Tom Lenerz

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Everything posted by Tom Lenerz

  1. http://beverage-master.com/article/when-fda-takes-control-what-alcohol-beverage-companies-need-to-know-about-the-fda/ "In addition to registration, breweries, distilleries, wineries, and other alcohol beverage facilities are subject to FDA inspections. On the domestic level, inspections are usually conducted by state agencies. While this rule is not new either, pre-FSMA alcohol beverage facility inspections were not very common. However, this number is growing what with inspection frequency mandates established by FSMA. Shortly after FSMA’s regulations were implemented, Wine Spectator reported that roughly 261 U.S. wineries were inspected in fiscal year 2011-12 in comparison to 132 in 2009-10. Although FDA inspections may be new to a brewery, distillery, or winery, an establishment that is alert, well managed, and informed should not fear an inspection. During inspection, alcohol beverage facilities are held to current Good Manufacturing Practices (“GMPs”), which are found in 21 CFR Part 110." The key line here is 'usually conducted by state agencies', so the level of inspection will vary from state to state. FDA sets the rules for things like GRAS, three-bay sinks, acceptable materials, etc... Which is then usually enforced by your local health inspector.
  2. I could definitely be wrong, but my guess is you are looking at 8419.40.0040. DSPs are regulated by both the TTB and FDA, because they are a food and beverage processing plant. I would imagine other would be for things like fuel ethanol or chemical processing.
  3. SCD: How much are you paying for corn where you are at? Commodity price of corn is $3.75 a bushel around here, I'm getting a number close to 15 cents a bottle with pure corn. (1000 pounds = 17.9 bushels, $67.13 for 450 = $.149). Cestrin: There are simply too many variables to just say "do this and you can be profitable". My first comment is to illustrate just that. I once had an operations manager for a large distillery tell me that by far our greatest cost would be grain. Which for us, it isn't even near the top. It is all about scale, labor, cost of grains, cost of botanicals, utility rates, capacity utilization, and that is just about COGS. Your finished goods price is going to have to be influenced by the market, and obviously the less you charge the more you sell to some extent. Major variables include, but are not limited to, raw material costs (varying based of equipment available, production efficiency and location), utilities (gas vs. propane vs. electric and location), labor (still size, skill level and location), packaging costs, market pricing (branding and you guessed it... location).
  4. Yeah, but they are literal life savers. The codes exist to protect you, your staff and your customers.
  5. Silk City has answered the legal requirements here from CFR 19.356 - must be done in 'representative intervals during bottling operations'. We do one about every hour. The results need to be logged via the requirements in CFR 19.600.
  6. Yeah, mixers can be useful to bring cooler liquid down to the bottom. Bigger the delta T, the better the heat transfer and efficiency. We used to run direct fire, without agitation and it was slow. At least in the brandy world, it is believed that the high heat and copper contact in a slow warm up contributes positively to flavor. Not sure if that is the same for rum or not. We switched to direct steam coils, still no agitation on that still and warm-up is faster, but still slow, agitation would help with that, but it is fast enough, and the flavor profile seems unaffected. We used to pre-heat our wine for the still to 120 to shorten warm-up. Might be an option for you if you have an insulated tank, drain the still through a coil in an insulated tank (or use another heat exchanger of your choice) to save the heat for the next day. My understanding is LP is typically much more expensive than NG, (although I'm sure that varies depending on location), so that could be another reason to try to save/reclaim heat.
  7. See CFR and look at regs for package, as TTB defines package as follows. "- Package. A cask or barrel or similar wooden container, or a drum or similar metal container." Examples of relevant regs, 19.324, 19.476, 19.484, 19.485, the list goes on and on and on. https://www.ecfr.gov/cgi-bin/text-idx?SID=f722e5eefe1b4eee15f709476f2159d8&node=pt27.1.19&rgn=div5#se27.1.19_1484
  8. I believe that the ruling stated something along the lines that Maker's Mark dripping red wax is iconic and unique enough to qualify as part of their branding trademarks. That doesn't extend to other colors of dripping wax or non-dripping red wax, just dripping and red. It isn't illegal to use dripping red wax, but if Maker's tells you to stop using it, they have the law on their side. https://casetext.com/case/makers-mark-distillery
  9. If you are in America, start with HAACP, there are lots of exemptions for Bev Alcohol https://www.fda.gov/food/guidanceregulation/haccp/
  10. Not exactly the same, but in the same vein, it might be worth looking into how American craft distilleries are handling making, Irish and Scotch style whiskies. A lot of American craft distillers are in that same situation of trying to make a whiskey that isn't defined by the law or known by consumers.
