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  1. 4 points
    It's only Quarantine if it's in the Quarantine province of France. Otherwise it's just sparkling isolation.
  2. 3 points
    Wow. That was unexpected. Especially in an industry built around Pasteur's work.
  3. 2 points
    I had a client inquire about this and I'll make this short and sweet. You can check references. To deal, as a distiller, in industrial alcohol, you must have a permit issued under part 19. This is in addition to the FAA Act basic permit that you hold. If all you are qualified to do is produce beverage alcohol, and that is probably at least 95% of you, then you also must amend your registrations to include industrial alcohol and must obtain a bond or post a cash bond - minimum $15 operatons and $1K withdrawals.. All of that is easily accomplished, but it takes time. By the time you do that the shortage will have long ago passed. If you qualify to produce industrial alcohol, you are liable for the tax on the head faction. They haveethyl alcohol in them too. You can destroy the heads and be rid of the tax. You must keep records of the destruction, prior to the production gauge, as I am sure you all do. If, prior to the production gauge, you remove the ethyl alcohol so that it is less than 10% of the the product, you might be able to remove the remaining heads from the production account as a chemical byproduct on which you could place a Mr. Yuk sticker. Read what that requires and decide if you think you have a market. But undenatured alcohol removed from the DSP for industrial use is subject to tax. No matter how nasty your heads are, they are not denatured alcohol. You may also only ship to the authorized industrial user. You make denatured alcohol according to a formula found in part 21 of the regulations. You can denature alcohol in your processing account, but you must do that with alcohol you have counted as produced an transferred to the processing account. The alchol you use to make SDA must be not less than 185 proof, unless otherwise specifically stated in the formula or unless otherwise authorized by the appropriate TTB officer. You are relived of the tax when you denature the product according to an approved formula. You may then use certain SDA products to make a sanitizer, which TTB calls an artical, which you may ship from your DSP. Okay, it ain't short, but its a lot shorter than it is when I justify what I say by references. Try §19.307, §19.308 and §19.381 and following,, along with the links stated therein, as a starter. Then delve into parts 20 and 21. And it isn't sweet. If you are not keeping track of your heads and recording their destruction, and TTB audits, and the auditor checks, and the auditor cares, then they could cite a violation and enter an assessment. That is "could." If you are shipping the stuff out the door as a commercial product, I think an assessment of tax would be likely - I've no experience with this because no one I know of has done it - unless you have used 185 plus to make a denatured product which you then used to make a sanatizer under whatever rules the FDA might apply to such products. If anyone finds I am wrong, let me know.
  4. 2 points
    If you think the world is over-reacting to COVID-19 you have not understood the problem. Comparing it to normal flu is irrelevant. You need to compare it to the 1918 Spanish Flu. The only good news so far is that the Chinese have proven that it can be beaten - using basically the same techniques that worked in 1918 and against SARS. If you are prepared to invest half an hour into understanding the process and the risks we face, have a read through this article. Our problem in the west is that we rank personal freedoms above those of the group and this makes it more difficult for us to implement the group focused solutions that have worked for the Chinese.
  5. 1 point
    No, I think it is not the same waiver that has been talked about on this thread. That is why I asked this question. I think it is far more reaching. Here is how my argument goes: There is a general presumption in law that congress acts purposefully. Under the Internal Revenue Code there already was no excise tax due on any alcohol used to produce a denatured alcohol, in accordance with part 21. Because those provisions already existed, there was no need for congress to purposefully act to waive a tax on denatured alcohol used in sanitizers. Therefore, congress must have meant something more. I would conclude that congress meant what it plainly said it meant; it waived the tax on undenatured spirits used to make hand sanitizers. If congress waived the tax on undenatured alcohol used to make hand sanitizers, then congress must have intended to permit the use of undenatured alcohol in the production of hand sanitizers. The wavier was an unambiguous expression of congressional intent that undenatured alcohol may be used, as long as the bill is in effect, to make hand sanitizer. Therefore, while TTB and FDA may make rules that govern the use of undenatured alcohol in hand sanitizers, they may not prohibit such use. Thus, both agencies should issue new guidance, consistent with the statutory language, on the rules for the use of undenatured alcohol in the production of hand sanitizers. Because the provisions are emergency provisions, they should issue the rules immediately. That is why I want to see the language of the bill itself. I want to see what rules would seem to be consistent with congressional intent. But without seeing the statutory language, I think it is likely it is the nail in the coffin of the FDA's ridiculous position in this matter. If I am correct,then the silliness will end. I assume that if I have figured it out correctly, DISCUS, ACSA, and attorneys for the large producers, who lobbied for this change, will figure it out too. But I intend to add my voice to those calling on TTB and the FDA to provide guidance documents that comport to congresses intent that taxes be waived to expedite the use of beverage grade alcohol in the production of hand sanitizers. Large distillers have argued, "“If we could get the FDA to say yes you can use the beverage grade and for the duration of this emergency at least for some point in time here for the next two weeks you can waive the denaturant we would literally have millions of gallons of hand sanitizer available within a matter of days,” said Monte Shaw, CEO of Iowa Renewable Fuels Association, an ethanol trade group. “Every one of our plants has gotten contacted by people who want this stuff and we can’t send it to them.” https://time.com/5811201/ethanol-producers-hand-sanitizer/. But, as small distillers, I think you are a more effective distribution channel, at least initially, for sanitizes than the large producers are. You can deliver to the hospital down the street without having to establish and fill a distribution channel that brings the spirits from the large producer to the far away warehouses for subsequent delivery to those who need them to protect the lives of health workers, etc. Such delays cannot be justified. So now we ask that TTB let you do that. I will post my analysis of why the ban on undenatured alcohol should end even if the FDA takes issue with my arguments here about congressional intent. I've been silent here while I worked on a "shame on you, FDA" argument. But, if I am right, about the import of congress' recent action, there is no need for such an argument none. Congress already made it.
