Bartletts Distillery

Floor drains and fire sprinklers

21 posts in this topic

Continuing to work on my distillery plans.  I'm 3 weeks away from signing a lease and still have some unanswered questions.  FYI, I'm going to be making rum (sugar, molasses) and whiskey from malt extract, i.e....no grains and no mashing.   

Question: are floor drains actually "required" by the FDA? I know many highly recommend floor drains, but I'm trying to set this up as clean of a facility as possible, and would rather not have floor drains that would a) harbor a place that could produce TCA, and b) cost a lot of money to install into a facility that I will be leasing. 

That being said, the Current Good Manufacturing Practices state the following:

Section 117.20(3) Adequately draining areas that may contribute contamination to food by seepage, foot-borne filth, or providing a breeding place for pests.

Section 117.34(4) Provide adequate floor drainage in all areas where floors are subject to flooding-type cleaning or where normal operations release or discharge water or other liquid waste on the floor.

 

So, does anyone know if they are really required, or just a really good idea?

 

Cheers,

VB

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You will spill stuff and it will be much harder to cleanup without proper drains. I would not have a facility without them. Why are you worried about TCA in a distillery? Assuming you are talking about   2,4,6-trichloroanisole ?

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Your local health department is going to have more to say than the FDA.  They might require all sorts of new fixture if this wasn't a food processing facility before.  We needed three basin sinks, hand wash stations, mop sinks, etc.

Operate without floor drains?  No way you could be meticulously clean without floor drains.  You'll be mopping the floor all day long.

i couldn't fathom how you could possibly clean equipment, hoses, etc without the ability to spill and spray down, but that's just me.  Heck, a 2 inch hose is going to hold a couple gallons of mash or beer, and when you disconnect that hose, the remainder is going to pour out.

I love linear floor drains and wash down hoses.

 

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I'm a small distiller and couldn't imagine operating without at least one floor drain.

I was visiting another distiller without a floor drain and one of the tanks overflowed, using a shop vac and a mop to clean up ~20 gallons of liquid didn't look fun.  I've had a tank foam over, I squeegeed everything into a drain, parked the tank over the drain and washed it off, then sprayed down the floor and mopped it with cleaning solution.

Also your subject asks about sprinklers.  I couldn't imagine doing any real quantity of production without the increased capacity which sprinklers give.  I can't remember, but I think without sprinklers it's MAQ of 120 gallons of ethanol in a closed container?  I've got 115 gallon spirit tanks that are becoming too small, and to give you an idea of my size we started out with less than $100,000 in startup costs and began production about 15 months ago.

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I filed my federal application in May, so we are not up and running yet and therefore have no input on floor drains.  However, based on feedback from everyone I've talked to, I am spending the money to have them cut in.  I am just doing 4" trough drains.

I am not sure what local codes require for sprinklers, but I just met with my architect last Friday (who is also an attorney) and his feedback was that if I sprinkle the distillery, it will simplify everything else.  Our distillery is attached to another building, so without sprinklers it increases requirements for fire rated walls / doors.  Also, I spoke with my insurance agent, and he also indicated that they will want to see the distillery sprinkled.  Regardless what you decide, I would talk with a local contractor or architect familiar with fire code, and also talk with your insurance agent.  They can both likely give you the feedback you need. 

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I cant imagine not having my slot drains.  As for TCA,  that's a cork production issue not  a  crap-in-the-drain issue.  

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You need floor drains. You don't necessarily have to have trench drains or sumps, but if you don't, it makes it hard to dump large quantities of liquid waste.

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Thanks guys, but this has become a moot point, at least for the moment.  

I just got a call from my fire protection engineer (required by the county Fire Marshal.)  With an H3 classification, I would need 0.4 gpm / sq.ft for 90 to 120 minutes.  Since the local water main cannot supply sufficient water flow, I would have to put in a rather sizable tank, pump, etc.  He said that I'd need between 125,000 to 150,000 gallons of water storage.  Or enough to fill the building halfway up.  Ummm, no thanks.

So, I'm back to square-1 on looking for a suitable property.  But this time, I'm hunting for a place with better access to large water mains, and existing floor drains! :)  Wish me luck.

VB

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Bartlett's story is not unusual.  

I work with a lot of distilleries and would be distilleries.  I consistently preach that you must deal with local issues first, and dealing with local issues means dealing with the people who will make the decisions.  Talk with the fire marshals, the code officers, etc., before you commit to any lease or even begin looking.  And make damned sure that the person to whom you are talking knows what they are talking about.  It can be very expensive to rely on bad information.  

I work with federal requirements and I always tell clients, pay me not cent one before you deal with the local requirements.  We can make things work on a federal level in nearly all cases in which a separate entrance from a public space is available, but local requirements can take a tire iron to the knees of your business plan. 

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Dunbar, that's sort of what I did.  Once I found a place that I though would be suitable, I laid out a basic plan and went to talk to the local Fire Marshal.  It was obvious he was not comfortable with a distillery, so he instructed me to get a Fire Protection Engineer to make a report.  I made it clear to the landlord's agent that I had to first ensure that I could get a fire permit before I'd sign any lease.  Getting a Fire Protection Engineer to spend a little time with me was difficult, but eventually I got my answer.  I didn't like it, but it was an answer.

