Retail Separation

[distill_me]

Working through our DSP permit and came across a decision point that I wanted opinions on. Our retail area is in the same physical building as our bonded and general premises areas. To separate the retail area from bonded and general premises areas I was thinking of putting up an 8ft wall but no ceiling, since the building itself has a 14ft ceiling and I don't want to go that high (so theoretically an enterprising spirit thief could climb the wall and get into the bonded and general premises areas via the retail area). Both retail and bonded premises will have separate outside access. Question is whether a wall is sufficient or if we need to add ceiling as well?

[glisade]

It all depends on the agent you get. I've seen distilleries with no wall at all and some with just a metal fence where you can almost touch a still with a bottle for sale in your hand.

[bluefish_dist]

I think that is an issue that they are cracking down on. I too have been in other distilleries that I could touch the still and we had to adjust our floor plan for approval.

I have also been in distilleries that have partial walls. I would call your specialist and ask. Once I was that far most of them were helpful and wanted to approve the application.

[bluestar]

Some have gotten away with the wall. But most will not. And a close reading of the CFR suggests any scalable wall would not be sufficient, since you have to be able to secure with appropriate locks the bonded space from non-bonded space, especially if it is publicly accessible.

[Huffy2k]

I had to go floor to ceiling (25ft) for my separation wall.

[distill_me]

Thanks for all the info. I don't really have a problem with the reg's, just want to make sure I'm doing it right. I guess before putting up the wall I'll be sure to get buy-in from our local TTB rep. Don't want to have to go back and change it after the fact.

[clearwaterbrewer]

It was told to me by an expert (ex TTB) that frequents this forum that 'if a 6-foot fence is good enough for a storage tank of thousands of gallons, it should be good enough for your DSP, right?...' I guess the question becomes: how does a outside storage tank get away if the CFR is specific enough to outlaw a scalable wall?

Me? what did I do for the gift shop? I spent way too much and have a 2-hour firewall and 90 minute door because I tried to make my local officials happy, and kick myself for doing so.,... Customers cannot see the still unless the door is open, which means one of the two named people on the DSP has to be there... distillery consultants are worth every penny... especially if you get them involved before approaching a contractor or local official...

[bluestar]

It was told to me by an expert (ex TTB) that frequents this forum that 'if a 6-foot fence is good enough for a storage tank of thousands of gallons, it should be good enough for your DSP, right?...' I guess the question becomes: how does a outside storage tank get away if the CFR is specific enough to outlaw a scalable wall?

I think that is a poor comparison. The TTB has to make a ruling on the security of the revenue, in other words, how easy/hard it would be to remove product from the premise. Sure, if the product is in giant lock-secured tanks, a peripheral fence might be deemed enough to protect it. But if the product is in bottles or small containers, it needs to be secured in a way that you can't simply slip through or carry over a bottle of product. The CFR is not specific to that degree, that is interpreted by the TTB officers for each application. But the need to be secure is the bottom line.