a premium price point (added package, effort, energy engineering etc) or purchasing special sized cans (more money) and doing even more work to make it fit in that package. I've spent 9 years making dreams realities for people at a 1.9 million cs/year custom bottling plant (we have 7 bottling lines). customers bring us their vision and we deliver them goods in package. The number one thing people do is come in with a cocktail saying they want it canned/packaged spouting off the same shit you're saying now-but people forget that we don't live in a world of technicalities limited to their own scope of experience and vision. You "seeing no reason why it wouldn't be stable" when you have no experience trying to do this for a consumer, or for yourself, doesn't mean theres not a reason it won't work. When you say G and T, vodka soda, etc these are simple mixed drinks that could be packaged with alcohol in them for sure. But when someone says can a cocktail, that implies a true cocktail, so a combination of ingredients (usually a base spirit, other spirit/liquid, an acid, and an aromatic garnish/bitter element). An old fashioned is the best example of a cocktail. I am able to can/bottle you liquid that resembles in taste and flavor an old fashioned, but it will not be as simple as putting 2 packets of sugar, some water, 2 ozs rye and 2 dashes angostura in a can. And an even bigger problem is it won't be your exact perfect cocktail. Taste will skew to the limits of manufacturing. [I contract manufacture 2 premade old fashioneds that are super successful in marketplace and ti took us forever to get it dialed in just right]. Try this. Mix 80 proof ethanol and lemon juice in a bottle and let it sit closed for two weeks. Is it the same? No. The acid will degrade and become purely bitter instead of pleasantly tart. Try mixing your perfect manhattan and put it in a mason jar with no air space for five days. Is it the same? No. The bitters leach into the rest of the immiscible fluid and there is no contrast. And depending on your vermouth (we make our own in house) that likely will change as well.
  23. 0 points
    We use two 380l stills, one plated column and one stripping still. Both use immersion elements and we run grain washes & rum without issue.
  24. 0 points
    Can’t we just be helpful, or not respond at all... I recently ‘searched the forum’, and of the recommendations from posters interested in helping others, Kessler had the best pricing. Here are some of of the prices I was quoted in November.
  25. 0 points
    Growlers in the tasting room are not allowed for at least two reasons. 1. The tasting room is not on bonded premises. If it is, TTB erred in approving it (19.52 ). All DSP operations, which include bottling, must take place on bonded premises. So no bottling on other than bonded premises (see definitions of distilled spirits operations and bonded premises in 19.1). 2. You cannot remove spirits in bulk (containers of more than one gallon) from the DSP to anyone not qualified to receive bulk spirits . The proprietor of a tasting room, retail area, is not among those qualified to receive spirits in bulk at any place other than the bonded premises (27 CFR 1.80 and following). Bottling is a processing operation. The bottling line must be on bonded premises when you conduct the bottling operations (19.1 again). You could alternate an adjacent brewery line from brewery to DSP, but it must be adjacent (19.143). You could probably qualify an outside area to DSP premises (you can have outside tanks - 19.74 -, so ...), but I'd want to frame that proposal carefully. Ditto from alternating an outside area that is designated as general premises to use as bonded premises (19.143 again). TTB talks about containers. Containers for sale to consumers can be either approved liquor bottles or cans. 5.11 - "Bottle. Any container, irrespective of the material from which made, used for the sale of distilled spirits at retail." The standards of fill for cans is found in 5.47a(2) For metal containers which have the general shape and design of a can, which have a closure which is an integral part of the container, and which cannot be readily reclosed after opening— 355 milliliters - 200 milliliters 100 milliliters 50 milliliters
  26. 0 points
    Sorry for the years delay in getting these photos up. Here are a few shots of the rickhouse. It was easy to build for professional carpenters. The trick is in the bracing, and in bolting it to the floor and the walls.
  27. 0 points
    Here in Australia it is a whole new line and ours has been going really well. The stores that stock our products, sit them in the Bourbon area. On average per store, they are selling between 10-12 bottles per week, per variety (ie; Apple Pie Moonshine) and a high percentage is repeat customers. I think it can be a new successful spirit category but I was curious on what was happening with the legal shine market in it's homeland.
  28. 0 points
    here in saskatchewan everyone jus calls it home brew , there is a micro distillery here thats cleaning up on it they cant keep it on the shelf . just do a google search of ...great gedos home brew . or try this link https://saskatoon.ctvnews.ca/video?clipId=1114273
  29. 0 points
    Just taking a flyer but I bet if you google "Vancouver still maker" you will get your answer.
