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Showing content with the highest reputation since 07/14/2019 in all areas

  1. 4 points
    It's only Quarantine if it's in the Quarantine province of France. Otherwise it's just sparkling isolation.
  2. 4 points
    I 'll be one just give me your address and a time when your not around .
  3. 3 points
    Wow. That was unexpected. Especially in an industry built around Pasteur's work.
  4. 3 points
    the midwest. if you're from New York, it starts just West of Philly until you get to Nevada. If you're from Texas, it ain't anywhere near Texas. Texas is Texas. If you're from California.. hey, man, like, whaat? If you're from Chicago, that's the midwest, but they aren't happy about who's in the rest of the midwest. If you're from the South and don't say "y'all" then that's not the South, it's the midwest.
  5. 2 points
    oh jesus christ here's this "idiot again". What an "unbelievable dipshit".
  6. 2 points
    We are running just shy of 30,000 gallons of keg beer per week all into sanitizer
  7. 2 points
    This issue is a mess because both the FDA and the TTB guidelines are for hand sanitizers and only hand sanitizers. They did not address other sanitizers. Specifically, they do not address sanitzers used for cleaning surfaces, which is a common use when you sell sanitizer in spray bottles. Because I do not know squat about the issue, and because there is an emergency need, and because ... well, just because it is easier to be quiet sometimes and let things play out, I decided to shut up. I summarize the current situation as follows: Someone yelled "pandemic" (belatedly) in a crowded room and since it was, hey, a real pandemic, everyone bolted for the doors without much regard to regulatory decorum. Consequently, persons with access to alcohol for use in sanitizers have gone off in all directions to fill emergency needs in just about any way imaginable. Collectively, you've delivered all sort of products to hospitals, doctors offices, fire departments, police, ambulance services, prisons, individuals, and, well, just about anyone who feels they have a need for a santizer for any use for which they feel that they might have that need. Lines between uses are blurred - it's a hand sanitize, it's not a hand sanitizer, - if not complexity ignored - who cares if its a hand sanitizer - and the general refrain, in practice, is "Rules. Rules? We don't need no stinkin' rules." That is the nature of an emergency. The general who was in charge of federal Katrina aid, when the government decided they had to get serious after it turned out that Brownie had done a hell of a job messing things up, said officials should not make rules they cannot enforce. I'll say this, TTB tried, but in my opinion, the FDA was just plain officious. But the dust from the bolting will settle. This thread asks, "What then?" EPA and FDA This question sent me, via a Google search, to a CDA web site - https://www.cdc.gov/infectioncontrol/guidelines/disinfection/disinfection-methods/regulatory-framework.html. The document is headed, "The Regulatory Framework for Disinfectants and Sterilants - Guideline for Disinfection and Sterilization in Healthcare Facilities (2008). Note that it is specifically for health care facilities. It discusses the role of the CDC, EPA, and FDA. I will not pretend to have any expertise on these matters. Some excerpts from that site: In the United States, chemical germicides formulated as sanitizers, disinfectants, or sterilants are regulated in interstate commerce by the Antimicrobials Division, Office of Pesticides Program, EPA. Any substance or mixture of substances intended to prevent, destroy, repel, or mitigate any pest (including microorganisms but excluding those in or on living humans or animals) must be registered before sale or distribution. To obtain a registration, a manufacturer must submit specific data about the safety and effectiveness of each product. For example, EPA requires manufacturers of sanitizers, disinfectants, or chemical sterilants to test formulations by using accepted methods for microbiocidal activity, stability, and toxicity to animals and humans. The manufacturers submit these data to EPA along with proposed labeling. If EPA concludes the product can be used without causing “unreasonable adverse effects,” then the product and its labeling are registered, and the manufacturer can sell and distribute the product in the United States. FIFRA also requires users of products to follow explicitly the labeling directions on each product. The following standard statement appears on all labels under the “Directions for Use” heading: “It is a violation of federal law to use this product in a manner inconsistent with its labeling.” Failure to follow the specified use-dilution, contact time, method of application, or any other condition of use is considered a misuse of the product and potentially subject to enforcement action under FIFRA. In general, EPA regulates disinfectants and sterilants used on environmental surfaces, and not those used on critical or semicritical medical devices; the latter are regulated by FDA. In June 1993, FDA and EPA issued a “Memorandum of Understanding” that divided responsibility for review and surveillance of chemical germicides between the two agencies. Under the agreement, FDA regulates liquid chemical sterilants used on critical and semicritical devices, and EPA regulates disinfectants used on noncritical surfaces and gaseous sterilants 793. EPA continues to register nonmedical chemical sterilants. In January 2000, FDA published its final guidance document on product submissions and labeling. Antiseptics are considered antimicrobial drugs used on living tissue and thus are regulated by FDA under the Food, Drug and Cosmetic Act. FDA regulates liquid chemical sterilants and high-level disinfectants intended to process critical and semicritical devices. FDA has published recommendations on the types of test methods that manufacturers should submit to FDA for 510[k] clearance for such agents. I suspect that uses of sanitizers outside of the health services is not regulated at all by the FDA, since it is for neither internal or external human use, but I do not know what I am talking about, so any further comment would be inappropriate. But the path to a continuing market for sanitizer is a mind field of testing requirements, etc. Are they enforced? I don't know. It's not my bailiwick. TTB As to TTB, sanitizes made with alcohol are "articles" under its regulations. You find the rules for articles in n part 20, which requires that the articles be made with denatured alcohol. There is no provision for using undenatured alcohol as an ingredient in sanitizers,hand or otherwise, so, you start with denatured alcohol and then add further sanitizing