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Topping off barrels

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Thank you Roger. See you soon. Visiting distilleries in Wisconsin this week. Be upstate soon

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Like I said. It's the spirit not the water.  Tax!$

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8 hours ago, Roger said:

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Results:

The product has been rejected for the following reasons:
 
   

Formula not required per 2016-3 - This distilled spirit product does not require formula review nor sample analysis. You may proceed to Labeling. [See TTB Ruling 2016-3]
Additional Description - This whisky does not require formula review.

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Unfortunately, that is something of a non-answer. Specifically, you don't indicate the maximum amount of water you may add. The cited TTB ruling is specifically calling out the ability to add harmless materials (water in this case), that would typically be added in production or processing (not storage) for the type. But for that ruling to apply, the amount added must be less than 2.5% volume. So maybe they are trying to say you can add 2.5% water and not require a formula, because it will still be whiskey. Which begs the question, what if we add MORE than 2.5%, since then the TTB ruling would not apply?

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1 hour ago, bluestar said:

Unfortunately, that is something of a non-answer. Specifically, you don't indicate the maximum amount of water you may add. The cited TTB ruling is specifically calling out the ability to add harmless materials (water in this case), that would typically be added in production or processing (not storage) for the type. But for that ruling to apply, the amount added must be less than 2.5% volume. So maybe they are trying to say you can add 2.5% water and not require a formula, because it will still be whiskey. Which begs the question, what if we add MORE than 2.5%, since then the TTB ruling would not apply?

While I don't disagree that the TTB boilerplate response is somewhat cryptic, I do not believe it is in reference to HCFBM. 

There is no mention in any TTB publications that they consider H2o to be HCFBM, therein I can't see it being restricted to 2.5%. Even if it was,  2.5% of what ? Proof gallons ? Wine gallons ?.

i see it as a done deal. We will proceed to market, and I will advise if we hit a future stumbling block.

Prost/Roger

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On 12/7/2017 at 4:15 AM, Florida Cracker said:

Doesn't the spirit become "better" as the angels take their share, ie evaporation, oxygen contact, etc? I have always wondered if a half filled barrel would not produce a smoother spirit because of the increased contact with "air" and it's components. By refilling with water at some point, don't you limit the aging to some extent because of the lack of air in the barrel? 

Not sure of the regs but it would seem like the addition of anything would change the outcome.

Wood is gas-permeable so oxygenation occurs regardless of fill level.  There's also significant oxygenation during the filling process.  If you fill a barrel half full then you'll have significantly higher surface contact with oxygen but no contact below surface level (assuming you don't rotate) but you would also have half the contact with the barrel.  

You cannot "limit" or extend the aging process without defining what you mean by aging.  You could likely mean aging to refer to lactones, acids, sugars, etc or any specific combination of them.  (reference Lost Spirits where if you have an increase in one component in an older profile you have somehow replicated the entire profile?).  Is a super dark, naturally sweet whiskey thats 6 months old more aged than a 23 year light-fruity spirit?  

to the OP: (I'm not a lawyer and this is not legal advice)  So long as you are not going over or under proof for the standards of your product it *should* be legal.  However, it will be hard as hell to track, replicate, and grow.  It would seem to be a lot easier and less legally contentious to dump the entire barrel, reduce to whatever proof you choose, then refill the same or different barrel.  

As to the slow distillation topic:  I think what they mean to say, is that it is better to manage the production cycle to minimize defects than to correct them post-distillation.  This is largely mimicking R. Arroyo's myriad papers on rum production that basically all say this:  better ferments will always make better distillates. You can age a dookie distillate as long as you like but it'll never achieve the greatness of a well fermented wash. 

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29 minutes ago, nabtastic said:

You cannot "limit" or extend the aging process without defining what you mean by aging.  You could likely mean aging to refer to lactones, acids, sugars, etc or any specific combination of them.  (reference Lost Spirits where if you have an increase in one component in an older profile you have somehow replicated the entire profile?).  Is a super dark, naturally sweet whiskey thats 6 months old more aged than a 23 year light-fruity spirit?  

