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Still_Holler

Inventory Requirements - barrels

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I've been re-reading some cfrs trying to make sure I am doing all the reporting correctly.  My question is does the quarterly inventory include all barrels?  Do you have to move and weigh all barrels each quarter?

19.333 Physical inventories. A proprietor must take a physical inventory of all spirits and wines held in the storage account in tanks and other containers (except packages) at the close of each calendar quarter. A proprietor must record the results of the inventory as provided in subpart V of this part. TTB may require additional inventories at any time.

 

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You found the section that has your answer, but getting the answer requires that you know that a barrel is a package.  If the regulation uses a word, like "package", and you are not sure of what it means, look to definitions  section (19.1) for answers .  In this case, package means "A cask or barrel or similar wooden container, or a drum or similar metal container."  So you need not inventory the spirits you have in barrels.   

Note, this would not exclude, as I read it,  larger plastic totes, which are an anomaly.  They are not tanks, they are not packages, unless we take "drum" to be inclusive, which i think is not intended.  So totes, I suppose, are portable bulk containers with a capacity of over 101 gallons.  The regulations do not address how to handle that kind of container.  Container is also a defined term, by the way.  It means "A receptacle, vessel, or form of bottle, can, package,tank or pipeline (where specifically included) used or capable of being used to contain, store, transfer, convey, remove, or withdraw spirits and denatured spirits." 

TTB fixes anomalies when they present problems.  Since they have not dealt with the tote issue, they apparently do not perceive a problem that is worthy of the time necessary to give an answer.  I've treated the totes question like a sleeping dog.  I chose not to kick it.

  

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Thanks, I just found those definitions. The efcr.gov website is much easier to navigate the the gpo.gov site.

So is being in the storage vs. production account what differentiates a "tank" from a "package"? 

If I do my production gauge on each still run and then transfer  into the storage account to a 100 gallon metal drum, the 100 gallon drum would be a "package" and not subject to the quarterly inventory?

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This is getting a bit specific, but ...

Tank vs. package is not account dependent.  Further, there is nothing in the regulations that definitively differentiates a tank from a package.  One part of the reg (19.75 maybe)  says something don't need to list portable bulk containers of less than 101 gallons unless they meet the criteria for a tank under 19.182, but 19.182 only says, if you have a tank, then you must equip it with ... and totes have none of what is required by 19.182.  Nor do barrels or drums.  That does not say that a metal container  of some size, say a million gallons, noit so equipped, would qualify as a drum.  It would certainly be a tank, and if it didn't have what 19.182 required, it would be in violation of that section.  But beyond that we have anomalies that TTB has not chosen to address, as far as I know.

Webster - Tank - a large receptacle or storage chamber, especially for liquid or gas.  Large?  TTB may intend that anything larger than 101 gallons be equipped as required for tanks.   They have not said so.  Their de facto acceptance of 275 gallon and larger plastic totes  may be taken as an answer not otherwise given.  The same question could apply to how large an oak  barrel can you have to store whiskey?  At what point does an oak tank not serve as a container fit for aging?  That is a question I will not ask until I have to answer a question for a client.  

Finally, a metal drum is a package and need not be inventoried.  The section for processing inventories is Sec. 19.371  "A proprietor must take a physical inventory of all wines and bulk spirits (except packages) held in the processing account at the close of each calendar quarter."

Holler by PM  if you want me to go still further into this on your behalf :-). 

 

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