Paul Tomaszewski

Gents, there's just too many variables on your individual operation, location, NAICS classification, production amount, cost of equipment and/or product storage, safety measures in place, and we're not even getting into employees. It could literally be $500/month or $5000 (of course you'd have to be relatively big and/or in a very risky classification setting). Just like anything else for your estimation, take as much information that you know, then make a well-educated guess your unknowns, and get a quote. You are going to know those possible numbers better than anyone, plus it will do you good to get something established with an insurance entity and keep up a dialogue with them. They may help you along the way in making certain determinations that can help drive your insurance costs down, particularly with things like sprinkler systems, maybe a fire hose hookup, etc.

Once you have a suitable site, think 1-2 years until you have approved products (labels) that you can sell. I've heard of shorter and longer, but that time frame seems to be the general trend.

I can see the control state issue on the case size. We're in 10 markets and 6 packs seem to be preferred and very much appreciated by both distributors and retailers. However, researching your target market(s) is obviously always your best bet.

Your grain ratio doesn't seem to be much of a problem, but your malt should go in at high 140's, low 150's F. Your enzymes aren't going to convert very well, if at all, when you start getting higher than 175 F or so. No matter what, you're well above optimal conversion temp. Try adding corn and rye as you normally do, then put in your malt at 150 F. The amount of malt you're using seems to be more than sufficient, I think it's more the enzymes not liking the temp. FYI, you can also get liquid enzymes that can help thin your mash at a higher temp when you put in your corn/rye and/or to help convert your starches. You can also throw in a handful of malt to "pre malt" or even "post malt" once the corn & rye are in. There's also liquid enzymes you can get to help break down the beta glucanase from your rye. On a separate note, get you some brewing books and study up on the different grains, their makeup, what's in them, how to best cook them. And then there's enzymes, learn them, love them.

Unfortunately this is a tough thing to nail down. As far as sales goes, it really is relative to your individual situation and products. As a rule of thumb, unless you're in a sure bet tourist area that sees many, many folks come in (a good example not too far from you would be "a little place called Aspen"). But, all kidding aside, plan for a relatively small number of cases to be sold out of your tasting room, your 50 of each is probably a safe amount. Past that it really depends on your regional/state market, who your distributor is, how much you do to help out your distributor/marketing your brand, etc. I've spoken to many folks in the business and numbers are all over the place. Some folks you think are selling thousands and thousands of cases/yr aren't, and others you've never heard of are churning out 10-20K cases/yr. So many things are just relative to your individual circumstances. You should be able to reasonably double your sales your first few years as you are just getting established and your sales for your first year or two are likely to be nothing in the grand scheme of things. The one nugget I can give you and anyone else reading this is that you need to remove a case of 12-750ml from your vocabulary. ANY craft distiller starting out should be selling cases in the form of 6 x 750ml bottles. When you start selling 10K+ cases/yr you can start flirting with the idea of selling 12 packs. Otherwise your distributor(s), buyers, and sales folks will all thank you if you go with 6 packs.

We've set FEB 17th, 2014 as our next "Camp Distillery" date. This course is basically two days in one when it comes to the amount of subject matters covered and quality of content. We stick to a one-day course from 6am - 5pm due largely to overwhelming end of course feedback. The first half of the course covers mainly grain mash/whiskey/moonshine production, the second half is mainly govt regs, govt reports, licensing, product planning, marketing, distillery planning/budgeting. This course is laid out in true military precision (designed by a former Army officer), we always improve the course after each date. More information can be found on our website at http://mbrdistillery...Distillery.html. Our January course filled up a few weeks ago and this one will likely be filled up by the end of the year. We'll only hold one or two more after this course until next fall due to the weather (it's easier to heat a distillery than it is to cool one). Call me for more information, (270) 640-7744.

Cincinnati Insurance Company, there may be brokers/agencies that offer them in your area. They've recently developed a "turn-key" (for lack of a better phrase) program for craft distilleries.

I think a good way to think about asking any question on this forum is to treat it like a call in radio show. Sometimes a simple, "how do you do X?" or "do you see any point in Y?" are easy to ask questions with pretty black and white answers. On the other hand, asking a question that is tied to many specific individual business needs/desires, to include your budget, is a bit tougher to just give a blanket answer. I'm not saying no on can answer your question, but I will say that no one can answer your question better than you.

Call Jesse Lupo at Trident Stills, he has the best thing I've heard of going for grain-in-mash heat exchangers (www.tridentstills.com).