I think you might be conflating aging with maturing. Legally and practically speaking, aging is time spent in the barrel, so yes the 23 year old spirit is more aged. Is it more mature? That is up for debate.

The question here is strictly how does the TTB define aging in regards to this one specific practice. With brandy and rum there is no concern, because there definition of age is not tied to type of cooperage, simply time in any cooperage. 

Bourbon and Rye and other Straight whiskies require time in new cooperage, and any sort of finishing or process that takes them out of new cooperage changes their type and class from Straight Bourbon or Rye to something else. It appears the TTB did answer one question - does adding water to a barrel in storage change the spirit from Straight whiskey to something else? The answer was it "does not require formula". They did not clearly answer the question - does adding water to a barrel in storage stop the clock on aging? My guess is not, because that would be consistent with brandy and rum, but that doesn't mean that's the how they will enforce the regulations.

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These are all "Craft Issues" . Granted one would have a hard time hitting the same old representative flavor profile with this technique, but that is exactly the point of the exercise. I have no desire to make cookie cutter whiskey. I will leave that to Big Gulp and the pretenders. I am personally sick of hearing "Single Barrel" while knowing that the producers do everything in their power to make sure that "Single Barrel" tastes exactly like the last one. 

Prost/Roger

 

 

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No disrespect Tom but I'm not confusing or conflating the two terms.  I'm emphasizing the importance in distinction.  Cracker's question seemed to me to imply maturation in the organoleptic sense, not in time/duration.  It's also important to note that his question is in regards to contact with "air" but we need to point out that water has oxygen in it and although tightly bound, it will react and continue to *mature*, or form new chemical bonds, within the spirit.  Cracker - look into Oxygeen, a defunct absinthe company that sprayed atomized spirit into a pressurized (hyperbaric?) chamber filled with O2.  There are also several companies that force reactions with oxygen via air stones, rotations, microwaves, UV lights, etc but (again, my opinion) it's still better to make the best mash/wash possible before trying to alter distillates.  

With regards to the TTB - they care about proof gallons removed regardless of which spirit you are making.  The OP question is not in regards to a cooperage but whether or not you can add water after it is in the barrel, which are very separate issues in my opinion.  

As for Roger's comment on single barrels tasting the same ... yes and no.  For us, many of our single barrels releases are very distinct [laphroaig, Madeira, chardonnay, etc] and many of the large producers use several distinct recipes that are blended together for uniformity.  To an extent yes, a bourbon is a bourbon, but a bourbon can also be drastically different from one barrel to the next depending on it's mash bill. 

Yes, you can add water to your cooperage at any time.  You could, in theory, add the 10 gallons of water before maturation begins because the TTB cares about the proof gallons in/out of storage not how many barrels you use to get there.  The methods and merits of doing so are debatable but it would appear that the TTB does not care one way or the other so long as the defined parameters of your class/type are not crossed.  

[the intent of these comments is purely adult conversations - please do not take offense or injury to them.]

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I  understand the desire for slow proofing, but what are we talking about in terms of water additions at one time?

To make slow proofing easier for us, I've been looking into small metering pumps, which would let me add water to holding tanks very slowly, on the order of a few ml per hour, or even less.  I could theoretically add a few gallons to a holding tank over the course of weeks if I wanted to, and I could do it in a way that allowed me to add a minimal amount of water at any given time.  Drop, by drop, by drop, by infernal drop.

In the context of a barrel, what are we talking about in terms of additions?  A few mL from a 5ml syringe, every day, or other day, for a month?  Adding a gallon of water directly to the barrel seems awfully abrupt, if we're looking at this in terms of proofing very slowly.