It was a great learning experience.  It didn't cost me anything but some time.  Now, moving forward, I have a lot better understanding of what I need in a location. 

As for the floor drains..OK, OK, OK!!!!  Heard, loud and clear.  Make sure to have floor drains.  Check!

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On August 9, 2016 at 9:20 PM, dhdunbar said:

Bartlett's story is not unusual.  

I work with a lot of distilleries and would be distilleries.  I consistently preach that you must deal with local issues first, and dealing with local issues means dealing with the people who will make the decisions.  Talk with the fire marshals, the code officers, etc., before you commit to any lease or even begin looking.  And make damned sure that the person to whom you are talking knows what they are talking about.  It can be very expensive to rely on bad information.  

I work with federal requirements and I always tell clients, pay me not cent one before you deal with the local requirements.  We can make things work on a federal level in nearly all cases in which a separate entrance from a public space is available, but local requirements can take a tire iron to the knees of your business plan. 

+1 on the local requirements. Spend some time networking with local elected officials too to ensure there's support there if you need it. That time we spent was worth more than I can account for now that we are open. 

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On 8/7/2016 at 7:25 PM, Bartletts Distillery said:

Question: are floor drains actually "required" by the FDA? I know many highly recommend floor drains, but I'm trying to set this up as clean of a facility as possible, and would rather not have floor drains that would a) harbor a place that could produce TCA, 

On 8/8/2016 at 7:49 AM, kkbodine said:

Why are you worried about TCA in a distillery? Assuming you are talking about   2,4,6-trichloroanisole ?

On 8/8/2016 at 0:38 PM, indyspirits said:

I cant imagine not having my slot drains.  As for TCA,  that's a cork production issue not  a  crap-in-the-drain issue.  

Maybe the missing link here is in reference to cleaning floor drains with bleach? Chlorinated Bleach + any organic material (grain, barrels, etc.) becomes a serious TCA infection very easily.

https://www.extension.purdue.edu/extmedia/FS/FS-50-W.pdf

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Ahh my old friend Dr. Butzke (and no I'm not making a joke there). Anyway that is all well and good but unless you are using corks it should be a non-issue.

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If Nancy Fraley says TCA can be detected in spirits, I believe it. 

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We opened discussions with the local fire marshall's office early on.  They were insistent on sprinklers but offered a compromise of separation (fire walls) plus sprinklering only the still area.  We built cheap 1hour walls (2 sheets of 5/8" wall board) and sprinklered that smaller space with just a few heads off domestic service.  Toss that back at your engineer...

 

 

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14 hours ago, kkbodine said:

Ahh my old friend Dr. Butzke (and no I'm not making a joke there). Anyway that is all well and good but unless you are using corks it should be a non-issue.

Doesn't have to come from corks.  It can be formed in the spirit and become noticeable in the barrel.  Entire distilleries have been mothballed because of TCA in barrels well before packaging.  Real stuff. 

http://nyloveswhisky.com/lost-spirits-update/

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According to that, they literally had a swimming pool on site that leaked chlorinated water into the soil around the foundation and then got into their wooden fermenters. Sounds like a unique situation to learn from.

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18 minutes ago, RobertS said:

According to that, they literally had a swimming pool on site that leaked chlorinated water into the soil around the foundation and then got into their wooden fermenters. Sounds like a unique situation to learn from.

I definitely agree, but I also think it's unwise to assume that anyone is immune.  This was an outlier of a case for sure, but the take-away is that chlorine has no place in a distillery!

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2 hours ago, ThomasM said:

Doesn't have to come from corks.  It can be formed in the spirit and become noticeable in the barrel.  Entire distilleries have been mothballed because of TCA in barrels well before packaging.  Real stuff. 

http://nyloveswhisky.com/lost-spirits-update/

OK so according to the article they had wooden tanks and a wooden still contaminated with TCA and literally distilled it into their products. A very specific situation and problem. I think he will be fine though because he can apparently create 20 year old flavors in six days https://www.wired.com/2015/04/lost-spirits/

I don't think the take away is ban chlorine from the distillery; it really is be careful what you do with it. It has been a major problem in some wineries and is very noticeable in wine. I don't want TCA in my facility which is a winery and distillery, so we rarely and very carefully use bleach.

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2 minutes ago, kkbodine said:

OK so according to the article they had wooden tanks and a wooden still contaminated with TCA and literally distilled it into their products. A very specific situation and problem. I think he will be fine though because he can apparently create 20 year old flavors in six days https://www.wired.com/2015/04/lost-spirits/

I don't think the take away is ban chlorine from the distillery; it really is be careful what you do with it. It has been a major problem in some wineries and is very noticeable in wine. I don't want TCA in my facility which is a winery and distillery, so we rarely and very carefully use bleach.

Fair enough.  I've chosen to ban it entirely as there are many other options for cleaning that are safer for us across the board.  Also our facility only produces distilled spirits though, so I'm sure our cleaning requirements are very different.

Cheers!

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Finally a question straight forward enough for lots of reply's...

We put in a 4'' floor drain and wish it were 6". The other big issue for our municipality was what went in to it. So we put in a filter at the discharge and it captures all the solids that go into it and very little goes into their waste water treatment system.

 

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