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  1. 2 points
    This is an interesting thread to which I will bring a dose of oh god the boredom of regulation. You make a production gauge. When you do so you have to designate the product. Assume the production methods used meet the production procedures (19.77) you have on file for for bourbon, corn whiskey, and whiskey distilled from bourbon mash and also meet the the grain/proof standards (80% or more corn at not more than 160) for each. Once produced, you must immediately make a production gauge (19.304). The rules for production gauges state, "Spirits in each receiving tank will be gauged before any reduction in proof and both before and after each removal of spirits." (19.289). I read this to say that you can can have more than one removal of spirits ("each removal") from a receiving tank - or more than one receiving tank ("each receiving tank"). So, let's assume, in either case, three gauges, each of which is deemed a separate production gauge (19.304). I see nothing that prohibits you from entering two of those to the storage account, where you put them into a stainless tank and cut them to 125 or less - this must be done after the production gauge (19.289), designating the first "bourbon designate" and the second "whiskey distilled from bourbon mash designate" (19.305). Then, you transfer (19.324) the first to new charred and the second to used oak as "bourbon" and "whiskey distilled from bourbon mash," respectively, and proceed through a nanosecond or more to create age. The spirits in the third gauge go directly to processing, where you bottle them as unaged corn whiskey. I see nothing in the regulations that prohibit that and 19.304, 305, .324 and .289 seem to authorize it. At the least, it would be an interesting challenge to a TTB investigator or auditor who sought to challenge what you did. I think they would lose the argument that you violated any provision of the regulations. The caveat is that your records would have to include the gauge record (19.618 and 19.619) for each of the three production gauges, showing the quantity and designation in each case, and create the trail that would establish that the products are eligible for the designations you give them. Note that I have not mentioned a formula once, although someone's comment above that you have to have a formula for bourbon is correct, not to show what you did to it, but to show that you did nothing to it that would change the class and type under the special rules that apply to bourbon and not to other American type whiskeys. Now, the above discussions about the methods and procedures you use to create the spirits are a lot more interesting, but wasn't the original question :-).
  2. 1 point
    My opinion on this is that as a buyer of equipment, first, I need an equipment manufacture that is up to speed on the current certification code compliance. Then I want to be educated on the value proposition for decisions. I need you to be the expert and help me the customer understand what you think I need and the trade offs for less or more features... what you are doing in this post. Paying more is fine if it makes sense and is a value to me. I would also advise you to think about your market and what you want your brand to represent... and just be committed, convicted and passionate about what you decide. Can you be a lower-cost equipment manufacture while also being tops in safety code compliance? Maybe. But it will certainly create some challenges. Low cost buyers are sometimes willing to take risks on product quality. Just check out those Walmart buyers acquiring inexpensive Chinese-made appliances... things that they could not afford otherwise... so the binary decision they have to make is to go without, or take a chance on the cheap Chinese brands. Some roll the dice. Maybe you don’t want those cheaper product risk-takers as customers? As you point out there are plenty of still manufacturers creating inexpensive systems. Maybe your market sweet spot is above them and below those willing to spend twice as much on Vendome and wait for 2 years for it to be delivered. I am not saying you are a cheap Chinese brand... far from it. You have already established a brand of affordable AND reliable/quality equipment. So maybe you add to that “safe” to that. Affordable, Reliable and Safe! Personally, I believe some distillery equipment manufacturers have jacked their prices due to the craft distillery fever. I appreciate that you have taking an approach to keep your margins consistent and focus on value and customer service. It is my opinion that this is the approach that wins the long-game. Those built on hype and greed will crash when the fever ends. Lastly, I think there is some great responsibility for still manufacturers to over-engineer safety features. Especially with all the craft distillery fever... because so many dreamers without experience are going to be creating highly flammable vapors that can kill them and others around them.
