bluestar

If you are denaturing, they are there. NB: the label from the FDA does not say ETHANOL, it says ALCOHOL, and I think that is how they get around this, because methanol is also alcohol, so the mixture would be, I guess?

Normal.

I am still unclear that the TTB will allow a DSP to denature the alcohol without additional permits. And the FDA just indicated they will require the sanitizer to be made with denatured alcohol. Catch 22 for a DSP?

So, what seems NOT to be addressed is that normally a DSP can not denature alcohol for some other use without a permit. The TTB does not seem to have indicated that requirement is waived. And while they indicate you could make sanitizer with un-denatured alcohol if you pay the federal tax, the FDA has issued guidance requiring that the alcohol be denatured according to TTB formulas. I will note, interestingly, that the FDA ingredient list does not list the denaturing agents in the final product. Also, WHO does not require denaturing, which is what the TTB refers to. So, there seems to be a small Catch 22 regarding denaturing for DSPs that want to produce the sanitizer themselves for distribution.

All the newest guidance is great, but some things still seems up in the air? WHO does not require denaturing. FDA does require denaturing, per TTB denaturing formula. TTB says if not denatured, you pay tax. But FDA suggests you can not make with un-denatured ethanol. Nowhere can I find from TTB guidance where a DSP will be allowed to denature their beverage product without additional permits. I also note FDA gives required labeling, and says you must register with them you are going to distribute product. I also note that the denaturing elements, like methanol, are NOT listed as ingredients on the FDA labeling (seems misleading to me). Anyone have any further clarification on these issues?

@dhdunbar, how do you think we are supposed to handle what looks like the allowed production of the sanitizer from beverage spirit (pay tax of course), if we follow WHO formulation? For example, how do we report that in our production and processing monthlies? If we label it, does it have to be labeled as if it were alcoholic beverage? Would a label have to be approved? If so, and we submit a COLA, what has to be on it for description? You get my train of thought? It was not obvious to me from the TTB notice that these go out the window, just because we are allowed to make it...

Yup, and for the few plastic bottles I could find, you could not get a dispensing top for them, just a simple screw off. Not sure they were alcohol compatible either.

Also consider that for Denaturing formula NO. 1, the primary agent added is METHANOL, so trace methanol in heads should not be a medical/safety issue. The secondary agent is a KETONE, so having traces of that in the heads should not be an issue either?

That is the WHO formula. That is what the TTB will now allow...

Interesting point about the lead. Unfortunately, there are some lead-organic volatile compounds, that perhaps could be created during distillation (specifically tetraethyllead, what they used to add to gasoline). While the amount that might come across is very small, the toxicity of the lead is far worse than for any copper-organic compounds.

REGARDING WHITE or UNAGED WHISKEY labeling: In the proposed rule changes for § 5.143 there is a table that includes the possibility of labeling whiskies as such. It also allows that the may be labeled as "White <grain name> whiskey or unaged <grain name> whiskey" if there is 51% or more of the named grain. All well and good, but ironically, that would create a situation where you could do so for white or unaged product, BUT NOT AGED whiskey in grains other than standard. Currently, you can not label something as "Spelt Whiskey" if it is made with 51% or more spelt, regardless of how it is aged. These "off grain" (something other than malted barley, malted rye, rye, wheat, or corn) whiskies must be categorized as "whiskey" with an added field (not part of the official description) describing its make up, and for which no set of standard rules apply, other than not being misleading. I would argue, if they are going to create this rule for white or unaged whiskey, they should also extend it to aged whiskies, OR treat white/unaged whiskies the same as aged whiskies when labeling for "off grain" mashes, for consistency.

The answer is in the passage you quoted. Your second distillery IS your bonded warehouse (that used to be a separate license, but you can do it under your DSP). Your second distillery is ALSO the bottler. So you can source the whiskey from elsewhere, age it in another distillery and bottle it there. You must identify both where it was distilled and where it was bottled. Long ago, this would be common, one place distilling, another place bottling, and in between, at a dedicated bonded warehouse for aging. NOTE: the TTB is considering the modification of rules for whiskey (and maybe other spirits) that would require ALL of them to indicate where distilled and where bottled. Currently, you only have to identify where bottled, unless you are Bottled in Bond.

Only comment is that it depends on your still design, and your starting ABV. I know there are many that can get below 160 with 4 plates, but I know many other stills that can't do so even with the bypass open. So, if you are planning to do this for a new operation, and have not yet purchased the still, make sure you know how that still performs under these conditions.

Yes, of course. I actually like some of the rhum agricole, with their herbaceousness. I haven't liked most of the syrup-produced rums I have tried. Some of the Guatemalan rums are produced that way. None of the craft rums of that type have impressed me, but admittedly, 1) I haven't tried many, and 2) I am a fan of rums with strong molasses-derived flavors, like Jamaican and Barbados.

You can. Depends what you are distilling from. If you are distilling from fermented mash, rather than clear beer, you might have to worry about fouling the first plate. But since you mentioned you are using a wash, that might not be a problem, especially if you use antifoam. More of a challenge might be getting below the 160 proof for a whiskey, but getting the desired flavors. Our still, with 10% wash, will produce over 175 proof with 4 plates. I can drop down to 2 plates and get down to 160, but I won't get a clean enough product or good enough separation on cuts. By doing a double or triple run method, since you are usually rediluting the product between runs, you can stay below 160 proof on the final distillate, but get a cleaner, better separated product. YMMV. BTW, when making product that does not have the 160 proof limit, we usually do run our still with 4 plates and a single run. But for our whiskies, we remove the plates, and double distill. Again, YMMV.