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My proof reduction occurs over a 2 week period dropping 5-10 proof every 2-3 days.  Seems to work pretty well but I don't have GC reports or double-blinds to back up my methods.  I'm also playing with filtering before, during, and/or after proof reduction to see if there is a noticeable effect on flavor/stability (so far nothing notable)

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53 minutes ago, nabtastic said:

No disrespect Tom but I'm not confusing or conflating the two terms.  I'm emphasizing the importance in distinction.  Cracker's question seemed to me to imply maturation in the organoleptic sense, not in time/duration.  It's also important to note that his question is in regards to contact with "air" but we need to point out that water has oxygen in it and although tightly bound, it will react and continue to *mature*, or form new chemical bonds, within the spirit.  Cracker - look into Oxygeen, a defunct absinthe company that sprayed atomized spirit into a pressurized (hyperbaric?) chamber filled with O2.  There are also several companies that force reactions with oxygen via air stones, rotations, microwaves, UV lights, etc but (again, my opinion) it's still better to make the best mash/wash possible before trying to alter distillates.  

With regards to the TTB - they care about proof gallons removed regardless of which spirit you are making.  The OP question is not in regards to a cooperage but whether or not you can add water after it is in the barrel, which are very separate issues in my opinion.  

As for Roger's comment on single barrels tasting the same ... yes and no.  For us, many of our single barrels releases are very distinct [laphroaig, Madeira, chardonnay, etc] and many of the large producers use several distinct recipes that are blended together for uniformity.  To an extent yes, a bourbon is a bourbon, but a bourbon can also be drastically different from one barrel to the next depending on it's mash bill. 

Yes, you can add water to your cooperage at any time.  You could, in theory, add the 10 gallons of water before maturation begins because the TTB cares about the proof gallons in/out of storage not how many barrels you use to get there.  The methods and merits of doing so are debatable but it would appear that the TTB does not care one way or the other so long as the defined parameters of your class/type are not crossed.  

[the intent of these comments is purely adult conversations - please do not take offense or injury to them.]

I take no offense, and I too did not mean to offend. 

I am just trying to illustrate while often used interchangeably in our industry, maturating and aging are different as one has a legal definition. Below is how the TTB defines age, 5.11. 

Age. The period during which, after distillation and before bottling, distilled spirits have been stored in oak containers. “Age” for bourbon whisky, rye whisky, wheat whisky, malt whisky, or rye malt whisky, and straight whiskies other than straight corn whisky, means the period the whisky has been stored in charred new oak containers.

It is the definition of age with regards to these types of whiskey and new cooperage that are specifically being debated. Blue Star had argued that expanding the bourbon in the barrel with water was the same as putting bourbon into a barrel that has already been used because the water is now causing the bourbon to cover used barrel.  Hence, ending the aging process (not maturation) in the eyes of the TTB per this definition. This is the central point that is being debated in this thread. 

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Our interest in this is not in reference to proof reduction heat mitigation(slowly adding proof water) although we do subscribe to that theory, especially with brandy,  up to and including proofing with ice. 

The OP is entirely based on aging/maturing a larger portion of the finished product that ends up in the bottle. If industry standard is 5% evaporation per year, then the refreshing process should remain pretty lineal. 

But again it's all personal choice on the path you choose to take with your products and branding. 

 

 

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Tom - (no offense was taken, I'm just confused) I don't see how the TTB rule cited implies or states that aging has anything to do with water addition.  According to 5.11 age is counted for the duration between distillation and bottling when *spirit* is in new oak - it does not reference water.  

If Bluestar is correct, in that exposure to any interior wood surface that has been previously exposed would require you to restart the clock - whether you add water or just roll the barrel over (after evaporation) you would be contacting previously exposed wood.  I do not believe that was Bluestar's or the TTB's intent.  The remaining whiskey that was in the barrel is still in the barrel, thus it remains arguably virgin whiskey.  Proofing water does not require aging.  If it did, you would have to package everything at cask strength because it never entered a new charred oak cooperage.   IMHO, this is a perfect example of where intent of the law is most important - the TTB was saying that you cant count the time in hold tanks.. I feel like we are overthinking the legality of this (but in a good way).  

I would definitely agree that if you were topping with spirit (as in solera aging) then you have to stop the clock but I don't believe water has the same restrictions.  