  3. 1 point
    I'm not sure what anyone would have patented other than a unique process in using UV. Using UV and US on spirits have been around prior to 1962. I would think you are able to try anything with either except the unique process that has been patented if you could find it out. http://hilgardia.ucanr.edu/fileaccess.cfm?article=152560&p=AXWYZG
  4. 0 points
    I added a few relevant case studies: The first was birectifier examination of a historic gin. The gin was Hiram Walker 5 0'Clock gin from the early 1940's. This was made under the tenure of Herman Willkie and Paul Kolachov. The second was a look at 1970's Cointreau. A fascinating part of this case study was seeing the auxiliary botanicals show up in fraction 5 very much like gin. You get an idea of how much weight they should have. The orange aroma gets spread out across fractions better than I thought making it practical to assess organoleptically. There was no detectable louching in the first fractoin which shows they took terpene removal seriously. Sugars did not interfere with the process at all if the 8th fraction went uncollected. Next up more gins and green chartreuse?
  5. 0 points
    I've got to get to work, but ... Part IV is where TTB collects the information it uses to prepare its statistical reports. Period. I think it has no other use; at least I don't see how it fits into an audit, because I don't see the way to establish an audit trail. Part 1 of the form reports bulk ingredients, as does part IV, column b. So the total dumped in cell 6(b) should equal the total dumped in cell 67(b). But what does that prove? Nothing. I don't know what purpose the comparison makes and the part IV data seems to have no sue other than to inform industry, or any others who may want to know, how many proof gallons of blended light whiskey, for example, were dumped in the month of June. It is purely statistical, but the total of all commodities can can compared to the total dumped. But there is no way to compare the part 2 and part 4 bottled entries. One is in wine gallon s and one in proof gallons. So, unless you bottle everything at the same proof, there is no way to reconcile the two figures short of converting proof gallons to wine gallons from the bottling records. "For what reason?" is a rhetorical question. What you want to ensure is that the dump records for the processing account total to the quantities you show as dumped into the account on the operating report and that the records create a trail back to the materials from which produced, so you have evidence in support of label claim.
  6. 0 points
    Did I mention I don't deal in either COLA or formula submissions? There are reasons for that. Label questions are complicated. Since it appears to the internal controls to ensure that all employees act consistently, the employees sometimes (often/usually) bring their own rules to the game. When people start applying personal interpretations, things are not only complicated, they are complex. You can reason through complicated, but things that are complex are unpredictable. That said - here is a basic rule - don't worry about things like whiskey specialties not being included in some list that lacks the authority of regulation. I repeat, don't worry about that, unless, of course, you must. Let me explain how I reach that conclusion: TTB classifies as TTB will. I lump that into the category of things that "are because TTB says they are" and dismiss the idea of arguing unless necessary.. The numbering system is an unnecessary hodgepodge. So too all those BAM tables. (Yea, a pun does lurk in the homonym suggested). The basic rule YOU follow is you must designate the class and type on the label (5.32). The rules for class and type statements are in 5.35. It provides that if a product does not comport to a standard of identity (5.22), then it is a specialty item and must be labeled as required by 5.35. Applying the rule, what TTB deems a "whisky specialty" is not, in TTB's opinion, a whiskey and does not comport to other standards in 5.22. Now, 5.22 includes a number of class and type standards for products that can include bourbon, or straight bourbon. These include bourbon (5.22(b)(1); a couple of blend variants (5.22(b)(4) and 5.22(b)(5)i)); bourbon liqueurs (5.22(h)(2)); and flavored bourbon (5.22(i)). Add to that the specialties (5.35), which may in some cases be designated in accordance with trade and consumer understanding, and it is a daunting potpourri. I'm not sure how many TTB specialists understand how to split those hairs. And if they can't, how can you or I. But split them, they do, into all those number categories and lists like you find in the BAM and which you may, for most purposes, ignore. Okay, you may need them to determine whether you need a pre-COLA evaluation, but other than that, let TTB deal with it. So, that is how I arrive at the conclusion that is usually best to let TTB sort it out and accept what they say. If what they say somehow takes an iron pipe to the knees of your plans, you can argue with them,. However, given a label approval, in hand, like the one for Parkers discussed above, do you really care how TTB categorizes it as long as they approve it? What difference does it make if they enter 641, 732, or the square root of the average distance to the moon.The only practical difference, it seems, is how you report it on the back of the processing report, which is info TTB collects solely for the purpose of publishing the statistical reports that congress requires. What can be interesting is disagreement between the label people and the formula people. With that I return to, "Did I mention that I don't submit formula or COLA applications? And yes, I know you must. But the best I can do is advise you how to try to maintain sanity while doing that.
