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Everything posted by bluestar

  1. bluestar

    Liqueur/DSS Labeling

    Yeah, I wondered about that, by using the word whiskey, and calling it a liqueur, if the base spirit is not a whiskey, it could be mistaken for a whiskey liqueur, which has a specific meaning in the CFR. But that problem usually shows up with the COLA evaluation, but not the FONL. So, you may be right, this initially is what tripped the COLA rejection, but still does not explain the FONL reclassification.
  2. bluestar

    Liqueur/DSS Labeling

    You could push back, although I would have someone read over your formulation to make sure something else isn't tripping the DSS classification. They make mistakes, and more importantly, you own their mistake, meaning if they later figure out it is classified wrong, they can make you change it back. Do you "age" the product before or after you add the sugar?
  3. bluestar

    Liqueur/DSS Labeling

    To start, you mean you had a formula approved as a liqueur where you did not describe finishing it in barrels? And then you submitted a COLA request that included "Finished in Whiskey Barrels" on the label? Well, of course if so, that would fail, because the label and formula did not match. So now the question is with FONL, why is it approved as a DSS instead of a liqueur if it has spent time in a barrel. It can't be because it has been in a barrel per se: there are many liqueurs based on whiskey as the source material. You might want to ask the question in just that way to someone in formulas, why does spending time in barrel prevent it from being a liqueur? 5.40 (5) (d) prohibits age statements for BOTH liqueurs and DSS, so I don't see why if that phrase was allowed for one, it is not allowed for the other, as far as age statement. So, they are not regarding it as an age statement. A liqueur is something with at least 2.5% sugar and extract flavors from natural materials. Perhaps you need to point out to them that oak barrels are natural materials, and any extract that may result from them would be just part of what constitutes the total of extractive materials for making the liqueur?
  4. bluestar

    750 ml Nordic-style with a ROPP closure?

    Similar question, for Arizona...
  5. bluestar

    Question re: 27 CFR 19.489 (case labeling)

    Yes, we put more on there than we must, but we also want it clearly labeled with the information that the retailer might want to see on the case, like number and size of bottles. We group all the "quantity" information together, so it is clear to find and verify self-consistency. Like putting both volume in liters and proof gallons, since most don't know what proof gallons are, etc.
  6. bluestar

    Issues with a small equipment supplier

    This is an important point, to use NEMA 4 or 4x enclosures anywhere near distillation or storage of spirit. And since you are likely going to be using SSRs, not just mechanical relays, for power control, you also have to make sure you have adequately sized heat sinks for the SSRs, not only to cool them, but to avoid getting so hot themselves that the heat sinks or box itself gets to too high a temperature for potential exposure to ethanol vapor. Our box was so good, that when we did have a catastrophic failure (burn up) of an SSR, we only knew because those elements went out. The vaporized remains of the SSR (including odor) was completely contained in the sealed box, as it should be.
  7. bluestar

    Question re: 27 CFR 19.489 (case labeling)

    We include something like this, for example: 12 x 375ML Bottles • 44% Alc. by Vol. • 88 Proof 4.5 Liters Total Volume • 1.05 Proof Gallons
  8. For the control box: Looks like 6 switched SSRs, instead of 5? And there are a couple more SSRs, are those for the motor control, or something else? Looks like each of the heating elements is set up for single phase 120?
  9. In the end, it will be up to who at the TTB reviews your application. But the general answer is no. You can pass through space you control that is not bonded premise to get to bonded premise. But you can't do the reverse, or at least that can't be the official entrance to that space. For example, I know a distillery that had to add a bathroom to a tasting room because the existing bathroom was in the bonded premise, and that could not be treated as publicly accessible, as required by code. And you might have fire code issues with egress, as well, having to go from a public assembly or mercantile area through a hazardous or industrial space for exit. Without seeing layout, it is hard to speculate. But what you will likely need to do is create an entrance lobby that is not bonded premise on the first floor that both exits outside and is the location of the base of the flight of stairs. And while there have been some distilleries that have had less than floor-to-ceiling wall separations of bonded premise from other space, the rule essentially says you can't do that. Best might be to give the drawings to a TTB field officer to review for you.
  10. bluestar


    I do consulting also, with a sliding hourly rate, depending on size of facility. But I also consult as a scientist in other high-tech areas, and my rates for that are double or more. I try to be liberal with my knowledge on the forums, but often people's questions require the dedicated time and attention that they will need from a consultant. There are many good ones that post or lurk in the forums here.
  11. Other non-named whiskey types can also be aged at higher proof, like light whiskey.
  12. bluestar

    Macerating and distilling with Plates

    We find that if we are going to put all of the botanicals in the pot, that yes, running 4 plates and dephleg would remove much of the botanical flavor. So, if we are running a redistilled gin with fairly clean base spirit, we will run without plates. But we do a distilled gin off of beer with 4 plates and dephleg, and while we put some juniper in the pot with the beer, we place the rest of the botanicals in a makeshift gin basket above the plates below the dephleg, and that turns out to be very efficient in extracting flavors and aromas from the botanicals. Keep in mind, any change of where and when you introduce the botanicals will change the flavor profile, and not in a uniform way, since different botanicals extract differently. So, you must test and determine what works, adjusting botanical bill as you see fit.
  13. bluestar

