Guidance on TTB requirements for Security of Bonded Spaces

[SchultzLP]

Our distillery in Virginia is looking to add an offsite location so we can have a tasting room in a part of town with more foot traffic. State laws require that the location counts as a distillery space with the TTB so we can operate it as a bottle shop. 

What we are looking to do is set the location up as spirit storage and have a barrel or two aging in the space. We'd like these barrels to be in a space where the customers can see them, and were looking to put them inside of a cage inside the tasting room that would count as the bonded storage. 

Does anyone have experience doing something similar? Did you get any feedback from the TTB on what their minimum needs are for it to be "secure"? Outside of the very specific guidelines for locks, I can't find anything that gives any sort of guidance on this topic.

We're currently looking at something like in the image below and securing it to the wall from the inside, but we're not sure if that's going to be up to snuff.

[JNorris]

When I do a new permit or amendment for my clients, the application asks if you will have a tasting room or retail area.  If you do then you must have floor to ceiling walls separating the DSP area from the tasting room and/or retail area.

Here is the exact verbiage:

If you charge for samples, parking, or tours then you are prohibited from establishing a tasting room on the premises. The tasting room must be separate from the distillery with floor to ceiling walls and must have its own entrance. It cannot be part of the distilled spirits plant and must be shown on the diagram. Do you understand this requirement?:

 

If you do not plan to charge for samples, parking, or tours then the tasting room can be located on the general premises, but must be separate from the bonded premises with floor to ceiling walls, have its own entrance and be shown on the diagram. Do you understand this requirement?:

 

Will you have a retail store?:

 

If you are only selling merchandise (e.g., shirts, souvenirs) then the retail store can be located on the general premises and should also be shown on the diagram. Do you understand this requirement?:

 

Do you plan to sell any alcohol in the retail store?:

 

If any alcohol is sold in the retail store then you are prohibited from establishing it on the premises. The retail store must be separated from the premises by floor to ceiling wall separation and have its own entrance from the outside. Do you understand this requirement?:

On top of answering these questions, I have also had the specialist reviewing the application specifically ask if the separating walls are floor to ceiling.