Checking Fill Level (27 CFR 19.356)

[indyspirits]

19.356 states:

Quote

 In no case will the quantity contained in a bottle vary from the quantity stated on the label or bottle by more than plus or minus:

(1) 1.5 percent for bottles 1.0 liter and above;

(2) 2.0 percent for bottles 999 mL through 376 mL;

(3) 3.0 percent for bottles 375 mL through 101 mL; or

(4) 4.5 percent for bottles 100 mL and below.

 

 

Our current internal SOP specifies to use mass thus our 45% ABV product's net weight must be between 692 grams and 720 grams (actually a bit tighter than +/- 2%).  What I can't wrap my head around is if this is OK.  The thought of making volume temp corrections and testing that way fills me with FUD.  Are we in compliance using mass?

 

[Silk City Distillers]

Working at 60f, 750ml with 2% variance by volume would be 735 to 765ml, which corresponds exactly to your 692-720g.

Keep in mind though, the regulation immediately preceding this one says you need to have the same number of over fills as under fills, so you likely aren't consistently filling at the upper or lower limit of your SOP range, but somewhere more tightly clustered around 706g.

Variance of a bottle filled with 706g (750ml of 90pf at 60f) based on temp would be 741ml at 30f and 760ml at 90f.

If you wanted to stay within 2% tolerance across the entire 30-90f temperature range by both volume and mass, you'd probably go a little bit tighter, 698-716g.

Or, keep exactly what you are doing and tell the TTB they shouldn't be testing your volumetric fill at 30f or 90f, because that's absurd and unrealistic.

 

[Silk City Distillers]

Besides, it's significantly more accurate to check your fill by mass.

A 1000ml graduated cylinder is something like +- 10ml accuracy, and the tiny graduations are 5ml, so adding the potential to misread by 1 graduation puts you around +- 15ml, which means your 750ml could ready anywhere from 735ml to 765ml, exactly where we started!

[captnKB]

Ill second @Silk City Distillers Mass is the way to go on volume fill test. It is definitive and accurate.

With a good volumetric bottle filler like a Mori filler it is easier to be within 1% at all times as long as your glass is consistent and the filler is calibrated to the temp of your spirits.

[indyspirits]

10 hours ago, Silk City Distillers said:

tolerance across the entire 30-90f temperature range 

Where are you getting the 30 to 90 range?

 

 

 

[Silk City Distillers]

Made it up, seemed like a pretty plausible range for bottle temperatures around the US, coldest or warmest.  Plus Minus 50% of the typical 60f calibration point, so +-30f around 60f.

I don't think the CFR makes any statement regarding the specific temperature that fill level should be measured at.

[indyspirits]

2 hours ago, Silk City Distillers said:

Made it up

Whew! That's what I thought. I was looking at the temp range in Table 7 and thought, "No way in hell I'm doing that".   Riddle me this batman... if a consumer buys a bottle of 45% ABV that was bottled at 100F and then takes it skiing (ignore the impracticalities of the premise) where it's 10F will the fill be out of spec? More rhetorical than anything. Bottom line is that we may tighten our internal range-of-acceptability but will continue to audit by mass

 

 

[meerkat]

In the TTB document SSD:TM:516 they give an example of correcting fill levels for temperature, but don't seems to state the target temperature!  Or maybe I just read it too quickly.  But they use Table 7 to get the temperature correction factor so I guess the standard fill temperature must be 60°F.  https://www.ttb.gov/ssd/pdf/tm516.pdf

 

[Silk City Distillers]

There are lots of references to 60F in the CFR, but mostly around calibration of hydrometers or for table calibrations, not bottle fill.

 

[indyspirits]

1 hour ago, meerkat said:

In the TTB document SSD:TM:516 they give an example of correcting fill levels for temperature

Meerkat... 

Is there a way in AlcoDens to enter a volume/temp and then amend the temp to see how that affects the volume? I played aroudn a bit this morning and it wasn't intuitive to this casual (and a bit lazy) user.

 

 

[meerkat]

@indyspirits, Yes there is.  The icon with the ruler next to the beaker calls up the Volume Correction Calculator (which also converts between mass and volume).  The calculation below shows that 750 ml at 60°F becomes 756.4 ml at 80°F.  Note that the mass remains 706.1 grams and this is why almost everyone prefers to bottle by mass.

[indyspirits]

53 minutes ago, meerkat said:

this is why almost everyone prefers to bottle by mass.

That and preserving ones own sanity. Thanks for the primer!

 

 

[JailBreak]

On 7/31/2018 at 8:48 AM, indyspirits said:

 Riddle me this batman... if a consumer buys a bottle of 45% ABV that was bottled at 100F and then takes it skiing (ignore the impracticalities of the premise) where it's 10F will the fill be out of spec? More rhetorical than anything. 

 

 

If you bottle by mass then you would still be in spec. In the TTB document SSD:TM:516 @meerkat posted the example just measures volume and applies a correction factor based on proof and temperature of the sample. Whether the sample is at 100F or 10F, the correction factor should change observed volume into a standard volume close to 750 hopefully.

[TACD]

Hi, this question is related to this topic so thought I would ask it here. if it doesnt belong I am happy to start a new topic. I know we have to keep records for these tests (27 CFR § 19.600) but does anyone have a standard for how many bottles you have to test? Correct me if I am wrong but I don't think TTB specifies how many we need to do. Just checking if this is something that is standard for people or is up to each distillery? Curious what everyone's experience is.

 

§ 19.600 Alcohol content and fill test record.

A proprietor must maintain a record of the results of all tests of alcohol content and quantity (fill) conducted. The record must include information that will enable TTB officers to determine whether the proprietor is complying with the requirements of § 19.356. The record of alcohol content and fill tests must contain, at a minimum, the following information:

(a) Date and time of the test;

(b) Bottling tank number;

(c) Serial number of the bottling record;

(d) Bottling line designation;

(e) Size of bottles filled;

(f) Number of bottles tested;

(g) Labeled alcohol content;

(h) Alcohol content found by the test;

(i) Percentage of variation from 100 percent fill; and

(j) Corrective action taken, if any.

[Tom Lenerz]

When we do a single barrel bottling I test a bottle at the beginning and then at the end again. For our larger batches I test a bottle about once per hour, which is usually just one 2 or 3 total off the automated line. 

[ODW]

We end up testing around 5 bottles and we dont do it that much differently from what Tom suggested. Never had any issues because we check if our equipment is dialed in correctly frequently. Just curious of there was a standard for sampling that the TTB expects.

[JNorris]

The regs state that they must be tested "at representative intervals." What does an interval mean to your business?

I tested at the beginning, middle and end (although we only bottled less than 40 cases every time). The beginning to make sure all the fillers and the proof are within tolerance. In the middle so that you can make any necessary adjustments if needed. And at the end so that you can confirm that you have been within tolerance during the duration of your bottling.  I would suggest doing more testing in the middle of you are doing larger bottlings.

Really, write up a bottling fill and proof check SOP and stick to it.