Classick

We're just starting our aging program... but I'm already thinking about things down the line.

Anyone got any tips or tricks for emptying 53gal barrels?

I think our plan is to fashion some kind of rack they can roll on out of 2x4's and just empty them over a 350 gal stainless steel tank... i know thats gonna take forever though due to the exchange of liquid and air when emptying.

i know there are racking stems that wineries use... just curious if anyone else has a trick setup.

Cheers

just posted our setup and link to the nozzle we use in this thread

We have a self cavitating tank pump that we set up for circulation (so the spirit doesnt stratify)

I set up a "T" on top of the pump output, which connects to a transfer hose and a gas pump style filling nozzle from Finish Thompson (http://www.burtprocess.com/shopping/search/nozzle?brands=13)

When the filler handle is depressed, the output of the pump is channeled into the transfer hose, and when the handle is released, the flow goes back into the tank for circulation. much quicker than gravity feeding. I can fill a 53 gallon barrel in about a minute.

i should also clarify,  we werent "worried' about  it. . .  just curious as to how often others might be experiencing it

thanks for the replies.  ill have to inquire about the sparging details. 

the main problem thats being faced is its impossible to tell if the bottles are afflicted ( its a frosted bottle... of course) until the product has already been bottled.

per that link above, the glass can be treated with fluorine gas or something, but im not sure if the manufacturer can offer that option.

i was just curious how common this was... I had never even heard about it until this happened, and had never seen it mentioned here. Perhaps there are others that have experienced it.

New to spirits bottling, but have a long record of bottling other products.

I believe they've had their water tested, and it passed muster. Im reasonably satisfied that the information contained in the link above is the culprit, I was just curious if any other small batch distillers had experienced anything similar.

Seems like the main factor would be storage of glass bulk glass either at the manufacturer, or in transit... not sure if glass order size (custom vs stock glass, etc) would be a significant variable.

Hey All,

Just wondering if anyone has experienced a milky haze (tested via lab as calcium carbonate) suspended in their product after bottling, described in the link below, and if so, what you did about it.

A client we produce for (but do not dilute or bottle) recently experienced this and we're trying to offer them solutions.

In my 16 years of distilling, we have never once come across this. Any thoughts?

http://www.qorpak.com/pages/glass-weatherization

depends on what you're trying to clean from the surface. But if it's normal Brewing stuff we have had very good luck with PBW. I believe that's what most breweries use to clean their tanks as well

if its a standard bung hole,  they make stoppers with small. apertures in the top on which to afix the air lock

https://www.morebeer.com/category/airlocks-stoppers.html

On 7/23/2016 at 11:17 AM, dhdunbar said:

Bluestar is correct about the legal designations.  But the term "rectifier," or its variants, now appears only in the Federal Alcohol Administration Act regulations, parts 1 (permits) and 5 (labeling).  It does not appear in part 19, the distilled spirits plant regulations.  It was banished, so to say, when congress eliminated the separate excise tax on rectification.  If I recall, correctly, that was in the early 1980's.  And prior to that, distillers could also be rectifiers.  Small players who only rectified and/or bottled were commonly called "bottling houses."  Few of them professed to craft.   Most made well products that sold on the bottom shelves in liquor stores.

In part 19, "rectification" has become "processing," which also includes bottling, etc.  TTB approves the registration required by part 19 for distillers, warehousemen and processors.  Although it will approve a registration as a distiller or warehouseman only, a processor must also be either a distiller or a warehouseman.  So, in the United States, if you do not distill, but do conduct processing operations, then you must also register as a warehouseman.  

This terminology has not yet found its way into the permit and labeling regulations of parts 1 and 5.  The permit provisions 27 CFR 1.21, provide that "no persons, except pursuant to a basic permit ... shall ... engage in the business of distilling distilled spirits ... or rectifying or blending distilled spirits, or bottling or warehousing distilled spirits."   If this were rewritten in the language of part 19, it would say that except pursuant to a basic permit, no person shall engage in the business of distilling, warehousing or processing distilled spirits. 

Part 5, the labeling regulations, make repeated references to "rectification," or variants thereof (the terms occur 11 times), but the regulation does not define what the term means, either within the definitions section, 5.11, or in the definitions section of part 1, section 1.10.  The regulations rely on the meaning of the IRC regulations at the time the FAA regulations were written.  