Incidentally, I didn't realize that finish aging wasn't allowed to count in the age statement of whiskey ... thank god I make rum lol.  

Roger - what do you mean by "refreshing process should remain pretty lineal"?  I read that as meaning that the ABV evaporation rate would stay at 5% as long as the volume remains constant.  I do not have sources to cite here but I was under the impression that the evaporation rate changed with the proof content, no? 

Love this conversation though.  Always down to learn.  

 

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In regards to nabs interpretation of bluestar touching used barrel by adding water or rolling is absurd. Dumping and adding new spirits constitutes a barrel being used. I disagree with this. This means you can never change or move the barrels placement EVER during its time in the barrel . Again absurd.

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9 hours ago, nabtastic said:

Tom - (no offense was taken, I'm just confused) I don't see how the TTB rule cited implies or states that aging has anything to do with water addition.  According to 5.11 age is counted for the duration between distillation and bottling when *spirit* is in new oak - it does not reference water.  

If Bluestar is correct, in that exposure to any interior wood surface that has been previously exposed would require you to restart the clock - whether you add water or just roll the barrel over (after evaporation) you would be contacting previously exposed wood.  I do not believe that was Bluestar's or the TTB's intent.  The remaining whiskey that was in the barrel is still in the barrel, thus it remains arguably virgin whiskey.  Proofing water does not require aging.  If it did, you would have to package everything at cask strength because it never entered a new charred oak cooperage.   IMHO, this is a perfect example of where intent of the law is most important - the TTB was saying that you cant count the time in hold tanks.. I feel like we are overthinking the legality of this (but in a good way).  

I would definitely agree that if you were topping with spirit (as in solera aging) then you have to stop the clock but I don't believe water has the same restrictions.  

Incidentally, I didn't realize that finish aging wasn't allowed to count in the age statement of whiskey ... thank god I make rum lol.  

Roger - what do you mean by "refreshing process should remain pretty lineal"?  I read that as meaning that the ABV evaporation rate would stay at 5% as long as the volume remains constant.  I do not have sources to cite here but I was under the impression that the evaporation rate changed with the proof content, no? 

Love this conversation though.  Always down to learn.  

 

I'm glad we are on the same page. I wasn't trying to argue for Blue Star's position, just reiterate that that it was the point of debate. 

Per finishing, here is an example COLA of a finished whiskey. https://www.ttbonline.gov/colasonline/viewColaDetails.do?action=publicDisplaySearchBasic&ttbid=11046001000153 If you look at the bottle it just kind of looks like it is Kentucky Straight Bourbon Whiskey, but if you look at the COLA you can see it is indeed a whiskey specialty and requires a formula. Which is a type and class I am not familiar with and cannot find the specifics of. I'm not sure if age statements are even allowed for a specialty.

7 minutes ago, mattabv said:

In regards to nabs interpretation of bluestar touching used barrel by adding water or rolling is absurd. Dumping and adding new spirits constitutes a barrel being used. I disagree with this. This means you can never change or move the barrels placement EVER during its time in the barrel . Again absurd.

I am more in line with this view point, the barrel remains in it's 'new' state until it is emptied or in the event the barrel has some spirit added. 

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So what if a barrel requires two distillations, and two fills, before it's bunged?

So if I have a new char 53, put 25 gallons in one day, and then 25 gallons in the next.  Is it no longer bourbon because the second fill a day later was into a used barrel?

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57 minutes ago, Silk City Distillers said:

So what if a barrel requires two distillations, and two fills, before it's bunged?

So if I have a new char 53, put 25 gallons in one day, and then 25 gallons in the next.  Is it no longer bourbon because the second fill a day later was into a used barrel?

That is how I've always interpreted it. 

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2 hours ago, Silk City Distillers said:

So what if a barrel requires two distillations, and two fills, before it's bunged?

So if I have a new char 53, put 25 gallons in one day, and then 25 gallons in the next.  Is it no longer bourbon because the second fill a day later was into a used barrel?

I believe the regulations allow this, provided that it is distilled in the same location and is the same product, but it must carry the date of the last addition. 

