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Jaguiler

Question about separation of distilling area and samples area

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Hi everyone,

I have another question. I am looking to lease a 2 story building.  Think of it like a townhouse.  The bottom floor would be my production area, the top floor will be my sales area.  Both areas are naturally separated by a stairwell.  My question is - my bottom area is the front entrance also - meaning that customers would walk through my production area in order to get to the stairs to go to the sales area.    Both areas are separated because they are on different floors, but people would walk through adjacent to my actual production area to get upstairs.  I can block off area where they cannot walk with half walls for safety reasons. Is this allowed ?

 

Thank you all in advance - John

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I am sure someone will come along with the actual spec, but I believe you have to have a physical separation between the two.  So you would need some sort of wall and door to make them separate spaces.  

With that said I have been in facilities that have no separation.  

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If I place a door at the steps, they would be separate.

But how about the issue of people walking in through the DSP side ?

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If you are selling bottles the customers can not pass through the bonded area when they leave as tax paid alcohol would be passing into a tax unpaid area.  For samples only it's probably OK, but the TTB will not allow bottles to be sold in such a configuration.

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Interesting, thank you. If I have a separate exit it may work.  I know this question has come up, but I will ask again. What is the requirement for the separation? I believe it was floor to ceiling.  Any specification as to material ? 

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Do you have an elevator? If so, consider the implications both legal (like in regards to ADA and fire code) and practical (like carrying all of your merchandise up and down and making your customer's walk up and down creating bottle necks) of having a retail space that can only be accessed by stairs for both you and your potential customers.

Beyond that, I'm pretty certain they both need separate entrances to the spaces. So a separated 'joint entry'  that has doors to each space would work.

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In the end, it will be up to who at the TTB reviews your application. But the general answer is no. You can pass through space you control that is not bonded premise to get to bonded premise. But you can't do the reverse, or at least that can't be the official entrance to that space. For example, I know a distillery that had to add a bathroom to a tasting room because the existing bathroom was in the bonded premise, and that could not be treated as publicly accessible, as required by code. And you might have fire code issues with egress, as well, having to go from a public assembly or mercantile area through a hazardous or industrial space for exit.

Without seeing layout, it is hard to speculate. But what you will likely need to do is create an entrance lobby that is not bonded premise on the first floor that both exits outside and is the location of the base of the flight of stairs. And while there have been some distilleries that have had less than floor-to-ceiling wall separations of bonded premise from other space, the rule essentially says you can't do that. Best might be to give the drawings to a TTB field officer to review for you.

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