Federal TTB statement of certification of accurate calibration

[Bartletts Distillery]

Under 27 CFD 19.166, the code states "A statement of certification of accurate calibration shall be included in the description of tanks that are to be used for gauging distilled spirits or wine for any purpose."

Could someone translate this from LAWYER into ENGINEER for me?  Does this mean that if a tank is used for measuring volume, that it must be calibrated and certified?

 

[Skaalvenn]

Your best bet is to use a certified scale and measure weights instead of volume.

 

500 pounds of 95% ethanol is always 500 pounds of 95% ethanol.  100 gallons of 95% ethanol is not always 100 gallons of 95% ethanol.

[Bartletts Distillery]

Roger that.  

I'm just looking to fill out my Distillery Registration.  Should I include a statement that all quantities of alcohol will be determined by weight and ABV%?

[Skaalvenn]

It's been about 18+ months since I filled it out and I can't remember what I put.

You want a certified scale that reads to at least .2 pounds. I'd put that down as part of your process.

[dhdunbar]

I missed this discussion.  27 CFR 19.166 talks about the penal sum for bonds.  There is no requirement for a statement of the type you describe in the application to establish a DSP.  Your reference to 19.166 is from the regulations prior to the current revision.  The provisions of 19.166 were incorporated into the current 19.75.  According to that section, for any tank, all you need list is the serial number (one you give to the tank) and its capacity.  I quote:

The serial number and capacity of each tank in the plant. The list does not need to include any bulk containers having a capacity of less than 101 wine gallons on the plant premises if those containers do not meet the criteria of a tank under Sec. 19.182 (perks, small totes, etc.).

By the way, the above provisions of 19.75 an 19.182 leave everyone who bothers to read them wondering about those ubiquitous 275 gallon or more totes.  But putting that aside, you need not make a statement certifying the accuracy of the tanks.  However, if you are using a scale tank, or a package tank for that matter, you should get it certified from time to time for your own purposes.  

Finally, you need not tell TTB how you are going to gauge.  You just must do so as required by the gauging manual.