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bluestar last won the day on December 16 2019

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About bluestar

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  1. Most of these are out of stock or can not ship to most states.
  2. aged product no smaller than 1 micron. unaged can be smaller.
  3. I was always curious about the ethanol inks. Okay, for the most part, everything will evaporate. But carbon black, as a powder (not while bound in ink) is a carcinogen, and the ethanol will be denatured. So you don't want any of that ink to get into your final product. Also, for spills, is the ethanol based ink more permanent than inks that use a different solvent? I've sometimes wondered if one wouldn't be better off with a low-toxicity water-based acrylic?
  4. We have used poly cone fermenters. The 60 gal have a pretty high angle cone, but we found the fermentation provides sufficient agitation for our mash bill to keep the solids moving and suspended until near the end of the fermentation. We have to stir things up before pumping over, otherwise, there is a solid plug at the bottom of the cone where the valve is, and you can't pump out. You need a good size valve on the exit, we are using 2" triclamp hardware there. Still, it was a bit of a challenge, so we switched over to 200 gal, with a much shallower cone. These work much better, although you still want a stir up before pump out.
  5. Okay. Looks like my thinking was correct on both fronts. Yes, the law REQUIRES FDA approval, regardless if other parts of the bill suggest the intent was otherwise. But, the FDA, on it's own, went ahead and made use of tert-butanol OPTIONAL when using formula 40B, as I suggested would be the best option!
  6. Correct, the newest law does NOT override the FDA, although I understand why @dhdunbar might have suspected so, and in fact I would not be surprised if the legislators intent might have been along those lines, but it is the language of the bill that matters. HOWEVER, there is another solution to this problem, I think. I think the FDA does not want to use undenatured alcohol because they are afraid if hand sanitizer is distributed as coming from a liquor distillery, there is a great likely the item could be consumed accidentally or intentionally, so they want it denatured to prevent that. But the TTB makes the rules on denatured formulas, so they wanted to point to a preapproved TTB formula for denaturing. Since their primary concern is preventing drinking, they chose 40A and 40B, I think, because of the use of Bitrex or similar agent. But those formulas also require tert butanol. Whenever the recommend a formula, the other ingredients disappear from the marketplace. The tert butanol is not really required to make the product impossible to consume, it is the Bitrex. The Bitrex is a very commonly available ingredient, and the amount use is extremely small, so it likely can be obtained. So, if the TTB were to announce that using Bitrex alone (call it formula 40D?) for use in hand sanitizer explicitly is now an allowed formula for denaturing, then the FDA could point to that formula, and almost all of us could probably produce the hand sanitizer or supply denatured alcohol for that purpose! And the two agencies won't being going out of their jurisdictions.
  7. Just accept the funds as a deposit toward purchase of the bottles when the barrel is bottled for them.
  8. For me the most IMPORTANT take away from this update, is the ADDITION of Formula 3C (adding 5% isopropanol) to Formulas 40A and 40B in the updated guidance. This means those already using Formula 3C can continue to do so. This also adds to the guidance the denaturing method I previously suspected would be most appropriate.
  9. https://americancraftspirits.org/wp-content/uploads/2017/02/Ethanol-for-Hand-Sanitizer-FINAL-3.24.20.pdf
  10. UPDATE: ACSA obtained an update from FDA. Important points: ethanol must be distilled to 94.9% abv, water added must be boiled or distilled, and ethanol must be denatured with tert-butyl alcohol and either denatonium benzoate or sucrose octaacetate. https://americancraftspirits.org/wp-content/uploads/2017/02/Ethanol-for-Hand-Sanitizer-FINAL-3.24.20.pdf
  11. American Craft Spirits Assc. webinar just finished, mostly confirmed my own research to date, and what we have discussed here. TTB and FDA difference on undenatured alcohol not yet resolved, FDA still requiring denaturing, and webinar recommended isopropyl alcohol.
  12. Actually, if you are denaturing only with methanol or isopropanol, as per formulas 3A and 3C, the combination is still "alcohol" which is how the ingredient is described in the FDA provided back label.
  13. It's not the tax, it is the current FDA guidance that requires the product be denatured. You can't not denature according to FDA, even though the TTB suggests you can. Unless there is an updated guidance since Saturday? Under normal conditions, the isopropanol could be cheaper in bulk than your beverage grade GNS. But right now you can not get it except in larger quantities.
  14. Thanks for this. Am I correct that 3C as well as 3A can be used for sanitizer (see my post above)? I missed that formula 1 would also qualify, but I found that more problematic than either formula 3A or 3C.
  15. Okay, if you are correct, let's put the relevant info here for all to easily find: Antiseptic solutions, U.S.P. or N.F: 23-A, 37, 38-B, 38-F. Note that NONE of these formulas use methanol. Formula 23-A is the simplest: 8 gallons of acetone, U.S.P. for every 100 gallons of ethanol. Formula 37 is interesting: Forty-five fluid ounces of eucalyptol, N.F. XII, 30 avoirdupois ounces of thymol, N.F., and 20 avoirdupois ounces of menthol, U.S.P.; as is Formula 38-B: Ten pounds of any one, or a total of 10 pounds of two or more, of <a long list of aromatic and other oils>. The latter might make a nice product, but there could be issues of sensitivity for some users with any of these additives. Still, in any case, we are talking about a relatively high percentage of acetone or aromatic oils, and I wonder how this does NOT have to appear on the FDA required labeling, since it is not "alcohol" and not a trace amount. Actually, formulas 3A and 3C might also be applicable, and easier to implement. Formula 3A adds 5 gallons of methanol; Formula 3C 5 gallons of isopropanol. While not indicated for antiseptic solutions USP, it is indicated for disinfectants and for sterilizing solutions. When you consider that the sanitizer can be made with isopropanol, one would think this would be the "safest" solution. Note both formulas are all "alcohol" and the ingredient labeling for FDA lists "alcohol" not "ethanol", so I would presume it is accurately labeled for these formulas. (And, after @dhdunbarsubsequent post, I have added...), and looks like formula 1, adding 4 gallons methanol and gallon MEK or MNBK would do, but it seems easier to use 3A in that case. Regarding without additives, it is not the TTB guidance that limits, it is the FDA.
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