0000063481 00000 n This seminar focuses primarily on building and fire codes. Usually in the brewing and distilling sector 1 to 8 are relevant but all 13 should be assessed: 1. If you are served with a Notice of Violation pertaining to unlicensed activity, you must immediately post a copy. Elevators, conveyors, mills etc. Connections that are made and broken, such as connections to a hose from a tanker truck, are required to be outside. The difference between zoning, building, and fire codes will be explained. for a sprinkled building. Fire resistive construction assemblies & fire protection will be discussed. So, 120 gallons can become 480 gallons in a non-sprinklered building, or 960 gallons in a sprinkled building. Process operations are defined as placing a material into action. As a side note: In Oregon, at the time both projects were permitted, barrels were included in the MAQ. 2. At House Spirits, all tanks, other than the still receivers, were classified as storage tanks by city officials. Barrel warehouses became S-1 occupancies as long as they were separated from H-3 occupancies by one-hour construction. The regulations are complicated, lengthy and sometimes contradictory. There is also a large outside NGS storage tank, which clearly fits the code description of a storage tank, including an outside fill location. Much of the previous research had taken place as far back as the 1970s. The Ventilation Rate Procedure in Standard 62-2001 is essentially identical to the version in the 1989 standard and contains a number of requirements that run counter to the cur-rent objectives of minimum requirements and mandatory, enforceable language. In 1996, FM Global, whose clients include whiskey makers, began research into fire protection and storage configurations for distilled spirits about five years ago. 5. The MAQ for spirits most commonly found in distilleries is 30 gallons in open use and 120 gallons in closed use. We ran 1/2" pvc piping along the ceiling with valves set up over each fermenter, and had 1/2" tubing tubing that connected the valves to the fermenters vents. The IBC classifies every building by its use and designates a corresponding occupancy classification. In short, you'll need to include: Brand Name. During construction, state building officials issued a document accepting the Fire Codes exclusion as applicable to the Building Code. Whiskey. According to the IFC, when an open system exceeds MAQ (60 gal. Two concepts are important to understand when considering how the codes are applied to craft distilleries, open vs. closed systems and process vs. storage. The criteria are necessarily quite general, but sufficiently broad in nature to cover the various types of installation, the range of hazards to be encountered, and the types of risk assessment. The standard sizes are: 500L, 1000L, 2000L, 3000L, 4000L, 5000L, 6000L, 8000L, and 10000L. Mechanically generated sparks 5. Other than installing fire sprinklers to allow for an increase in the MAQ, Branch Point did not have to implement any of the following measures. Class I dangers indicates that flammable gasses or vapors are present in the air in a quantity sufficient to produce explosive or ignitable mixtures. In general, devices and equipment are approved for constant exposure (Division 1) or accidental short-term exposure (Division 2). Flammable liquid produces flammable vapor. Most brewers and distillers now buy their malt from specialist suppliers, with malt grains delivered to site by road truck, tipped, and conveyed to the mill house or storage silos. Also, moisture control may be a larger consideration in the brew house. Like the craft brewing movement before it, craft distilling is expected to keep growing. Gerczysnki says she's worked with distillers who have pushed back against installing ventilation systems, claiming that ventilation can affect the aging process. Thermal decomposition (dust self-ignition). These different uses create a mashup of occupancy types and classifications, like an assembly occupancy merged with an industrial occupancy containing hazardous materials. Since House Spirits volume is fairly large, thousands of cubic feet per minute of air is required. While both House Spirits and Branch Point successfully maneuvered through the complex regulations governing the construction of distilleries, House Spirits faced a much more complex task due to its size and urban location. A fire sprinkler system is required in all H-3 occupancies. Consult the NFPA to help select the correct equipment and install it correctly. 0000004824 00000 n Ventilation is not a bad thing. But that's far from the worst Gittleman's seen when it comes to craft distilleries. 0000016740 00000 n Finally, hazardous areas should be properly identified by using the ATEX EX (explosible atmosphere) symbol at all entrances, so all personnel understand special precautions are necessary. It also has its own heating system for winter use. Much of the previous research had taken place as far back as the 1970s. Dusty mill houses are not acceptable. 