As for all the rest, thanks everyone for the dialogue. I think we all have enough regulatory info to move forward in any direction people choose, if at all. I am however done discussing nuance of process and results in the open. There are too many fakilleries and re-bubblers on this site to risk giving up proprietary process info. Anyone who is a real distiller (and I define that as 100% of your products are fermented, distilled and bottled in your facility) then please message me direct and I would be happy to discuss.

Prost/Roger

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People think what your saying. This would mean every time you move a barrel rack or pallet with barrels on it you will have to restart the clock. How do all of you keep your barrels from drying out? If you rotate you stop the clock. If you saturate you would stop the clock. 5% lose now exponentially increases as staves shrink and vapor escapes. Glad you all don't make and interpret the laws. 

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12 hours ago, mattabv said:

In regards to nabs interpretation of bluestar touching used barrel by adding water or rolling is absurd. Dumping and adding new spirits constitutes a barrel being used. I disagree with this. This means you can never change or move the barrels placement EVER during its time in the barrel . Again absurd.

If adding spirits and then emptying the barrel doesn't count as using it, then what does? 

I think you misread or I mis-wrote?  My opinion is that a barrel is used after it has been filled and emptied. When/if water is added is irrelevant.  If you add spirit, then the age statement is altered. And with that, I end my interpretation. 

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Bottom line IN MY OPINION is unless the original spirit is removed from said NEW barrel Aging continues until the SPIRIT is removed changing the NEW unused barrel to a USED barrel status. Addition of water inside or out. Movement or rotation left or right. will not and does not change the aging of the SPIRIT until it is REMOVED from a NEW unused barrel. remove it and the second addition of un-aged spirits defines a used barrel. get real guys. nobody would have age to their spirits. stop splitting hairs.

 

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And yes nab, the emptying dictates the USED definition not adding

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OH yes and if Mona LOa erupts and your barrels vibrate your aging has been reset with the contact with the USED barrel. Sorry

 

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On 12/13/2017 at 1:13 PM, mattabv said:

Like I said. It's the spirit not the water.  Tax!$

Like I said, add enough water, and maybe it ain't the same spirit. Okay, another thought experiment: if I add spirit to partially fill, and then add more later to complete the fill, usually the way we treat that is that the START of the aging clock would be when the final addition is made to the barrel. So, another effect of adding water could be that it means you START the clock, although I doubt the expectation would be to do that after a significant time in the barrel in that scenario.

As for the "rolling barrel" stuff, that's just nonsense. What happens in the barrel stays in the barrel, so to speak. Why we are having this discussion is because something is from outside the barrel is being added to it.

By the way, there is a corollary question: If I remove spirit from the barrel, does it stop the clock? Obviously, the answer is no for sampling, for example. But since there is no de minimis, you could in principle remove half the contents of the barrel at one age, let the rest of it continue to age, and then later bottle that as older whiskey? Hmmm. And if that were so, and you could add water, you could refill the barrel with water after removing spirit, and continue to age it. Thus, the barrel could produce more than its filled volume in final product aged in new cooperage. Hmmm. Sounds like we are going down a rabbit hole.

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11 hours ago, mattabv said:

Bottom line IN MY OPINION is unless the original spirit is removed from said NEW barrel Aging continues until the SPIRIT is removed changing the NEW unused barrel to a USED barrel status. Addition of water inside or out. Movement or rotation left or right. will not and does not change the aging of the SPIRIT until it is REMOVED from a NEW unused barrel. remove it and the second addition of un-aged spirits defines a used barrel. get real guys. nobody would have age to their spirits. stop splitting hairs.

 

If you are saying that any addition of water will not stop the aging clock, as I mentioned before, that can not be right in ALL cases. If sufficient water is added so the gauged product no longer meets the requirement of a whiskey (below 80 proof) say, then the category/type has changed. So it must now become about how much water is added. Never mind the difficulty of trying to gauge in a barrel (get accurate proof and volume or weight) without removing it (which would stop the clock).

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