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Application submission/approval play-by-play

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  • Application submission/approval play-by-play

    I probably wasted at least a week worrying about whether I should submit my TTB app because I wasn't 100% finished with it or wasn't sure how accurate the information I was providing needed to be. Since time is money, I wanted to provide a glimpse into the future for anyone in my position or a step behind me.

    Once you click the final submit button you're taken to a Record Submittal page where you'll see your new tracking number. One piece of helpful info listed here is that "TTB will consider your application abandoned after 15 business days if all required supporting documents are not received." There's a button on that page that I guess you have to click that just reads "copy record". No mention as far as I can tell about why you need to copy a record but once I did that, I got to the next page.

    Next you're magically whisked away to a page asking you to allow pop ups. This seems to be a required thing to accept.

    The next page is an error page, in case you forgot you're on a government website. It does give you a 'here' to click to "continue exploring the system". By that they mean you'll go back to the Permits Online homepage where you can get into your application record and review/edit contact info and add but not delete attachments. If anyone knows how to delete an attachment, I'd love to know how.

    So if you're mostly done with your TTB application and antsy to get it submitted, it appears safe to submit, keeping in mind that you have 15 days from the date you do submit before you need to have all your attachments in. I'll add updates here about all of my future correspondence, steps, mistakes, and anything I come across that helps or hurts my application processing time. If you have any advice, I'd love to hear it.

  • #2
    Originally posted by seekingalpha View Post

    So if you're mostly done with your TTB application and antsy to get it submitted, it appears safe to submit, keeping in mind that you have 15 days from the date you do submit before you need to have all your attachments in. I'll add updates here about all of my future correspondence, steps, mistakes, and anything I come across that helps or hurts my application processing time. If you have any advice, I'd love to hear it.
    Actually you have 15 days from the date they contact you letting you know of the missing information. This usually happens on day 45. Good luck. The only ones telling you this is too hard are ones that have not done it or they want to do it for you! The TTB is surprisingly helpful.

    2. On application for Taxpaid Wine Storage - must have the statement "Taxpaid product will be kept segregated from product in bond and clearly marked." This can be added to the application with your permission since once submitted online you cannot add or make changes.

    This information may be emailed or faxed to --------

    If the above information is not received within 15 days from the date of this email, your application will be considered abandoned. This would require you to resubmit the application. The abandonment would have no bearing on future submissions.

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    • #3
      AmbrosiaOrchard, interesting, so you're saying they have 45 days to review the submitted app and if they find anything missing I have 15 days from then to get it in, or in the case of your example OK'd to add?

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      • #4
        Originally posted by seekingalpha View Post
        AmbrosiaOrchard, interesting, so you're saying they have 45 days to review the submitted app and if they find anything missing I have 15 days from then to get it in, or in the case of your example OK'd to add?
        Right, so now it is 74 days average wait time, you probably have 60 days before they review your application.

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        • #5
          Just got off the phone with a TTB customer service person. Apparently "these days" they are requiring at least either a 4' or 6' tall wall separating the brewhouse from where customers will be. I asked if there is a secret website that lists rules such as this and she didn't know but is sending a message to my application reviewer to get back to me about what the current rule on the wall height actually is. Also to any existing breweries that didn't have to abide by that rule, she said that if you apply for an extension or put on an addition to the brewery and need to submit a new diagram, that you'll have to add the wall.

          The original reason I called was to ask if there is a way to delete an attachment so I can submit an updated one and she "no just upload the new document and we'll see that it's newer".

          We'll see what this application reviewer says if they ever get back to me....

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          • #6
            Originally posted by seekingalpha View Post
            Just got off the phone with a TTB customer service person. Apparently "these days" they are requiring at least either a 4' or 6' tall wall separating the brewhouse from where customers will be. I asked if there is a secret website that lists rules such as this and she didn't know but is sending a message to my application reviewer to get back to me about what the current rule on the wall height actually is. Also to any existing breweries that didn't have to abide by that rule, she said that if you apply for an extension or put on an addition to the brewery and need to submit a new diagram, that you'll have to add the wall.

            The original reason I called was to ask if there is a way to delete an attachment so I can submit an updated one and she "no just upload the new document and we'll see that it's newer".

            We'll see what this application reviewer says if they ever get back to me....
            It sounds like you are asking too many questions. Simply mark on the print a separation between the brew house and customer area. Don't go into any more detail than that unless requested too at a later date. The separation can be a rope or chain.

            Remember, the TTB regulates duties on alcohol. They aren't responsible for building code, fire safety, or anything else.

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            • #7
              Originally posted by AmbrosiaOrchard View Post
              It sounds like you are asking too many questions. Simply mark on the print a separation between the brew house and customer area. Don't go into any more detail than that unless requested too at a later date. The separation can be a rope or chain.

              Remember, the TTB regulates duties on alcohol. They aren't responsible for building code, fire safety, or anything else.
              I do ask a lot of questions, but I do so because it can save time down the road. I'd prefer to have the plans reflect the right details from the beginning. Below is a recent email transcript between me and my application specialist.

              TTB: I was contacted by our call center in regards to your online application with the Alcohol & Tobacco Tax & Trade Bureau. I will be the Specialist in charge of processing your online application. Since your application was received on 7/11/2018, it will be several weeks before I am able to process or review this application. All applications are processed in the order that they are received into our office.