  30. 0 points
    I haven't checked the numbers but you say "Hence, a total of 870000 BTU is required to vaporize all 500 liters of this mixture." When distilling alcohol you do not vaporise the whole 500 liters. If you did you would end up with the same ABV that you started with. You only need to boil off about 1/5 of the volume. By then there is no alcohol left in the pot Maybe you have not explained properly but you appear to be starting with a 40% ABV in the pot. I would assume there are no solids in that so you could go direct fire and save all the work building a steam boiler. BUT 40% in the pot is pretty high and could be dangerous with direct fire even with bain marie jacket. Cut back to below 30 % to make a little safer. That might not be what you are trying to achieve so please explain in more detail I suggest you spend some time at a small distillery before you go any further.
  31. 0 points
    I would recommend Paul (SouthernHIghlander) highly. I also would recommend Cassell systems, Headframe Spirits Manufacturing if you got the gumption for it, and if you wanna go international get a Frilli.
  32. 0 points
    I have never thought about that. I don't know why they put the PS identifier into the mix. I can't see that it is going to affect class and type. First, part 5 does not contain the word "steamed" nor "soaked." It makes no exception of the sort, "which has been stored in new charred oak that was not steamed or water soaked prior to use." You can't bury such an important requirement in an obscure section addressing cooperage identification, and that is the only place the issue appears in either part 5 or part 19. Second, the "PS" designation is stated in addition to one of the other required identifiers, not in lieu of, so the record would still show the CH or R designations necessary to establish, for example, whether a whiskey otherwise made in accordance with the standards of bourbon, 51% or more corn, etc, should be designated, based on the type of cooperate in which it was stored, as "bourbon" or as "whiskey distilled from bourbon mash." The container does not lose its CH designation because it was soaked. Therefore, I've got to believe it would be new charred for purposes of part 5 standards of identity and aging requirements. While TTB, or some predecessor agency, must have had some reason for requiring the PS designation, figuring that out would be a research project for which I do not have the time. Since it would require a research project, I conclude it is not something that has ever been an issue. Since it has never been an issue, I think it comes under things listed beneath the heading, don't kick a sleeping dog.
  33. 0 points
    Shhh>! Don't openly advertise that you are distilling prior to getting TTB's permission.
  34. 0 points
    Hello Thatch, my 2c: although in a completely different country (NL) I face the exact same issue over here. Am allowed to sell to bars, restaurants and liquor stores. The two main things I've learned in the last year are: - a. only go after companies that sell drinks in your price bracket (in my case 55 USD a bottle average retail price; so that's Michelin starred restaurants and specialty liquor stores) and - b. try to find some "ambassadors" who can introduce you (in my case several well-known chefs and a sommelier who worked at ** starred restaurants) Once you meet people immediately become friends with them on LinkedIn and FaceBook so once people look you up they see you know many of their colleagues. One more thing: try to find out what the typical markup is, so ask someone you know in a liquor store or a bar/restaurant (different) for the formula they use to go from purchase price to sales price for a bottle or a glass. Paul.
  35. 0 points
    Would imagine a better approach is a direct fire bain marie for stripping, and eliminating all the headache and complexity (and failure) of a wood fired steam boiler. Use immersion elements on the spirit still for simplicity.
  36. 0 points
    I was looking at trying to run a boiler system on wood pellets and found some manufacturers in China selling small scale high efficiency boimass powered low pressure steam boilers, I think it was on Alibaba or similar website. https://www.canadianbiomassmagazine.ca/images/stories/2011/mayjune11/biomassboilerbuyersguidelr.pdf has some boiler systems that run on a variety of fuels. You will have to try and find one that does not need electricity to operate or maybe provide power from generator to the boiler unit to power controls. Most of these systems are almost power plant size, make some calls they could maybe help you find smaller systems to power 132 gal still.
  37. 0 points
    Today I learned how I should be filling my CIP system with ketchup instead of citric. What brand do you recomend for a 300 gallon hybrid still? PBW and citric are quite different cleaners. For starters one has a pH of about 2 and the other has a pH of about 12. You can't clean a still with just acid and you cant get copper shiny with PBW.
  38. 0 points
    we have a 3" tri-clamp fitting on our mash tun so we used a valve to stop the steam. we were using a butterfly valve but switched it out today for a big stainless ball valve because it kept clogging. we open the valve right before the grain starts to fall and close it once done.
