TTB regs and a sink in distilling area

[Jaguiler]

Hello - 

I have a question - does the TTB mandate a sink or a 3 sink basin in the distilling area ?  Does your state require this or the health department ?

Thank you !

[Silk City Distillers]

TTB doesn’t care about sinks.

This is typically determined by your local health department and/or the FDA, along with separate handwash sinks, etc.

[dhdunbar]

I'll add a more general comment.  For the most part, TTB is unconcerned about any health or safety issues.  The only health issue that comes to mind is the requirement that all ingredients be "generally recognized as safe" by the FDA.  They are not concerned about sanitation, or fruit flies, or hand washing habits.  GRAS is their issue only because of the dual jurisdiction that FDA and TTB share over beverage alcohol, which the law considers a food.  By a memorandum of understanding, TTB's labeling regulations apply to most alcoholic beverages and all spirits.  So TTB agrees that it will police, for the FDA, the GRAS standards, which FDA determines.  For GRAS, TTB is the tail and FDA does the wagging.

This is not to say that TTB employees don’t care about health issues, but it is a personal concern.   There is a first principal at play here -  TTB can have official concerns only about things which are contained in laws over which Congress has given it jurisdiction.  While you cannot know, unless you have my sort of intimate familiarity with those laws and the regulations "promulgated" under them, what you may not know you do not know about what TTB requires, one trick is to find searchable versions of parts 5 and 19 of the regulations and do a search for a word like "sink" or anything else about which you might be curious.  

The DSP regulations - part 19 - are issued under the Internal Revenue Code.  Think about that.  Every business in the country is subject to the provisions of that code.  Every business, profit and nonprofit, sole proprietor, partnership, corporation, LLC - none of that matters.  The IRC is a hefty document, not hernia heavy, but if it were to include concerns about health, etc., lifting it could become an event in the strongest persons in America competitions.  

The FAA Act, the other principal stature under TTB's jurisdiction, is concerned with what you say on the label, your trade practices, the need for permits, and the requirement that you submit formulas.  The formula requirement touches on GRAS issues, because TTB evaluates the ingredient use to see if the FDA has said they are GRAS as used.  But that is it.  

However, you must register your facility with the FDA and it is subject to FDA inspection.  That is the federal agency that is going to enforce the health standards, if anyone is.  About what FDA requires, I am as ignorant as most everyone else in the country is.  And, as Silk City points out, state and local authorities enforce their own codes. How do you determine what you do not know you do not know about such things?  You must identify the agencies that have jurisdiction and ask them.

[Jaguiler]

Thank you both for these great answers - 

[Thatch]

5 hours ago, Jaguiler said:

does the TTB mandate a sink or a 3 sink basin in the distilling area ?  Does your state require this or the health department ?

The State of Ohio Department of Ag, Division of Food Safety does require both a hand wash sink and a 3 basin sink to wash support items.

[bluestar]

Since you are a food facility, and must register with FDA, eventually you will be under the jurisdiction of a state agency, in most states, tasked with doing the inspections for food agencies. Sometimes that is the state agricultural department. In any case, in most cases, they will be looking for a hand sink and some means to clean and sanitize equipment coming in contact with food stuffs during processing or packaging, which means 3 basin sink or steam cleaning system.