ingredients. The formulas for denatured alcohol are in part 21. Not all formulas are approved for use in sanitzers. Any alcohol used to make denatured alcohol must be produced at a plant that is authorized to conduct operations in "industrial alcohol" That requires a permit issued under part 19 - this is different than the basic permit that beverage plants must have - and a registration, as an industrial alcohol plant, under the same part . Any DSP conducting operations in industrial alcohol must have a bond. There is no exemption based on the excise taxes paid, as there is for beverage spirits. You can be both a beverage plant and an industrial plant, but unless you declare the acohol to be beverage at the itme of the production gauge, you mustd have a bond sufficient to cover the liability for the taxes on the alcohol. Only a DSP can denature alcohol. When a DSP denatures alcohol according to a formula in part 21, the tax is not due upon removal of the denatured spirits from the DSP. Because the hand sanitizer is made with denatured alcohol, if it is made in accordance with the guidance formula, there is no tax due. That is true whether you sell it or give it away. If it is made with undenatured alcohol, then there is tax due. That is true whether you sell or give it away., A DSP may make articles on the DSP premises. Persons who are not DSPs and want to make articles must get a users permit under part 2o and buy a bond. DSPs are exempt from that, but must follow the other rules for making articles in part 20. The rules require an approved formula for all articles made. The hand sanitizer guidance provided a temporary exemption from the the requirements that DSPs have an operating permit, register as an industrial plant, and post bond. It also removed the formula requirement for hand sanitizers made according to the formulas provided in the guidance document. TTB initially provided that you could make hand sanitizers - specifically hand sanitizers - using undenatured alcohol, but after the FDA demanded for no good reason that the hand sanitizer be made with denatured alcohol, TTB changed its requirement. Under the ruiles, if youy make any sanitizer other than hand sanitizer produced according to the guidance document, taxes are due. Period. Whether TTB will ever attempt to collect those taxes is a real question. I doubt it. With all the sanitizer that has been sold, it would require that they devote most of their resources to collecting that tax, which is going to be a very small portion of the taxes that it collects each year. However, after the emergency ends, all of the requirements come to apply. You need an operating permit, you need to register as an industrial alcohol plant, you need to make the articles with SDA that is designated for use in sanitizers, you need to have a and you need to have an approved formula. What about alcohol delivered to hospitals, state agencies, etc. That is a different subject. For it to be withdrawn free of tax, the entity receiving it must have a permit. I do not want to go there now. Nor do I want to provide a citation for everything I just said. One final statement. Certificates of label approval are for beverage alcohol only. You must label industrial alcohol, denatured alcohol and articles according the rules for such products, but you do not get a label approval because they are not beverage products. I am now going to shut up again.
  8. 2 points
  9. 2 points
    The guidance in the document is precisely worded. The excerpt you quote has three separate sentences, each describing a different set of circumstances. The three sentences are clear, but you have to carefully parse them. First Sentence - Part 19, 20, and 223 requirements Any existing DSP Can immediately commence production of; Hand sanitizer or Distilled spirits (ethanol) for use in hand sanitizer, As described below, Without having to first obtain authorization. What does that allow and prohibit? The sentence is relatively free of embedded clauses. Nothing in that provision prohibits manufacturing , for sale, hand sanitizer or distilled spirits for use in hand sanitizer. This is a blanket authorization. Nothing in that sentence addresses whether you must pay taxes on the distilled spirits that are in the hand sanitize that you produce or on the distilled spirits that you produce for use in hand sanitizer. This sentence waives the requirements of part 19 that a DSP be qualified as an industrial plant and have a bond to engage in such transactions. Part 19 allows you to make "articles," a class of products to which hand sanitizers belong, on DSP premises, without an additional SDA users permit, as long as you make the articles in conformity with the requirements of part 20. Part 20 requires formulas for articles produced. If the formula is not a general use formula, then you must file a formula and obtain TTB's approval of it before making it. However, the "as described below" provision of the first sentence has the effect of making the formula in the guidance a general use formula for the duration of the emergency. Thus, you do not have to have additional authorization, i.e. the formula, to make a hand santizer if you do so in accordance with the formula in the guidance. You will not need to pay taxes if you produce the sanitizer according to the current TTB guidance, since the current guidance requires that you produce hand sanitizer with specially denature alcohol (SDA). You make SDA according to a formula ion part 21. If you follow the formula, , tax is no longer attached to alcohol used to make the SDA. Therefore, the hand sanitizer made with SDA is not subject to excise tax. You remove it without paying tax. Second Sentence - Part 19 and 22 requirements re: governments The second sentence describes a different set of circumstances. It is independent of the first sentance. It addresses the removal, from a DSP, of alcohol. for use by a restricted class of persons, only a state or local government, for use by such persons, to make hand sanitizer. Any existing DSP Also may remove Undenatured or denatured ethanol From bonded premises free of tax For use by any state or local government to produce hand sanitizer. What does that allow and prohibit? The provisions of this sentence apply only to removals made to state or local governments. The government would be the person using the product. In this case, the removal is free of tax, but only if they have an industrial use permit issued under part 22. Again, the guidance waives the requirement that the DSP be qualified as an industrial alcohol plant and the requirement for a bond. It does not waive the requirement that the government have a permit under part 22. Third Sentence - Part 19 and 22 requirements re: hospitals, pharmacies, etc. The third sentence describes a third set of circumstances. It is