  6. 1 point
    @Thatch it says pharmacies or Federal facilities. You are a federally bonded DSP with bond correct? This might make it easier to understand: https://www.ttb.gov/public-guidance/ttb-pg-2020-1a "Permit guidance for alcohol fuel plants (AFPs) and beverage DSPs: TTB is exempting AFPs and beverage DSPs from the requirement to obtain additional permits or bonds to manufacture hand sanitizer or to supply ethanol for use in the manufacture of hand sanitizer to other TTB permittees who are authorized to receive such distilled spirits. TTB is authorizing this exemption under 26 U.S.C. 5562. AFPs and beverage DSPs must continue to keep records of their operations, including any undertaken as authorized under this exemption." Read that whole bulletin to make sure you understand it before producing. Feel free to ask any questions here. Keep an eye on this page for any updates: https://www.ttb.gov/public-guidance/other-public-guidance-documents
  7. 1 point
    Are you guys doing your part by donating labels for sanitizer use to distilleries? DSPs are already loosing out on sales by diverting resources to making free sanitizer, plus footing the bill for labor, ingredients and bottles. Any help from other related industries would surely be appreciated I'm sure!
  8. 1 point
    Fuck off with that flat-earther/sovereign citizen/crisis actor/faked moon landing bullshit. You believe you know better than the thousands of doctors and scientists that are on the frontlines of this disease because you watched some Youtube videos made by people just as nutty as you. That's not enlightenment. It's narcissism.
  9. 1 point
    Hi all, Below is a summary of the conversation as I've been hearing it from a variety of sources . My goal is to put this logic in front of people who do regulatory work. Anyone care to comment on the logic, pick apart my arguments, or add information? Thanks! A few facts: It's established that we need large volumes of hand sanitizer across the country. There are upwards of 1800 craft distillers distributed across the country, and even more licensed DSPs (rectifiers, etc.). Every DSP has personnel trained and licensed to work with ethanol products safely and most are situated in populated areas for efficient local distribution. Craft spirits sales follow discretionary income, which means that the craft industry has an unknown future in an uncertain economy and will likely need help Conclusions: The craft industry should be making hand sanitizer to assist medical personnel and their local communities to fight the pandemic In order to support economic recovery *after* addressing the acute emergency, the craft industry should be able to offset at least the cost of raw materials, if not recover some of the lost sales revenue, by offering hand sanitizer for sale to the public Challenges: Hand sanitizer has to be made with 96% +/- 5% ethanol as one of the starting ingredients Even with a rectification column, neutral spirit is difficult and expensive to produce from fermented substrate at the levels needed by health care providers. At best, production of neutral spirits from fermentable substrates at the craft level is inefficient, at worst, impossible GNS is usually available from bulk suppliers, but the supply chains are supporting existing accounts and/or large industrial suppliers of hand sanitizer. Bulk suppliers are not responding to small DSPs. Other ingredients (emollients, isopropanol, essential oils) are also difficult to source right now There's lack of guidance from regulatory bodies concerning legal formulas, sales and pricing Questions: Can formulas be further relaxed to allow other ingredients? Can transfer in bond rules be relaxed (or applications processed) to allow bulk orders to be split among small producers so that bulk suppliers are incentivized to support an alternate supply chain? Can regulatory agencies provide clear and cohesive guidance on formulas and pricing? Are there enough DSPs interested in a cooperative effort that these ideas make sense to pursue? Or is it everyone for themselves?
  10. 1 point
  11. 1 point
    I have a special denaturing wand I crafted from meteor fragments and banana peels. When I wave that in the general direction of a tank of alcohol or sanitizer it becomes denatured through the chaotic molecular bias inherent in the universe. And now I don't owe FET. damn those f'ing torpedoes, I agree.
  12. 1 point
    i sent the following to a couple of people I know in TTB who are in a position to get something done or at least put it into the hands of persons who can do that.. We'll have to see if it works. “Houston, we have a problem.” Many distillers want to supply hand sanitizers to local agencies and health providers who are in need. TTB and FDA recognized the emergency and each agency issued emergency “guidance.’ TTB allows the use of either undenatured or denatured alcohol. The FDA has a different position. It requires that the sanitizers be made with “Alcohol (ethanol) (USP or Food Chemical Codex (FCC) grade) (80%, volume/volume (v/v)) in an aqueous solution denatured according to Alcohol and Tobacco Tax and Trade Bureau regulations in 27 CFR part 20; or Isopropyl Alcohol (75%, v/v) in an aqueous solution.” I have been contacted by several clients concerning the FDA’s “denatured” standard. They want to comply. This is also a hot topic on ADI’s forum. I have pointed out that; · No alcohol is denatured under part 20, it is manufactured under the provisions of part 21. · Part 20 governs the use of SDA, already produced under part 21, in the manufacture of articles; · DSP’s may make articles, but they must do so according to either a general use formula or an approved formula. · There is no general use formula for santizers (use .430 under part 21), but the guidance document served to create one. · TTB requires denatured only to protect the revenue. · In the past, FDA has stated, “To prevent the ethyl alcohol in a cosmetic from being diverted illegally for use as an alcoholic beverage, it may be "denatured." This means that it contains an added "denaturant" that makes it undrinkable.’ · The FDA states no other reason for requiring denaturants. · In this time of emergency TTB determined that the production of santizer was more important than protecting the revenue, and so allowed the use of undenatured alcohol. · Thus FDA should not have an objection to the use of undenatured ethyl alcohol, for a limited time, in the emergency production of sanitizers. I point out that I am not an employee of either TTB or FDA and cannot speak for either agency. I also point out that I am not an attorney and I am not giving legal advice. I request, on behalf of my clients and those who have expressed concerns by posts to the ADI forum, that TTB and the FDA clarify the situation, by stating whether the FDA intends to require denatured alcohol or whether it will, as TTB has done, allow the use of undenatured alcohol for a limite time, to meet the emergency demand for sanitizers. Thank you for your consideration of these matters. Clarification will mean a lot to the proprietors of distilled spirits plants who want to assist their local health organizations, fire departments and others until such time as normal commercial channels can meet the need for sanitizers.