So, if you are qualified to do business, as a distilled spirits plant,  in the United States, you may be dubbed either a processor or rectifier, depending on which regulation you are reading, but the bottom line is that there are no longer any operations conducted on bonded premises that are identified as "rectification."  It is all processing.  In my early years in college, we had a sophomoric expression, "It's all semantics."  In this case, that is true.  

To further confuse, the mandatory statements of name and address allow for different statements depending on the operations you conduct.   The bottler must state that they are the bottler.  The bottler also may state that it is the distiller if it distilled the spirits, either by original distillation or by redistillation in the processing account.  If the bottler is also the "rectifier" of the spirits, it may state in addition to the mandatory bottled by statement, that it blend, made, prepared, manufactured or produced the spirits, depending, as the regulation states, on whichever term may be appropriate to the act of rectification involved.  By regulation, "rectified by" is not among the optional terms.  I do not know what TTB does in practice (who does?), but rectify is not among the optional terms listed in the beverage alcohol manual either.  

I'll leave it to you to determine the differences between manufacturing, producing, making, and preparing, and what specific operations make one more appropriate than the other.  I think TTB does not care.  I think if you conduct a processing operation, as defined in part 19, then you could claim the right to use any of them.

But this is all very far removed from the character of the spirit that is in the bottle.  It is intended to inform the consumer.  Long explanationslike this speak volumes, I think, to whether it actually does so.  It takes a wonk, i.e, someone who takes an excessive interest in minor details of policy, to even try to get this straight.  I take that interest because as a consultant, if I do the wonky work, I free others to do the real work without fear of getting crosswise with TTB.  

Finally, let me ask a few questions?  Who in the public knows the difference between 'produced by" and "distilled by?"   Would the number who know be even 1% of the purchasers?  And among those who do know, what percentage would make the purchasing choice based on the distinction?  You may want to point this out as a part of your marketing, but I think you market to a small percentage of buyers, in most cases probably to those who come to your tasting room or find you on social media, i.e., those who are inclined to participate in your story to begin with.  You don't have advertising budgets that allow you to sway public opinion.  This leads to a final observation.  I'm not sure that casting aspersions at small companies that hold forth as craft players, whatever the circumstances, is good for the craft market you are trying to build.  But about that I'm over my head.  I'm a regulations wonk, not a marketing wonk.  .  

that was an excellent read. thanks for the effort

are you talking about a fermentation lock? 

Well at least thats a diagnostic... if it were predictable, you'd know something.. that it isnt... you know what it isnt.. and that something too  haha. the absensce of evidence is not evidence of absence, as they say.

Only thing else i can offer is that when we notice our yields are not what we expect, and the settings at the still (flame, water etc) were according to SOP, then it means we had a leak in the still somewhere, i.e. we didnt latch down the top of the still properly, or one of the connections was loose.

Love to see the group troubleshooting though.

Are you seeing the same type of fluctuation at the same time of day each day? Is it predictable? 

maybe post a pic of your still? might give folks a better idea of the physics

are you turning over the wort tank before you fill the still each time to harmonize the alcohol in the solution? with an ABV that low, i shouldnt think it would stratify so much to have an effect, but just trying to get a complete picture

I have really enjoyed reading all this. great contributions.

worked for me

When we get wine with free so2, we just add hydrogen peroxide to it.

You can figure out how much to use with these calculators http://vinoenology.com/calculators/SO2-addition/

Hi Mike,

We are in the process of planning an expansion, and will adding a closed loop system to our new facility. When we get to that bridge, ill reach out and see what ya have in stock/could put together for us.

Cheers

having seen this industry grow for the last 16 years.. i can definitely say its different than say the brewing and wine side of things.

Since so much of our products are a result of our individual stills, there is not nearly as much competition (comparatively) as there are for purely procedural sciences like brewing and wine making.

Recipes and techniques can be discussed more freely between distillers, particularly if the stills are of different origin.

As long as you are not asking them to create FOR you (without compensation), I would appreciate and or consider any thoughts they might have to offer. Cordiality (and sharing of spirits) between distillers is a wonderful thing.

just my 2cents

PS, if it hasnt been said yet.. thank you for your service. we are a Combat/Service Disabled Veteran Owned Small Business ourselves.

