BAD HABITS COMMON GAPS ON THE ROAD TO COMPLIANCE WRITTEN BY DONALD SNYDER
etting the approved Distilled Spirits Plant (DSP) application was the easy part. Keeping ongoing operations compliant with the TTB is the hard part. Somewhere between running the still, reordering raw materials, bottling for orders, providing directions to staff, meeting with distributors, and manning the gift shop, distillers must maintain meticulous records of operations and taxable withdrawals from bond. For many distillers, hastily scratched production notes or a simple excel file may help them fill out the month-end reports, however these notes alone may not be sufficient in the event of an audit. The TTB wants to ensure everyone pays the correct amount of tax and have set up basic ground rules to ensure everyone stays compliant. Here are some common compliance gaps that distillers and owners should look out for... WWW.ART ISANSPIRITMAG.COM
OVERLY COMPLICATED B U T INCOMPLETE PRODUCTION RECORDS
It is common for distillers to have copious notes on their daily mashing and distilling processes. Pages upon pages of notes on the day’s cooking temperatures, enzyme introductions, pH levels, brix measurements, vapor temperatures, spirit “cut” proofs, and other observations are great for ensuring consistent quality and to track issues. However, if a distiller cannot easily and quickly identify how many pounds of fermentables were used and how many proof gallons they made from the run, the notes are no help at the end of the month or during an audit. Compliant gauging records from a distillation run must
also include the supporting calculations to how the proof gallons were gauged such as scale weights, corrected wine gallons or liters, hydrometer readings, temperatures, applicable correction factors, and other notes. Keeping streamlined production gauging records separate from internal operational notes will not only simplify the month-end reporting but make an internal audit much easier.
NO T A N K
Most craft distilleries do not have large, permanent storage tanks. However, even for mobile totes, distillers must keep a tank log of deposits and withdrawals. Source and destination tank identifications should be a part of every record and should create a traceable story of what happened to a batch of distilled spirits along its path to