  13. 1 point
    https://www.dalkita.com/portfolio/ Distilleries are their specialty, very knowledgeable about all building and fire codes concerning distilleries.
  14. 1 point
    You should post a pic of your set up so we can see how / where it might fit in
  15. 1 point
    I have no coin or loyalty in this "debate/conversation" but only looking at it from a 3rd party standpoint. Concerning the copy: I think that was just an allegation without any proof. The two controllers are built quite differently, so not sure how one was copied from the other. I believe your last line is correct. I've also know people who have purchase from the two different vendors most active in this thread with good comments about both. If you sell enough products (of anything) you will have a customer or two who go out of their way to slander or give you a very hard time. It's just law of averages, but how you rise to these types of things says a lot about character IMHO. One thing however that doesn't look good is the multiple logins (shill accounts) to give reviews of one's own products. That is pretty obvious in this thread and doesn't look good. BTW, I know your username from other forums but you should make a post in the intro section here as well.
  16. 1 point
    Post what ever you want, nothing i said is not true. I could post it for you if you need me too. Yes I tried to buy additional products from you. What does that have to do with the way you treat people? I like how your fixed on the shipping, you have nothing to say about your quality of your product. Oh and BTW, i thanked the members of your group, not you... i have that screenshot too if you need to see it since you kicked me.
  17. 1 point
    Seller protection is more important the customer service. Seller protection gets you those return customers. You asked your customers for reviews on Feb 18th, i can see those hundreds of people flooding here to give that "honest" feedback. Great attack BTW. Why would you take a review and try to learn from it like a real business owner. This is something i would expect from Jon Zajac.
  18. 1 point
    I have about 3 distilleries worth of hardware (stills ferms cookers) no infrastructure support for it though (chillers, heat Xs, etc) hit me if you want something.
  19. 1 point
    Our Ultra Pro Vodka stills can distill from 25% to above 190 proof and everything in between. Running low wines from a stripping run you can distill to 120 proof, 130 proof whatever you like 120 or above. Our Ultra Pro Whiskeys stills will do the same as the above with the upper limit from two runs being 180 proof. Below is one of our Signature Series, Ultra Pro Vodka Stills with Gin Basket.
  20. 1 point
    Wow - great stuff. Thanks. LCP - right - I don't often think of TN Whiskey, tho' I have some Dickel here somewhere. It is diferent way to impart wood flavors.
  21. 1 point
    Foreshot, For just R&D purposes a backyard fire pit or BBQ grill and a a tin can (never used empty paint can or cookie tin to 5 gallon metal bucket) with a small hole punched in the top works. Lots of videos on Youtube on how to do this. Walmart sells "Western Premium BBQ Products Smoking Chips" in a range of wood types including apple, cherry, maple, mesquite & hickory and these seem to work well for R&D purposes and only about $3/bag or so that makes it easy to source for testing. This is what I've been using. Silk City Distillers, Wow, not sure where to begin. Purely talking basics and craft, I like a bit colder ferment than typical (8% to 9%), so it's done in roughly 5 to 7 days vs 3 days. I prefer pure pot stilled whiskey over columns, doublers, thumpers or plates using a worm. I like a slow pot still spirit run (after fast stripping). When I say slow, I mean probably 1/2 speed of what most people run. This allows for more natural refluxing as well as have more time for esterification to take place in the boiler which I think produces a better spirit. I like a generous cut (not super wide or narrow) to get the late heads and early tails which give the whiskey it's unique flavor that will develop as it ages. Hell, I'd even barrel up late heads and early tails (separately) once in a while to use for back blending later after aging which can turn out spectacular on their own. I like rerunning feints with heavy oils skimmed off or separated. I'd strip down to at least 10% on the strip run (adjust as needed) so that the spirit run ABV is just about perfect for aging without having to dilute. I doubt there is anything new here. I'd rather produce less product of higher quality and price it accordingly.
  22. 1 point
    Thanks for joining. It will be interesting to see your opinions on things. That's a really good idea. I didn't think that the LCP would bring over flavor from the wood as it's turned to charcoal. Definitely something to experiment with. See, you've change craft distilling with a single post.
  23. 1 point
    Being able to adjust your reflux condenser temps on the fly makes exploring whiskey heads technique fairly interesting, especially if you have a few plates to play with. For example, running high reflux to stack heads, slow take off >190pf, then flipping off the reflux condenser entirely and shifting to quasi-pot mode. You can get the product yield efficiency of a column, and the flavor profile of a pot.
  24. 1 point
    The irony of arguing about a heads cut in a topic started by a brandy distiller. Heads? That's not heads, that's flavor.
