Tasting room / retail separation from DSP

[Joshnamu]

Hello everyone! My partner and I are starting a new distillery in the Boston area which we're very excited about. We have a prospective location picked out and are in negotiation for a long-term lease, but we're not sure the layout of the facility is appropriate. The facility is one large warehouse-like building with high ceilings, so we already know we will have to construct a floor to ceiling wall to split the warehouse into the DSP and retail / tasting areas, each with their own separate egresses to the outside. However, the building only has one bathroom which is currently located in the planned area for the DSP.

Would it be possible to designate the bathroom as "general premises" in the DSP and have customers walk through the general premises of the DSP in order to access the bathroom? The TTB call center suggested we would need to build a permanent 4ft. physical wall / barrier to separate the bonded premises from the general premises in the DSP to comply with security requirements, but are there additional requirements regarding unsupervised access to the general premises portion of the DSP?

[Pofarmer]

I see no one has replied, so I'll just say what I've seen done in small distilleries. You don't say how big this is. I have seen several where the bathroom is in the tasting or customer area, and that serves the workers also. I've seen at least one, where the restroom is in the production area, and guests can use the restroom while on a "tour". In the end, it's going to depend on what your local inspectors will allow. I'd call your local health department and ask them. In the end TTB is worried about revenue. The local health department is going to worry about most everything else, and state inspectors are the ones looking at DSP facilities unless there's a tax issue.

[captnKB]

Id agree with @Pofarmer your local authority is going to determine if the single bathroom is allowable based on occupancy of the space. TTBs concern is protecting the revenue aka you paying your excise taxes.

Cheers, -KB

[antoRCB]

 

Hey there! Congrats on starting your distillery, that’s exciting! 🎉

From what I've seen in similar setups, the bathroom situation can vary depending on the local authorities. Like @Pofarmer mentioned, I’ve been to distilleries where the restroom is in the tasting area and it serves both workers and guests. Sometimes they’ll even let customers use the bathroom in the production area if they're on a tour, but that's pretty situational.

As for the TTB, yeah, they’re mostly focused on tax and revenue stuff. They’ll want that clear separation between the bonded premises and general premises, so if they told you to build a 4ft barrier, that’s probably non-negotiable. But your local health department and building inspectors will have the final say on whether the bathroom location works based on building codes and occupancy. I’d definitely give them a call to see what they’ll allow.

Good luck with the project!