independent of either of the two preceding sentences. It addresses the removal, without payment of tax, of undenatured or denatured alcohol, to specific types of entities. Any existing DSP may remove undenatured or denatured ethanol from bonded premises free of tax for use by hospitals, blood banks, sanitariums, certain pathological laboratories, non-profit clinics, and qualifying educational institutions seeking to use it to manufacture hand sanitizer, and not for resale or use in the manufacture of any product for sale. What does it prohibit and allow: The provisions of this sentence apply only to removals made to the enumerated parties, hospitals, blood banks, sanitariums, certain pathological laboratories, non-profit clinics, and qualifying educational institutions The enumerated parties will be the persons using the product (they do so under the second set of FDA guidelines, which differ from the set that applies to DSPs that are manufacturing hand sanitizers, which has been a cause of some confusion here). In this case, the removal is free of tax, but only if they have an industrial use permit issued under part 22. Again, the guidance waives the requirement that the DSP be qualified as an industrial alcohol plant and the requirement for a bond. It does not waive the requirement that the government have a permit under part 22. Resale Provisions Importantly, the phrase "not for resale" does not apply to sales of sanitizer made with denatured alcohol under the provisions of the first sentence. The not for resale provision apply only in the circumstances described by the third sentence, i.e., where a DSP sells spirits "free of tax" to one of the enumerated entities. The liability for the tax passes from you to the entity upon removal of the spirits from your DSP. That is why the entity must have an industrial use permit and why you must verify that it has such a permit prior to selling the alcohol free of tax to the entity. If the entity then produces a hand sanitizer for which it makes a charge, the entity owes the excise tax. The regulations assume that the government entities to whom you may remove spirits free of tax for their use will not manufacture articles for sale.. This is my reading of the requirements. I am not an attorney and this should not be construed as legal advice. I offer it for general guidance as a result of my experinece with these matters, If you think that I am wrong, or may be wrong, contact TTB to determine if what I am saying comports to the intent of the regulations in question.
  10. 2 points
    I have avoided getting further involved in this because it is a rats nest. The FDA guidance documents say that it contains nonbinding recommendations. WTF does that mean? The whole thing centers on FDA's concern about it GRAS ruies. Whai Would call the FD's overly cautious approach to covid 19 testing poked a stick into the spokes of an essential program. It put us way behind the wave. It's caution on hand sanitzers is having the same effect. In 1996 and 2009 and nine the FDA was prepared to recognize undenatured alcohol as GRAS in hand sanitizers, but in 2016 it reversed that, calling for further testing. Why? Out of a concern that kids might drink it and poison themselves. Let';s put those two concerns on the scales by which we measure this emergency. To me, the FDA's position is indefensible. The are running much too scared. And as a lot of you know, the result has been a "wild west" scene around the country. What has the FDA's conservatism accomplished? So I stay out of it. Once burned. But I will insert a bit more here. TTB's guidance document addresses TWO different matters. One is the production of an article, in the parlance of part 20 of its regulatons. The article is the hand sanitizer. TTB says that you can forget the rules in part 20 for the production of articles if you make the hand sanitizer according to the guidance document. I'll leave that there. The second matter is the sale of undenatured alcohol, plain alcohol, not containing any other substance other than water, to persons who are eligible to receive it under the provisions of the Internal Revenue Code. Normally, you would need to be an industrial alcohol plant to do that. Normally you would need a bond. TTB's guidance document waives those two requirements. It does not waive the other requirements that part 20 p[laces on such sales. If you look at the TTB guidance document carefully, you will see that every reference to "not for sale" applies to the removal of the undenatured alcohol, not hand sanitizer. Here is every reference to "not for sale" that you will find in TTB's guidance document: 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. Any existing DSP also may remove undenatured or denatured ethanol from bonded premises free of tax for use by any state or local government to produce hand sanitizer. In addition, any existing DSP may remove undenatured or denatured ethanol from bonded premises free of tax for use by hospitals, blood banks, sanitariums, certain pathological laboratories, non-profit clinics, and qualifying educational institutions seeking to use it to manufacture hand sanitizer, and not for resale or use in the manufacture of any product for sale. See 26 U.S.C. 5214(a)(3). These measures are generally authorized under authorities that apply in disaster situations, and as a result, are initially approved through June 30, 2020, with the possibility for extension as necessary. Guidance for hospitals, blood banks, sanitariums, certain pathological laboratories, non-profit clinics, and qualifying educational institutions. Hospitals, blood banks, sanitariums, certain pathological laboratories, non-profit clinics, and qualifying educational institutions may obtain alcohol free of tax for their own nonbeverage purpose use and not for resale or use in the manufacture of any product for sale, as described in 26 U.S.C. 5214(a)(3). Manufacturing hand sanitizer is one such nonbeverage use. As with state and local governments, such alcohol must be obtained from a distilled spirits plant and may only be obtained by those holding an alcohol user permit from TTB. See 26 U.S.C. 5271(a); 27 CFR part 22. TTB will offer these organizations the same streamlined application, as authorized under 27 CFR 22.42 and 22.43(a)(2). Again, please note that recent FDA guidance specifies using denaturants when making hand sanitizer. The requirement that the person obtaining the alcohol have a permit cannot be waived because it would waive a tax provision. Only congress can do that. The rules are different for the removal. for industrial purposes, of tax determined bulk alcohol The TTB guidance document does not waive those rules. But there is no issue that I can find with selling hand sanitizer made in accordance with the provisions of the guidance document.
