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fotoski

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fotoski last won the day on December 6 2018

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    Photography, Chess, Brandy and Bourbon.

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  1. It certainly seems as if TTB is trying to codify an assumption that they have held for decades. In this case, I think they should drop the assumption rather than codify it. Exploration of different types of barrels is one of the exciting changes that is occurring in the craft spirits movement. If the distillers who collectively have millions of dollars in inventory in smaller barrels can no longer label their bourbon as bourbon or rye whiskey as rye whiskey, then small distillers all over the nation will have a huge problem. Who would benefit from this change in the regs? People who have all their spirits laid down in standard barrels.
  2. This seems to be the issue a lot of people are focusing on this week: The 50-gallon requirement would not only stifle a lot of people who have had a lot of whiskey in other size and shape barrels for years, it also stifles creativity. Instead of narrowing the definition of barrel, TTB should be opening up the definition to include more types of barrels -- toasted instead of charred, oak from other continents, larger and smaller sizes. Barrels are a way that distillers define flavor and the more the definition of an oak barrel is restricted, the less creativity we will see in this highly inventive aspect of flavor creation.
  3. The TTB is accepting public comments regarding changing the CFRs until March 26, 2019. The proposal is incredibly lengthy: https://www.gpo.gov/fdsys/pkg/FR-2018-11-26/pdf/2018-24446.pdf Here is the TTBs summary, with links: NEW RULEMAKING IS THE NEXT STEP IN OUR LABELING PROGRAM MODERNIZATION We are pleased to announce the publication of a rulemaking document (Notice No. 176) in the Federal Register of Monday, November 26, 2018, in which we propose to update, simplify, and clarify the labeling and advertising regulations for wine, distilled spirits, and malt beverages. This rulemaking is the latest phase of our multi-year effort to Facilitate Commerce through a Modern Labeling Program Focused on Service and Market Compliance, one of the five strategic goals outlined in our current Strategic Plan. In recent years, we have made significant improvements to modernize our labeling program and reduce approval times for labels and formulas by employing a range of strategies, including: Eliminating the need to obtain formula approval in certain instances; Expanding the list of changes that can be made to approved labels without getting a new Certificate of Label Approval (COLA); Updating COLAs Online and Formulas Online to better meet user needs and expectations; Increasing guidance about label and formula requirements by improving content on TTB.gov and offering webinars; and Adding staff to improve overall service levels. When finalized, the updated labeling and advertising regulations will facilitate industry compliance by simplifying and clarifying regulatory standards, incorporating guidance documents and other current policies into the regulations, and reducing regulatory burden on industry members where possible. We encourage public comments on the regulatory amendments proposed in the rulemaking document (Notice No. 176), particularly from affected industry members. In addition, we welcome suggestions for other changes to these regulations not specifically proposed in the rulemaking. We are accepting comments through March 26, 2019. Please see the notice for instructions on how to submit a comment.
  4. I saw an item in today's ADI e-news that could have an impact on every liquor bottle sold in California: New Prop 65 Labelling Requirements Take Effect August 30 This could be huge as many beverage alcohol components, including ethanol itself, fall under the new regulation: Acetaldehyde, Methanol, Furfural alcohol,... etc. For the complete list of Prop 65 ingredients, please see: https://oehha.ca.gov/proposition-65/chemicals Liquor bottles appear to fall under the regulation, so booze sold in California may have to wear a warning label as of August 30... unless, of course, this contradicts the TTBs regulation against having any health claims on liquor labels. WARNING: This product can expose you to chemicals including [name of one or more chemicals], which is [are] known to the State of California to cause cancer [and] [or] [birth defects or other reproductive harm]. For more information, visit www.P65Warnings.ca.gov
  5. This reinforces the need for pressure relief valves. If you are operating a still and there is not a proper PRV, install one.
  6. Yes, this is the approach and there are many more avenues to explore. It also involves distilling the spirit differently if you intend to harvest the barrel in two years rather than ten. There are many other barrel management techniques -- such as transferring to neutral barrels, slow reduction to bottling proof, marrying blends for six months in cask -- that preserve flavor congeners in the spirit while providing a smoother, subtler final product.
