Hi all,
Below is a summary of the conversation as I've been hearing it from a variety of sources . My goal is to put this logic in front of people who do regulatory work. Anyone care to comment on the logic, pick apart my arguments, or add information?
Thanks!
A few facts:
It's established that we need large volumes of hand sanitizer across the country.
There are upwards of 1800 craft distillers distributed across the country, and even more licensed DSPs (rectifiers, etc.). Every DSP has personnel trained and licensed to work with ethanol products safely and most are situated in populated areas for efficient local distribution.
Craft spirits sales follow discretionary income, which means that the craft industry has an unknown future in an uncertain economy and will likely need help
Conclusions:
The craft industry should be making hand sanitizer to assist medical personnel and their local communities to fight the pandemic
In order to support economic recovery *after* addressing the acute emergency, the craft industry should be able to offset at least the cost of raw materials, if not recover some of the lost sales revenue, by offering hand sanitizer for sale to the public
Challenges:
Hand sanitizer has to be made with 96% +/- 5% ethanol as one of the starting ingredients
Even with a rectification column, neutral spirit is difficult and expensive to produce from fermented substrate at the levels needed by health care providers. At best, production of neutral spirits from fermentable substrates at the craft level is inefficient, at worst, impossible
GNS is usually available from bulk suppliers, but the supply chains are supporting existing accounts and/or large industrial suppliers of hand sanitizer. Bulk suppliers are not responding to small DSPs.
Other ingredients (emollients, isopropanol, essential oils) are also difficult to source right now
There's lack of guidance from regulatory bodies concerning legal formulas, sales and pricing
Questions:
Can formulas be further relaxed to allow other ingredients?
Can transfer in bond rules be relaxed (or applications processed) to allow bulk orders to be split among small producers so that bulk suppliers are incentivized to support an alternate supply chain?
Can regulatory agencies provide clear and cohesive guidance on formulas and pricing?
Are there enough DSPs interested in a cooperative effort that these ideas make sense to pursue? Or is it everyone for themselves?