Someone may correct me here, but my understanding on getting an experimental dsp is that it's basically the exact same (bond & all other regs required), except that your dsp says "experimental" on the permit. I actually had a discussion with a former TTB official about this years ago and their advice was "get the regular permit and just don't sell anything if you're not ready to produce for that purpsose." You only pay taxes on what leaves your DSP (translation, is sold). Otherwise, books and the internet and visit some other places.

Unless you plan on being a nano-sized operation and staying that way, no. I consider us quite small and we have a 2,000 sq ft production area, another 2,800 sq ft in storage for bottles, cases, unused barrels, grain, etc, a 1,000 sq ft retail space, and then our aging warehouse that's in a separate building. I do realize we have some room to grow, but I also see the limitations in our setup and how if you plan to try to make any amount of real money you'll be extremely strapped for space.

For federal compliance/verification purposes, you should send your product(s) to a TTB-certified lab. You can try to find one in your local area and ask them if they are certified. I'm in Kentucky, I recommend Brewing & Distilling Analytical Services in Lexington (www.alcbevtesting.com).

We have set another date for our "Camp Distillery" course - January 27th, 2014. Our NOV course was fully booked 3 months out, so I do recommend you register as soon as possible. Camp Distillery - A one-day, all-inclusive course on whiskey/moonshine production (to include hands-on application), regulations, building/planning process, equipment requirements, licensing, monthly reports, marketing/distribution, and some retail instruction. Applicable for those interested in the business or if you are in the process of setting up. The class is limited to 15 attendees, cost/person is $350, $400 for registration after DEC 1st (but there probably won't be any). We have given this course for 2 years and continue to improve it with each offering based on previous course feedback, as well as with our rapidly-evolving industry. Past attendees resoundingly give us positive feedback on the quality of the instruction/information provided and that they appreciate it all being contained in a single day. The course starts at 6:30am and wraps up at around 5-5:30pm, CST, breakfast & lunch provided. We are located in Western Kentucky, one mile off I-24, Nashville International Airport is an easy 55-min drive away. More information on the course, as well as registration information, can be found at http://mbrdistillery.com/Camp_Distillery.html. We only offer the course a few times each year and put a lot of effort into it to make it as professional and user-friendly for all in attendance. I do anticipate this course filling up before the end of the year as we have had several folks inquire about it already. If you have any questions at all, call me (Paul) at 270-640-7744.

Bottom line is to ensure that they are "IRS Certified" hydrometers. If they are IRS certified, they'll have individual serial numbers & an actual certificate of calibration that comes with them. I get mine from www.novatech-usa.com (not being paid by them, but they are very good as I have received broken hydrometers before and they have gladly replaced them free of charge).

We have always operated by the premise that 22% abv or higher is antiseptic, therefore covering ourself when it comes to bottling, shipping, etc. However, I've seen various liqueurs out there that are bottled at lower proofs than that. Does anyone know how low is too low for bottling proof for liqueur-type products? Also, if you do drop to a certain abv/proof, is there certain shipping conditions to take into account? Thanks much for any information.

Well the good news is if you submit your formula using COLAS/Formulas Online, the turnaround time for formulas is a day or two vs. COLAs being a month or more. The Formulas Online can be a little tricky getting used to the first time, so probably not a bad skill to get knocked out. Not sure why they made Formulas Online so different in the setup and use of it vs. COLAs online.

Yesterday I spent most of the day in Lexington, KY at Brewing & Distilling Analytical Services with Gary & Nathan. We went over some lab techniques/procedures and ran some samples in their DMA-5000. I know that Gary did a write-up for the ADI newsletter, but figured I'd spread the good word about how they can help you out with lab needs, especially if you happen to be a small-scale producer and you need an external lab to help you out or just certify/analyze your products. You can simply ship to them via UPS, you don't need to be a walk-in like me. There aren't many labs like these out there that can provide the services that they can, and cost is more than reasonable. If you need further info, feel free to contact me directly.

My apologies, I meant 9-10 dollars per hundred and I'm not looking for legal advice, I understand all of that and have done so accordingly, just wondering if there's other categories and/or ways of working this.

Well the day has come for us to bring on some part-time folks to help out in the distillery on a regular basis, and I know that employees are not considered "equipment," but this was the best fit I could find as far as topics go. For those of you who have experience with covering your employees under workers' comp, I was wondering about your experience for those working IN the distillery (vs. tasting room, sales, or something not related to day-to-day production operations). I know that not every insurance company is the same, but the cost to cover someone as a distillery employee (as quoted to me) is in the neighborhood of 90 cents to a dollar per 100 dollars of salary vs. a gift shop employee being a fraction of that. Has anyone had different experiences with this and, if so, were the employees covered under a different category than simply "distillery operations?" Maybe there's a "small-scale production facility" category or something like that? If there is a microbrewery category that isn't as high as a standard-sized brewery, than maybe we can work the channels to develop a "micro distillery" category.