    Resting Gin what Proof

    We do that, works for us.
  14. For the most part, I agree with everything @dhdunbar just said, but would add: TTB ultimately will disallow anything that they consider might be fraudulent. So while "single malt" is not defined in the CFR, since it has a typical meaning in the industry based on Scotch requirements, they would likely not approve to use the term if not meant in the same way. That being said, they won't know you used it improperly unless either your label description or a formula indicates you don't meet the Scotch requirements, or you get audited. So the label would likely be approved for the term "single malt" unless contradicted elsewhere. All that with the caveat that as @dhdunbar said, many labels get approved by TTB erroneously, but that does not establish any precedent as far as the TTB is concerned. Just think about how many labels for a while were approved for whiskey with "aged less than" on the label, even though expressly prohibited by the CFR. It was so bad, the TTB had to issue a circular reminding everyone it was not allowed, even though obviously they helped to promulgate the mistakes.
  15. bluestar

    T Top (Bartop) issue

    Make sure you are using a spirit bottle design and not a wine bottle design. Wine bottles don't have enough head room for spirits. Make sure you bottle at RT or higher, avoid bottling at refrigerated temperatures. If the bottles are going to be exposed to heat or sun, you definitely need to further secure the bartop with an adhesive seal strip, shrink wrap, or both.
  16. I would avoid small bourbon barrels, wrong flavor. Rye barrels are better. If you are doing Norwegian style, it would be a used sherry cask.
  17. bluestar

    Equipment for Sale

    Important clarification, thanks. Not unusual for a gas-fired system to be set up to use different voltages for secondary systems, like switches, blowers, pumps, etc. Often, to do that, the main connection is sized for the higher current when operating at lower input main voltage.
  18. bluestar

    Distillery Controls

    Some of the more sophisticate PIDs have complex "approach" algorithms that can compensate for lag in systems. These avoid overshoot and ringing, but they are sensitive to any change in the operating conditions of the unit. And they require some expertise to learn how to program, even though the better ones can be run in "autotune" to determine the programming parameters. Examples of that level of sophistication are Omega and Watlow (although there are many others). We use the latter. Typically, these run new about $200 list.
  19. bluestar

    Issues with a small equipment supplier

    If you are going to purchase yourself, make sure you get SS and that the gasket and/or feedthrough materials are resistant to high temperature alcohol. Otherwise, they can corrode or leak quickly.
  20. bluestar

    Grain in mash pump

    That's why we have both, and would recommend others do the same.
  21. Not likely. We only have a 50 gallon still. We pay about $2k/mo for utilities! Unless your electric, water, and sewer are nearly free? Your insurance rate is probably at about the correct minimum, but that means instead of $6K/yr, you might budget $15K/yr or more for the two combined to start. Keep in mind, the minimum might be a fixed cost, but that will scale proportionally with increase in production.
  22. So start a brewery first, and add a distillery. A brewery has 5x better chance of being profitable, and then it can finance an incremental addition of distillery, you will already have tasting, brewing, marketing, etc., in place.
  23. bluestar

    Distillery Controls

    Even if you get a more responsive thermal reading, there can still be lag on the reading. In programming your PID, you need to include this lag factor in your programming. Cheap PIDs may not allow this, good ones do. Most importantly, you can not adjust much faster than the rate at which the whole system responds, and that is not just the temp probe, the entire stillhead needs time to equilibrate, and I would suspect that is actually slower than your temp probe response.
  24. Space is too small. Double or triple that, if you are going to have a tasting room. Your estimate is good as a base, but then you should double that for what to plan for, or $140K. And double the time to get things fully running. Rent seems high. Where are the operating costs? Utilities (electric and water, too small for steam)? Labor? The reason it looks reasonable, is labor is not in there, and that is what gives scaling up an advantage (same labor, more product). You are going to sell for $35/bottle? Planning all direct sales, no distribution? What about marketing costs?
  25. bluestar

    Grain in mash pump

    Okay, my mistake, I often use the term "centrifugal pump" to cover both the rotary positive displacement pump and the variable velocity centrifugal pump. The difference is the shape of the impeller, RPD don't allow liquid to bypass the vanes. You could in principle use a centrifugal pump, but they will lose pumping speed with increased viscosity or solid content. But the RPD we have been using for years ourselves. You need high-enough horse power, but we do 2" with corn mash or rye mash, and we actually run those while heating to 190F using a heat exchanger. A 1hp Baldor motor at 1750rpm works, but you want to make sure there is adequate cooling on the motor if using hot fluids. The caution about cavitation, running dry, need to prime, are true for both of these kinds of pumps. But both of these pumps are used for viscous applications in many industries, including oil, food processing, sanitation, etc. The wear we see does not seem to be on the impeller itself (a big hunk of stainless), but on the bearings, which do need to be maintained.