  39. 0 points
    We noticed that our sweet mash unaged corn whiskey (Water Tower White Lightning™) sold in the southern part of Illinois, but got little traction in northern Illinois. So, there definitely seems to be a north-south divide culturally. But I do consider our product, a true corn whiskey, different from some moonshines, like my great grandpa made, because they were distilled to higher proof, above 160, too high to be considered whiskey. And others, like Popcorn Sutton, might add sugar to the corn, again no longer considered a whiskey.
  40. 0 points
    HottyToddy We have sanitary spools in many different sizes and all of the other parts that you need for making your carbon filters, including the screen gaskets. We have one of the deepest sanitary parts catalogs in the US. Our quality is excellent and our prices are much better than glacier tanks. https://shop.distillery-equipment.com/collections/pipe-tubing-spools/Tri-Clamp-Spools We have double diaphram ethonal pumps for pulling ethonal through filters. We also have vacuum pumps and traps if you want to use vacuum to pull the ethonal through the filter. Pooring it through can take forever. We do not have the vacuum pumps and traps on our site. You would need to call 417-778-6100
  41. 0 points
    Very valuable insight. Thank you Beach Time!
  42. 0 points
    A Neuroscientist and you aren't working on a more cerebral spirit (har har)? Lots of focus on terpenes as psychoactives these days, along with other potential (non-proven) "health benefits". Alpha-pinene or eucalyptus (1,8-cineole)as AChE inhibitors, Limonene as an anti-depressant, Linalool as a sedative, Myrcene as an analgesic. All fairly common terpenes found in typical gin botanicals.
  43. 0 points
    Actually we have had some great luck running water in our Baine Maries lately. At first we thought oil was far better and that is what our testing showed. however when we did the testing the still jacket was full of water. We did some recent testing starting out with the jacket only 40% full of water. This worked a great deal better than our first testing with water and the heat up to operating temp time was only a little longer than oil and the run time was pretty much the same as oil. We are running more testing next week with water. So here is why we are getting better results with the jacket 40% full of water. Even though the jacket is open, there is steam in the upper part of the jacket. We start out with steam in 60% of the jacket and by the time that we were done 80% of the jacket was full of steam. So you are probably asking, how the hell could 215 F steam heat a vessel almost as fast as 300 F oil. Its because the oil has a terrible heat transfer coefficient and steam has one of the best heat transfer coefficients, Much better that water and glycol. With 400 liters you should run 22,000 to 27,500 watts of power. Also water is much safer than oil because it is not flammable like some of the oils. Also water is not nearly as messy and it is much easier to keep water from leaking around your immersion heater connections. Oil leaks where water would never leak because oil has a great deal less surface tension than water. Also you might consider pulling a little vacuum. With just a little vacuum in the still you can get the boiling point of ethanol down to 140F and then water is a much more viable heating solution with no need for steam. The problem with a vacuum system is, how do you do the cuts from a closed system? We have solved that problem but it is proprietary, however if you email me privately I will tell you how it can be done. We will start taking orders for our new vacuum stills next week. They are truly amazing and really safe. I think that they are going to change the face of the beverage distilling industry. Also for our bigger vacuum stills, instead of a $30,000.00 steam boiler, all that you need is a $3,000.00 water heater or a $5,000.00 hydronic boiler. That's right, you will be able to fire these vacuum stills with a wood fired hydronic hot water boiler. Also we are getting higher proofs with less column with these vacuum stills. You other equipment vendors better look out, because your world is about to change.