I was given a tip once about having a business inspected.

Purposely have one minor but obvious fault that the inspector can find, eg a fluoro light cover missing, or a piece of gaffa tape in the wrong place.

They might then be satisfied that they have done their job and not look too much harder.

bingo...

just passed our annual fire inspection today too.. phew... that makes FDA, Hazmat, AND fire guys all in the last 2 months... Talk about sleepless nights. Even though we passed them all with flying colors, its still pretty nerve racking

Hoses on the floor could be a trip hazard but why would she ask for the duct tape be removed?

LOL... we just have a saying at our shop (family owned and operated) If you can trip over it, burn yourself, or gouge yourself, you will... so watch out.

so after 3 hrs, and detailed description of what we are doing at our shop... the Major (they're a branch of the armed services???) determined that we are of such little "risk"... that we could be removed from their inspection list... so thats good... one less inspection to worry about.. .but in 16 years of operations, this is the first we've ever heard from the FDA... who knew?

HUH.. so after some research.. i found this.

I. PURPOSE

This agreement between the Food and Drug Administration (FDA) and the Bureau of Alcohol, Tobacco and Firearms (ATF) is to clarify and to delineate the enforcement responsibilities of each agency with respect to alcoholic beverages considered adulterated under the Federal Food, Drug, and Cosmetic Act of 1938, and for other related purposes. Specifically, this Memorandum of Understanding will:

(A) Effect a more efficient system of communication and exchange between FDA and ATF;

( Confirm ATF policy with respect to the labeling of ingredients and substances in alcoholic beverages that pose a public health problem; and

© Clarify and coordinate the responsibilities of each agency with respect to the identification, testing, and recall of adulterated alcoholic beverages.

II. BACKGROUND

A. Pursuant to the Federal Food, Drug and Cosmetic Act of 1938, as amended (FD&C Act), 21 U.S.C. §§ 301, et seq., FDA has authority, inter alia, to take action with respect to adulterated food products, including alcoholic beverages, both domestic and imported. Among other things, a food is adulterated under section 402 of the FD&C Act if it was produced, packed, or held under insanitary conditions; if it contains any poisonous or deleterious substance which may render the food injurious to health; or if it contains an unapproved food additive. FDA has authority to initiate seizure of adulterated foods, including alcoholic beverages, and to seek to enjoin the introduction of such products into interstate commerce. The FD&C Act also authorizes FDA to refuse entry of imported products that appear to be adulterated and misbranded.

B. Pursuant to the Federal Alcohol Administration Act (FAA Act), 27 U.S.C. §§ 201, et seq. and the Internal Revenue Code of 1986 (IRC), Title 26, U.S.C., ATF has authority over distilled spirits, wines, and malt beverage products, both domestic and imported. In particular, section 5 of the FAA Act (27 U.S.C. § 205) vests ATF with the authority to promulgate regulations regarding the labeling and advertising of alcoholic beverages to insure that they provide the consumer with adequate information concerning the identity and quality of such products. Section 5(e) also makes it unlawful to sell or ship or deliver for sale or shipment, or otherwise introduce into interstate or foreign commerce, or to receive therein, or to remove from customs custody for consumption, any distilled spirits, wine, or malt beverages in bottles, unless such products are bottled, packaged, and labeled in conformity with regulations prescribed by the Secretary of the Treasury. ATF is charged with the administration and enforcement of the FAA

Act and does this through, inter alia, the issuance of permits and through procedures that require the prior approval of all labels. In addition, ATF is charged with the administration and enforcement of Chapter 51 of the IRC, relating to Distilled Spirits, Wines and Beer. This chapter in conjunction with the FAA Act establishes a comprehensive system of controls of alcoholic beverages, including on-site inspections and procedures that require the advance approval of statements of process and of formulas showing each ingredient to be used in the product. The IRC also vests authority in ATF to detain any container that will be removed in violation of law (26 U.S.C. § 5311) and vests ATF with seizure and forfeiture authority (26 U.S.C. § 7302).

