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Recommendations for Canning lines for canned cocktails?


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  • 2 weeks later...

I have supplied chillers for canning for a couple years.  Usually a small glycol chiller will do the trick to chill product to temp for use on the canning line.

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Piggybacking on Silk Cities post - brewers may be using mobile canning lines, so your local brewer (there is one of every corner, right) might be able to give a lead on who has one. 

Remember that, going by the book, the canning line must be on your bonded premises when you use it to fill containers :-).  Maybe someone should start a business as a DSP that contract cans.    

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Piggy backing on DH Dunbars post

 

and correct me if I'm wrong mr DH Dunbar!

 

You can extend your DSP out to cover your parking lots and loading bays, in case it's easier to set up outside 

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9 minutes ago, SlickFloss said:

You can extend your DSP out to cover your parking lots and loading bays, in case it's easier to set up outside 

I don't known.  I have never done it and I know of no TTB rule that addresses the issue. 

I have received approval for a line around an area with a bottling line that alternates between brewery and DSP premises, but such areas are within a building that is locked when not in use.  To comments like that I must add that past performance is no indicator of future results.  I do not know if TTB would approve the line on the floor again.  They might instead require some minimum barrier, like a portable knee wall.  Lines on the floor seem to trigger a sort of visceral, not acceptable, initial reaction from TTB specialists.  But I speculate.

I have never qualified an outdoor area that was not within a fence.  I qualified one still in a chain link cage, but it was a big still and the chain link went something like 20 feet high on the three sides that were not a wall.  I also qualified one area for barrel storage that had a roof, three sides of "hard" walls, and one side of chain link.

The regulations make no mention of open areas.  They refer, in the same breathe, to rooms within buildings and to outside tanks [see, for example, §19.76(a), which addresses the security of the premises], which could be taken to mean that they exclude any area that is not either within a building or  a tank whose walls, or other "enclosure" (see §19.192(c) below)  provide the security required.  

§19.192  provides the general security requirements.  Here it is in folk text except for the long list of the features approved locks must have:

(a) General. The proprietor of a distilled spirits plant must provide adequate security measures at the plant in order to protect the revenue.

(b) Buildings. The buildings, rooms, and partitions must be constructed of substantial materials. Doors, windows, or any other openings to the building must be secured or fastened during times when distilled spirits plant operations are not being conducted.

(c) Outdoor tanks. Outdoor tanks containing spirits, denatured spirits, or wine must be individually locked or locked within an enclosure when they are not in use.

(d) Indoor tanks. Indoor tanks containing spirits, denatured spirits, or wines, or the rooms or buildings in which such tanks are housed, must be equipped so that they may be secured.

Again, the only provisions are for buildings and outdoor tanks, both of which must be equipped for locking and kept locked with not in use.

Further, the provision that "doors, windows, or any other openings to the building must be secured or fastened when operations are not being conducted" implies a need for a secured barrier around the DSP premises other than outdoor tanks, which must be individually locked or locked within an enclosure when not in use. 

I think the "individually locked or locked within an enclosure when not in use" provides an opening for a variance under §19.27, if one were to state that all spirits, either in bulk or in packages,  would be immediately removed to an inside area of the DSP upon completion of a day's bottling and that in no case would any spirits remain in the outside areas when the bottling line was not being used, or something like that, perhaps more artfully stated.   The goal would be to convince TTB that the outside bottling line is not contrary to law, and that it creates no additional danger to revenue or any  administrative difficulties.  

For those who might cite, as precedent,  a brewery that has outside areas approved as a part of the brewery premises, I point out that the tax does not attach to beer until it is removed for consumption or sale, whereas tax attaches to spirits at the time they come into existence.

So, I wish I could say, with confidence,  that TTB would approve the extension of the bonded DSP premises into an open parking lot, I can't offer any assurance of that.  If someone has experience in which TTB has specifically addressed this issue in writing, maybe they would be able to share what TTB had to say, with the caveat about past experience.  Otherwise, as I said, I'm speculating. 

 

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On 3/4/2021 at 12:34 PM, dhdunbar said:

I don't known.  I have never done it and I know of no TTB rule that addresses the issue. 

I have received approval for a line around an area with a bottling line that alternates between brewery and DSP premises, but such areas are within a building that is locked when not in use.  To comments like that I must add that past performance is no indicator of future results.  I do not know if TTB would approve the line on the floor again.  They might instead require some minimum barrier, like a portable knee wall.  Lines on the floor seem to trigger a sort of visceral, not acceptable, initial reaction from TTB specialists.  But I speculate.

I have never qualified an outdoor area that was not within a fence.  I qualified one still in a chain link cage, but it was a big still and the chain link went something like 20 feet high on the three sides that were not a wall.  I also qualified one area for barrel storage that had a roof, three sides of "hard" walls, and one side of chain link.

That's wild! I've worked on a couple projects of people who wanted to colocate a distillery and brewery and share spaces/critical infrastructure and we had a lot of trouble with it. This way you've mentioned seems a lot more manageable but it wasn't exactly what they were looking to do.

 

As for the area I was referring to which I believe was approved (or they just ran out there) had a stripping column out side in a parking lot and was fenced and secured

 

As always, thanks for the input!

 

Cheers

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11 minutes ago, SlickFloss said:

That's wild! I've worked on a couple projects of people who wanted to colocate a distillery and brewery and share spaces/critical infrastructure and we had a lot of trouble with it. This way you've mentioned seems a lot more manageable but it wasn't exactly what they were looking to do.

 

As for the area I was referring to which I believe was approved (or they just ran out there) had a stripping column out side in a parking lot and was fenced and secured

 

As always, thanks for the input!

 

Cheers

When TTB insists on making "case by case decisions" based on "a number of factors," they create a situation in which there are a lot of balls in the air (multiple factors) at the same time, so when they say yes or no, one is left to guess what factor might be tweeted a bit to get a different outcome. 

For that reasson, I generally advise people to avoid alternation if at all possible.  In the case of a brewery/DSP "collocation," that would mean establishing an area with separate entrances to both from the exterior, and  partition to demarcate the two premises.  TTB has accepted (remember my case by case admonition) chain link fencing and in some cases - I can't keep track - the fence did not reach from floor to ceiling.  Then the brewery can produce the distillers beer and remove it whiteout payment of tax (it is not a transfer in bond because beer is not held in bond, but it is a transfer of the likability for the tax on the beer) to the distillery as distilling material. 

The bottling line is more of a problem.  If the brewery is small and the space allows, they can move the canning line out of the brewery and into the DSP and viz versa.  If it is not portable, then you must alternate the area in which it sits.  Suddenly the balls start flying.

I'm open to discussing any of this, in particular circumstances, as a consultant, keeping in mind the case by case caveat.  But I like to share general info because you guys are the ones who assume the risks.  As a consultant, I'm like the merchant selling supplies to prospectors.  I get mine up front, whether they strike gold or not :-).

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