  11. 2 points
    I'd personally have no issue using H2O2 regardless of supplier if I could get it. It should be cheaper to transport as well. I see it available still from many suppliers. It would be almost impossible for H2O2 not to fall into footnote 7 on the FDA document. https://www.fda.gov/media/136118/download "Hydrogen Peroxide Concentrate USP or Hydrogen Peroxide Topical Solution USP. Technical grade hydrogen peroxide falls within this policy if the concentration is within that of Hydrogen Peroxide Concentrate USP or Hydrogen Peroxide Topical Solution USP." It surely is when you dilute it! Take for example: https://growershouse.com/h2o2-hydrogen-peroxide-34-5-gallon?utm_source=google&utm_medium=cpc&adpos=&scid=scplp9483&sc_intid=9483&gsacid=952889933&keyword=&gclid=CjwKCAjwvZv0BRA8EiwAD9T2VTKMenEZtMtMdSoKvt2TjwtITTZKmBe87MovWnhsak5GK16-Hb8YJxoCq2gQAvD_BwE It's 34% not 3% or 12% as you typically purchase Hydrogen Peroxide. It's a much purer form. 1 Gallon of 34% when diluted would be the same concentration as 11.33 gallons of 3% or enough to make approximately 1030 liters or 272 gallons of sanitizer per FDA recipe.
  12. 2 points
    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.
  13. 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.
  14. 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.
  15. 2 points
    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.
  16. 2 points
    Ask the cooper for references, find people who use them years ago and still use them. We prefer The Barrel Mill, they are local to us, make a good barrel, and I don't think I've ever heard a negative thing about them.
  17. 2 points
    Thanks so much--that saves me some time! Right now we have 2x 6 spout fillers, a Mori from TCW and a 6 spout from Criveller that we use regularly https://store.tcwequipment.com/products/mori-filler http://www.criveller.com/products/winery/bottling-solutions/manual-bottling-systems/fillers/ Both are good fillers, and both have their advantages and disadvantages, depending on the bottle shape and how you use it. I have less headaches with the Mori, and Michael at TCW has been great to work with. The only real headache with the TCW unit was that the fill height is only adjustable by the tray itself, and the Criveller is adjustable by both the tray and knobs on the nozzles (very important for accurate fills on SOME bottle shapes). The tray on the Mori doesn't allow for fine enough adjustment for SOME bottles to meet the TTBs allowable fill tolerances. HOWEVER, I just received a prototype infinitely adjustable tray from TCW for me to test out, and I believe it will solve the aforementioned issue. The Mori is also longer by about 10 inches, which does add up if you're running a few thousand bottles a day. The Criveller unit was sent with a Flojet BEER pump, which is almost the same as the G70 except my brief research tells me that the internals may not be ethanol compatible. We swapped that out immediately, so if anyone wants an unused beer pump, let me know. The main headache we get from the Criveller unit is that the nozzle tips are very soft and prone to getting bunched up on the bottle neck, which can cause overfilling and overflows. The second headache with the Criveller is the pneumatic float isn't strong enough to completely shut off the pump, so if you stop filling you'll want to manually shut off the air supply. We never have those problem on the TCW unit. Again, overall both units are good fillers. I can't say one is absolutely better than the other for everyone, but I'd lean towards the Mori from TCW.
  18. 2 points
    Wait you mean something made by Corson wasn't made correctly? Thats a shocker!!!
