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Red Pine

Finished Product Storage and Exemption

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Hi All,

I'm working with my city officials so I can get started up and am having some road blocks that I'd like to ask everyone about.

1) Are any of you being forced to have a separate enclosed "controlled area" for your finished packaged products? My officials are insistent that I do so. I've been to several different distilleries and have never seen this.

2) Is there an exemption in the IFC or IBC for bottled products? I have the one for spirit in barrels and I could swear I've seen a bottle exemption mentioned on other threads but I searched through and couldn't find it.

3) Is all of your equipment UL listed? I wasn't aware of this stipulation, is this common or is my city just being extra strict? Are there any ways around this?

4) They are currently trying to classify me as an M occupancy, I know in most cases distilleries are F-1. Should I roll with it and go with M occupancy or correct them to F-1?

 

Thanks in advance for the help and input!

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1 - I have never heard of this. Sounds like some old prohibition era thinking.

2 - I believe barrels and bottles are exempt. You should be able to search the forum and find a thread or two on that.

3 - In MN my non-UL listed electrical panel needed to be inspected and "certified" by an engineer.

4 - M occupancy? I could see the part of the distillery that performs merchant operations being classified as M, but the part of the distillery that manufactures wouldn't be a merchant operation.  Is this your municipality or your architect deciding this?

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There are many posts on this forum that refer to the Authority Having Jurisdiction (AHJ).  Your local building department is this entity and they call the shots.  

1.  Never heard of this.

2.  Bottles do not count towards you "storage"   Here's a good article    http://www.klausbruckner.com/blog/distillery-storage-dilemmas/

3.  This is up to the AHJ.  Most equipment coming in from Europe is not UL but there are billions of dollars in European equipment running in the US.

4.  Doesn't seem logical but this is a call for the AHJ

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Bottled spirits if below a certain size are exempt from both fire and building code qty.  barrels are exempt from some fire code requirements, but still count towards your maq for building code.  This causes some confusion as the exemption is only in one code not both.  So you can't store unlimited quantities of barrels inside in a F1.  

Ibc totes are not exempt and will cause you to exceed the maq even with sprinklers (240g). So you will have to have an H rated area to store the totes.   I know one of the local gin guys breaks down totes when they arrive to keep below the maq.  

Seperate control areas may be to deal with the maq.  You can have up to 4 control areas in a building which can help in meeting the maq requirements.  

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Skaalvenn,

I've searched every key term I can think and came up bust on the forums.

Thatch/bluefish,

I know of that exemption (IBC table 307.1(1), but it reads that it is for retail and wholesale sales occupancies. Were you able to get your AHJ to buy into letting you use that exemption?

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Our fire marshall is okay with anything in consumer packaging and not counting it towards our total allowed.  Please understand that means nothing.  Your AHJ gets to determine the meaning of the specifications and his comfort level.

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My fire marshal is fine, it's the building inspections office that is raising all the concerns. It also blew their minds that I'm going to do open fermentation.

Also Skaalvenn for got to respond to your last comment. It's my building inspections office saying M occupancy, when my architect did his write up and sent it to them, he referenced me as F-1.

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12 hours ago, Red Pine said:

It also blew their minds that I'm going to do open fermentation.

 

I'm curious, what were their concerns about the open fermentation?

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How I would be able to keep bugs or dust from getting into them.

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I don't do open fermentation because fruit flies are a complete pain, but many, many distilleries do it and it is almost "the standard", and just like in every other part of the food industry there will be the occasional insect that makes it's way in there.  However, that insect and the dust will not make it through distillation, and your final product coming off the parrot is basically sterilized (which is better than sanitized) by heat and alcohol. Once distilled I would keep your spirits in closed top containers because at that point you're dealing with concentrated alcohol and it's now your final product and susceptible to contamination. It sounds like you just need to sit down with your locals and simply educate them on the industry and alleviate their fears.

I mean heck, a sour mash whiskey is exactly that. Mash that has "spoiled" and has become infected with bacteria. Sour mash whiskey is not any more harmful than regular whiskey due to the process of distillation.

As for the barrel exception.  I didn't dig through them, but you should find something here:
https://www.google.com/search?q=distillery+barrel+exemption+fire+site:adiforums.com&sa=X&ved=0ahUKEwi8rZ7t-MXXAhXn34MKHXqgDEIQrQIINygEMAA&biw=1600&bih=791

 

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Both the FD and regional building are on board with retail packed product not counting toward the maq.  We did have a few distilleries that were taking the barrel exemption too far and the FD and RBD cracked down on that.   Since we have quite a few distilleries in town the FD is aware of the regulations and how they apply.  In fact they are updating them to try and make it more clear what is required.  

If you need a pe to help out I would look to Scott Moore at Dalkita. He specializes in distilleries and knows the codes very well.  

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