  7. Yes, it is a slow learning curve and there are many mistakes out there to make. If distillers can share knowledge about what happens when you run your still slower, and to explore the subtleties that happen with proper barrel management over time, more of those long awaited experiments will turn out well. The rules would not pertain so much to production as they would to labeling, so that it may be determined what production techniques were used. This is more concerned with truth in labeling, so that a consumer can pick up a bottle and decipher how the spirit was made; where it was distilled, from what ingredients, what size barrel, how much time, presence of any additives... etc. It would be a voluntary system for those who would like to have a recognized standard of quality on their label.
  8. The Slow Distillation Movement Hubert Germain-Robin Being an aficionado of the Slow Food Movement since the beginning, I would like to add another antidote to the tyranny of the fast food industry and the frenzied pace of modern culture. Slow Distillation By using ancestral methods of distillation, when time was not such a pressing issue, one would conduct the distillation at a slow pace to be able to separate with precision the different components, to make clean cuts and to respect the temperature during the gathering of the distillates. With today’s hurried approach, many of these parameters are undervalued or even ignored by craft distillers. For centuries, distillers passed down to successive generations the nuances of creating flavors from the materials available. These artisans created good spirits before thermometers were invented, not understanding the molecular difference between methanol and ethanol or even knowing the names and vapor temperatures of any of the compounds they were separating. Distillers must listen to a spirit coming off the still in order to understand how much time in the barrel it will take for flavors to blossom and come to full beauty. Little thought or teaching is currently given to the understanding of how to ferment and distill a spirit when one intends to age it for 4, 12, or even 20 years. The rapidly made products often seen today have a limited appeal to consumers who pay attention to what they are drinking. This commodity approach to spirits production may produce a few small fortunes, but will no doubt produce many more inferior products that will need the presence of a bartender to bring to full flavor. Slow Maturation: By learning from the experience of generations of cellar masters, one realizes that time and patience are factors you cannot fully control, except by having proper levels of humidity and temperature in your cellar. Forcing the aging process by raising temperatures and using smaller barrels (which are usually made of wood of lesser quality) to obtain faster extraction often results in harsh and excessive tannins, which will take many years for the spirit to digest. Balance and harmony are reached by knowing the pace of transformations occurring in the barrels through the periods of oxidation and of rest. This is necessary and elementary to have a quality product. In the modern distillery age, the distiller is more likely to be flooded with information about saturating their spirit quickly with wood extract to make it marketable than they are presented with information about how to slowly nurture barrels into producing a supple, round, full flavor from the depth of years. Consequently, today’s distiller is more likely to toss their precious water of life into barrels and forget about it for two years, or for six years, and with little regard to maintaining proper maturation conditions, whatever the recipe, like a cake baking in the oven for whatever amount of time. By making abstraction of, or simply ignoring, either slow distillation or slow maturation, these craftsmen limit themselves in creating true artisan products. The consequences are not always obvious in the short term but appear later, resulting in regrets and disappointments. Remember: In this long journey, you cannot go back in time; you have to live with your decisions—good or bad. Can a rum or whiskey, after being stored in a barrel for only a year, truly be called mature or aged when, at the same time, a brandy, Cognac, Calvados or Scotch (and many other spirits) have to rest at least 2.5 years in oak (which is still quite young) to get the due appellation? I urge the distiller to slow down, take a mindful approach and join in the sharing of small details that, when combined together, have the effect of creating a spirit that can be savored. At the beginning of this revolution—which will go on for years, decades and centuries—the foundation can be laid so that craft will become the designation of quality. Rules should be put in place—by the craft distilling industry itself—to establish control over the declaration and on the labels for the consumer’s good. The Europeans have put a strict system in place that could be used as an example to make designations fair for everyone. Such a system will also serve to elevate quality, and reinforce appellations and sub-appellations, that will be created in the near future. For more information, email: Hubert Germain-Robin hubertgermainrobin@gmail.com Nancy Fraley nancylfraley@yahoo.com Andrew Faulkner drew@distilling.com
  9. Hi Andrew, are you in New Orleans yet?