  19. 2 points
    Whoa - things are spinning here. There is a need for more discipline and rigour. Yes, adding sugar to wine is chaptalization or amelioration. But neither of those words appear in the standard of identity for brandy, which you find in §5.22(d). Fruit brandy §5.22(d)(1), is, among other things, “brandy distilled solely from the fermented juice or mash of whole, sound, ripe fruit, or from standard grape, citrus, or other fruit wine." The standard goes on to discuss pumice additions, etc., which are not relevant to the question. If real estate is "location, location, location," regulation is "definition, definition, definition." So, you must ask, "What is "standard wine?" Terms like "stand wine," which contain a modifier, almost beg the reader to look for a definition within the regulations. The regulation could have said wine, but it said, instead, "standard wine," and the notion that the wine must be "standard" reflects a conscious choice to include it. That sends us to part 24, the wine regulations (part 4, do not define the term). Part 24 defines it. Standard wine is "Natural wine, specially sweetened natural wine, special natural wine, and standard agricultural wine, produced in accordance with subparts F, H, and I of this part.. Now, that leads us on a merry chase, which I will not pursue to the end here, but "natural wine" "specially sweetened natural wine" and "special natural wine" are all defined too. "Natural Wine" is The product of the juice or must of sound, ripe grapes or other sound, ripe fruit (including berries) made with any cellar treatment authorized by subparts F and L of this part and containing not more than 21 percent by weight (21 degrees Brix dealcoholized wine) of total solids. Natural wine is produced in accordance with subparts F and G of part 24. Now,. things get deep. §24.176, which is headed " Crushing and fermentation," provides, in pertinent part, that , " At the start of fermentation no material may be added except water, sugar, concentrated fruit juice from the same kind of fruit, malo-lactic bacteria, yeast or yeast cultures grown in juice of the same kind of fruit, and yeast foods, sterilizing agents, precipitating agents or other approved fermentation adjuncts." The addition to juice or natural wine before, during, or after fermentation, of either water or pure dry sugar, or a combination of water and sugar to adjust the acid level" is called amelioration. A winery may only do it within limits. What are those limit? Let's go a little further down the rabbit hole. §24.178(a), which is headed "Amelioration," provides, "In producing natural wine from juice having a fixed acid level exceeding 5.0 grams per liter, the winemaker may adjust the fixed acid level by adding ameliorating material (water, sugar, or a combination of both) before, during and after fermentation. The fixed acid level of the juice is determined prior to fermentation and is calculated as tartaric acid for grapes, malic acid for apples, and citric acid for other fruit. Each 20 gallons of ameliorating material added to 1,000 gallons of juice or wine will reduce the fixed acid level of the juice or wine by 0.1 gram per liter (the fixed acid level of the juice or wine may not be less than 5.0 gram per liter after the addition of ameliorating material). There's more on amelioration, but there is also a limit to how far down I want to go to make my point. However, before leasing part 24, you can also add sugar to sweeten a wine. "§24.179 provides: (a) General. In producing natural wine, sugar, juice or concentrated fruit juice of the same kind of fruit may be added after fermentation to sweeten wine. When juice or concentrated fruit juice is added, the solids content of the finished wine may not exceed 21 percent by weight. When liquid sugar or invert sugar syrup is used, the resulting volume may not exceed the volume which would result from the maximum use of pure dry sugar only. (b) Grape wine. Any natural grape wine of a winemaker's own production may have sugar added after amelioration and fermentation provided the finished wine does not exceed 17 percent total solids by weight if the alcohol content is more than 14 percent by volume or 21 percent total solids by weight if the alcohol content is not more than 14 percent by volume. (c) Fruit wine. Any natural fruit wine of a winemaker's own production may have sugar added after amelioration and fermentation provided the finished wine does not exceed 21 percent total solids by weight and the alcohol content is not more than 14 percent by volume. So you can use wine to which sugar has been added to produce brandy. However, before leaving the issue altogether, all of this that raises a question that is not answered clearly. Yes, you could receive in bond standard wine produced at a winery, with acceptable additions of sugar, and you could then distill it, as standard wine, to make a standard fruit brandy. But, could you, as a DSP proprietor, ferment juice, in the manner of standard wine, which would allow the addition of sugar within limits imposed on standard wine, to make distilling material. I don't know. If you can, and you did, you would create a need for a lot of records to prove that the addition of the sugar was within the limits allowed by part 24. So ask TTB. But before you do, understand what the regulations say. When you understand, sort of - and I'd say that is the sort of understanding that I have, a sort of understanding - what the regulations say, you have a clue about the TTB employee to whom you are talking has a clue about what is required, prohibited, or allowed.
  20. 2 points
    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.
  21. 1 point
    I just take my shirt off. Everyone's a winner
  22. 1 point
    Do not agree to this you are being manipulated
  23. 1 point
    Here you go. Like I said, I went for usability and cost over looks.