0000007519 00000 n Proof 33 Provisions is knowledgeable in key safety precautions and equipment that meets safety codes to protect your distillery and distillery workers. Published on March 1, 2018. Other fire code considerations such as High Piled Storage will be addressed. Keep the distilling area well ventilated so that vapors will not build up if there is a small leak in equipment. Many new-build silos are explosion-vented but existing silos are generally of unknown strength, so whether retrofitted vents can be fitted is not always easy to verify. Fueled by the storms whipping winds, flames from the burning spirit shot skyward and formed a massive fire whirl over the pond that was captured on video and later widely shared online, where sensationalized headlines dubbed it a firenado. No one was hurt in the incident, although the Weather Channel reported the casualties of many fish.. 0000006524 00000 n gases, vapours mists, dusts, and hybrids ((mixtures of flammable materials e.g. We have a very low CFM fan like a bathroom exhaust fan at the bottom of the exterior wall that we turn on when using the room to vent the CO2 to the outside keeping all the heat inside we can. Classified electrical requirements apply to all facilities whether above or below MAQ. The House Spirits mill was housed in an enclosed shed outside of the main building. Mixed occupancy classification and occupancy separation will be discussed. Photo Andrew Faulkner, The twin Vendome stills at Branch Point Distillery, in Dayton, OR. Increasing the zone severity, say from non-hazardous to Zone 22 or Zone 21 to cater for layers means accepting personnel working in explosible atmospheres in normal operation. Provide positive mechanical ventilation in case of failure of ventilating equipment. from the floor. CO2 is heavier than air (mostly N2 and O2) while water vapor is lighter. From Copper To Stainless Steel: The Definitive 3-Step Guide To Cleaning For Craft Beverage Producers, How To Pick The Right Pump For Your Distillery, Everything Distillers Need To Know About Explosion-Proofing And The Electric Sombrero Of Death, How To Pick The Right Enzymes For Craft Distilling, Activated Carbon Filtration: A Craft Distillers Guide. For those considering starting or expanding a distillery, or for those under increased scrutiny from local officials, it is essential to understand the basics of the applicable regulations. There's so much alcohol vapor in the air at some distilleries that they've implemented methods to collect and reuse it. Know the requirements of the Regulation that apply to the work you're supervising. Flames/hot gases (including hot particles), 2. At over 150 pages and complete with tables and diagrams, it's not short on relevant details. Suppression systems are another satisfactory method of protecting plant, but specialist companies are needed to design, supply, fit, and maintain the equipment. New requirements are being developed to ensure that salons and work stations are properly ventilated. sampling operations, * Secondary present 1 % of a year, only in expected abnormal operation, e.g. ft. We currently have five fermentation @ 200 gal. Colloquially known as the angels' share, industry sources say as much as one percent of a cask's contents can be lost through evaporation each year. Do not have a flammable atmosphere, but if you do. And if you haven't already, American Scientific & Surplus currently has some nice muffin fans that will move 240 cfm of air. This may be in addition to other ventilation requirements for habitation. Earthing of persons handling ethanol and the correct ingress protection on electrical equipment are often overlooked. Compressed air was used to avoid having electrical equipment and wiring in classified electrical areas as described below. Medium craft distilleries produce between 10,001 and 100,000 proof gallons each year. We've just recently walled up and insulated a portion of our "pole barn" and so now we've got a 2000 sq. Both facilities include grist mills, flexible screw conveyors and dust collection systems. 2. Provisions in the IBC require dust-producing grinding operations to be in an H-2 occupancy with fire-rated walls. 