If you look at my reply, you will see that I did anticipate the some of the conditions you describe. Yes, if your filters require higher pressure differential than 14 psi, you can not use vacuum alone. However... Let's talk safety: One advantage of a vacuum system for filling of higher-proof spirits (as opposed to beer, wine, or non-alcoholic beverage) is that it could be nominally safer. Yes, it will fail by cavitation if there is a leak, but you won't leak high-proof spirits and continue to run, which is an unsafe condition. And the leak does not have to be major, if pressurized, just enough to provide ethanol vapor. Also, if you are going to pressurize ABOVE 15psi with high proof spirits, you may change the safety requirements for your distillery, since you will need to have a pressure vessel with flammable materials. Of course, part of why I do use them is because I do so with vacuum filler systems. And they have worked so well for me, that when we set up to filter spirits without bottling, we set up a vacuum based system as well. Yes, you must purchase filters that will operate efficiently below 14 psi, and you will not be able to extend the lifetime of the use of the filters by raising the pressure above that. Generally, this has not been a problem for us filtering spirits, I can see it being a definite problem filtering wine or beer. BTW, for most of the pleated filters we use with our spirits, while the maximum rated pressure is as high as 50psi, their nominal operating pressure is far less, typically below 10psi. I stand by what I said, although I appreciate your clarification. By the way, I certainly agree with you, I would not set up to use vacuum on one side and pressurize the other, that was not what I meant to describe. I meant that if you are using filters that should operate BELOW 14 psi, you can use flow control to drop the pressure further. Nevertheless, I think we can agree, that if you want to operate filters that require greater than 15psi differential pressure, vacuum is certainly not going to work for you.

There is a distillery in NY that was known to do 100% green (unmalted) rye whiskey without addition of enzymes. It is hard to do, but possible, because rye is one of the few grains that has some enzyme available in the unmalted grain and is one of the easier grains to convert. We do our "rye" whiskey with 100% malt rye.

Rhum agricole.

Maybe, but just a semantical clarification: Most all pumps people use are positive displacement pumps. Most such pumps would exhibit problems with pulling vacuum because their seals are not rated for vacuum. But plenty of them are, and the vacuum quality needed here is very poor: even a 1 psi will give you most of the pumping you need on the vacuum side, and almost all positive displacements pumps can do that. And of course, a diaphragm pump is a positive displacement pump, and generally can pull a fairly good vacuum. There is ONE exception, and that is a positive displacement pump that is designed to use the pumped fluid as the lubricant for the displacement element. This is the case, for example, in most impeller pumps used for things like wine, beer, or mash transfer. On the other hand, these are bad choices for use with spirits. Similarly, most momentum transfer pumps, also used for wine, beer, or mash transfer, will not pull a vacuum at all, and in fact, must be pre-primed before pumping. But again, these are even worse choices for use with spirits. By the way, any self-priming pump is pulling a vacuum, although some are limited in the quality of vacuum, and some can only be run unprimed for limited amounts of time.

I am sorry, but generally this is just not correct. The physics doesn't work that way. Filters work on pressure differential. The filter only "sees" the difference in pressure across the filter material, and doesn't know that, relative to outside air pressure, the pressure on the low side is at atmospheric pressure or zero or something in between. But the TOTAL pressure drop across the filter is what matters, so it IS true, that if you want to operate the filter at significantly LESS or MORE than one atmosphere differential drop, that pulling a vacuum on the low side without something to adjust pressure on the high side would not do what you want. I don't know what the STRONG ARGUMENTS are against pulling through filters, as far as the filter function is concerned, UNLESS that filter is meant to operate at something very different than one atmosphere (1 bar, 15 psi) differential pressure. If the concern is controlling flow, that is simply done by a flow control valve, same as if you pressurized with a pump. The latter will also allow you to drop the differential pressure down below 1 atmosphere, since the differential pressure across the filter and the flow rate are roughly proportional.

That is somewhat surprising, because when pumping spirits, most commonly used is a diaphragm pump. Those operate the same as pressure or vacuum pumps.

Sucking and pushing are the same, provided it is the same pressure differential. And regular filters should not be run at high pressures, so sucking is a great way to do things, because you can't get above 1 atm pressure. Enolmatics work on this principle.

We use these when we have to for events that require biodegradable. They are poor cups to be used for tasting, they are really for condiments. The roll over lip is meant for a cover lid and to stiffen the cup, and is not well suited for sipping, since it cuts into your lip, and tends to dribble. Also, the cups don't stack well, any more than a dozen or so tend to flop over. And they melt at 114°F, so don't leave then in the car on a hot sunny day. And while PLA is biodegradable, it is not considered well-suited for disposal in land fills, since when buried, decomposition is slowed. It must be composted industrially in digesters designed to handle it.

We have a high-temp glasswasher for our bar/tasting room, so cleaning shot glasses would be no problem for us either. So, indeed, we have thought about it. But even if you don't normally plan to give them away, I suspect you have to plan on a few of them "walking off". But our concern is that you still need a solution for OFF-SITE events. For many events, we are now being asked to use biodegradables, so we really wish there was a good choice available. Where they only require recyclable, I think the medical dosage cups might work out fine.

But if you want to use a phrase like "single malt whiskey", then, even though it is not a standard US type, since it would be assumed it has a similar meaning by the consumer as used elsewhere (like Scotland), it would have to be 100% malted barley and from a single distillery.