  24. 1 point
    I've never really had much success in trying to directly control vapor temperature. While controlling vapor temperature would be the ideal case, I've found that the control logic would need to be much more complex than simple PID control - mostly due to dead time and the fact that the control function is likely nonlinear. Consider that what you are really controlling is the column reflux ratio, and it takes time for the column to equalize to the new reflux ratio - and then be reflected in the vapor temperature. Controlling dephlegmator temperature via flow rate is far easier from a controls perspective. I've been running this for a few years now and it gives me quite a bit of flexibility in control. What happens when you maintain a fixed dephleg temperature, the coolant flow rate increases as the run progresses (more coolant required to maintain the same set point) - and the reflux ratio increases through the run - so the output speed falls, but output proof is more stable. Fairly easy to run a low temp at startup, to quickly load the column, compress heads, take heads at a very high proof (usually 190 for me). I can then increase the dephleg temperature and drop the proof dramatically, through hearts. Finally once we get into late hearts, I set a cooler dephleg temp, and it allows me to push back tails a bit further than if I just kept a constant temperature. I feel the higher reflux ratios - higher proof output - makes the cut points "clearer" if you are doing it organoleptically. Back to using the vapor temperature as your process variable (PV) - the issue seemed to be dead time associated with column equalization. I could get it working reasonably well one day, only to have it fail spectacularly the next. Input coolant flow rate and temperature needs to be rock solid and consistent, otherwise you have to deal with variable dead time - a complete killer for process logic. I toyed around with the idea of a kind of simple step logic system, not PID based at all - but simple logic control - if vapor temp > set point temp, open coolant by 1% and wait 10 minutes, repeat until set point reached. Realistically, it seems far easier to just code up the control logic in a plc or little mini computer (arduino, etc) - this way you could build in all the constraints, etc. Back to dephleg temperature control - the nice thing about this, input coolant temperature can vary without upsetting the system. Our rig uses recirculating coolant for the condensers. Depending on the time of year the chillers can't necessarily keep up, so the coolant increases from the start of the run to the end. PID easily compensates for this by increasing the flow rate. Easy Peazy. So after thinking about vapor control for a while - I came to the realization that it would just make more sense to use a single overhead condenser. Run a PID on the overhead condenser and coolant tank to keep a constant reflux temperature. And use a proportional valve to vary the flow between column reflux and product. The home distiller guys typically call this liquid management. I believe this is the way the Genio and iStills work. Easier to decouple the reflux condensation process from the reflux proportional control - the control logic/process becomes far more simple - even though the physical still design is a bit more complex. If I were to go down this path. I'd use an oversized reflux condenser with a small ballast tank. I'd use a PID to control the overhead condenser flow rate based on the (small) ballast tank temperature. I'd probably use a solenoid based system to control reflux/product ratio, varying between flowing liquid back into the top plate of the column, vs exit as product. I'd use an additional product cooler on the output, since I'd want to run the ballast tank temperature far hotter than I'd want my product temperature. With this, I'd target vapor temperature as PV and control the proportional distribution. Feel like with a fixed ballast tank temperature, and the ability to alter the reflux flow far more quickly, not to mention a consistent dead time - this would work far better. But who has the time to play around with all of this stuff?
  25. 1 point
    The karmic value of giving all of ours away far exceeds any profit we could have made. Distilled spirits are all about sharing a drink with friends and family, the very thing we can't ever do with social distancing. So, the quicker we win over the virus, the quicker we can come together again, and I'm pretty sure it's going to be over a drink.
  26. 1 point
    That's exactly what the distributor recommends, but not water, ethanol. Directly from the distributor: Using Bitrex-USP/NF In Crystal Form Treat Rate Pure Bitrex Add to each: grams 54 gallon drum 1.0 100 gallon = 1/16 avd. Oz. 1.8 270 gallon tote 4.9 If you want to make a Stock Solution to make it easier to handle Bitrex is readily soluble in Ethanol, but NOT WATER. I'd suggest a 10% weight/weight solution in ethanol, then math on treat rate would be 10x above chart.
  27. 1 point
    Vendome makes a continuous GNS redistillation rig that takes as input 95% and produces 96% as output. Takes a tiny tails cut through the bottoms product drain. Most folks don’t put them in the cheater camp.
  28. 1 point
    Neither of the docs that you mention allow Technical Grade Hydrogen Peroxide. My point is that I think YOU are the one that's looking for a loop hole in an "other" document. Specifically the "Compounders" document, which nobody (i.e. TTB or FDA) has said applies to you. We have, of course, been making calls to FDA but they are skittish about going on the record. I maintain that the distinction only matters (technical grade vs. USP h2o2) if you are selling the product, in which case I feel (morally and legally) you have a higher standard of accountability. If you are donating it, I think we all know that the two are functionally equivalent in this particular use case.
  29. 1 point
    Just to make sure this is clear distillers in the USA must follow TTB rules and labeling exactly as written and pay tax if the alcohol was not prepared to United States Pharmacopoeia (USP) grade or wasn't denatured. WHO and FDA set guidelines. TTB sets rules and waivers that DSP & AFP must follow for Covid-19 production of sanitizer. If in the USA start with the TTB guidance listed here and make sure you comply. https://www.ttb.gov/public-guidance/other-public-guidance-documents
  30. 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.
  31. 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.
  32. 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.