  7. 0 points
    It's been a little while since we gave ADI an update, but for those who aren't already subscribers, we've got a few more episodes out!!!! As always we appreciate any feedback, show idea, guests you want to hear...you name it!!! you can reach us here, on our site, or directly at info.stilltalking@gmail.com Ep 14 - Origin Stories https://stilltalkingpodcast.com/ep-14-origin-stories/ The guys talk about their origin stories in the industry. Kind of like all that superhero shit, but way less badass. Insider tip: there is a bit of extra content at the end. Listen all the way through for a bonus story about Brian’s time in the funeral business. Ep 15 – TheConsumer https://stilltalkingpodcast.com/ep15-theconsumer/ an episode for the consumer, which is funny since we’re pretty clueless abut what’s going on with consumers these days. We discuss questions you should ask your bartender, why you should go on distillery tours as much as you can, and why Zeno loves a brandy old fashioned. Enjoy! Ep 16 – Men & Animals https://stilltalkingpodcast.com/ep-16-men-animals/ Mergers & Acquisitions! As the industry grows, so will instances of merging brands to larger spirits groups and sales to conglomerates. We’ve seen it in beer, and the negatives associated with it, but will the same happen in spirits? We discuss this and more on the ep. Ep 17 – Get A Lawyer https://stilltalkingpodcast.com/ep-17-get-a-lawyer/ the guys talk about Pay to Play in the distilled spirits industry. It should be noted that they are NOT experts on this issue, and if you are a distiller or distillery owner with questions on this topic, get yourself a lawyer. Otherwise, feel free to listen to three industry professionals fumble through this concept and talk about Brad Pitt some more. Enjoy! Look for us wherever you download your podcasts from and check out our website...StillTalkingPodcast And don’t forget to follow us on all the social media sites, @stillcast
  8. 0 points
    WARNING, Potential Fraud - We Pre-purchased barrels from Atlas Barrels after being cold called by them. We figured we would give a new barrel maker a chance. Barrels were promised in 6 weeks. Inquired about the barrels around 12 weeks and that is where all the problems started. First few phone calls, we were told the appropriate person would give us a call back... never happened. Finally got a call back from Remington, who we asked for our money back. Weeks later, still nothing. Called again asked to talk to Owner/CEO, never received any contact back again. Thankfully this bill was on our credit card, which we contacted the credit company as fraud, and were issued our money back from Master Card, as they would then go after Atlas. Still Atlas has never responded back.
  9. 0 points
    Having done both, it’s very hard to differentiate between backset sour mash and acidified and nutrient-dosed sweet mash. The differences are subtle. I don’t know about non-acidified mashes, because, well, why would you? I’ll leave bacterial souring out for a moment. I’ll say you can distill a cleaner whiskey from a properly mashed and fermented “sweet mash” base, this is a fact. Backset adds 4 major components to a mash: Acid - primarily carboxylic acids and primarily acetic and lactic within that category. Also propionic, butyric, etc. Nutrient - Backset is very high in nitrogen and yeast derived nutrient. High-boiling Alcohols - This is going to be the Propanols, Butanols, Isoamyl Alcohols. Water - Worth mentioning. Also worth mentioning the origin has nothing to do with hokus pokus, and everything to do with saving money. Use less water, save money on acid, utilize nutrient that would otherwise require costly wastewater processing, gaining yield along the way. From the accountant view, it’s a win win. Except, we are adding a greater amount of high boiling alcohols and carboxylic acids that would typically exist. Put those together and you get lots of ester-based flavors. Some good, some bad, but most definitely more flavors than would exist otherwise. So running tight cuts and greater separation on a Backset sour mash is going to bring you closer to sweet mash, running loose in the sweet will get you closer to sour. Bacterial sour mashing, in particular late lactic souring will result in a similar increase in carboxylic acids and corresponding esters as dosing Backset would, so realize there is a pretty interesting relationship across all these. We haven’t even touched on Backset ratios, which vary wildly across producers. I’ll look back through my literature but I believe it’s wider than 5% to 30%. So do you like 5% sour mash or 30% sour mash? Would you even know? Likewise, wooden fermenters that many of those producers use, full of bacteria, primarily lacto. So you can’t even pigeonhole these guys into one approach, because it’s both. There is no black and white here.