    I am at the Monteleone, my cell 4043452215 if you want to catch up for a drink or chat.

    Peter Bignell

  10. The TTB is proposing several changes to the regulations. The goals seem to be simplifying paperwork, reducing mostly reporting, streamlining the COLA process and many other things. There will now be a period of public comment regarding many of these changes. The link leads to an article in the National Law Review that summarizes TTBs proposals: http://www.natlawreview.com/article/alcohol-and-tobacco-tax-and-trade-bureau-ttb-publishes-projected-regulatory-agenda
  11. Good Luck! Let us know if you need anything. Cheers, Drew
  12. The hourly schedule for the ADI Conference and Vendor Expo, March 30 -- April 2, 2015, has just been released. You can find it on the ADI site: http://distilling.com/wp-content/themes/TFA-ADI/images/uploads/2015/01/ADI-2015Schedule.pdf
  13. The complete schedule was just posted online: http://distilling.com/wp-content/themes/TFA-ADI/images/uploads/2015/01/ADI-2015Schedule.pdf
  14. Craft Certification Update A call for greater truth in labeling As of press time, the Certified Craft Spirits™ database has swelled to 874 brands by hundreds of distilleries in 44 states and Canada. The list of American craft spirits has now reached critical mass and can be taken to the next level in building a bring from the producer to the consumer. On Monday March 31, ADI staff met with an advisory board of distillers to discuss possible changes to the ADI definitions of Certified Craft Spirits™ and how to handle certain products that may fit within the spirit but not the letter of the rules, and to consider possible changes to the craft certification program. Present were ADI staff members Andrew Faulkner, Nancy Fraley, Eric Zandona and Matt Jelen, and distillers Darek Bell of Corsair Distillery, Ryan Hembree of Skip Rock Distillers and President of the Washington Distillers Guild Steven Stone of Sound Spirits. This was followed Tuesday April 2 by a panel discussion featuring Bell, Hembree, Stone, Faulkner and Jim Blansit, of Copper Run Distillery. Primary topics of discussion at the meeting were the definitions of Certified Craft Distilled Spirits™ and Certified Craft Blended Spirits™, and if the craft-blended designation was necessary or denigrating to the program. Also discussed were more than 70 spirits that had applied for craft certification but had not been approved because of minor variations from the rules. The vast majority of these were spirits that stated “produced by” instead of “distilled by” on the labels. The panelists weighed in on the distilleries and spirits using their personal experience and knowledge to determine if they fit the definition of craft. Most were approved conditionally, which is to say they are placed on the database but denoting that their was an variation from the rules that had been discussed by the advisory board. Many distillers have a large stock of printed labels that may say “produced by” or “handcrafted by” and it would be costly to reprint these. Good news coming from TTB is that distillers need not re-apply for a COLA to change these words to “distilled by”, if indeed they do distill what is in the bottle. Methods to handle such variances in the future were discussed and solutions include changing label wording, inspection of the distillery by ADI personnel, or review of the TTB-approved formula. The most interesting proposition put forth both at the meeting and at the panel discussion, and one that would further promote truth in labeling, is for producers to print the DSP number of the distiller(s) on the bottle, similar to the NOM that Tequila producers must print on their labels. This would clear up any confusion on where a spirit had been distilled. ADI advocates that moving forward, craft producers should all put the DSP numbers of all distilleries that had a hand in producing the spirit in the bottle. This push to further extend “Truth in Labeling” could clear up confusion regarding the pedigree of a spirit. Another issue of contention is the Certified Craft Blended Spirit™. The distillers on the panel moved for the elimination of this designation saying that it muddied the water. At issue is how to exclude producers who simply watering back neutral spirits to produce vodka or release Kentuckiana whiskeys under a label implying they were created in-house. Germain to the idea is whether the flavor of the spirit is significantly altered by the artisan. The vast numbers of gins start with a purchased spirit that is then macerated and redistilled by the producer. There is no doubt that the flavor profile of the spirit is produced by the hand of an artisan, but many of the distillers feel the crucial step in determining what is craft is that of transforming a fermented product into a distilled product. Many fantastic liqueurs with the aesthetic imprint of the hand of a creator begin with bulk spirits produced on the open market. Most DSPs think the definition of craft should describe exactly what they do. Farm distillers are entitled to feel that they have a greater degree of craft because they grow the raw ingredients they ferment and then distill. Those that ferment have a hands-on contact with the process to a greater degree than those that purchase wine or wash for distillation. Those that distill from scratch can feel a greater sense of involvement than the creator of a redistilled spirit from NGS (as is the case with most gins and liqueurs). All these steps connote a greater or lesser degree of involvement in the process of creating spirits. Some distillers who have built their own stills have expressed the opinion that those distilling on purchased equipment show a lesser degree of craft. At the panel discussion, the conversation was passionate and diverse with most of the sentiment echoing that a spirit is created in the act of distillation. Toward the end, John Wilcox of Rogue Spirits took the microphone for a thought provoking opinion that created laughter and applause. “I want to make sure we don’t forget that we are all artisans,” said Wilcox. “We are all tied to a very lengthy history of art. And when we think about art, we have to think about all the artists that have come before us, outside of distilling, in all the various different trades they were part of. Once upon a time, artists used to make their own tools. They used to grind beetles to make cadmium. They made their own brushes out of whatever, … Picasso is very well known in the art world for making wash, but he also used found and common objects for his collages. And of course all artists decry the presence of Duchamp and his very-famous Readymades, which are still elevated to fine art to this day. Art is not dead, mind you. It is still alive.” “What we have to focus on is that we are artisans and the big people are not, … ‘cause they’re using weird science, and computers and, … God is dead,” with laughter from the crowd and the speaker. “The question should never be who is more craft than the others. There is an element of craft distilled, but I think we should be focusing more on artisinally-produced or artisinally-whatever because there are amaros being made with NGS; there are gins being made with NGS but they are being transformed. We don’t have to crush our own beetles to make cadmium anymore. We don’t have to do that. We can buy that at the store, and you can still make amazing paintings, but does that make that painting less valuable because you used store-bought cadmium with artificial color in it? Just a thought.” “Let’s all celebrate the art of what we are doing and not celebrate the division and the elitism that we are dealing with here. Let’s all bind together and take out the people who have killed god,” followed by rousing applause.
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