  25. 1 point
    As quinoa is one of the least-utilized grains in alcohol production, we thought we'd give it a go. I thought I'd share some of our experience trying to make a go of it, since so little is out there. We experimented with quinoa as an adjunct, flavoring grain, in a predominantly corn mash bill. Even in smaller quantities, quinoa dominates the aroma and flavor. It has an incredibly distinctive nose, and if you've ever cooked quinoa at home, eaten quinoa, you'll be familiar with it, because that aroma dominates the distillate. I really need to emphasize this, we talk about tasing and smelling aromas of the underlying base grains in whiskies, corn, wheat, this is an entirely different level. The distillate is amplified quinoa. It permeates. Everything. Clothes. Hair. Quinoa. Everywhere. As terrible as it sounds, there is this very redeeming nutty, caramel, chocolate, roasty flavor. Doing some research, I came across some old brewing articles that referenced 2-pentylfuran as being a key contributor to the quinoa aroma. 2-pentylfuran not very common among conventional grain, but prevalent in some of the ancient grains (Kamut). Also very common as a Malliard reaction output, common in other roasted items like bread, coffee, chocolate. It's a really appealing profile. We tried experimenting a bit with chocolate, coffee - the problem is they amplify the flavor profile to the point at which the distillate starts to get this kind of savory flavor profile (think the savory aspect of a roast). Very interesting, screws with your mind, because there is something, almost a kind of umami, in the flavor profile of the distillate. In the end we gave up on trying to build a corn-based mash bill - it was impossible to dial back the quinoa impact without distilling far above 160. After a few more trials, we started to like distilled far cleaner. Ultimately we decided to go 100% quinoa, and use the very unpopular light whiskey category, stripping, then distilling it a hair above 180 proof. It's still choc-ful of quinoa flavor, very, very strong. However, much more approachable as a whiskey. Went to sleep in some fresh dump used char-4s. Operationally, quinoa is incredibly difficult to work with. The tiny size makes milling very, very difficult. We couldn't get a tight enough gap on the roller mill to get a good crack, the 1/8th inch screen on the hammer mill really didn't do a good job. The flour screen we have on the mill is painfully slow, and is a dusty mess. If you look at the structure of quinoa, it's a little different from a typical cereal grain. There isn't a big pocket of starch, with the germ off to the end. The starch is encapsulated at the center of the quinoa seed. The tiny size, the grain structure, made the cereal mash among the worst we've ever mashed. It simply does not mash. We held it in the 190-195 range for more than 6 hours, impossible to get a negative starch test. We ended up letting the cook go overnight, yes, overnight. In the morning, still could not get a negative starch test. Lots of high temp alpha amylase, glucoamylase, beta glucanase, protease, xylanase - we finally decided to call it quits and cool to pitch. The best we can surmise is that without milling it to micron-sized flour, the tight pocket of starch gets trapped by the seed structure, and slowly "leaks" out as it hydrolyzes. Anyone who thinks that protracted cooking will simply cause the seed to expand, burst, and fall apart - nope, sorry, there was still obvious whole quinoa particles in the mash, after nearly 18 hours of cooking. We didn't notice it so obviously during the test batches, however most of the test batches were corn-predominant, so the lower-yield wasn't as obvious. Yield was mostly terrible. 1200 pounds of quinoa in, roughly 35 proof gallons out. We fermented down to about 1.01, on the grain, with active enzyme. What was really interesting was the amount of bulk that was remaining in the mash. Attribute this to the much lower starch content of quinoa relative to other grains. We had another 1200 pounds of quinoa for batch 2, we decided to give it to our farmer as feed. The effort involved is simply not worth it. To get any chance of reasonable yield, we'd need to have gone to fine flour, even then I think we'd be dealing with an impossible to dewater stillage/sludge. We'll see how the distillate ends up, I think there will be fans, but ultimately, it'll be a very polarizing whiskey. Maybe I'll be wrong, and maybe it'll be fabulous, and maybe I'll regret giving away a metric ton of quinoa as goat feed (they love it by the way). That said, if you really want to try it, go for it. You'd probably get enough impact with as little as 5% of the mash bill - given the high price of quinoa, it's a much more cost effective approach. The most difficult grain we've ever worked with, and we've worked with Millet (Size challenges) and Whole Oats (worse than rye)
  26. 1 point
    Georgeous - The American whiskey industry uses the term "beer gallons" to describe mash thickness for grain-in fermentation and distillation of things like corn, rye, wheat and malt. The reason for this, is most equipment and process can handle one level of mash thickness, and scaling up or down or comparing yields from plant to plant or recipe to recipe is much easier done this way. A beer gallon is the total volume of liquid per bushel. Big distilleries typically run a 28 to 35 gallon beer. We run a 30 gallon beer, and hit a starting gravity around 1.065. So, for 500 gallons of finished mash, we start with 16 and 2/3rds bushels. This is important as bushels are a measure of volume, not weight, and we are working in volumes here. So this means my mash with 61 lb/bushel corn has more pounds of corn than if I used 56 lb/bushel corn, yet it has the same thickness so I know my pumps, agitators, exchangers and hoses can handle it. We start with about 380 gallons of 90 degree F water, and use live steam inject to add about another 55 or 60 gallons worth of water getting it to high temp. With the grain we hit 500 gallons +/- 5 or 10 every time. So for your 600 gallon recipe, as a 30 gallon beer, would be 20 bushels. (20*75%) 15 bushels of corn times its test weight (56 is average, but you should test your grain) = 840 lbs (20*21%) 4.2 bushels of rye (54 is average, again should test) = 227 lbs (20*4%) .8 bushels of malt (38 is average) = 30.4 lbs of malt Use about 528 gallons of water (less the appropriate amount of steam if using steam sparge) These weights are for field grains, not flaked. I'd also recommend starting with a 30 gallon beer and see how your equipment runs it, and thicken/thin it out based off experience. We test all of our grains upon receiving, and update our mashbill in pounds to match the new test weight.