  10. 0 points
    Sorry, I don't agree. In Kentucky and Tennessee, bourbon is traditionally (since early 19th C) made from sour mash. Sweet mash bourbon was made BEFORE sour mashing (so it is the earliest style), and continued to be in many states where there was access to more neutral (less alkaline) water. And sweet mash actually makes GREAT bourbon, but it is different. Sour mashing originally was not done because of flavor per se, it was done as a cheap quality control method to correct pH from overly alkaline water generated from limestone springs, which had a tendency to spoil sweet-mash beers.
  11. 0 points
    Maybe I'm wrong, but I do what you are talking about. I will aggregate whiskey from multiple runs into a tank, then barrel some as bourbon and bottle some as unaged corn whiskey. Or sometimes if I am using a small barrel, will fill it with part of a run to make single batch bourbon and put the rest into the spirit tank for future bottling. On the production report I put my monthly production into the appropriate type and class; but I don't see where in law it says you have to put all of a single run into one class and leave it there. If at the end of the month I record having a bulk tank of unaged corn whiskey in storage, and then the next month I barrel half for bourbon and move the other half to processing for bottling as unaged corn whiskey, I would record that half has left storage and half remains in storage. There is no where on the storage report to record moving product already in storage into barrels. I "think" as long as each months new months production and storage are recorded as the appropriate class they are in at the end of the month then regulations are satisfied? I would think if TTB where to question the authenticy of your bourbon as bourbon, your package records for the barrel and the corresponding mash record with mash bill would satisfy the requirements. I'm sure there is someone out there with more experience than me.
  12. 0 points
    CFR 27, Chapter 1 Subchapter A Part 5 Subpart C 5.22 (ii) “Corn whisky” is whisky produced at not exceeding 160° proof from a fermented mash of not less than 80 percent corn grain, and if stored in oak containers stored at not more than 125° proof in used or uncharred new oak containers and not subjected in any manner to treatment with charred wood; and also includes mixtures of such whisky.
  13. 0 points
    Yup, that must be what is driving it. Your product is sold and marketed by Palmer's Tropical Beverages, LLC. So, if you are going to put that on as the brand, you may have to make clear the relationship of that company to your distillery. If they are one and the same, then it must be listed as a DBA for the DSP. If in fact they are NOT the same, that is where their suggestion that you label it something like "Distilled and botteld by Cotherman Distilling Company for Palmer's Tropical Beverages, LLC". It depends on the relationship of the distillery to the LLC.
  14. 0 points
    Stick to you guns! Call and ask to speak to a manager for the label division. You are correct, a brand name does not have to have anything in common with the distillery name WHATSOEVER. We have 20 different brands all distilled and sold by us, and none refer descriptively to the distillery name. As long as you have the correct "distilled by" or "produced by" identifier on the label, you should be good. You do have to worry if a brand name somehow suggests something false. For example, if there IS a registered distillery named as your brand, then you might not be able to use that name for your brand. Also, if the name suggests something descriptive that is considered misleading, then you can not use it. For example, a brand like "Rum Spring", but it is not rum.