III. AGREEMENT

It is understood and agreed between the parties, as follows:

(A) ATF will be responsible for the promulgation and enforcement of regulations with respect to the labeling of distilled spirits, wine, and malt beverages pursuant to the FAA Act. When FDA has determined that the presence of an ingredient in food products, including alcoholic beverages, poses a recognized public health problem, and that the ingredient or substance must be identified on a food product label, ATF will initiate rulemaking proceedings to promulgate labeling regulations for alcoholic beverages consistent with ATF's health policy with respect to alcoholic beverages. ATF and FDA will consult on a regular basis concerning the propriety of promulgating regulations concerning the labeling of other ingredients and substances for alcoholic beverages.

( FDA will, upon ATF's request, provide ATF with a health hazard evaluation with respect to any substance found in alcoholic beverages. ATF agrees to provide FDA with any data or analyses it may have with respect to the substance in question.

© ATF will be responsible for testing alcoholic beverages to determine the extent of an adulteration problem. To the extent practicable, FDA will provide laboratory assistance at the request of ATF.

(D) ATF will prepare, in consultation with FDA, comprehensive formal procedures and guidelines for implementing voluntary recalls of adulterated alcoholic beverages. These procedures and guidelines will be developed in light of the FDA procedures and guidelines for such recalls and shall be implemented by ATF after review and comment by FDA.

(E) ATF, as the agency with a system of specific statutory and regulatory controls over alcoholic beverages, will have primary responsibility for issuing recall notices and monitoring voluntary recalls of alcoholic beverages that are adulterated under FDA law or mislabeled under the FAA Act by reason of being adulterated. This agreement does not affect or otherwise attempt to restrict the seizure or other statutory and regulatory authorities of the respective agencies.

(F) When FDA learns or is advised that an alcoholic beverage is or may be adulterated, FDA will contact ATF.

(G) When ATF learns or is advised that an alcoholic beverage is or may be adulterated, ATF will consult with FDA before it takes any action with respect to a notice of recall for the product. FDA, in turn, will expeditiously provide ATF with a written health hazard evaluation of each product involved in a recall situation or potential recall situation. ATF will provide FDA with any data or analyses it may have with respect to the product in question to assist FDA in undertaking a health hazard evaluation. Upon receipt of a FDA health hazard evaluation indicating a definitive hazard, ATF will advise the responsible firm as to an appropriate course of action which might include a voluntary recall.

(H) In situations involving a recall notice of an adulterated alcoholic beverage, ATF will advise FDA of how ATF intends to proceed and will keep FDA apprised of developments with respect to such recall.

(I) In situations involving a recall of an adulterated alcoholic beverage that poses a significant risk to the public health, ATF will consult with FDA before issuing any press release. Press releases will be issued in accordance with established ATF procedures and guidelines.

(J) FDA and ATF laboratories will continue to exchange information concerning methodologies and techniques for testing alcoholic beverages.

(K) FDA and ATF will continue to exchange a wide variety of information, including relevant consumer complaints concerning the adulteration of alcoholic beverages.

IV. PARTIES TO AGREEMENT

The parties to this agreement are:

The Bureau of Alcohol, Tobacco and Firearms
Department of the Treasury
1200 Pennsylvania Avenue, N.W.
Washington, DC 20226

and

The Food and Drug Administration
Department of Health and Human
Services 200 C Street, S.W.
Washington, DC 20204

V. DURATION OF AGREEMENT

This agreement becomes effective upon acceptance by both parties and shall remain in effect indefinitely. This agreement may be modified by mutual consent or terminated by either party upon a thirty (30) day advance written notice to the other.

VI. LIASON OFFICERS

For ATF: Norris L. Alford
Chief, Special Progress Branch
Bureau of Alcohol, Tobacco and Firearms
Washington, DC 20226
Telephone Number: (202) 566-7569

For FDA: Curtis E. Coker, Jr.
Division of Regulatory Guidance
Center for Food Safety and Applied Nutrition Food and
Drug Administration
Washington, DC 20204
Telephone Number: (202) 485-0024

This is a first in 16 years of operations.

As far as we understood, DSP licenses are not regulated by the FDA. Does anyone have any documentation that says one way or the other?

We do have an FDA number, because we bring in yeast for the fermentation of molasses and fruit brandies, but as i mentioned, this is the first time in 16 years that we've been inspected.

Has anyone else been bothered by FDA?