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  • TTB Requiring a Wall?

    Help,

    We're planning to open as a 2.5 bbl brewery. The TTB has finally gotten back to us after 5 months of waiting only to claim we need to have a 6' wall or 4' wall with locks on the vessels separating our tasting room from the brewing area.

    WTF! First I've heard of this. The strange thing is that there are three brewery's within 50 miles of us that have their brew vessels right next to seating areas. How did they get approved I asked? TTB doesn't know about those.

    I asked the TTB to provide documentation specifying this wall. They said they need to get back to me.

    I'm looking for advise, a citation of federal regs, or counsel.

    Steve

  • #2
    I have no knowledge of that specific requirement, but there are a lot of requirements I do not know. What I do know is the only ppl allowed per the TTB in a brewery are employees, owners, and TTB personnel. There has to be some type of delineation. Also, fighting them will only lead to delays in processing your requests. To be honest it does pass the common sense test, I would not want a drunk customer to have the ability to reach over and open a valve on a tank and have CO2 or beer come shooting out. Finally for every brewery you have seen with tanks next to tables I have seen far more that have walls or windows separating brewing area from customer area, it is a huge safety issue. There are lots of grey areas, it just depends on what kind of day the person reviewing your app is having, as to how they interpret your plan. My best advise is just don't piss them off, they can do far worse than making one or two requests. Trust me!
    Joel Halbleib
    Partner / Zymurgist
    Hive and Barrel Meadery
    6302 Old La Grange Rd
    Crestwood, KY
    www.hiveandbarrel.com

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    • #3
      Interpret

      BrewinLou is right, the person reviewing you application makes a big difference in how much trouble you have with the TTB.

      We had a similar issue with the taproom separation and I indicated on our plan that we would install moveable barriers that would be locked in place during taproom hours. I found some online that were 4' tall and then I was told I had to lock my tanks as well.

      I found locking tri-clamp clamps online and sent the specs on the barriers and clamps to the agent and that satisfied the requirements.

      PM me if you want more information.

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      • #4
        TTB Wall

        Hi,

        Thanks for the info regarding the TTB wall. I'd be really interested to see pics and a link of the material you used to create your barrier. Is there a minimum distance the barrier must be from the vessels? Our manufacturer said they can install hasps on the man ways but what do you do about butterfly valves and such? Do they make locks for valves?

        Comment


        • #5
          HBC2193, you should check out the regulations here: http://bit.ly/22JY0to
          Short answer is: You do not need a wall.
          Slightly longer answer is that you need to educate the TTB on the scope and content of their own rules. I feel like they have gotten kind of lazy over there and are simply insisting on a one-size-fits-all solution rather than allowing creative uses of taproom space. There are endless examples of open plan breweries, including mine.

          If you are waiting on your license to start brewing then I suggest you just get the brewery license, scrap the taproom piece and then once you are approved amend it. That is what we did. I had a rookie officer who insisted on a wall, I yanked the floorplan and submitted one without public spaces, got the license and then we submitted an amendment. three weeks later we had taproom approval. The key is that it didn't slow down the launch.

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          • #6
            Emerson, thanks for the reply. I did research the the regs and we painstakingly planned a layout that creates a showroom brewery facing the tavern area and would be divided by a fabric guard ropes and signage . I tried to debate the wall requirement with our ttb rep but she insisted a 6' wall is required to divide OR a 4' wall with an additional measure of locking my tanks. I requested to be shown where this is mandated in the regs , but she could not produce it. Since then ive not been able to reach our agent or her supervisor. Were at the mercy of the ttb. What choice do i have when facing a federal org and a difference of opinion in the interpretation of federal regs?


            Sent from my iPhone using Tapatalk

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            • #7
              All, this is what the ttb sent me regarding the wall. There were no citations to indicate whos reg this is. "Additional Security Measures for all breweries that have public areas (tasting rooms or taverns/brewpubs)
              They must have adequate separation between the brewing area(s) and the public area(s). This usually consists of walls with a locked door or a fence with a locking gate. The walls/fence should be at least 6 foot high. If this type of security measure is not entirely feasible, they still must have some type of separation that TTB will evaluate on a case-by-case basis and they must store all untaxpaid finished product in a locked area and they must add locks to all tanks containing fermented liquid as an additional measure. The security statement they submit with their application must address the measures they have in place to keep the public from the brewing area(s) in addition to the standard statements about locked doors and possible surveillance cameras."



              Sent from my iPhone using Tapatalk

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              • #8
                that sucks. i agree, what can you do? i pulled the public space from our taproom when i ran into the "6 foot wall" problem with our newbie inspector. so instead of the brewery/public-house license I got the straight brewery license. that way we got our license to start brewing sooner. i then amended the application, and got an inspector who approved our layout. you can see pictures on our instagram and facebook. i can't guarantee that you get a better inspector the second time, but hey double the chances, right?

                as far as that memo, or whatever, from ttb, that seems like training material they are fed, not the actual rule. it is manifestly not the rule because many of the breweries here in oregon have nothing more than a chain or rope. it is either a question of working with your current inspector to bring them around. obviously you can't really win a fight against the government, but you can often luck out and get a good employee who understands the system. all i can say is that a sweet demeanor and persistent calling, especially to the supervisor, will produce more results than any other approach. at the least the supervisor could tell them to let it go this time to keep you from calling back.

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                • #9
                  Hello, we received our approval a couple of weeks ago. At the time we were not planning on serving food. After talking with several local breweries, they had mentioned that they regretted not having food. Originally our brewhouse was a kitchen, so we were thinking of moving the brewhouse into the public area and roping it off when open to the public. At no time while we are open would we be brewing. Our fermentation will be handled in the basement. So at no time will there be any sort of sort or CO2 in the vessels. Just HLT, MT and BK. Would we still need locks and could we get away with something like ropes you see at like a theatre? Also how long does an amendment usually take?

                  Thanks,

                  Kevin
                  Prosper Brewing, LLC
                  Last edited by Charmin1073; 01-26-2018, 10:47 AM.

                  Comment


                  • #10
                    TTB isn’t too concerned with the CO2. Mainly the alcohol and subsequent taxes associated. I would call and email your TTB contact and ask. That being said, we had one amendment to our floor plan and it took maybe a week...


                    Sent from my iPad using Tapatalk
                    Prost!
                    Eric Brandjes
                    Cole Street Brewery
                    Enumclaw, WA

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                    • #11
                      Barrier...

                      Kevin,

                      I think we've all been there. Don't over think it. Just depict a simple line labeled "4' barrier" on your floorplan for the TTB. Don't install a barrier. Simply have a chain with a sign or some stations (like movie theatre) on the side ready to be put of if requested. The TTB is extremely inconsistent with the integration of this barrier being required. They will never come to see you so long as you pay your taxes. If they do, put the chain up as it was ambiguously depicted and approved in the floorplan.

                      Steve

                      Originally posted by Charmin1073 View Post
                      Hello, we received our approval a couple of weeks ago. At the time we were not planning on serving food. After talking with several local breweries, they had mentioned that they regretted not having food. Originally our brewhouse was a kitchen, so we were thinking of moving the brewhouse into the public area and roping it off when open to the public. At no time while we are open would we be brewing. Our fermentation will be handled in the basement. So at no time will there be any sort of sort or CO2 in the vessels. Just HLT, MT and BK. Would we still need locks and could we get away with something like ropes you see at like a theatre? Also how long does an amendment usually take?

                      Thanks,

                      Kevin
                      Prosper Brewing, LLC

                      Comment

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