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TTB Locks - 27 CFR 19.192

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We are building out a very small craft and R&D spirits DSP.  We have no inside tanks, outside tanks and have no intention of storing portable tanks such as totes.  We will have a small amount of barrel storage, retail packaging, and some spirits in small process containers not considered portable tanks (glass carboys for example). CFR 19.192(e) makes it appear we may not have a need for TTB approved padlocks:



(e)Approved locks. Locks meeting the specifications prescribed in paragraph (f) of this section must be used to secure:

(1) Outdoor tanks used to store spirits, or an enclosure around such tanks;

(2) Indoor tanks used to store spirits, or the door from which access may be gained from the outside to the rooms or buildings in which such tanks are housed; and

(3) Any doors from which access may be gained from the outside to rooms or buildings containing spirits stored in portable bulk containers.


Question 1:  Does anyone have experience with TTB visiting or auditing a site that had nothing but barrel storage, or retail storage and gotten any grief about padlocks?

Secondly, If we do decide that we are subject to paragraph (f), we would prefer not to padlock from the outside because of the safety issue of possibly locking someone in.  Plus, our front door is in a mixed retail/light industrial center, and an external padlock would seem out of place.  Our preference would be a secure mortise lock for the door, with a no-key-needed knob on the inside for emergencies.  We have the door alarmed.

Question 2: Has anyone had experience in getting a mortise lock approved by the TTB, as 27 CFR 19.192(f)(2) provides?

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You are asking for comments from persons who have had visits from TTB.  I would like to hear that as well, but the lock requirement is generally not enforced because, in my opinion, it does not apply to entry doors, etc.  Iy is meant to apply when you secure tanks with locks.  I know of no instance in which TTB has taken exception to  the lack of padlocks on doors.  If you have locks that adequately protect  your assets, then you will have locks that protect TTB's interest in the revenue.  That said, if you secure a garage door with a padlock, I think it should be one of the type described in 19.192(f).  Remember, I am not TTB and I do not pretend to answer for them.  I speak only from my experience.  If you want to know, ask TTB, but remember the adage about letting sleeping dogs lie.

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