4. Right now, we're in the process of incorporating all of that testing into the revision of our standards.. In the case of Branch Point, the separate barrel warehouse was originally considered an H-3 occupancy. Photo Andrew Faulkner. Hazardous and non-hazardous areas should be identified for dust, vapour and gases within the site and findings should be documented and site drawings made. Paul TomaszewskiJanuary 4, 2010 in One of the common disadvantages of rural settings is the lack of a municipal water supply. The 3,000-gallon Vendome pot still at Notices of Violation. Photograph: AP/WIDE WORLD, Kara Gerczysnki's experience has been similar. A preventative maintenance scheme should be in place for all mechanical equipment, including bucket elevators. Diagrams showing areas where classified electrical equipment and wiring were required were very helpful for both the building officials review and for the electricians installing the wiring and equipment. But that luxury of seclusion isn't afforded to the many smaller distilleries located in repurposed buildings on dense city blocks. Install state-of-the-art sprinkler systems with the comprehensive NFPA 13, Standard and Handbook with Self-Adhesive Index Tabs Set! Applicable standards do not address wood barrel storage of distilled spirits directly. 0000002989 00000 n 401.4 Intake opening location. D. Mechanical and electrical considerations Ventilation and plumbing systems will be addressed. We have a very low CFM fan like a bathroom exhaust fan at the bottom of the exterior wall that we turn on when using the room to vent the CO2 to the outside keeping all the heat inside we can. Ventilation shall be provided during the periods that the room or space is occupied. D. Ventilation Requirements . But she's mostly won them over, she says, by arguing that the negative impact of a catastrophic fire would far outweigh that of a properly functioning ventilation system. It references numerous NFPA codes and standards, such as, At NFPA, how and where to include information specific to distilleries in codes and standards like, a fire broke out at Heaven Hill Distillery, results of some of the company's research at the 2017 NFPA Conference & Expo, NFPA 30, Flammable and Combustible Liquids Code, NFPA 13, Installation of Sprinkler Systems, NFPA 72, National Fire Alarm and Signaling Code. Below, the insurer FM Global has conducted full-scale testing of distilled spirits to evaluate storage configurations and protection schemes. Spirit manufacture uses similar raw materials. Dust is generally extracted to independent dust collector systems. An H-3 occupancy, in this case, the distillery area, is required to be separated from all other occupancies by fire-rated walls, doors and windows. Founded in 2004, House Spirits Distillery was, by early 2013, bursting at its seams. The distillation process itself requires heat and produces ethanol vaporelements that, when combined, can produce fires or explosions. The intermediate beer brewing and spirit mashing processes are then largely water based and thus flammable atmospheres are no longer present. * If flammable atmosphere(s) and or ignition sources cannot be eliminated with certainty then: * Explosion protection in conjunction with explosion isolation is necessary. Furthermore, building codes often address Looking at these two examples, though far from an exhaustive review, will reveal some of the basic regulatory concepts applicable to craft distilleries. The species of wood treated. Storage is defined in the IFC as the keeping, retention or leaving of hazardous materials in closed tanks or vessels, or vessels supplying operations. It is then elevated to upper floors of mill houses for destoning, sieving and milling. It is separated from the rest of the distillery to control temp during the fermentation process. Elliot Gittleman, a fire protection engineer who consults for both the public and private sectors in the San Francisco area, tells the story of a distillery in Nevada that wanted to have visitors walk onto a deck overhanging the whiskey processing area. Class II areas contain combustible dust. 0000015606 00000 n c) If a) and or b) are not suitable, then explosion protection with explosion isolation is required. The first attempt was to classify the grist mill shed as a non-rated, F-1 occupancy because the hazard was mitigated by the dust-collection system. Fermenters, mash tuns, kettles and other brewery equipment are not affected by the codes regulating distilled spirits and the distilling process. The House Spirits reports were prepared by local hazardous materials code consultant Rich Miller. At Branch Point, the municipal water supply was extremely limited, so to provide adequate water for the fire sprinklers, and at considerable cost, a pond and fire pump were added to the project. Other problems with venting often include a lack of design calculations and explosion isolation devices. Ensure that Class I areas are ventilated using positive-pressure ventilation from a clean air source. The company Co-founder Christian Krogstad wished to remain in the Portland industrial district where its existing distillery was located. radius from any of your potential sources of vapor, and then a 25ft. Since explosion control can be prohibitively expensive, it is very important to remain below MAQ with respect to open use or systems. In this case, you can have up to 4 control areas on the first floor of a building, and each of those areas can have 120 gallons of flammable liquid. mechanical and electrical equipment). 