  44. 0 points
    Whoa - I misread this the first time. I bet you mean the proof and fill check you make at the time of bottling. I'll talk about that here. I wish I could do it in a few short words. I can't. The law says TTB must make regulations that make sure consumers are not misled as to the quantity of the product in the bottle. For spirits, the quantity is the volume, but it is also the proof. So TTB requires that you tell consumer how much and how strong. Because TTB is not making tests to determine if you are doing that, they require that you keep records to prove that you are. It sounds good in theory. It sounds professional. But it is not. Your records will not provide assurance of compliance. Let’s look at why I say that. The regulations provide for a record of the proof and the fill of bottles. You find the record requirement in 19.600, which is headed "Alcohol content and fill test record." It requires specific information, but you will not find a "form" that TTB offers as appropriate for your use. In the broad sense, the records you keep of the tests you perform for each bottling are supposed to allow a TTB official to determine that you are complying with Sec. 19.356. Sec. 19.356 requires that, during bottling, you take adequate samples of bottled spirits, at representative intervals, to "ensure" that products are within the tolerances established by that section. I add the emphasis to point out TTB doesn't tell you how to do what they require. The regulations do not discuss how many samples you must take and at what intervals you must take them in order to "ensure" compliance. They place the onus on you. Why doesn’t TTB give sample sizes and frequency? It doesn’t do that because it is impossible for you to do what they ask. Sampling is not an easy subject and I am not an expert. I know just enough to recognize hogwash. It is hogwash to expect any small distiller to have a sampling program that “ensures” compliance. It also is hogwash to expect any small distiller to have a sampling program that will allow statistically valid projections of compliance at any reasonable confidence level. If pressed about sample parameters, the TTB officer who is auditing your records would probably dance to the side with a comment, every case is different, so we can’t specify sample size. Well, sure, every case is different, but the rules for statistical sampling, i.e., for sampling from which the TTB officer can draw the conclusion required by 19.356, that the sampling program ensures compliance, don’t change. And that leads to problems. The basic rules of statistical sampling do not allow for a sampling program that will ensure compliance. Talk of ensuring is prattle. Since TTB cannot possibly create a sample standard that ensures, it punts. TTB says it is up to you to devise the program. Going a little deeper. If we want to draw a conclusion from a sample, we must know the sample size needed to establish, within an acceptable degree of accuracy, that the bottles are consistently within the tolerance established by 19.356. Assuming you select the sample in a valid way, given the sample size, the frequency of the sample, the expected error rate, and the universe from which it is obtained, you will have a level of assurance, say 95%, that between 96% and 98% are within the tolerances allowed. Note that it is a qualitative finding. It says nothing about how much things vary. An error of 5% counts just as much as an error of 50%. All errors are created equal in frequency sampling. Which is fine, as far as theory goes. But when the universe is small, i.e., the size of a bottling run by a small distiller, no sample size will provide results that will allow a conclusion of the sort, we are 95% sure that the between 96% and 98% of the bottles were within tolerance. Even if TTB were to have a standard that said, you must take sufficient samples to establish, with a 95% confidence level, that between 96% and 98% of the bottles were in tolerance, TTB would have to determine how taking stratified samples, instead of random samples, affect the assurance of compliance, what rate of error is expected, etc., i.e. how to deal with all the variables that bedevil students in college statistics classes, let alone a small distiller left adrift by broadly stated requirements for which TTB provides no further guidance. Worse yet, in a small business, audit standards provide that an auditor looking at compliance must assume that the internal controls are inadequate to ensure. And proof and fill tests are "internal controls." Because the auditor cannot place any reliance on internal controls (you could be inventing all the test data), the auditor would have to test every bottle to ensure compliance. But most of those bottles had best be gone from bond or your business is probably in deep trouble. My point? Sampling is not an easy subject and I am not an expert. I know just enough to recognize hogwash. It is hogwash to expect any small distiller to have a sampling program that ensures compliance. So, what would I recommend, recognizing that I am not TTB, but that TTB has chosen to punt? The practical answer is, provide the TTB officer with information that satisfies the TTB officer, who, like you, is without an objective standard for how many and how often to test. I know, that is a statement of the obvious, but it is all we are left with. My best advice, in practice, is ask yourself, based on your sampling, if you are reasonably sure that you are within tolerance. If you are reasonably sure and the TTB officer is a reasonable person, your program will pass the test. That is the best guide I can offer. I'd be interested in hearing comments from any statisticians and/or auditors on my comments.
  45. 0 points
    Hi- Small MA, orchard based hard cider producer here who is setting up a nano distillery at our farm. Love, brandy and Calvados and can't wait to get it going. Working on licensing a small space and small still for a few years to get things figured, and then see where it goes.
  46. 0 points
    We still do this and it works out great. We first obtained written permission from the TTB and also verified legality with our state- some states require bars to destroy the bottles. We pick up and buy back (.50ea) from our wholesale accounts and consumers can return their bottles to our tasting room and get $1 in store credit for each bottle. We redesigned our labels and use an adhesive that cleanly comes off with a hot water rinse. We wash in a high temp washer (we discard anything that looks suspect- like bottles that were used for infusions) and have had no issues. I have one part time mom who does the work. We have reworked over 6000 bottles so far this year.