Classick

1 minute ago, StonesRyan said:

It appears I misunderstood.

It's been a dizzying whirlwind trying to keep up with the ever-changing rules.

No kidding.. 

I've been reading things over 3 times, trying to make sure WHAT im reading is the most current.. .then asking questions here just to get 2nd eyes on it... I think as long as we're all respectful, and appreciative of the considerable time folks are donating to clarifying things... we'll get through this

Thanks to all who have contributed guidance so far. Its helpful and maddening at the a same time haha. i guess this is the new normal

54 minutes ago, StonesRyan said:

Yes, as far as I can tell. Someone please correct me if I'm wrong but, if you want to sell it, even just to cover your costs, you must denature it. 

We offered to give our first batch  to our local city fire marshal for free, and they're insisting on paying fair market value for it... something about it needing to be like that for their books.

*Shrugs*

SIGHHHHHH.

Thanks all for your inputs and efforts in wading through all this stuff

I might have just answered my own question... footnote #9 on the most recent FDA guidance says

WE have specifically been told that DSP's are free to use undenatured alcohol... which Im choosing to use to negate the part in that footnote that says "in an aqueous solution denatured according to TTB"

Any thoughts?

I know its been brought up here previously, but has anyone heard of any movement on the discrepancy between the commercially available sanitizer at 71% vs what we're being required to produce at 80%.

Obviously stretching our scarce materials is of utmost importance.. but in addition to that... we've been in discussion with our EMS guys, Fire marshal, safety coordinator and various doctors, and all have been specifically requesting 70% vs 80%.. to save their hands the additional desiccation from higher proof product. Especially considering we cant ad anything but glycerin to our products as an emollient.

I've read and understood that FET relief only comes from producing according to FDA/WHO recipe... but that doesnt seem to be what "the people" want

Ok i did some due diligence on it and everything seems legit now... The guys from Gr Buffalo are just handling the bulk spirits side of things for Chrome, which purposefully decided not to include the ethanol side of their business on that website. I just spoke on the phone with the head guy.

Sorry to cause any concern

20 hours ago, SlickFloss said:

So this guy just unsolicitedly messaged me..... weird...... happy hunting folks!

 

Hello, I have tankers and totes of ethanol 200pf USP and SDA 40-B in stock and ready to go. Please give me a call if interested.

 

                                               Doug the Ethanol Guy,

 

 

Doug Towle (Co-Founder)

Green Buffalo Group LLC

Cell (562)357-0360

DougT@grbuffalo.com

www.grbuffalo.com

Has anyone tried purchasing from this guy?

I reached out, and they only have 200 proof in stock.

I've asked several times for their DSP number and company info so we could fill out a transfer in bond, and both times the request has been ignored.

He did send a pro-forma invoice.. but the information on that invoice is for a company called Chrome Diagnostics... https://www.chromediagnostics.com/ which apparently does indoor LED lighting and doesnt appear to have anything to do with spirits production

This is starting to raise some red flags for me. Just curious if anyone has had similar contact.

Thanks

Some of us have "been doing" for 2 weeks... Doesn't mean  we can't be cerebral about it

Good luck out there

10 minutes ago, DrDistillation said:

Curious, how many of you guys have noticed the WHO formula targets 80% ABV but commercial sanitizer like Purell only start with only 70% ABV before adding other ingredients including water?

"Ingredients: Active Ingredients: Ethyl Alcohol (70%) (v/v). Purpose: Antimicrobial. Inactive Ingredients: Water (Aqua), Isopropyl Alcohol, Caprylyl Glycol, Glycerin, Isopropyl Myristate, Tocopheryl Acetate, Acrylates/C10-30 Alkyl Acrylate Crosspolymer, Aminomethyl Propanol, Fragrance (Parfum)."

Purell is basically selling a 65% or so formula while the WHO is pushing an 80% formula.

Purell is the Canadian Club living in a cask strength world of sanitizers.

 

I've been wondering this very thing.

Hoochware just put out a calculator too

https://www.hoochware.com/calculate/handsanitizer

26 minutes ago, daveflintstone said:

fyi if you're having problems sourcing hydrogen peroxide: grow stores aka hydroponic stores aka where people go to get weed growing supplies, regularly sell gallon containers of 34%.

great call!

I just bought out my smart and final, they only had 4 gal of 3%.. but ill be getting some 30-35% from our local labpro tomorrow.

The form on DISCUS may or may not help distilleries connect with vendors looking to help supply necessary ingredients 

https://www.distilledspirits.org/distillers-responding-to-covid-19/

53 minutes ago, StonesRyan said:

Sourcing GNS seems to be a no go unless you were already a customer. It's cost prohibitive for a small operation like us to produce our own base for sanitizer and it's a damned shame we can't use fores/ heads for this purpose.

Apparently the FDA is now saying it must denatured.

well per the link above from bluestar https://americancraftspirits.org/wp-content/uploads/2017/02/Ethanol-for-Hand-Sanitizer-FINAL-3.24.20.pdf , these agencies are not talkin to each other... no real shock there

Formula guidance for the manufacture of hand sanitizer: TTB is authorizing the manufacture of hand sanitizer products consistent with World Health Organization (WHO) guidance. All TTB-permitted DSPs (including AFPs and beverage DSPs) may manufacture hand sanitizer products that are comprised of denatured or undenatured ethanol, glycerol (not less than 1.45% of the finished hand sanitizer product on a volume basis), and hydrogen peroxide (not less than 0.125% of the finished hand sanitizer product on a volume basis), without first obtaining formula approval from TTB.