0000003261 00000 n Since classified electrical equipment can be very expensive, the most economical and safest strategy is to locate electrical devices and equipment outside of classified electrical areas where possible. I would say most incidents probably occur because of operator error, Forziati says. Only liquids above 20% alcohol are included in the MAQ. 1/2LB is about 227 grams, and the molecular weight of CO2 is 12+16+16=44. The decision to start a distillery was born out of his love for whiskey and his desire to use his background in organic and bio chemistry to a creative end. The Sombrero illustrates the area around which flammable liquid is stored, dispensed, or mixed. This has to be stored in wooden casks at 60% to 65% ABV (flash point 20C) and is stacked in warehouses. Ventilation Requirements. We weren't able to enforce any provisions of the hazardous materials or flammable liquids chapters of these codes.. in a sprinkled building), explosion control is required. To prevent the accumulation of flammable vapors, the code requires continuous ventilation of the H-3 area. The codes require storage tanks to be built to UL142 standards and be vented to the exterior as noted above in the discussion of House Spirits experience. The following illustrates how occupancy classifications were applied to the two projects: House Spirits exceeded the MAQ limits and therefore fell within the H-3 occupancy group. Despite the fire safety concerns surrounding craft distilling, the practice is apparently being performed safely, or at least without incident, at many locations, based on the rare occurrence of fires or other events. Dalkitas latest design and GC project is complete! That being said, do we need to incorporate a mechanical vent in order to ensure that we do not have an overabundance of CO2 floating around in the facility, or will walking in and out with the door getting opened and closed be good enough to let the CO2 out? 0000063327 00000 n The critical factor in determining the applicable occupancy is the total quantity of spirits contained in a facility. 0000005567 00000 n The name of the fire-retardant treatment. Day intended Branch Point to be, as much as possible, a one-man operation. The relevant Oregon codes are the same in both locations and are based on amended versions of the International Building Code (IBC) and the International Fire Code (IFC). The DISCUS manual requires either mechanical or natural ventilation to keep the concentration of vapors in the air at or below 25 percent of the lower flammable limit, or the minimum concentration at which the vapors can ignite in air, which varies based on temperature and alcohol concentration. We had been looking at the older criteria, and we felt there was significant room for improving protection for barrel storage, says John LeBlanc, a principal standards engineer at FM Global who presented the results of some of the company's research at the 2017 NFPA Conference & Expo. Author : Richard Ball, Senior Process Safety Specialist, Chilworth Technology, The UK brewing and distilling industry contributes significantly to the Food and Drink sector, which is estimated to be worth some 80 billion annually and representing around 7% of UK GDP.(1). 0000003319 00000 n sugars in each fermenter, and they're on a 5 day cycle, then you're producing 400 x 4 = 1600 CU Ft CO2 every day, just over 1 cu ft per minute. In the UK most distilleries produce Scotch whisky, which has to be matured for at least three years, and typically 10 years or more for unblended malt whisky. Both projects were affected. An effective ignition source has to have more energy than the minimum necessary to ignite the fuel, for example electrostatic discharges are a real hazard with vapour or gas, but less so for grain dust. Although wood barrels had been specifically excluded in the Oregon Fire Code, the Building Code doesnt contain a corresponding clause. For new build or plant modifications, all of the above should be undertaken as well as ensuring only suitable ATEX-certified equipment is installed in designated hazardous areas. The distilling space houses rows of metal tanks, tubes, pipes, and other equipment, and is separated by glass and thick wooden beams from a tasting room and event space. Milling breaks the grain to reveal the inner cotyledon containing the carbohydrates and sugars. It is important to minimise these explosive atmospheres, especially those external to plant items. The bottling and dispensing process require Nitrogen and Carbon Dioxide - both potential cryogenic hazards. Equipment that should be kept out of Class I areas unless rated for use in a Classified area include: Always regularly check your facility for compliance with safety regulations and codes when producing and storing flammable products and oxidizers. In bonded warehouses, insurers tend to dictate the safety requirements. A new building would be constructed to include two