  15. 0 points
    Kegged craft cocktails originated on my blog about ten years ago. Crappy margaritas on the gun existed, but no one had done anything with quality ingredients. I continuously learned more and updated a lot of the ideas. One of the big ones is reflux de-aeration to remove oxygen and the idea that you can un-couple enzymatic bittering of citrus from citrus oxidation. I ended up with formulations bottled in champagne magnums for more than 12 months. Reflux de-aeration is a really old imprecise term, but it basically uses the rule of partial pressures to show that dissolves co2 in a liquid can force oxygen out of solution. You can prototype formulate products with pre-bittered citrus (non-oxidized) to predict how they will evolve, but the hole thing is really just a tease. When you get to large scale products sold at wholesale margins, the ideas just aren't that viable. You cannot purchase bulk citrus juice properly processed to my knowledge. For prototyping and work for my restaurant's inhouse sales I developed a Champagne bottle manifold, a manifold style keg to champagne bottle version and then two different very affordable full enclosure systems. One is for small bottles and one is for larger sizes. They use quick disconnects and can be operated in an array of multiple units. The counter pressure designs allow the hitting dissolved gas levels well past 7g/l which is coca cola to 9g/l which is prosecco and beyond where true Champagne is sometimes 12g/l of dissolved gas. These last two products were designed for far flung resorts that needed tools to bottle carbonated products in whatever bottles they could get their hands on because they could not purchase idealized new bottles. I've shipped the tools around the world, from pro formulators to eco hotels and from Michelin starred wine programs to the top bar programs internationally. Adding to the ideas was the concept that you can measure dissolved gas with a kitchen scale so you can rapidly create progressive series for tasting panels. This makes carbonation more independent of the pressure/temp methodology and easier to make comparisons. You can work in reverse with the concept and start analyzing competitors and role models for patterns that may dictate what equipment you need. Weigh things, then de-gas, then measure liquid volume. Another formulation idea to consider is the notion of delle units for stability. Many products will want to be at the minimum of alcohol content for stability. Professor delle's concept states that units of sugar can trade for units of alcohol in contributing to stability and best bets exist. This goes further and dissolved CO2 can also participate. This is used in some really smart products on the market, but formal best bets are not known. For distillers, I recommend people start producing products for their tasting room which becomes a great focus group. A lot can be viable for those retail prices and you can learn a ton of skill sets to scale up. Weddings and general catering can be a not insignificant market. You may be working with distillates, but consider your shelf life to be that of fragile beer with a drink by date. Many formulation ideas are for bomb shelter products. A lot can be learned there, but it is not craft. Dream to make something you're truly proud of. The market is flooded with junk. People are getting paid, but I cannot imagine anyone is truly proud of some of the new carbonated canned cocktail products. Too many compromises get made when fruit juice is forced into the bomb shelter. My personal bunker has nothing but whiskey and rum.
  16. 0 points
    Hello all. A very neglected thing in the new arm of the distilling industry is analysis. Lately, I'm trying to make my focus developing a pragmatic best bang for the buck distillery laboratory. I'm hoping to learn what people are currently practicing and what they would like to take on next, even if they're only growing from a hydrometer and pH meter upwards. Lots of people are buying big ticket u-tube densitometers before they buy other tools like automatic titrators, but is that a good idea? One of my projects is trying to add pycnometry to my analysis tool set as a stepping stone before a u-tube densitometer. It is no walk in the park, but I'm getting there. The big tool that is looking like the foundation for any distillery lab is Arroyo's birectifier lab still. It can tell us incredible things about spirits and allow us to intimately compare them. As far as time goes, when manually operated it can take 2.5 hours to operate and then perhaps 20 minutes to assess the output. Is that too long for many people's busy schedules? We are hoping with automation to dramatically slash the active time it takes to operate so it can run twice a day unattended. My consulting work is showing that it can significantly shorten product development time and expense for products like gin, paying for itself quite quickly. The birectifier also allows a priceless education in the inner workings of role models and competitors. Is anyone currently using automatic titration? I'm looking at buying a model that is about $3500 from