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Stainless steel barrels for temporary holding tanks

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Filling out the last part of the TTB online permits form. Opening a small craft distillery in Ashville, Ohio. We are going to use 55 gallon stainless steel barrels for fermentation, holding tanks prior to going into oak barrels and for some of the aging. Do they need to be registered with a serial numbers with the TTB? And if they do, can I number them after they are acquired?

Thanks!

Doug

M&O Spirits, 

 

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You do not need to include, in the equipment list, any portable bulk containers having a capacity of less than 101 gallons.

Sec. 19.75  Major equipment - As required by Sec. 19.73(a)(9), the application for registration must include a list of the major plant equipment. If the equipment is set up and used for the production, storage, or processing of distilled spirits, wine, denatured spirits, or articles, the list must provide the following information:

    (a) The serial number and capacity of each tank in the plant. The list does not need to include any bulk containers having a capacity of less than 101 wine gallons on the plant premises if those containers do not meet the criteria of a tank under Sec. 19.182 (perks, small totes, etc.).  

The only problem with that is that 19.182 does not contain criteria for determining if something as a tank.  It contains requirements for how you must equip a tank if you have a tank, but it does not say what a tank is.  

 

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Sorry to bump this and hijack, but It think it may add to the conversation.  What is the best way to label small plastic barrels for fermenting?  These barrels would only be used for the fermentation stage of test batches on our test stills.  Can a sharpie be written on the side?  Or is there a specific way the TTB would prefer to see the serial number on the barrel?

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There is no requirement that you mark small containers used for fermenting with serial numbers.  In fact, in most cases, even barrels that contain spirits do not have serial numbers.

Packages that contain spirits filled during production or stoage operations must be marked with a lot identification number (19.485). 

A package is "a cask or barrel or similar wooden container, or a drum or similar metal container (19.1).  Although the definition does not include plastic or glass containers that function as barrels - no, I do not know why it does not, but would guess it was simply an oversight when the regulations were rewritten in 2011) - I assume it applies to those sorts of containers. 

As used in part 19, the term lot identification number is synonymous with the term package identification numbers (19.1).  The requirement is more easily understood in terms of lots.  As the term "lot number" implies, different packages may bear the same lot number (see 19.485 for details on this). 

The lot identification number is coded to show, , among other things, the year and month and day on which the package was filled.  It does not include a unique identifying number for each of the individual packages into which a lot of spirits is filled.

TTB can require a  separate serial number on a package, at the time of filling or withdrawal from bond, but this is not required unless "the appropriate TTB officer" explicitly requires it.  Unless TTB tells you, put a serial number on packages, you need not do so.

However, TTB does require a "temporary" serial number,  "for control purposes," on spirits that are transferred in bond in an unsecured conveyance or gauged after tampering within the storage account (19.485).  For the curious, TTB explains securing devices, for use on conveyances, in 19.441. 

To round things out, with information not germain to your question, you need to make a separate, package gauge record  (19.619) when you fill packages on the production gauge (19.289).  Further, when packages are held in the storage account, you must keep package summary records that show the date of deposit to and transfer from the storage account, along with the quantity remaining in the account (19.591).   Although that section does not specifically mention the lot identification number, it seems a handy way to approach things.

I explain all of the above only to show how TTB uses the terms and why  none of it applies to packages used for fermentation.   

Finally, the fact that TTB does not require a serial number  on packages used for fermentation does not preclude you from assigning a temporary number for your own record keeping purposes.  If it helps you track and evaluate the samples, use serial numbers, temporary or permanent,  with whatever form of coded identification you might chose to use.  Write it with marker, crayon, whatever you chose if you chose.  

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And on not needing to identify individual packages within a lot, I still find it much easier to have a secondary serial code (I just tack an extra letter on the end) to ID each individual barrel. It takes almost no extra effort and makes inventory and tracking progress much easier, at least for me.

Also, when I put spirit in drums for temporary storage (or long-term macerations) I still give them serial codes. Again, very little effort and makes it much easier when more than one person may touch things.

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Nothing precludes additional information on the barrels.  Wineries have used barcodes and computer programs to track the way in which they have used their barrels for a long time - at least back into the 1990's.  

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Guys does anyone have a picture or an example of the labeling they are using on packages, containers, etc. to be inline with the CFR requirements? I get the identification of our equipment (we have S1, M1, F1 and F2 like Silk City said), but the CFR makes it sound like ever time I put something in a different tank or package, then I have to have a new label with various requirements.

Having read some more on the TTB website I think I am more concerned with an example of the various gauging records that we have to keep. The CFR and TTB websites are typical government-ese and it would be ideal to see an example of a record in the format that they expect us to have.

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Drums can be funky at a small scale distillery, since they may be treated as a tank by some places and a package by others. If you don't move it around, especially if you have added a drain port, you can probably call it a tank and give it a static ID. If you palletize and store it, it would be given a package ID. I don't have any literal drum-tanks, but I do have a couple tanks that are smaller than drums and it's made sense in record keeping so far.

When I transfer into/between tanks, I have a record that says how much of what was moved, from where to where. If it splits and remerges a single lot, no problem. If it blends two separate lots, time to make a mingling record entry of how much of what went in and thus became the new lot. Either way, I have a step-by step record of what was in each tank when, where it came from, what it became, and where it went. The tank is also labelled with its current contents at any given time, but that's dry-erased on while the tank number stays the same.

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RobertS, thanks for the info. We are about to get our state license, which was the only thing we were waiting for and I realized we are not prepared form a record keeping standpoint. I had a minor freakout this weekend, when I realized that doing all this through excel seems daunting, having re-read the CFR. As much as we'd love to have software I think the excel approach is a better way to understand our own operations, and the regulations. Just trying to figure out the best way to get everything lined up.

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