  11. Since California isn't exactly cold, I would imagine sometimes your air could be as hot, or potentially hotter than the water you are trying to chill. These types of chillers do exist, and are often used in colder climates during the winter to offset demand, however you would need a very very large one if you have a smaller delta T. I would consider other ways to use the existing BTUs for other activities requiring heating, like warming water for your cooks or for the never ending cleaning. Buffer tanks work well to even out the demand on the chiller if you aren't running 24 hours a day.
  12. The issue is one gallon of 100 proof liquor plus one gallon of water, with or without sugar does not equal two gallons.
  13. Are you using a hydrometer to do this? If so, this check the gauging manual in reference to dissolved solids, and this sweet, sweet video series. https://www.ttb.gov/spirits/proofing.shtml
  14. There are some more issues here too, like how the still is setup, hybrid vs pure pot, how clean your cuts are, etc... Our real world numbers, we run a 30 gallon beer (30 gallons of volume per bushel) so our mash varies from 7.5% for rye to 9% for bourbon. We do 500 gallons a day on a hybrid, single pass, and we see between 3.8 to 4.5 pg/bushel of hearts. So 16.66 bushels per day, results in 63 to 75 PGs, or a barrel and change a day. Running pure pot double distilled, we see about 70% of the mash PGs make it to hearts.
  15. We have an AODD Yamada NDP-25 and our still came with a small EXP Jabsco flex-impeller hard piped in. No complaints on either.
  16. Pretty much three ways to move liquid, gravity if you have it, pump if you don't, and bucket and funnel. We have a few situations we let gravity do the work. Most of it is pumping. Collect the last in the hoses or tank in a bucket and dump. Just a bucket and funnel would work, but you are wasting your time, pumps aren't that expensive. I can't imagine operating a distillery without a spirit pump.
  17. If a brush and PBW work for the tanks, fill a bucket or tank with PBW solution and try pumping one of these. We run the ball through our flex impeller pumps, but have not tried with our lobe pump. http://www.gwkent.com/hose-cleaning-sponge-ball.html
  18. Shane, thanks for sharing all the reasoning here!
  19. Technically under the FSMA here in the states we have the same, but there is a blanket exemption for breweries and distilleries. This exemption was called into question a few years ago, but ultimately industry won for now, it could become an issue again in the future though.
  20. I would rethink the concept personally. Simply put distilling exists as way to store and minimize transport cost of raw material. In France, they used to have mobile stills that would go from vineyard to vineyard, bring the still to the fruit not the fruit to the still. Not saying you can't do what you want to do, but it hardly seems worth it, regardless of the 'concept'. If it is a high traffic area and you want people to see your cool still, get an ugly stripping still at the other facility and just truck low wines. That's what Buffalo Trace does with the Bowman Distillery. Everything about moving the mash and having two facilities will only increase your cost and lower your margin, and provides zero value add to customers in the process.
  21. Curious as to why if you have near unlimited space nearby the whole operation isn't there? Nearby being a very interpretive term, pipeline close?
  22. I don't necessarily disagree with 3d0g here, but I do want to point out a few things. Craft beer was up 13% by volume sure, but they were up 15% by number of breweries, so that means they were making less beer per brewery than the year before. If you are getting your data from here (https://www.brewersassociation.org/press-releases/2015-craft-beer-data-infographic/) you will also notice that regional breweries were up 26% versus the smaller pubs (10%) and micros (20%). Which means more of the volume from big players. So while I don't believe a bubble to the point of falling flat is going to happen in either industry, there is definitely crowding as more players get in the game. The argument about shelf space is true as well, just remember though that owner kicked some other beers slot out to make space for a beer he knew he could sell. We are seeing this everywhere with taplines and coolers with beer, and I've witnessed it with spirits as well.
  23. The main reason for a centralized cooker, is to remove extra and expensive apparatus from fermentors, IE, heat source, agitation and any grain handling that fills it. That being said, if the only thing extra is hot water you are minimizing that. The idea would be getting the grain to it, one flex auger to fill a cooker is cheaper than a system that could move grain to each fermentor.