Hanna Instruments. I want to investigate the concept of Δ acidity for working with ferments that have large buffers. This is an idea first brought to my attention by Michel de Miniac in a French paper I translated. The Δ, as opposed to the pH, can imply how many acids beyond the norm of your yeast were created by bacteria. This can either be used to tell when clean spirits go dirty or perhaps when intentionally dirty products like heavy rums become a run away train. Within anyone's current experiences, would that tool pay for itself quickly? or are the learning curves of integrating the equipment another large barrier? Is there any interest in other titrations such as for fusel oil or esters and has anyone priced them out? It is surprising me that ester obsessed people are not investing in counting esters or perhaps I'm just not aware of it. Some analysis such as ester contents seem like it can be woven into marketing. Has anyone tried the exhaustive test which is a low cost rudimentary alternative to titration that works in a variety of scenarios? The Germans developed a variety of organoleptic techniques that seem really useful before shelling out the money for chemical analysis equipment. Is anyone interested in botanical assay? I have the lost Seagram procedures that I haven't done much with. They cost about $3000-$4000 to fully implement (half of that is an analytical balance). The tools required can also help perform a bunch of other tasks such as measuring barrel solid obscuration by the TTB evaporation method. Seagram used two specialty pieces of lab glass and I may start producing one of them (a modern day optimized Clevenger apparatus). Some gins are getting really successful. I'm suspecting the cost to accurately standardize botanical charges has to becoming viable for many. What are the biggest micros performing? I would love to start some discussion here, but if anyone want to discuss very specific things privately, feel free to DM me.
  17. 0 points
    The flavor profile of sour mash corn whiskey is much more suited for the barrel than sweet mash. Traditionally, good white moonshine was made from sweet mash and charter shine was made from sour mash and aged in an oak barrel. Charter refers to the char in the barrel. We will be producing both a white sweet mash corn whiskey moonshine made from 100% malted white Hickory King Corn and a charter shine (barrel aged) made from a 100% White Hickory King Malted, Corn Sour Mashed. For several generations Hickory King and Hickory Cane corn were the only varieties that the mountain people of the Appalachians would use to make white moonshine and charter shine. They believed that yellow corn made inferior whiskey and bourbon so they did not use it to make their good likker. Also many of them used malted corn and Hickory Cane and Hickory King malt well, while Yellow Dent does not. I'm surprised that the malt houses don't seem to know that. Jack Daniels only used Hickory King Corn or Hickory Cane Corn until Lem Motlow came along. Lem switched to yellow dent because of the price and availability.
  18. 0 points
    Sour mash corn whiskey that was stripped at 50 to 60 proof and then ran a 2nd time at around 125 proof and put into the barrel at around 117 proof. Best done in a pot still using no plates, in my opinion.
  19. 0 points
    Florida Cracker, using back set works well for so many different things especially if those things are going into a barrel. When I see people putting sweet mash corn whiskey into a charred barrel thinking that they are going to get a good Bourbon out, I know for certain that they don't have a clue about what they are doing. I see you have a picture of my cousin Jim Tom for your member picture. Old Jim Tom is a Case (character). I'm from the TN side of the The Great Smoky Mountains but I have a lot of kin on the NC side. We have some new rum still designs with and without thumpers. The price for a 200 gallon with the heating system is less than $10,000.00 if anyone is interested email me paul@distillery-equipment.com http://distillery-equipment.com http://moonshine-still.co http://triclamp.co
  20. 0 points
    Totally agree. I wonder why nobody has mentioned muck pit in this discussion so far? I use an "aged dunder" in my wash and it adds immense flavor. There is plenty of info on this subject as well. I strip my washes and then use a 4 plate StillDragon column still and get all of the rum flavor that I want. The benefit is that I have greater control over what goes into the barrel and it doesn't take 3 generations before it is very drinkable.
  21. 0 points
    The crew at the homedistiller site have been working on that for last year or so. The idea is similar to kombucha. The chemistry involved is complicated to say the least. They have also been taking specific acids and doping washes, low wines and finished spirits to develop esters and big flavors. I'm not sure of the legality of doing this for a commercial product unless you go for a DSS COLA. Once you start going down the ester rabbit hole you'll find yourself in a different world.
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