  33. 1 point
    Uhhm - viewing your other thread, this suggests your authority is unfamiliar with distilling and fire code related to such hazards. F-1 is your occupancy classification. I * SUSPECT * what that are asking for are physical diagrams/drawing, so they can define a "sombrero of death" (google it), then all the electricals w/in the 'sombrero' *should* be Class I, Division 2. If your still vendor won't spec their electrical still heating as class I Division 2, then you have a real problem. You'll likely bump into ventilation requirements too.
  34. 1 point
    I believe that your AHJ is incorrect. There is no MAQ if the ABV is less than 16%. You will be classified as H-3 is you exceed 120 gallon of Ethanol that is in excess of 16% ABV. What ABV are you achieving in your fermenters?
  35. 1 point
    When we were going through a similar process we wound up agreeing to all kinds of things way too early. Keep good notes, nod knowingly and don't agree to any conditions up front. If you have to go through a re-zoning process anyway - you want to make sure you have negotiating room and things to trade later for when all those previously keen neighbours suddenly turn against you.
  36. 1 point
    Thanks! On gin, I just got asked the question, what the basis is? What flavors and herbs should be there? Lots of confusing info out there. Lots of opinions, often based on personal preferences, not on the science of flavor or on history. So lets pick this thread back up and lets talk GIN: At the basis, juniper and coriander form the heart of the gin. Any gin. They are responsible for the middle of palate flavors that hit you (after swirling a sip through your mouth and after swallowing it) for the taste and flavor from seconds 2 - 6. You add a bit of fruit peel for the fruity flavors, that hit you in the first second. And that could be the base to any gin, since it is a two dimensional, forward oriented drink. A nice mixer for G&T.Juniper and coriander also serve a goal other than flavor, and that goes back to the history of gin, where you all know that it is a Dutch drink designed for sailors in the late middle-ages and beyond ... to help them keep healthy on very bad, old, salted and smoked food, after prolonged periods at sea. Juniper helps you piss. Coriander has protective qualities for the ligning of your stomach. Gin is derived from Genever and in fact a sub-class to the young style Dutch Genever or Dutch Gin (for most gin styles except maybe Old Tom's), so I feel it is important, that in designing a recipe, its historic role as a medicine should be at least considered.If you want to make your gin more three-dimensional (2.5 dimensional is closer to where you want to be) - especially important as a sipper on its own - you add rooty and/or nutty and/or earthy herbs and spices. They make sure flavor remains in your mouth after second 6. Probably you can count till 10 or 11. Shouldn't be much more than that. After 10 to 11 seconds of swallowing taste should stop or your back-end flavors may overrun the primarily two dimensional character.Angelica and orris root are other ingredients of importance. They bind flavors and work as fixatives. Angelica adds flavor, orris root hardly does. For gins that remain on the shelve a bit longer. And remember: less is more! So maybe start like this: fruit peel, juniper, coriander, one rooty/nutty ingredient, and orris root as a fixative. I hope you guys like this addition, If you have any questions feel free to ask. Regards, Odin.
  37. 1 point
    Look for a manufacturer in your area, as otherwise shipping will be a significant added expense. Also try to confirm they are actually the manufacturer, rather than a broker or re-seller, as that will also increase your cost.
  38. 1 point
    If you have a product already I heard a good way to dilute is to cut to proof then mix same proof NGS until desired flavor profile is matched. For example, your single shot gin is 88 proof, distill the multi-shot, cut to proof then blend 88 proof NGS until it matches the flavor profile of your single shot. It's more trial and error but it would probably be the easiest.
  39. 1 point
    Yup, that sounds about right. You have to keep pinging your local rep, they are your only point of contact. My situation was worse. Part way through, my local rep left the company, and I was in limbo. Luckily, after, a newly assigned rep eventually got us back on track, only a few weeks lost. Yes, you need those special labels, they will come by FedEx, of course! You will also have to learn how to properly navigate the use of their web portal for shipping alcohol, you need to have it appear as a selection on your account. That did not work for us on day one.
  40. 1 point
    Forget it. You'll need to buy very large amounts to make it worthwhile, and correctly dry the products. For example, my spice trader takes juniper berries which are typically 40% moisture and dries them to around 18% moisture. By the time you have everything in place (to process raw product) you have replicated a lot of what a spice trader does (at great expense). Definitely not worth it.
  41. 1 point
    Generally, the key with FedEx is regular contact with your officially designated representative by telephone. That's what they are there for. It took us 3 months.
  42. 1 point
    For TN: of course you'd have to go through local zoning and get your property first. But once you get your federal permit, then you apply to the state with owner info (similar to TTB OOI), pay distillers license fee, any local license (privilege fees) then sign up with a distributor and register your brands with state (more fees). You'll be inspected by TN ABC and TN Dept of Agriculture. Both are typically very fair to deal with. I have yet to see the TN ABC deny someone a distillery license. TN is a three tier system and your TN distributor "owns" you in that region they operate. They can dump you if they don't want your product, but you have to go in front of a state judge to get out of contract with them if they won't want you to leave. And then you still may not be able to leave.
  43. 1 point
    The bottling line filter should not be final filtration. Final filtration should happen as part of processing. The bottling line filter is simply a last line of defense for any stray dust are particulate which may have found its way in the product in final transfers, tanks, etc I agree with Adam - bottling line filtration should probably last damn near forever.
