Colocating with a Brewery

[jbohlinger]

Hi folks,

If a friendly local brewery in my state offered to sublet some space to my nascent distillery so we can produce, would Sec 19.133 disallow me from producing entirely, or would we just need to create a physical separation of the distillery from the brewery? If it would need to be a physical separation, would a fence suffice?

Thanks!

[Palmetto Coast]

There are many folks that operate in conjunction with breweries. I know the TTB has been cutting down on the "fence-as-separation" issue. I would suspect a wall would be needed, as well as a separate entrance. Don't quote me on that though.

Todd

[Hewnspirits]

Hey JB

I'm in the final stages of permitting my DSP in a shared building with a brewery that's separated by a 9' tall conventionally framed wall and chain link fence above to the ceiling so I'll keep you posted on any feedback from the TTB. My interpretation...as if that counts for anything...is that it's all about protecting the bonded area.

[bluestar]

Yup, typically they are requiring a barrier that won't allow passing in-bond bottles. They do seem to be looking for the "to the ceiling" thing lately, where as in the past, 12' might have been enough ;-)

[mattabv]

did you think of protecting your facility from accidents on their side affecting or consuming yours?

[Charles@AEppelTreow]

The talk of walls and fences makes me smile at the simple painted floor zones that we have. But I suppose that our adjacent BW and DSP are all under the same ownership and I think under 1 bond, as of the last revision.

[mattabv]

Charles, if you were not under one bond what do you think the issues would be?

Matt

[Two Bit]

Make sure you check your state regs. Ours is very strict regarding the separation between a brewery and distillery. Feds don't really care as long as everything is marked and legit in their very black and white, laid out in Part 19 ways. The state is who you need to worry about. And possibly your municipal code. The littler the government, the stricter - and fuzzier - the rules.

[jbohlinger]

Thanks everyone for the responses. I hadn't even thought about state regs yet - definitely next stop on my list though. I had been hoping that fencing would be all that's required.

The question of protecting facilities is an interesting one. For instance if we ended up needing to put up walls, would they need to be fire rated or would simple drywall suffice? I think this may be a municipality question as well.

Hooray.

[Charles@AEppelTreow]

Matt, we didn't start under 1 bond - and to be honest, I can't recall if we still have spearate wine and spirit bonds. My last update was a couple of years ago. It was an option, but I don't remember if I took it.

With separate wine and spirit bonds, both bonds had TTB specified supplementary langauge to allow transport of one type over the bonded area of the other. Not storage in - just transport over. The storage stection of the DSP is non-continuous with the production area. We have to take spirits over BW to put them in storage. The storage area is a locked room - but it too is divided into a DSP portion and a BW portion.

I don't even try to guess why some people get held to much tighter requirements. I'm just glad to make cider, pommeau and some apple brandy.