  27. 1 point
    Jason schnapp is a complete jackass. Most of his stuff is resale Still Dragon parts. Some of the pieces we got were clearly already used and damaged/ broken. I generally would not make such a poor review of anyone, but he screwed us out of a lot of money when we made an accidental overpayment on an expensive two column system that we bought from him. Instead of refunding the obvious overpayment back to us, he actually told us to go f*** ourselves. We have copies of checks and invoices to prove the error was his, but we don't have an attorney in Missouri. We have had problems with nearly every single piece of our order. One of the controller's had to be sent back because it didn't work, several of the PID cables are bad, the heating elements are underpowered, the dephleg does not circulate enough water to hold the column in reflux, he ships equipment in bad packaging so that it is damaged during shipment (and then expects you to pay for the repair). Basically just stay as far away as you can. If anyone else has had a similar experience and is interested in a class action suit against him, we would be interested to talk to you.
  28. 0 points
    Bringing WHO formula 1 to mind is a very valuable addition to this thread. 80% ABV, 1.45% glycerol, 0.125% hydrogen peroxide. Made from 96% ethanol, 98% pure glycerol, and 3% hydrogen peroxide. I call upon everyone that reads this thread and considers producing hand-sanitizer to strictly follow their national/regional guidelines! I added a warning to the original post to do so. Regards, Odin
  29. 0 points
    As I said somewhere a long time ago in this now too long thread, DISCUS and its likes are better able to deal with this by playing above the rim than a pipsqueak like me is. I'm copying, below, two documents from the Distilled Spirits Council's website. https://www.distilledspirits.org/news/discus-statement-on-u-s-reps-yarmuth-barr-letter-to-fda-commissioner-urging-flexibility-for-distilleries-producing-hand-sanitizer/ One is a letter members of congress have sent to the FDA on this issue. The other is the councils statement on the letter.. It's time to let the big boys play. I'll have one more post on the matter of things other than hand sanitizers and then I'm retiring. I never want to hear the word hand sanitizer again :-). I wash my hands of it, so to say. DISCUS Statement on U.S. Reps. Yarmuth, Barr letter to FDA Commissioner Urging Flexibility for Distilleries Producing Hand Sanitizer March 29, 2020 1:05 pm Statement by Distilled Spirits Council of the United States President & CEO Chris Swonger on a letter sent by Co-chairs of the Congressional Bourbon Caucus Chairman John Yarmuth and Congressman Andy Barr and 85 members of the House of Representatives to U.S. Food and Drug Administration Commissioner Stephen Hahn urging the agency to update its guidance to recognize the use of undenatured alcohol in the production of hand sanitizer during the COVID-19 health crisis: “Distillers across the country are jumping in to produce hand sanitizer for first responders, hospitals and those in need in their communities. The recently-passed CARES Act includes an important provision to guard distillers from having to pay federal excise taxes on the alcohol used. Unfortunately, FDA must first update their guidance to permit distillers to use undenatured alcohol, which is recommended by WHO and is the type of alcohol distillers readily have on hand. We appreciate the support of Chairman Yarmuth, Congressman Barr and the 85 House members in calling on the FDA to be more flexible during this crisis so we can get hand sanitizer to those who need it most. The Distilled Spirits Council of the United States is committed to working with the FDA to explore appropriate ways to address any safety concerns.” BACKGROUND: For weeks DISCUS has been urging FDA to update its Guidance to permit distillers to use undenatured alcohol in its hand sanitizer formula as directed by the WHO Guidance. Most beverage alcohol companies exclusively make products with undenatured alcohol and may not be able to access the required denaturing materials. Denatured spirits are those that are treated with bittering agents to make them unsuitable for human beverage consumption. DISCUS has raised concerns with FDA regarding potential shortages of denaturing ingredients as well as the effect the denaturing materials may have on distilling equipment. Due to the highly concentrated nature and toxicity of the bittering agents, these components are very persistent and distillers may have to develop a special cleaning method to remove them before beverage grade product can be reintroduced. Requiring denaturing could also significantly increase the amount of time it takes to produce this product and get it to those who need it now. The WHO Formula is a very high proof alcohol with hydrogen peroxide, which is less palatable than other denatured products currently on the market. Thus, further bittering should not be needed, particularly in light of the present need. ### ____________________ Friday, March 27, 2020 The Honorable Stephen Hahn Commissioner U.S. Food and Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 Dear Commissioner Hahn: We write regarding the U.S. Food and Drug Administration’s (FDA) guidance to manufacturers who are producing hand sanitizer as part of the COVID-19 crisis. As you know, hundreds of distilled spirits producers across the country have immediately responded to the current health crisis by halting their regular operations and quickly turning to the production of hand sanitizer. These distillers are fulfilling a critical need in their communities and providing the hand sanitizer to health care professionals, first responders, and local and state governments. They have diligently followed the guidance released by their regulator, the Alcohol, Tobacco Tax and Trade Bureau (TTB), and are producing hand sanitizer according to the World Health Organization’s (WHO) formula. Unfortunately, the FDA’s “Temporary Policy for Manufacture of Alcohol for Incorporation Into Alcohol-Based Hand Sanitizer Products During the Public Health Emergency (COVID-19): Guidance for Industry” does not acknowledge the reality that these distillers have stepped up in a time of crisis to produce hand sanitizer using the alcohol they have readily available, which is undenatured. Undenatured alcohol is food grade alcohol that is compliant with the WHO’s hand sanitizer formula and has the same effectiveness as denatured alcohol. The United States largely differentiates between the two types of alcohol for tax purposes – with undenatured alcohol incurring the distilled spirits Federal Excise Tax (FET) and paid to the federal government. A provision was included in the recently-passed COVID-relief package that would temporarily remove the Federal Excise Tax on hand sanitizer production as long as the distiller has followed FDA guidance. Through the current guidance, the FDA is standing in the way of hundreds of thousands of gallons of hand sanitizer from being produced and given to those on the front lines battling this pandemic. We have a responsibility to provide more resources to help flatten the curve and alleviating this burden would allow distilleries the opportunity to step up and help their communities. We strongly urge the agency to update its guidance to recognize the use of undenatured alcohol in the production of hand sanitizer during the COVID-19 health crisis and work with industry on reasonable safeguards to keep hand sanitizer out of the hands of children. This will ensure distillers do not face a tax bill for filling a vital need in their communities. Sincerely, _________________________ _________________________ John Yarmuth Andy Barr Member of Congress Member of Congress
  30. 0 points
    Yo Doc - That's what I meant. I am absolutely against any deviation whatsoever.
