It's practical to expect that you and your team know what your distilling equipment does, where it's located and what liquid is inside of your vessels, however TTB compliance officers will not inherently know this information during a visit to your DSP. That being said, it's vital to ensure that your equipment and DSP areas are clearly marked in accordance with 27 CFR ยง19.189 "Identification of structures, areas, apparatus, and equipment" (see excerpt below):
According to the Source below from the TTB, "the most frequent violation of this regulation is lack of signage on buildings, rooms, and areas that hold distilling material and unfinished spirit products. One way to mark the room or building is to use the DSP permit number, followed by a sequential number if there is more than one room or building used for spirits or productions materials."
The TTB also recommends that DSP's annually verify their compliance regarding the following:
- All structures, areas, apparatus, and equipment must be marked with a distinguishing number or letter (a unique serial number).
- All tanks used in production must be marked to show capacity.
- All stills, fermenters, cookers, yeast tanks, and other major equipment used for processing or containing spirits must be marked to show their use.
Review our TTB Source for more details and tips on how to stay compliant: https://www.ttb.gov/distilled-spirits/common-compliance-and-tax-issues-surrounding-distilled-spirits-plant-dsp-audits#_D.1_Application,_Equipment
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