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Everything posted by bluestar

  1. Definitely NOT alcohol burn. That is either just a function of proof, or of balance between proof and other flavors in the profile. Heat usually is a result of residual ketones.
  2. Hard to tell, since you are not using terminology that most of my friend distillers would employ. Alcohol burn is something very different from the "heat" of a new-make spirit: the latter will mellow with aging, the former changes ONLY with proof, or by being overpowered by other flavors. Are you tasting at 57%? I would expect anything over 100 proof to taste very alcoholic. Does that "heat" go away if you proof down to 80? Generally, I don't consider smooth the opposite of hot.
  3. I am assuming you don't mean something at the professional end like an HP Indigo? Those require space and expertise, are very expensive, and usually have be run with high % duty cycle to justify operation. If you mean something like the Primera line of printers, a would say they can be cost effective and reasonably straightforward to use. The most recent generation of printers have a reasonable printing rate for runs of a few to a few hundred labels, but too slow for 1000+, IMO. I have used both the older 810 and now the 900 extensively. For spirits, you are going to want to use pigment ink, not dye. And even then, you should consider you will need to coat or fix the labels afterwards, which turns out to be a more difficult problem than the printing if you don't want to do it manually with a spray can.
  4. 2 years in a 4 gallon! And little angel's share loss? That must be some dense oak. Don't know what YOU mean by hotter. Normally, I think of heat as resulting from ketones in virgin spirit, that aging almost always reduces. Now harsher is different than hotter. I would expect it to be harsh. Oddly, if you are not getting much angel's share loss, you could just leave it in the barrel, it might mellow out in a year or two. Also, how does it taste if you dilute it with large quantities of unaged rum? Say, 2-5 parts white to your 2yo? If one of those tastes good, you could make "light rum", which is a blend of aged and unaged rum.
  5. Okay, my problem is the excerpt on minimum proof in your text could be read differently then the excerpt I provided verbatim from the FDA footnote. The difference in punctuation could be meaningful. I find the Discus reply frustrating, because it doesn't really relay any justification or explanation for the use of lower proof alcohol, just says you only have to label with the final proof, which I already assumed. That is because from the punctuation of the footnote, I don't think the labeling mentioned for less than 189.8% refers to the final product, but to something else, and that is what my question is: what is being labeled at lower proof?
  6. 9 This is consistent with the USP and FCC grade requirements for purity. Lower ethanol content alcohol falls within this policy so long as it is labeled accordingly and the finished hand sanitizer meets the ethanol volume to content concentration of 80%. Can someone tell me what that footnote means? That is on the 94.9% alc by vol requirement on the ethanol for hand sanitizer. Some interpret that to say a lower proof can be used, but I can't find a corroboration of that interpretation. What is "labeled accordingly"? At first I thought it meant somewhere on the hand sanitizer, but I am suspecting they are saying if it is lower proof, but is labeled as meeting USP grade purity, it is okay, but that would mean it would not apply to distillers distilling below 94.9%, correct?
  7. Most of these are out of stock or can not ship to most states.
  8. aged product no smaller than 1 micron. unaged can be smaller.
  9. 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?
  10. 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.
  11. 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!
  12. 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.
  13. Just accept the funds as a deposit toward purchase of the bottles when the barrel is bottled for them.
  14. 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.
  15. https://americancraftspirits.org/wp-content/uploads/2017/02/Ethanol-for-Hand-Sanitizer-FINAL-3.24.20.pdf
  16. 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
  17. 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.
  18. 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.
  19. 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.
  20. 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.
  21. 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.
  22. Agree, that is the question. I think @dhdunbar said that he thinks we can denature, but then the next questions would be: which formula should we use, and what paperwork to do we do for monthlies and removal from bond? In addition, even if we are exempted from FET for non-denatured, currently the FDA is requiring denatured?
  23. Great, @dhdunbar, I think you answered my question: we can, in principle as a DSP, make the product. And, if the FDA, as I read it, requires us to denature it, we can do so, even without special permits, so long as we follow CFR normal rules for doing so. Practically, how should we denature it to meet the requirements? The WHO does not requires us to denature it, but FDA does, but does not indicate which formula we should use. Do you have a recommendation for which formula (I am still trying to read through the relevant CFR sections to understand that)? And if we denature that, how do we, as a DSP, report that change in our monthlies? And when/how do we remove that from bond, to distribute that?
  24. One of the interesting points regarding meeting WHO formulation and FDA /TTB requirements, is that while the FDA is asking for denatured alcohol, which using formula #1 would mean adding methanol and methylethylketone (both, by the way, likely to be found in foreshots), the WHO guidelines specifically recommend not including MEK because of its limited efficacy in preventing consumption and because of its unknown toxicity for long term exposure.
  25. If you are denaturing, they are there. NB: the label from the FDA does not say ETHANOL, it says ALCOHOL, and I think that is how they get around this, because methanol is also alcohol, so the mixture would be, I guess?
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