  31. 0 points
    Legal denaturants: https://www.law.cornell.edu/cfr/text/27/21.151 I'm starting this thread for people denaturing their product for use as hand sanitizer. I heard that the TTB is taxing GNS put in the WHO formula hand sanitizer unless it is denatured. Given that glycerin is on the list I don't understand that but it's not my call. I personally have no experience with this so I do not know what to use. If there's someone out there than can share this info please do. We do have to watch that whatever denaturant is used that it's as odorless and colorless as possible, not an allergen, and is safe on skin at whatever % is required for legal denaturing. I would rather use the FET money to buy more raw materials for hand sanitizer.
  32. 0 points
    We were lucky to get 200 2 gallon jugs donated by a local packaging supplier. We asked and they were happy to help out.
  33. 0 points
    https://www.ttb.gov/public-guidance/ttb-pg-2020-1a TTB Public Guidance Production of Hand Sanitizer to Address the COVID-19 Pandemic March 26, 2020 TTB G 2020-1A Summary Tax-free ethanol may be used to produce hand sanitizer if it is denatured according to TTB regulations and Food and Drug Administration (FDA) guidance. Alcohol, whether or not denatured, may be delivered tax-free to state and local governments for non-beverage purposes. The same is true for hospitals, blood banks, sanitariums, certain pathological laboratories, non-profit clinics, and qualifying educational institutions, if not for resale or use in the manufacture of any product for sale. TTB is temporarily waiving certain formula approvals for the manufacture of hand sanitizer using and expediting certain permit requirements. --- It goes on to clarify these items and mention this document dated March 26 supersedes other guidance and refers you to the FDA document "Temporary Policy for Preparation of Certain Alcohol-Based Hand Sanitizer Products During the Public Health Emergency (COVID-191) Guidance for Industry" for formulation, registration, denaturing, etc. It is available here: https://www.fda.gov/media/136289/download NOTE: This document was updated on March 27, 2020 (yes after the TTB bulletin). This document lists 8 steps to produce sanitizer including registration with the FDA. You must meet all 8 steps including labeling with their specific label requirements. What you make is considered "non sterile" sanitizer which may be of limited use to hospitals or sterile environments. This product is designed and labeled for consumer and health care personnel only it seems. With the updated wording today step 1 wording changed from something like "USP Alcohol" to now giving a list of ingredients that actually allows Glycerin of USP or Food Grade Index use. Hydrogen Peroxide Concentrate USP or Hydrogen Peroxide Topical Solution USP (see footnote) which probably isn't a big deal either. Step 2 covers denaturing and states Formula 40A or 40B with or without the tert-butyl alcohol from TTB Bureau regulations in 27 CFR part 20 and 21. https://www.ttb.gov/other/regulations §21.75 Formula No. 40-A. (a) Formula. To every 100 gallons of alcohol add: One pound of sucrose octaacetate and 1⁄8 gallon of tert-butyl alcohol. (b) Authorized uses. (1) As a solvent: 111. Hair and scalp preparations. 112. Bay rum. 113. Lotions and creams (hand, face, and body). 114. Deodorants (body). 121. Perfumes and perfume tinctures. 122. Toilet waters and colognes. 141. Shampoos. 142. Soaps and bath preparations. 210. External pharmaceuticals, not U.S.P. or N.F. 410. Disinfectants, insecticides, fungicides, and other biocides. 450. Cleaning solutions (including household detergents). 470. Theater sprays, incense, and room deodorants. (2) Miscellaneous uses: 812. Product development and pilot plant uses (own use only). §21.76 Formula No. 40-B. (a) Formula. To every 100 gallons of alcohol add: One-sixteenth avoirdupois ounce of denatonium benzoate, N.F., and 1⁄8 gallon of tert-butyl alcohol. (b) Authorized uses. (1) As a solvent: 052. Inks. 111. Hair and scalp preparations. 112. Bay rum. 113. Lotions and creams (hand, face, and body). 114. Deodorants (body). 121. Perfumes and perfume tinctures. 122. Toilet waters and colognes. 141. Shampoos. 142. Soaps and bath preparations. 210. External pharmaceuticals, not U.S.P. or N.F. 410. Disinfectants, insecticides, fungicides, and other biocides. 450. Cleaning solutions (including household detergents). 470. Theater sprays, incense, and room deodorants. 485. Miscellaneous solutions. (2) Miscellaneous uses: 812. Product development and pilot plant uses (own use only). ======================== So I've highlighted/bolded things that stood out to me. We are now clearly making a non sterile product and some rules are more lax. It does not appear we need to use USP grade products to denature now due to the update they just did. I would not sell the product with further clarification as it could change your taxes/bond etc as the new bulletins aren't the clearest on this at least to me. With this new wording I would not be afraid to use "normal" products for denaturing (meaning cheaper) per TTB 40A & 40B above which the FDA is allowing for this CONSUMER product. But with the FDA taking charge of the "rules" of how the product is made, please make sure to read that bulletin and make sure to follow all 8 steps including FDA registration and labeling for sure. Wish I could be more help, but that's it for now from me. What I am curious about is how the TTB/FDA will handle people making products that are not denatured and haven't registered with the FDA since there was a brief period where this was allowed? Hopefully in good faith if product is being given away!
