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Brian

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Brian last won the day on November 14 2017

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  1. please review bottom of post! Reference Doc below https://www.regulations.gov/document?D=TTB-2018-0007-0001 Notice No. 176: Modernization of the Labeling and Advertising Regulations for Wine, Distilled Spirits, and Malt Beverages 1. Subpart A—General Provisions Proposed subpart A includes several sections that have general applicability to part 5, including a revised definitions section, a section that defines the territorial extent of the regulations, sections that set forth to whom and to which products the regulations in part 5 apply, a section that identifies other regulations that relate to part 5, and sections addressing administrative items such as forms and delegations of the Administrator. Proposed § 5.1, which provides definitions of terms used in part 5, has some changes from the regulatory text that appears in current § 5.10. In addition to the proposed amendments discussed above in section II B of this document, TTB proposes to modify the definition of “age” to simplify it and to make clear that spirits are only aged when stored in or with oak. The wood contact creates chemical changes in the spirits, which is the aging process. Thus, for example, spirits stored in oak barrels lined with paraffin are not “aged.” Additionally, TTB proposes to add a definition of “American proof,” which cross references the definition of “proof.” The term “American proof” is used in some circumstances to clarify that the proof listed on a certificate should be calculated using the standards in the part 5 regulations, not under another country's standards. TTB proposes to amend the definition of “distilled spirits” to codify its longstanding position that products containing less than 0.5 percent alcohol by volume are not regulated as “distilled spirits” under the FAA Act. TTB also proposes to add a definition of “grain,” which would define the term to include cereal grains as well as the seeds of the pseudocereal grains: amaranth, buckwheat, and quinoa. TTB has received a number of applications for labels for products using pseudocereals, and TTB also notes that the FDA has proposed draft guidance allowing the seeds of pseudocereals to be identified as “whole grains” on labels (see 71 FR 8597, February 17, 2006). Finally, TTB proposes to define the term “oak barrel,” which is used with regard to the storage of certain bulk spirits. TTB and its predecessor agencies have traditionally considered a “new oak container,” as used in the current regulations, to refer to a standard whiskey barrel of approximately 50 gallons capacity. Accordingly, TTB proposes to define an oak barrel as a “cylindrical oak drum of approximately 50 gallons capacity used to age bulk spirits.” However, TTB seeks comment on whether smaller barrels or non-cylindrical shaped barrels should be acceptable for storing distilled spirits where the standard of identity requires storage in oak barrels.
  2. What is a BARREL? Below is the reference for the TTB asking for comment on proposed rule changes for the definition of "barrel", etc. (see very bottom of post) Anyone in the beverage industry has an open invitation to steer the TTB's definition and subsequent enforcement of rules impacting our businesses. Anyone using barrels in their business should (must?) be commenting on this proposed rule. These rules effect the definition of grain, barrel (and allowed sizes), proof, oak container, and aging. Anyone using a barrel smaller than 50-53 gallons should (must) be commenting on this proposed rule. Anyone trying to get to market faster by using barrels smaller than 53G to preform experiments or uses in steer the profile of their products by dosing with "over-oaked" or non-oak species should be commenting on this rule making. If your want to use barrels composed on non-oak species in the heads, interleaved staves of non-oak with oak staves or any non-standard aging system such as the "Squarrell" which uses a stainless steel frame with replaceable oak or other species panels. This non-round solution allows significant cost reduction and reduced impact on harvesting of oak and square/rectangular increased storage density. The TTB is as bound by tradition as any of our institutions. It was created to provide guidance for how our industry is allowed to grow and change with the hindsight of tradition as a reference. If the constraints of the TTB rules seem limited and restricted and in fact are slowing innovation and growth, this is the time to speak up. Notice No. 176: Modernization of the Labeling and Advertising Regulations for Wine, Distilled Spirits, and Malt Beverages 1. Subpart A—General Provisions Proposed subpart A includes several sections that have general applicability to part 5, including a revised definitions section, a section that defines the territorial extent of the regulations, sections that set forth to whom and to which products the regulations in part 5 apply, a section that identifies other regulations that relate to part 5, and sections addressing administrative items such as forms and delegations of the Administrator. Proposed § 5.1, which provides definitions of terms used in part 5, has some changes from the regulatory text that appears in current § 5.10. In addition to the proposed amendments discussed above in section II B of this document, TTB proposes to modify the definition of “age” to simplify it and to make clear that spirits are only aged when stored in or with oak. The wood contact creates chemical changes in the spirits, which is the aging process. Thus, for example, spirits stored in oak barrels lined with paraffin are not “aged.” Additionally, TTB proposes to add a definition of “American proof,” which cross references the definition of “proof.” The term “American proof” is used in some circumstances to clarify that the proof listed on a certificate should be calculated using the standards in the part 5 regulations, not under another country's standards. TTB proposes to amend the definition of “distilled spirits” to codify its longstanding position that products containing less than 0.5 percent alcohol by volume are not regulated as “distilled spirits” under the FAA Act. TTB also proposes to add a definition of “grain,” which would define the term to include cereal grains as well as the seeds of the pseudocereal grains: amaranth, buckwheat, and quinoa. TTB has received a number of applications for labels for products using pseudocereals, and TTB also notes that the FDA has proposed draft guidance allowing the seeds of pseudocereals to be identified as “whole grains” on labels (see 71 FR 8597, February 17, 2006). Finally, TTB proposes to define the term “oak barrel,” which is used with regard to the storage of certain bulk spirits. TTB and its predecessor agencies have traditionally considered a “new oak container,” as used in the current regulations, to refer to a standard whiskey barrel of approximately 50 gallons capacity. Accordingly, TTB proposes to define an oak barrel as a “cylindrical oak drum of approximately 50 gallons capacity used to age bulk spirits.” However, TTB seeks comment on whether smaller barrels or non-cylindrical shaped barrels should be acceptable for storing distilled spirits where the standard of identity requires storage in oak barrels.