I have had discussions with folks in labeling/formulation for submitted COLA's and how I can or cannot use certain statements that would be considered confusing or misleading to the consumer. Just my opinion, but when a statement such as this is made: "This particular Trybox Series New Make, when aged in new, charred, white oak barrels WOULD become the award-winning Rittenhouse Rye Whisky." Now, based on the proper TTB officials telling me that if you are making a completely unaged whiskey it MUST be a corn whiskey, and HH implying that this whiskey is unaged (but it's obviously not a corn whiskey), that seems quite confusing to me.

I could care less if I “put in the last word” or “have to respond in order to assure myself and make others believe that I’m right,” but this is highly uncalled for. First of all, I’ve never said the sky is falling Chuck. In fact, in my initial post, I did explain that maybe the TTB will get around to addressing this said issue with all folks involved OR maybe they won’t. However, I do know that folks in the industry appreciate me informing them of this latest experience, particularly some of those at the top of this organization. I’m sorry if we’ve offended you, considering “your credentials” and all. I’m sorry, I tend to think that those of us that start our own federal and state-regulated distilleries from scratch without big corporate funds, and are helping to push the envelope in an industry that is dominated by a few mega-conglomerate international corporations that are churning out a mere few examples of what is possible to make out there. I WISH the American whiskey market was anything close to that of the level of development that the (for example) Scotch Whiskey market is currently at, and when that day comes it will be because of not the big guys who make bourbon, bourbon, bourbon, and maybe rye (because, let’s face it, they enjoy the “status quo” because they’re on top), it will be because of us folks that are pushing the boundaries of this industry. I won’t go into my past prior to distilling, I’m sure many folks out there wouldn’t be all too impressed, but it says a lot for the comments that you’ve made in such an arrogant manner and I’m sure many folks in my place feel the same as I do reading your ever-so-bold postings and your assumptions that you are making about all of these unaged products being aged in some way or not and how you cannot accept the facts that I have lined up for you. How about overcomplicating things by assuming that it’s okay to “age a spirit/whiskey in oak for a period of time” but still call it unaged? I can tell you what the folks in formulation have told me. They have said that if is unaged (ie, has never ever ever EVER touched oak in any way, shape or form), then it’s unaged and isn’t whiskey UNLESS IT IS CORN WHISKEY. However, they have told me that if you age it for ANY period of time, it is then considered “aged” and, therefore, it would be misleading under their standards to call it unaged. How many times have you talked to formulation? Can you tell me who the director is? Why don’t you call them up and give them the argument you are giving us in defense of the many labels, to include the big producers, and how/why they are or are not whiskey? Now, if you happen to know that BT and HH are, without a shadow of a doubt, passing their “unaged spirits” through wood, than my hat is off to you my good man. But, I am merely making assumptions, from their very own products that they CLEARLY put on their labels for all to see, I’m sure many that have looked at those labels and will in the future can understand how I have gotten to my current conclusions on those products. Furthermore, I can look up various other labels that are not in compliance with the standards, that I agree never have changed, but have not been applied correctly over the past years as this industry goes through some much needed growing pains. Case in point, I have a label right now that is approved as a “straight bourbon whiskey” and never says anything about being “straight” or “bourbon,” so I have to inquire as to how/why that designation was given and how we can amend it. As the good lady in NY said, “I’m done.”

