How did government work change during your tenure?
If you could do it again, what would you do differently?
When I started in government, we did a lot of what today is very low priority work. I learned a lot back then because every day I had the chance to work on something different. As an inspector, I had the chance to work at vinegar plants, industrial DSPs, flavor manufacturers, hospitals and universities that held ATF permits, gun dealers, explosives users, tobacco export warehouses, cigar manufacturers, wineries, breweries, the list goes on. Today, the variety of work is much less. Consequently, the new people will never learn as much about the rules and the many intricacies of the regulations associated with such a wide variety of businesses. Also, managers today have a tougher job in government because of the lack of resources. When I started, ATF had more than 2,000 government officers devoted to regulatory work. Today, TTB has less than 400 officers, with the same rules, laws and regulations to enforce. Plus, they have to collect more taxes than ever before from so many more companies that hold permits to operate. This is an incredible challenge.
Some of the best people you had the honor to work with? The first person who comes to mind is Bill Drake, former Associate Director for Compliance operations, who retired in 1989. Heâ€™s passed now but he was a real leader and innovator who took risks when they were needed and always did the right thing. He was the hardest worker I ever met, putting in more hours than most CEOs. He always had the time to mentor people at all levels. Without the details, he was instrumental in ATF surviving its planned demise in 1981. Beyond Bill, just about every person I met at ATF left me with some positive impression. Integrity, hard work, and desire to serve were expected qualities of all ATF/TTB staff and I had the pleasure to see that displayed daily by just about every person for my whole career. Most people cannot say that and for that I feel incredibly privileged.
Any advice for lawyers who deal with TTB often? Yes, I do. The majority of people at TTB may not have a law degree, although many do, but they probably know more about alcohol law and policies than anyone can get from reading the law or from law school. My recommendation is to learn from them all that one can.
Any examples of really good lawyering, from the Bureau or the private side? The best alcohol and tax lawyer I ever met is John Manfreda, current TTB Administrator. John wrote and was a big part of implementing the all-in-bond regulations back in 1979-1980. John had a part in just about every regulation and law promulgated since he started with ATF in the 1970s. On the private side, Abe Buchman was so effective at helping his clients in some pretty sticky situations. He was a terrific communicator, was disarming in some pretty stressful situations and always had respect (which he earned) from ATF regulators.
Robert C. Lehrman is a lawyer at Lehrman Beverage Law, PLLC in metro Washington, D.C. Since 1988 he has specialized in the federal law surrounding beer, wine and spirits, such as TTB permits, labels, trademarks and formulas. The firm has seven beverage lawyers, over 50 years of combined experience, and publishes a blog on beer, wine and spirits trends at www.bevlaw.com/bevlog.
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