Storage Account

[Still_Holler]

I am doing monthly TTB reporting.  In December I distilled some whiskey and put it in a stainless tank and recorded the proof gallons on the December Production report as going into a tank.

In January I transferred the product from the tank to several barrels.  I see no where on the Storage form to show if the whiskey is in a tank or barrel.  Do I just keep internal documentation of the transfer to the barrels in case of an audit? Or am I missing something on the monthly storage reporting  as to where the spirits are being stored?  

Thanks, Athey

 

[dhdunbar]

When you made your production gauge, you should have reported that you made whiskey,  which you designate as "whiskey designate" (see 19.305  Identification of spirits. "Upon completion of the production gauge, the proprietor must identify containers of spirits as provided in subpart S of this part. When the proprietor intends to enter spirits into bonded storage for later packaging in wooden packages, the proprietor may identify the spirits with the designation to which they would be entitled if drawn into wooden packages, followed by the word ``Designate,'' for example, ``Bourbon Whisky Designate.''  You report it as whiskey (over 160 or 160 and under, depending on the proof of distillation" in part 1.  You report it as whiskey entered into tanks in part III of the form.  You apparently reported it correctly on your production report.  

There is no entry on the storage account where you show the type of storage.  You are correct about that.  You are also correct that it is information found in the distillery records.

Your records must establish that the product is eligible for the designation stated on the label. 

When the spirits are in tanks, you must keep the tank record required by 19.592.  When you transfer them to oak, you must keep the record required by 19.590(b)(5) and create the package record required by 19.591. The transfer is also recorded on the gauge record (19.618), which you must prepare when you package spirits from a tank in the storage account.   The gauge record must include  "Cooperage identification (``C'' for charred, ``REC'' for recharred, ``P'' for plain, ``PAR'' for paraffined, ``G'' for glued, or ``R'' for reused, and ``PS'' if a barrel has been steamed or water soaked before filling).  That requirement is buried pretty deeply in the regulations, but it is essential if you want to be able to prove your bourbon, rye, wheat or malt whiskey was aged in new charred oak, or that your whiskey distilled from malt mash was aged, Scotch style, in used oak, etc.  It is also what justifies age claims.  

Hope this helps.   

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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[Still_Holler]

12 hours ago, dhdunbar said:

When the spirits are in tanks, you must keep the tank record required by 19.592.  When you transfer them to oak, you must keep the record required by 19.590(b)(5) and create the package record required by 19.591. The transfer is also recorded on the gauge record (19.618), which you must prepare when you package spirits from a tank in the storage account.   The gauge record must include  "Cooperage identification (``C'' for charred, ``REC'' for recharred, ``P'' for plain, ``PAR'' for paraffined, ``G'' for glued, or ``R'' for reused, and ``PS'' if a barrel has been steamed or water soaked before filling).  That requirement is buried pretty deeply in the regulations, but it is essential if you want to be able to prove your bourbon, rye, wheat or malt whiskey was aged in new charred oak, or that your whiskey distilled from malt mash was aged, Scotch style, in used oak, etc.  It is also what justifies age claims.  

Thanks you for the reply, that does help.  I am now curious about the PS barrel designation for steamed or water filled barrels.  Would that affect its designation as a new barrel for making bourbon?  I recently purchased a couple new barrels and the cooper told me to fill them water for two days prior to filling with spirits to let the wood swell.

[dhdunbar]

I have never thought about that.  I don't know why they put the PS identifier into the mix.  I can't see that it is going to affect class and type. 

First, part 5 does not contain the word "steamed" nor "soaked."  It makes no exception of the sort, "which has been stored in new charred oak that was not steamed or water soaked prior to use."  You can't bury such an important requirement in an obscure section addressing cooperage identification, and that is the only place the issue appears in either part 5 or part 19.  

Second,  the "PS" designation is stated in addition to one of the other required identifiers, not in lieu of, so the record would still show the CH or R  designations necessary to establish, for example, whether a whiskey otherwise made in accordance with the standards of bourbon, 51% or more corn, etc, should be designated, based on the type of cooperate in which it was stored, as  "bourbon" or  as "whiskey distilled from bourbon mash."  The container does not lose its CH designation because it was soaked.  Therefore, I've got to believe it would be new charred for purposes of part 5 standards of identity and aging requirements.

While TTB, or some predecessor agency, must have had some reason for requiring the PS designation,  figuring that out would be a research project for which I do not have the time.  Since it would require a research project, I conclude it is not something that has ever been an issue.  Since it has never been an issue, I think it comes under things listed beneath the heading,  don't kick a sleeping dog.