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Help with risk identification

Hi everyone!

Very long time since I made a topic here. I am up and running my small distillery now and my still from StillDragon is making a wonderful job. This autumn I have been to a few events and I have received so much positive reviews. I love my still!

The Swedish FDA want me to describe the hazards in the mashing and distillation processes. I feel that I am stuck and need some help to identify the risks. Of course it is not hard to identify methanol, acetone, acetaldehyde as risks and what to do to avoid having them in the final product. But what about the tails? As a rum producer I collect quite a bit of the tails and there we have the fusel oils.

Any other risks I need to consider in the processes?


  • What specifically are they asking you? If they are not being specific you should ask them to be.

    There are multiple kinds of risks. You might need to address risks to staff while working, visitors on a tour/contractors doing work for you and also obviously the end consumer drinking the stuff.

    Also, risks come in various forms (physical, chemical, microbial, allergen...)

    Perhaps start by making a process flow diagram, number the steps, and for each step right down the potential risks no matter how trivial or unlikely they seem

  • Have a serious think about everything you do. Without much effort, I have thought of the following in no order...

    chemicals used for cleaning - spillage spillage / slip hazards trip hazards from hoses on floor between tanks electrocution intoxication via inhalation from open tanks product contamination waste management - incoming packaging; stillage in the still after processing; yeast rub after fermenting cuts - eg if you drop a bottle environmental - stilage is high BOD; alcohol spills will kill fish; noise; odour (from fermentation for example); explosion eg from grain dust C02 intoxication injury due to manual labour eg lifting heavy loads

    Don't forget fire...

    lots of info if you use google.

    @mark85 has a good ideas re categorising them, and working through processes step by step. If you work with others - run a brain storm session - don't forget to look for ways you can eliminate / minimise / implement controls for each and capture them too

  • edited November 2018

    Are they looking for consumer or employee safety?

    Are they asking for a haccp plan?

  • Because artisan distilling is fairly unknown int the Netherlands we used the already standardised safety protocols for artisan beer breweries as a start. In this way you have half the work done and you can use the already legally approved flowplan and regulations as a starting point. If you also have a tasting room / bar on site, use the protocols of a brewery with a bar where they also do tours in the brewery. They can never reject that part of your plan that they already approved.

  • Thank you all for your useful input.

    It is just the safety for the consumers the FDA wants me to identify. But they say that I don't have to write an full HACCP plan though.

  • edited November 2018

    I would reckon with proper cuts, your finished product will have less "contaminants" than a one or two week old jug of orange juice in the fridge.

    Never even mind what is routinely found in a bottle of sour beer, or a bottle of Rancino wine.

    They don't call it distilling for nuttin fer cryin out loud.

    StillDragon North America - Your StillDragon® Distributor for North America

  • Fermenting: The fermenting room should be wentilated and possible have a oxygen sensor if done in large scale. Silos: Grain and other material give of gasen, if stores in large silos its dangerous to go into one of these silos if they are not wentilated yet. Fire: Well but problable understood hasard Dust: Grinding if dry dust is produced risk for dust explosions Left over: Can create H2S ...

  • PS first you mentioned the process and then the product...Is the questions product related? I think the answer is that it it is safe and you must comply with some EU derictives on this part. Best is if you more or less do in that case.

  • Hi all!

    @Oswald: As I said in my posts it was only the hazards for the consumers health the Swedish FDA wanted me to describe ;)

    @Smaug: Yes of course and I had already described that for the FDA. The persons handling this at FDA had very little knowledge about distilling and no knowledge at all about rum production. I had to lecture them a bit.

    Anyway, I finally got everything approved after my spirit was analysed at a laboratory. And this is the results:

    • Acetaldehyde: 6,0 mg/100 ml pure alcohol
    • Methyl acetate: 0,62 mg/100 ml pure alcohol
    • Ethyl acetate: 0,41 mg/100 ml pure alcohol
    • 1,1-Diethoxyethane: <0,2 mg/100 ml pure alcohol
    • Methanol: 1,9 mg/100 ml pure alcohol
    • Butanol-2: <0,2 mg/100 ml pure alcohol
    • n-Propanol: 13 mg/100 ml pure alcohol
    • i-Butanol: 27 mg/100 ml pure alcohol
    • Isoamyl acetate: 0,28 mg/100 ml pure alcohol
    • Allyl alcohol: <0,2 mg/100 ml pure alcohol
    • n-Butanol: 0,41 mg/100 ml pure alcohol
    • 2-Methyl-(1)-butanol: 14 mg/100 ml pure alcohol
    • 3-Methyl-(1)-butanol: 70 mg/100 ml pure alcohol
    • Ethylcapronate: <0,2 mg/100 ml pure alcohol
    • 1-Pentanol: 0,57 mg/100 ml pure alcohol
    • Ethyl lactate: 2,0 mg/100 ml pure alcohol
    • 1-Hexanol: 0,20 mg/100 ml pure alcohol
    • Ethylcaprylate: 0,20 mg/100 ml pure alcohol
    • Benzaldehyde: <0,2 mg/100 ml pure alcohol
    • Ethylcaprinate: 0,87 mg/100 ml pure alcohol
    • Ethyllaurate: <0,2 mg/100 ml pure alcohol
    • Benzyl alcohol: 0,37 mg/100 ml pure alcohol
    • Phenylethanol: 0,71 mg/100 ml pure alcohol
  • Good going.

    How did your tolerances compare? Or did they not even know that as well?

    StillDragon North America - Your StillDragon® Distributor for North America

  • @Smaug: They must have compared to the tolerance levels because the hazard plan is approved now :) But I also think that they just are looking at the methanol level and the tolerance is 10 g/liter in EU.

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