              In regards to your questions of the separation of premises. Please be advised, the public area and manufacturing area must have appropriate separation before we can approve the application. Those businesses that do not have appropriate separation of premises, can be subject to penalties as well as an order to cease and desist their operations. If you are aware of businesses that are causing jeopardy to the revenue, feel free to provide the name and address of these businesses. In the meantime, I’ve listed some information below to help you identify what’s appropriate. If you have any questions, please feel free to contact me. Thank you for your cooperation.

              The following is a listing of unacceptable separation of brewery premises: Chain/Rope, sign stating “no access,” A line of tape on the floor, swinging doors or any obstacle you can go under.

              The following is acceptable separation; walls, gates, fencing or partitions.
              ____________________________
              ME: Thanks so much for contacting me. Everything you're saying makes sense to me, just a couple clarifying question I have is whether there is a height requirement for the separation barrier, if so what is it and also could the partition be on locking wheels or casters?

              Thanks again!
              ____________________________
              TTB:The obstacle should be tall enough where you can’t easily go over it. The structure you will use to separate the public area from the manufacturing area must be permanent. You shouldn’t be able to roll or push it out of the way. Let me know if you have any additional questions.

              Comment


              • #8
                Originally posted by seekingalpha View Post
                I do ask a lot of questions, but I do so because it can save time down the road. I'd prefer to have the plans reflect the right details from the beginning. Below is a recent email transcript between me and my application specialist.

                TTB: I was contacted by our call center in regards to your online application with the Alcohol & Tobacco Tax & Trade Bureau. I will be the Specialist in charge of processing your online application. Since your application was received on 7/11/2018, it will be several weeks before I am able to process or review this application. All applications are processed in the order that they are received into our office.

                In regards to your questions of the separation of premises. Please be advised, the public area and manufacturing area must have appropriate separation before we can approve the application. Those businesses that do not have appropriate separation of premises, can be subject to penalties as well as an order to cease and desist their operations. If you are aware of businesses that are causing jeopardy to the revenue, feel free to provide the name and address of these businesses. In the meantime, I’ve listed some information below to help you identify what’s appropriate. If you have any questions, please feel free to contact me. Thank you for your cooperation.

                The following is a listing of unacceptable separation of brewery premises: Chain/Rope, sign stating “no access,” A line of tape on the floor, swinging doors or any obstacle you can go under.

                The following is acceptable separation; walls, gates, fencing or partitions.
                ____________________________
                ME: Thanks so much for contacting me. Everything you're saying makes sense to me, just a couple clarifying question I have is whether there is a height requirement for the separation barrier, if so what is it and also could the partition be on locking wheels or casters?

                Thanks again!
                ____________________________
                TTB:The obstacle should be tall enough where you can’t easily go over it. The structure you will use to separate the public area from the manufacturing area must be permanent. You shouldn’t be able to roll or push it out of the way. Let me know if you have any additional questions.

                I sorta phrased that wrong. Questions are good in general, but the TTB is so inconsistent and they play by a secret rule book. I would rather let them ask YOU the questions. For example, I was told by the TTB that a rope or chain was sufficient separation. By being proactive with the TTB (A senseless federal government agency), you are really just causing more headaches for yourself.

                Per their response, once again they are only concerned with a LOSS of revenue due to the lack of separation.

                I would put a note on your print stating "partition" wall.

                Comment


                • #9
                  what does the "Brewhouse" entail that needs to be behind a wall? all our fermenters and brite tanks are located under lock and key directly below our electric brewing system which we have on a platform thats stanchioned off from the public. What would the wall do that effects the TTB in this case? the TTB told us it was the area in which the fermentaion and beer was stored which needed to be kept off premises. also We know that if gas was used in the brewhouse it would need to be a seperate room but were told an electric brewhouse that not in use while we are open and properly disabled would be ok behind ropes as we've seen other breweries do.

                  one frustration we did run into with the feds was having to change our license to a brewpub once they realized we are serving from a walkin cooler directly below the bar vs kegs behind the bar... no explanation why except it was one of the rule changes in January.
                  Last edited by augiedoggy; 08-23-2018, 08:19 AM.

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                  • #10
                    With us, it was the health department that required the brewing area be hermetically sealed, not the TTB. Since the taproom was not required to be brought up to "food prep" levels of cleanability (except the bar area itself) there had to be doors and windows between the two areas. I've seen others in the state that are less separated, but usually the taproom itself is much more updated (sterile) than our 100+ year old grocery store, so it was a trade off: Keep the awesome but hard to clean hardwood floors, and shiplap walls, or replace them with something we could eat off of and lose that character.

                    A couple doors and windows separating the areas was easier. Admittedly we already had a wall separating the spaces 7/8 of the way. We put a couple fixed windows in to open it up and closed off the open doorway with a pair of full light commercial doors and a sidelight unit to match. Letting more natural light into the brewing area and keeping the historic feel in the tapoom without having to recreate it was a win-win for us.


                    Patrick S. McGinnity
                    Whiskey Point Brewing Company
                    Beaver Island, MI

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                    • #11
                      Any further updates on your progress/process? Did you complete the process before the shutdown? What was your ultimate timeline?

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                      • #12
                        At what stage was the actual construction of the brewery when you submitted your application?

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