  34. 0 points
    Is your math wrong or is mine? Preferred formula for 100 gallons is 1/16 avoirdupois ounce (28.35 grams) denatonium benzoate. 28.35/16=1.77 grams per 100 gallons So 50 grams should be enough for 2820 gallons, not 282. Also I straight up cannot find a USP grade source for denatonium benzoate. Only source I've found is "for research use only" and specifically not FDA certified. Any leads?
  35. 0 points
    While I can't speak to label donations at this time, I can tell you our crew and presses are running 24/7 putting their own safety at stake, making every effort to get these labels out quickly. We have not been asked for donated labels that I am aware of. In speaking with friends at other label companies, they are conducting business as usual with hand sanitizer labels. We do have hundreds of cutting dies in house that can be used and our turn times are excellent considering all we have going on!
  36. 0 points
    Just about an hour ago (weds night) they finally passed the bill and it includes some pretty nice language: No federal excise tax for the entirety of 2020 spirit removals for hand sanitizer. Even bigger is that all you have to do is follow WHO. AND bulk sales / labeling requirements are waived. For once - some decent legislation. Thank goodness. House is supposed to vote on this on Friday AM so CALL YOUR REPS although one would hope this is a no-brainer. Source: https://files.taxfoundation.org/20200325223111/FINAL-FINAL-CARES-ACT.pdf (pg 212-213)
  37. 0 points
    Add questions about guidance for reporting which really hasn't been given much detail and will cause problems later for many DSPs not sure of how to report transactions. Would the federal government be willing supply ingredients & bottles (maybe under FEMA) to DSPs who can supply equipment and labor to turn raw ingredients into products? After all the federal government should be able to purchase in massive bulk and transport it as well streamlining the process.
  38. 0 points
    Yeah absolutely not. We're making what we can afford to give away (not hundreds of gallons) because I can't find anywhere that says we're even allowed to sell it. Is anyone aware of any literature stating we're allowed to sell it? If that were the case, we could produce a lot more. We don't even have our spirits available to the public yet, so definitely can't afford to just switch to a hand sanitizer production facility.
  39. 0 points
    No idea how many bottles you need to make but if you have or can throw a keg reflux still together you could likely run this while doing other things. If you made a 15% sugar wash with enzymes and ran 14 gallons at a time you could produce approximately 5.5 to 6 liters a run on a keg still. Depending on work day could likely get 2 runs in even on a small Hobby size still and produce 11 to 12 liters of ethanol per day. If you follow the WHO recipe 1 from https://www.who.int/gpsc/5may/Guide_to_Local_Production.pdf you would end up with about of 6 liters of sanitizer per run. If you package that up in 8 oz to 250mL bottles of some kind you get 26 to 27 bottles from each run. Not going to be setting the world on fire but it's better than nothing and might be able to keep local police, fire fighters/rescue squads, etc in stock and allow them to divvy up what you produce. Of course those numbers could double if doing two runs a day on a hobby/home size still easily. This amount would be easy to keep up with fermentations using just a couple of brute trash cans you could use to not bother other operations. If you did 2 runs a day that's 50 bottles a day x 5 working days or 250 bottles a week. That's not insignificant in some communities as every bottles helps especially when it goes to the right people who have no choice but to be around other people. Of course if you have a bigger reflux still available the numbers climb quickly. If you have an old pot still you could strip first, then you could put higher ABV in the reflux still, etc... Keep in mind you don't have to be making 100 bottles an hour to be helping the community, just do what you can, using the equipment you already have or can throw together for this purpose quickly and see that the bottles you are making go to those who need it most. Just food for thought.
  40. 0 points
    Records and Reports My brain is fried. I will provide information on records and reports soon. In the meantime, keep a log of what you do. Show all gauges that you make, the quantity of ingredients that you use to compound the sanitize (dump/batch record), the proof of the sanitizer you package (bottling tank and gauge record), the size of the containers into which you package it, the numbers of containers per case, the serial numbers that you place on those cases, the number of cases that you fill (bottling record), the cases or other packages that you remove and the person to whom you sold them (tax determination record), which may be an invoice from your normal sequence or a separate shipping record, each of which has a unique serial number. I've probably omitted one or more pieces of information you should be capturing. I'll try and get this done with some rigor sometime this coming week.
  41. 0 points
    Great, @dhdunbar, I think you answered my question: we can, in principle as a DSP, make the product. And, if the FDA, as I read it, requires us to denature it, we can do so, even without special permits, so long as we follow CFR normal rules for doing so. Practically, how should we denature it to meet the requirements? The WHO does not requires us to denature it, but FDA does, but does not indicate which formula we should use. Do you have a recommendation for which formula (I am still trying to read through the relevant CFR sections to understand that)? And if we denature that, how do we, as a DSP, report that change in our monthlies? And when/how do we remove that from bond, to distribute that?
  42. 0 points
    For even easier math: http://letsmakesomesanitizer.com/
  43. 0 points
    Seems everyone is jumping on the sanitized band wagon around here , so we contacted our lawyer for advice . After looking into the legal implication he has advised us to not get involved , the simple answer is we are not licenced to make pharmaceuticals. We are also not qualified or trained to make such products , one simple mistake and were wide open for a law suit . We are invested in this distillery with years of work and close to 2 million dollars , were not risking that to start making home made hand sanitizer . Thats our take on situation .