Actually Chuck, you are wrong. Simply because there are distillers out there bottling completely unaged product that is neither "whiskey" or "corn whiskey." I'm not about to start calling out any other adi members or craft distillers, so let's use the big boys for an example. Case in point, Buffalo Trace White Dog Mash #1 (TTB ID 10264001000042), as I understand, is unaged. However, the label does state "WHISKEY" on the front label as its legal class description. Now, one could argue that this specific product is produced at "at least 80% corn mash," and, therefore, can be called "whiskey." But, based off of the explanation given by formulation at the top of this thread, that would mean that the product would have to be called "corn whiskey." Looking at another example, let's use Buffalo Trace White Dog Rye Mash (TTB ID 10264001000040). I believe this one is even easier to explain as it clearly states on the label that it is distilled primarily from rye. Therefore, unless this spirit also touches oak at some point prior to bottling, it too is not a "whiskey." Both back labels also give explanations as to these being unaged products that are "raw, clear, un-aged and high-proof distillate right off the still." Looking at another large producer, let's take Heaven Hill's Rye New Make (TTB ID 10362001000171). In fact, this one is almost funny based on the fact that the front label reads, "RYE WHISKEY STRAIGHT FROM THE STILL." Again, understanding what formulation has ruled on what is and is not whiskey, the only way you can produce a "RYE WHISKEY" is if your "RYE SPIRIT" is aged in new, charred oak. Now unless anyone knows that, without a doubt, both BT and HH are running their White Dogs/New Makes through oak at some point in time (and for HH Rye New Make, new, charred oak), they should be labeled as "spirits distilled from grain" as Maker's Mark's White Dog is clearly labeled (TTB ID 11004001000096). Now if both BT and HH are running their spirits through wood in order to achieve the designation of "WHISKEY," than putting a statement such as "Straight off the still" seems a bit misleading to me, but that's just me. Again, I've seen, tasted and know of various of "us" that produce UNAGED spirit that's never touched wood and still label it as "whiskey" and/or have "White in close proximity" with the word "whiskey." The Public COLA registry is out there for all to view, and based on my initial posting for this thread, many, many labels out there are not in compliance with the standard of identity for "WHISKEY." You are right in that the regs have never changed. However, I believe that there are folks out there selling unaged spirit that shouldn't be labeled as "whiskey" doing so and they do have approved labels. Based on my conversations with ALFD, everyone who fits that category is going to be contacted by TTB and those labels will be forced to be amended and/or surrendered.

One could also argue that "you can age a whiskey in a very, very, very used barrel for a longer period of time (say months or even years) and not get a whole lot of color and/or flavor, perhaps so little that the whiskey still looks white." Certain Scotches out there (ie Ardbeg) tend to have a very faint color even after being aged for 10 years due to their aging process/techniques. In the end, it's what formulation says because that's who's in charge. Investigators/agents can advise them, but they still answer/refer to what ALFD determines is going to be accepted for given practices. Again, the true issue here seems to be WHAT are you bottling? Are you making an UNAGED CORN WHISKEY or an UNAGED SPIRIT DISTILLED FROM GRAIN that you would like to call a whiskey but can't because it has yet to go into oak for ANY period of time? Aging time may end up being another sticking point if all of us start aging in wood for so many seconds, minutes, or hours in order to just be able to call our "spirit" a "whiskey," hopefully I won't have to go this route again and it take another 4 months to get a final word on the situation. Case in point, when giving tours at our facility we use a bottle of "20 hour old bourbon" that has a very light, peach-like color that you can see it picked up from it's short rest in a new, charred oak barrel. However, I've also aged some whiskey for over six months in a used, charred oak barrel that had been previously used four times and the color is almost indistinguishable.

Due to this being a follow-up to a past post, I wanted to provide this in a new post so all interested parties may see how/if this will affect them. So I believe I have a final word from the TTB on the "White Whiskey" labeling issue. Basically, here goes, if you use the word "white" or "white dog" or anything that has "white," in conjunction with "whisk(e)y," you can put it on the front label. However, "white dog" (or white or white whatever) may not appear in close proximity with the class and type disignation "whiskey." Furthermore, and I quote, "the product is not allowed to be classified as a 'whiskey' if the product is unaged UNLESS it is a corn whisky" (I hope by now we all know what a corn whisky is). If the product fits the standard of identity for "corn whisky," than it must be so designated on the label, which I understand as meaning that if you are talking about an UNAGED, CORN whiskey, you MUST label it with the designator of "corn," as opposed to simply "whiskey." This came directly from the director of formulation for ALFD. So, if you don't like it, disagree, or believe it to be untrue, there ya go. Does this mean that all "white whiskey" products are going to be forced to change their labels? Maybe eventually, maybe never, but I would mentally prepare myself that any unaged, whiskies that are not "corn whiskey" products may come to be forced to be labeled as "spirits distilled from grain," or something close to that. Finally, if you have "white" on the front label in "close proximity" to the word "whiskey," you may have to change that as well.

This hits on many factors. After dabbling in this part of things for a while there's a few things to take into account. First of all, how you make your cuts off the still is going to affect congeners/fusel oils, so that's one factor. The next is, of course, how long you age in smaller barrels. We're starting to go for closer to a year vs. 6 months or so as you can definitely taste some difference in smoothness and some of the flavor components that come out. Next there's distillation proof and/or barreling proof, those will also affect how things mellow/mature in flavor. My recommendation is if you make anything with the desire to improve, it's worth at least trying it.