We are building out a very small craft and R&D spirits DSP. We have no inside tanks, outside tanks and have no intention of storing portable tanks such as totes. We will have a small amount of barrel storage, retail packaging, and some spirits in small process containers not considered portable tanks (glass carboys for example). CFR 19.192(e) makes it appear we may not have a need for TTB approved padlocks:
Question 1: Does anyone have experience with TTB visiting or auditing a site that had nothing but barrel storage, or retail storage and gotten any grief about padlocks?
Secondly, If we do decide that we are subject to paragraph (f), we would prefer not to padlock from the outside because of the safety issue of possibly locking someone in. Plus, our front door is in a mixed retail/light industrial center, and an external padlock would seem out of place. Our preference would be a secure mortise lock for the door, with a no-key-needed knob on the inside for emergencies. We have the door alarmed.
Question 2: Has anyone had experience in getting a mortise lock approved by the TTB, as 27 CFR 19.192(f)(2) provides?