Thatch

What the barrel adds is not a concern to the TTB, the regulation is referring to actually adding a dye to your spirit such as caramel coloring.

Anyone got a line on in-stock 2 to 4 ounce spray bottles for a reasonable price? We had delivery promised for Monday and now it's next month.

Great Job Dr D. This makes me breath easier. We're all just trying to help out and dissecting specs is not my long suit.

Called several, this is what they used in the 1980's but not now. Called tattoo supply houses - they use something else as a sanitizer. Apparently not USP from what I could find. I'm posting the above for other folks. We lucked out and scored several cases with a local Drug Mart. The initial response I got was one per customer. But, when I talked to the manager and told him what we're doing he was more that happy to turn loose of most of what he had.

Sent you a PM

You've misunderstood. That is not me, I simply gave you a contact to call to see if they would share their recipe. I saw it on FB and gave you the contact info. Call the number and see if the guy will talk to you.

Thanks, very helpful

Saw this on Facebook Flatrock Distilling Company· We had a few questions about mineral oil in some distillery made sanitizers. Our hand sanitizer is made with Aloe Vera and essential oils. We do not add mineral oil to batches. (419) 868-8114

Having great difficulty finding H2O2. We're in Ohio, anyone know any sources that have stock?

Thanks, but I'd really like to know if USP is mandatory, I can't find that requirement in the spec

Early on in this thread I had found some denatorium benzoate and I was asked if it was USP, it was not. I am searching the denaturing spec and I cannot find where it needs to be USP. Does it need to be USP? Please point me at the page.

My Bad, the text above is from Part 27 CFR part 20. Dr. D has the correct info.

I'm not a lawyer and I'm not a chemist. But, the spec says "95 parts by vol.; and Isopropyl Alcohol, 5 parts by vol." Therefore my answer is 80% since the WHO spec for Ethanol is 80%. I expect someone with a Doctorate in chemistry to correct this.

Dave, is this what you're looking for? Supposedly this is the text The federal excise tax is waived on any distilled spirits used for or contained in hand sanitizer that is produced and distributed in a manner consistent with guidance issued by the Food and Drug Administration and is effective for calendar year 2020. Seems like the FDA is driving the bus.

We were lucky to get 200 2 gallon jugs donated by a local packaging supplier. We asked and they were happy to help out.

First, I'm not a lawyer. This is the newest FDA doc https://www.fda.gov/media/136118/download You will note that at the top of many of the pages there is text that says "Contains Nonbinding Recommendations" When you search on that text, you come up with several legal opinions, one of the opinions was written by the Attorney General of the United States. The question is, do you have to follow FDA guidance that includes this text. The answer is, it is not law. https://www.achesongroup.com/post/fda-guidance-do-i-have-to-comply

Thanks Dr D, Well said. For @RevolutionSpirits and @Classick, he mis-typed, we have a line on 5 grams, not 50 and it is not USP. Going back to plan A.

Don't know, trying to get in touch with our distiller

My math is wrong, we're going to have way to much. Thanks for checking my math.

You can't skip the denaturing. The TTB has deferred to the FDA and the FDA mandates denaturing.

Sure, we're all trying to save humanity. These new chems are not inexpensive. We got the last of what they had a one place. It seems that they are also somewhat controlled according to my distiller. When purchasing you have to fill out a form and they may or may not ship to you. It was $68.40 for the Tert-Butyl Alcohol, 2000 ml of Tert-Butyl Alcohol enough for 400 gallons of sanitizer. 50grams of DENATONIUM BENZOATE enough for 282 gallons was $108

That's what it says on the ttb doc for sure. But, the ttb have deferred to the FDA who basically have said it must be denatured or we may pursue you.

Okay, the new FDA guidance just posted a few minutes ago by the forum moderator is allowing distillers to make hand sanitizer and the FDA says they will not prosecute us for making it. BUT, it has to be DENATURED. Here's the new doc Ethanol-for-Hand-Sanitizer-FINAL-3_24.20 (1).pdf

Dr D, I like your reading a whole lot better than mine. The key phrase is "pharmacists in State-licensed pharmacies or Federal facilities" To me this means only pharmacists can make the formula. That pharmacists can be in a Drug store or a Federal facility like a penitentiary and the FDA will not prosecute them. However, the rest of us are not allowed. It seems that the TTB is completely deferring to the FDA in this matter. I'll stay tuned for updates. I want to be wrong.

This is crazy. If you read the FDA doc they are only allowing State licensed pharmacies to make hand sanitizer or they threaten prosecution. https://www.fda.gov/media/136118/download This is no longer about denaturing, we are NOT allowed to do make hand sanitizer. 4 Specifically, FDA does not intend to take action against pharmacists in State-licensed pharmacies or Federal facilities, for the duration of the public health emergency declared by the Secretary of HHS on January 31, 2020, for violations of sections 501(a)(2)(B), 502(f)(1), and 505 of the FD&C Act (21 U.S.C. 351(a)(2)(B), 352(f)(1), and 355), or against outsourcing facilities for violations of sections 502(f)(1), 505, or 582 of the FD&C Act (21 U.S.C. 352(f)(1), 355, and 360eee-1).