  44. 0 points
    I use temperature monitoring all the time. It's one of the things I look at, but not the only one. In the case of a spirit run, I'm also looking at the parrot hydrometer, the run time, and the output volume or weight. However the most important factor is taste. Recognizing the characteristic flavors of heads, hearts, and tails is the most important part of making good cuts. Flavor recognition is particularly important in experimental runs. Now, in the case of a stripping run, you don't need to taste the output and can go by vapor temperature, the parrot hydrometer, and run time. Temperature monitoring is also very important in mashing and making wash.
  45. 0 points
    Watch it Silk City Distillers, you're giving away the Tito's formula. I don't think I'd load a pot still with 190 proof spirit, but would dilute it down to at least 60%, but that's just me. Since Vodka is normally 60% water and 40% alcohol the water used becomes an important part of your final taste. This would give you a chance to play with different water profiles used to dilute the spirit prior to running. A mineral rich water for example will leave most of the minerals in the pot, but by default some will make it through giving your product something slightly unique compared to other bottles on the shelf. It will leave it a different mouth feel compared to dilution with RO or distilled water (good or bad). The starting ABV,, the water used to dilute and the speed of the run (natural reflux) will all affect the profile of the vodka produced and is worth playing with a bit if you go down this route of starting with GNS and rerunning it in a plain old pot still. Even the temperature of the cooling water will come into play on the profile of the spirit. Colder water will condense the vapor faster at the start of the condenser vs warmer water that allows the vapor to travel further down the condenser before it cools to a liquid. Of course the water used to dilute the spirit to 80 proof (bottle proof) will play a huge amount in the final profile as well. Even if you never intend to produce vodka this way, it's a great set of experiments to run with neutral to see how these changes affect the profile of the spirit being made which you can then apply to your brown or other flavored spirits. People who make gin in a pot still for example know the difference the initial charge makes (all else being equal) and a 30% vs a 45% charge makes a different spirit with one being "more dry" than the other. Of course the botanicals come into play (like any flavor) but this holds true for neutral as well to a limited amount.
  46. 0 points
    You can. Depends what you are distilling from. If you are distilling from fermented mash, rather than clear beer, you might have to worry about fouling the first plate. But since you mentioned you are using a wash, that might not be a problem, especially if you use antifoam. More of a challenge might be getting below the 160 proof for a whiskey, but getting the desired flavors. Our still, with 10% wash, will produce over 175 proof with 4 plates. I can drop down to 2 plates and get down to 160, but I won't get a clean enough product or good enough separation on cuts. By doing a double or triple run method, since you are usually rediluting the product between runs, you can stay below 160 proof on the final distillate, but get a cleaner, better separated product. YMMV. BTW, when making product that does not have the 160 proof limit, we usually do run our still with 4 plates and a single run. But for our whiskies, we remove the plates, and double distill. Again, YMMV.
  47. 0 points
    Hello, We are looking to sell our contract for Stills currently being built by Vendome. This is a full DSP build out inclusive of all the equipment needed for a full production DSP. Cooker, Fermenters, Stripping Still, Hybrid Still, Vodka Column, Holding tanks, FIP Pump, HHT Tank, Gin Still, etc. Contact me for details and pricing. The build is due to be completed in January! David Alexander 318-465-6523 David@700cotton.com
  48. 0 points
    I am considering attending Moonshine University’s “6-Day Distiller Course” and would like to ask if any ADI Forum Members have any feedback about Moonshine University and/or their “6-Day Distiller Course”. Is it worth the $6250? Is it more of a sales pitch to use their instructors as consultants or do they really stick to the technical side of the training and remain unbiased around the sales pitch? It seems like it could be an awesome course and jam packed with many great topics. Just trying to get some feedback before spending the money. Thanks in advance for your comments.
  49. 0 points
    All I can say at 62 yo and selfemployed for 44 of them is I have always lead by example. Set the tone of your company. This can only be done if you are proficient in the tasks at hand. People want to get into this business because they want to run a still. Wrong reason in my option. This business is 15% production (a young persons position), 5% facility mantiance, 5% logistics, 15% hospitality and 60% sales and marketing. So with that, this is actually a sales and marketing business that people find themselves in. BTW doing production is physically more demanding than sales and marketing any day..... To clear things up these are the definitions that we use for staff and S&M positions. Brand Ambassador - Marketing; someone that promotes the brand and educates the end consumer. Sales Person - Sales; someone that sells and promotes your products through your on premise and off premise distribution network. Inside Staff - Hospiality; someone that bartends, does tastings & tours, cleans, and is the smiling face of the physicsial distillery. So, if you can find someone or several as we have that can do all 3 proficiently pay them as much as you can afford! So now back to the question at hand. Distrubtiors are the UPS/FedEx of your sales distrubtion. In reality they will just deliver your product for a huge fee. (Part of the business model). You are the only one (owners) that will sell in reality. If you don’t, can’t or want to sell your products then you need to employ a substitute for yourself. How much are you worth? How much would you want to be paid to do a stellar job selling your product. And how much can your company afford to pay for your replacement? These are the true questions you need to ask yourself. Not others. Each company has a different overhead cost and demands on real or implied margins. We calculate $35 of the case profit for S&M support efforts. I have seen some figures go as high as $110 per case for a period of time to open a new market. Ouch! From time to time we will use non staff (ambassadors) to help out with events and they usually get $15-$20 per hour for the event and usually a nice dinner or lunch prior and maybe a drink after. Always build camaraderie. And in closing, don’t forget in business “you get what you pay for” and you “only get back what effort you put in”. Go full tilt buggy and sell, sell, sell!
  50. 0 points
    Technically... If you were making a true Agricole and I'm sure you are trying to, you wouldn't heat or dilute the cane juice at all. You use the natural starting SG and just wait. Personally I heat mine 120F to kill off the local yeast and not high enough to change the flavor. I agree with Odin, I have a bakers yeast sugar cane wash going right now the only thing is it's very slow.
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