  44. 1 point
    The sizing of the reservoir depends on the mash cooling time plus the fermenter cooling as well, so if you had a 250 Gal mash load, a 500 Gal reservoir for that plus extraneous loads like fermenters. Recovery time should get done before you are ready to make a still run, so get the reservoir back down to around 50-55F before use again. If you are doing stripping runs, you'll have to upsize the chiller in some cases, especially if the tank starts to overheat- creeping above 70F before you're not close to the end of the strip run is not a good sign and you should adjust technique so you don't overheat the chiller. I am adding a 2-stage cooling technique for larger mash runs by adding a hybrid adiabatic glycol cooler which will give you performance of a cooling tower with a closed loop system, so I can run it along with the chiller to take the high heat out of the mash run which reduces the chiller size and overall KW. On a recently completed system, the savings winds up being 20 HP per hour of usage compared to cooling with a chiller. Hope to have pictures posted soon!
  45. 1 point
    I bought a Master Distillation kit from Pellet Labs: https://pelletlab.com/product/master-distillers-1000ml-distillation-kit/ I have sent so many of my distillers to them that I should be getting some sort of commission, but alas, no. You can also find them on Amazon with free shipping, if you are lucky. You do not need an Anton Paar, the gauging manuals are based on thermometer and hydrometer measurements. Buy a calibrated thermometer and calibrated hydrometers and LEARN HOW TO USE THEM CORRECTLY! Here is a video from Rudolph here as well as the instructions written out on how to to use a distillation apparatus: https://rudolphresearch.com/videos/distillation-obscured-alcohol-products/ BDAS is who I used for samples testing: https://bdastesting.com/ but find someone close to you as you have to pay to ship off your samples. Jennifer
  46. 1 point
    By the way, looking at the photos, I don't see what in that would be eligible for patent protection, looks like a fairly typical vacuum setup. There is a tremendous amount of prior art in this area. If you think you've come up with something brand new, the flavor and fragrance crew probably did it 50 years ago.
  47. 1 point
    We had issues early on with foaming in the fermenters and with slow stripping runs for Rye. We started by adding Beta-Glucanase to the mash in two steps, once during heat up when the Rye is gelatinizing at about 135f for an hour (milled to course flour and Alpha Amalyase added) and again after it has been cooled to 80f and is about to be pumped to fermenters (same time we add Gluco Amalyases). We do a higher cook temperature rest at 170f for 30 min for the corn we add (25%) and then take it up to 190f for half an hour to make sure any other nasties are held at bay, then malt is added during the cooling time at about 160f and another rest. Without the BG it was a lot thicker and we had more foaming and mashes that didn't finish where we wanted them. With the BG the foaming went down, we ferment much drier, and heat-up in the still was greatly improved. In the still, we do find that on occasion we have a rye run that will move very slowly. Typically this is because there is some scorching at the bottom of the pot (doesn't take much). To counter this we heat up the rye a bit slower than we do with Bourbon or Corn whiskey. Doesn't work every time, but we went from issues with every other rye run to 1 in 8. Super low tech way to help with foaming in the fermenter, spray PAM around the insides a few inches below the top. It helps break the foam while it rising and has saved me lots of time cleaning up in the morning.
  48. 1 point
    I purchased a controller from Schnapp Stills about 6 years ago. I was looking for someone to build panels for me at the time and since he was here in MO I ordered a panel from him so that I could test it. When I received it, most of the wires were either disconnected or loose. When I contacted him and sent a picture asking which wires went where he said you bought it, its yours now. I ended up trashing the controller. All of the components were garbage. It was the worst POS controller that I have ever seen. Here is something else. Jason Schnapp is running a scam on the ADI forum. Please see the below where he pretended to be his own customers and gave himself a couple of reviews. I think he needs to be removed from ADI. I guess he forgot that he did that and came out as himself using the same Avatar. It's like one of those stories about stupid criminals. What a dumbass!
  49. 1 point
    I just received a master series still from Olympic and it was a great experience. Obviously they were just the middle men from a company in china but we received a wonderful still that can do it all for a price nobody could beat. We have not put it together yet but everything looks good, and great quaility.
  50. 1 point
    So Im curious about the effectiveness/efficiency of the number of plates on a still. Now lets say I want to make vodka and I go with a larger still manufacturer, their set up will have 16+ plates. But if Im starting on a tighter budget and go with a component type set up, say the hillbilly flute or still dragon, I can apparently get by on making vodka with far fewer plates. Why is this? I get that more plates = a more pure distillate so it that it? The bigger systems simply produce a superior product in one run vs a smaller system requiring maybe two runs to get something comparable? Is it a scalability issue; bigger pot/more vapor = a need for more plates? Or, is it something else entirely and Im way off base/have a huge gap in my knowledge/understanding? EDIT: Just to clarify I am not sold on producing vodka. In fact I'd say I'm 95% set against it. This is just something that, as I've been researching and drafting my business plan, I've been really curious about.

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