I checked with Archer Daniels yesterday and they said they'd be out for the foreseeable future.

24 minutes ago, dhdunbar said:

 

The link doesn't work for me.  

it was really slow for my browser too.. i had to switch to a different browser.. but the link did eventually work

EDIT.. i just checked the link again and it loaded WAY faster.. maybe their system was overloaded earlier

Dont want to muddy the waters as i think this has been a very informative thread.... just wanted folks to be aware of this by the American Craft Spirits Association  (???) 

https://americancraftspirits.org/product/complimentary-webinar-hand-sanitizer-from-regulation-to-production/

The answer to this question is likely heavily dependant on the type of still you are running, and therefore very subjective. (perhaps adding pictures of yours, or listing the make/manufacturer might help?)

We dont run anything lower than 130 proof on our still, which is when fatty acids (turquoise floaties) start to appear (obviously depending on type of base material we're distilling)

However, we have the only still like ours in the US, so i doubt anyone uses the same settings we do.

I hadnt thought about that either... given these are used bourbon barrels... what do you guys do? use a sander and sand off the previous DSP information?

14 minutes ago, dhdunbar said:

If your records don't allow TTB to trace the spirits through the system, AND you can't account for what you are liable, then there is a potential for an assessment on the quantities for which you can't account.

And this is why im not too worried, because i can trace all the barrels, to all the gauge records and package records. I can account for each drop, which ,i'd think, is really what they care about.

Still, it had not occurred to me to staple labels to the barrels.. the only reason I've done it how i have was because all attempts to affix paper labels to parts of the barrels have failed I think I will give staples a try, since my barrel heads are already pretty crowded with jack daniels identification information

Thanks for all that info though! much appreciated 

3 hours ago, bluestar said:

I think if you got inspected you would be dinged for that, and asked to fix it.

maybe so...  cross that bridge when we come to it

of course as soon as i post a question... i find my own answer! sheesh.. oh well,, for the group, so you dont have to hunt

https://www.law.cornell.edu/cfr/text/27/19.485

Quote

§ 19.485 Package identification numbers in production and storage.

(a)General. A proprietor must mark with a lot identification number each package of spirits filled during production or storage operations. The lot identification number must show when the packagewas filled and must consist of, in order, the following:

(1) The last two digits of the calendar year;

(2) An alphabetical designation for the month from “A” through “L”, representing, in order, January through December;

(3) Two digits corresponding to the day of the month; and

(4) When more than one lot is filled into packages during the same day, for successive lots after the first lot, a letter suffix sequence starting with “A” representing the second lot, with “B” representing the third lot, and so forth. For example: the first three lots filled into packages on January 2, 2002, would be identified as “02A02”, “02A02A”, and “02A02B”.

(b)Packages constituting a lot.Packages of spirits, including any remnant package, received from customs custody or filled during any one day will receive the same lot identification number, subject to the following conditions:

(1) They are of the same type and either are of the same rated capacity or are uniformly filled with the same quantity by weight or other measurement method prescribed in § 19.289;

(2) They are filled with spirits of the same kind and same proof;

(3) If they are filled with mingled spirits, the mingling was conducted in accordance with § 19.326; and

(4) In the case of spirits imported or brought into the United States, they are filled with imported spirits, Puerto Rican spirits or Virgin Island spirits, as applicable.

(c)Serial numbers. At the time of filling, receipt on bonded premises, or withdrawal from bond, theappropriate TTB officer may require serial numbers on packages of spirits within the same lot in conjunction with the lot identification number. The proprietor must assign temporary serial numbers to packages for control purposes when they are transferred in bond in an unsecured conveyance or gauged after tampering within the storage account.

(26 U.S.C. 5206)

Hi all,

hoping the neural network can help me out here, im going nuts.

I know there is a TTB form or circular somewhere that gives the rules for how to create a barrel identification string, I know it exists because i have used it before... but for the life of me, i cant find it anymore.

I DID find this page: https://ttb.gov/spirits/common_compliance_tax_issues-during-audits-ds.shtml

Quote

If spirits are put into barrels (cooperage) for aging, DSPs must keep records that designate the type of cooperage:

·         "C" for charred;

·         "REC" for recharred;

·         "P" for plain;

·          "PAR" for paraffined;

·         "G" for glued; or

·         "R" for reused; and

·         "PS" if a barrel has been steamed or water soaked before filling. 

But i know there is a part where it says you use the 2 digits of the year, then letters A - L to represent which month, then the 2 digit day... but i cant find that page, nor to i remember if anything else needs to be in the string.

Help?

thanks

I have been printing stickers with the pertinent information on the rack underneath the barrels, then covering the stickers with clear tape to protect.

probably not strictly legal, but when using reused barrels that already have info printed on the heads, there's not much room for new info. hopefully any auditor would see we're making best effort

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sorry my bad.. thats who we use to test other stuff... this is who we used to test water.

http://www.torrentlab.com/