  3. https://www.driveswarehouse.com/ FYI.....these can be specified to run on single phase 240VAC.....thought de-rating is required they will work fine.
  4. sure.....take a hike over to: Q&A from :https://www.dalkita.com/prohibition-on-flammable-liquids-in-plastic-totes/ There is a Q&A at the end of that thread that has questions....so one of Dalkita's consultants made that comment. Best, Brian
  5. DISCUS has an Industry based document that may be applicable. I would STRONGLY suggest you pay the nominal fee and get this publication. "Recommended Fire Protection Practices for Distilled Spirits Beverage Facilities 3rd Edition"
  6. FIRE PROTECTION DOCUMENT---- DISCUS has an Industry based document that may be applicable in Canada. I would STRONGLY suggest you pay the nominal fee and get this publication. "Recommended Fire Protection Practices for Distilled Spirits Beverage Facilities 3rd Edition" Elsewhere in this forum lurk PE's who are familiar with the safety requirements and have successfully guided folks over this hurdle. Excised from the DISCUS document....to wet you whistle... 4-7 ALARM SYSTEMS AND WATCH SERVICE 4-7.1 Fire and evacuation alarm systems should be considered for each facility. Operations involve the production and handling of flammable alcohol along with utilization and storage of other combustible materials. These alarm systems will help with timely identification and notification of potential fire or other emergencies and will facilitate a quicker response by both private and public emergency services (fire, police, etc.). These systems also provide a mechanism to notify all personnel of the need to evacuate the buildings or area. Building, fire, or life safety codes or fire authorities may mandate installation of these systems. Refer to NFPA 72, National Fire Alarm Code and NFPA 101, Life Safety Code. 4-7.2 Proper installation of fire alarm system components, such as automatic fire detectors (smoke, heat, optical, etc.), manual activation devices, waterflow switches, alarm notification appliances, control panels etc., is critical to their satisfactory operation. Installation, testing and acceptance of the components and systems should conform to industry standards and practices. Refer to NFPA 72, National Fire Alarm Code and NFPA 101, Life Safety Code. 4-7.3 All fire alarm system wiring, initiating devices, detectors, alarm appliances, etc., should be listed for use in accordance with the classification of the area in which they are installed. Refer to NFPA 72, National Fire Alarm Code and NFPA 70, National Electric Code. Refer to Chapter 6. 4-7.4 Monitoring (supervision) of the fire
  7. Flash Point----Ethanol Q&A from :https://www.dalkita.com/prohibition-on-flammable-liquids-in-plastic-totes/ Matthew Taylor-Rennert says January 17, 2018 at 3:15 PM Correct. Flammable alcohol over ~ 16% ABV should really be stored in metal containers if over 5.3 gallons, by the letter of the code. `````````````````````````````````````````````````````````````````` Here is a little table on the Flash Point of Ethanol: Temp vs. % by Weight ------ Note this is for Ethanol not "heads" or any other mixture you may be using.
  8. For citation details read the posts about 4-5 back in this thread for citations and regs......you certainly can find plastics that are inert to ethanol and you can ship in them but you CANNOT store in them without fire risk and OSHA citation exposure. If or when OSHA cites you and you do not remediate your citation the fines can become extreme and you may be out of business. DOT regulations for shipping GNS to your facility are a different bird entirely. Simply grounding a plastic tote is not in conformance......I realize this is a pain in the butt. Moving a pallet of 53G barrels around in your facility without a rated forklift is also subject to citation.....you may wish it to be different and you may win the next Mega Lottery as well. Some of this confusion is around inconsistent and non-conforming regulations.....wood barrels, 60Gallon bulk storage, qualities of plastic, & etc......at the end of the day you may find an inspector at your door and wished you had made different decisions. This consultant has a nice summary: https://www.dalkita.com/prohibition-on-flammable-liquids-in-plastic-totes/
  9. in the bottom of my columns the downward liquid flow seals the down of the column which then drains from near the bottom of the column this "backup" functions as a kind of trap with separation from the in flow of high temperature vapor.....the tube returning to the pot was not uncovered.....
  10. is it possible you are driving it too hard and not allowing for the entire column to stabilize or the defleg is too cold and rejecting too much product and flooding the plates?....happen to have a laser temperature gun to check temps of plates as vapor goes higher and higher?
  11. my pots had a return well into the pot....the path was up through the helmet and over to the bottom of the column....the liquid from the downcomers draining out of the very bottom of the column and the vapor input 3-4 inches off of the very bottom of the column.....so when running the "seal" was the liquid in the bottom of the column... What is the diameter of the return to the pot? ru not doing something like mis-configuring the valves right? so another silly question: did the manufacturer commission your still....has it been wonkly from day one? If you have a grain in mash the return could be plugged with solids from previous runs and not allowing a return...
  12. if the liquid return path is above the liquid line in the pot, both paths could be feeding vapor....
  13. Are there two paths to the column....1) for vapor and 2) for condensed liquid being returned to the pot?
  14. So shipping in plastic IBC's is just fine but the second you take them off the truck you may be stuck....also you must ground the SS IBC's.....if your OSHA inspector doesn't cite you don't beg them to cite you because they just might....also when moving them or wood barrels around your facility you "must" use a rated forklift....but I am sure no one will believe this either....maybe we could make a new Mad Max movie....ya know driving a tricked out flaming IBC through a rick house!!!
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