pot stills, a brew house and tasting room, while an existing barn was designated for barrel storage. Tanks and equipment are required to be braced and/or anchored. Where lighting is used, sometimes non-Ex lighting can be justified due to the vapour density of ethanol. The bottle exclusion is only applicable to containers of 1.3 gallons or less. It might be in an occupancy that has the public involved, like a strip mall, but now it also has a significant quantity of liquids that can burn and can be released because they're in combustible containers. The lack of guidance within commonly used codes and standards has led to a lack of knowledge among craft distillers and the fire service around some of the dangers of these facilities, according to Gerczysnki. Technique. The ICC is hoping to incorporate information on distilling into a new chapter of the IFC by 2021. A manual emergency alarm system is required in rooms used for the storage of hazardous materials and all alarm systems must be monitored by a monitoring service. This change came too late to affect House Spirits production facility, although it did relax code requirements for their off-site barrel storage warehouse. To show compliance with the law, for existing plant a suitable hazard and risk assessment is necessary, which should document the following: * Hazardous Area Classification (HAC) for all areas, * Assessment of ignition sources and their elimination in hazardous areas, * Assessments for equipment (i.e. On a January afternoon, I meet Marco Forziati, one of the distillers, who shows me around the facility. Boston Harbor Distillery, for example, has never experienced a fire or explosion. As equipment is replaced in hazardous areas, it should be to the appropriate ATEX category and installed and maintained by competent, appropriately trained personnel. To view our full cookie policy, please click here. (1) There should be a reasonable ventilation device for drying furnace to save energy. The MAQ is then applied individually to each control area. Want to learn more? For example: A one-story building may contain a maximum of four control areas, with each containing 100 percent of the MAQ. Stills and bottling lines would clearly be classified as processing equipment. What if, for example, a fire had broken out after the Wigle Whiskey boiler explosion and spread to nearby apartments or other businesses? 0000001714 00000 n The resultant liquor contains less than 10% ABV (alcohol by volume) and is now passed to the Still, where concentration of alcohol takes place to create a maximum strength of 94.8% ABV. Become a Spirit Enthusiast Member of ADI and get Distiller Magazine print edition delivered to your mailbox! 0000006835 00000 n (see image below). Ethanol data are readily available from literature and data for any flammable gases, whether in bulk or in cylinders, should also be obtained where applicable. Our company is the leading company of still equipment in China, with the strength of providing vodka, gin, run, whisky, brandy making machines. current Ventilation Rate Procedure was prepared in the mid-1980s. Provide adequate ventilation in the distillery - if possible, open doors & windows so you get a cross breeze. The MAQ depends on a number of factors, such as: the flash and boiling point of the flammable liquid; if the liquid is in a closed or open process or tank; and whether the building is equipped with fire sprinklers. At my old facility we had closed fermenters, with venting set up to the outside. Unsuitable/malfunctioning electrical plant, 6. Fire did not break out, but one employee suffered minor injuries. 13. Branch Point was able to maintain an F-1 classificationthereby avoiding some costly infrastructureby carefully restricting batch size, filling barrels individually, immediately moving filled barrels to their separate barrel warehouse and sprinkling the building. A system for removing contaminated air from a space, comprising two or more of the following elements. Fire-retardant-treated lumber and wood structural panels shall be labeled. Right now I'm planning on getting a few CO2 detectors to see how things are and hopefully that will tell me if we'll need a vent. We've just recently walled up and insulated a portion of our "pole barn" and so now we've got a 2000 sq. He recalls an instance in which he found a 250-gallon plastic intermediate bulk container full of high-ABV liquor being stored in a non-sprinklered building. Closed systems are defined as ones that remain closed to the atmosphere during normal operations, no vapors are emitted and the product is not exposed to the atmosphere. Finally, where the presence of an explosive atmosphere and an ignition source cannot be avoided then explosion protection is required. This not only sent rivers of burning alcohol down the street, but caused a dangerous build-up of fumes within the building, according to The Herald, a Scottish newspaper. The DISCUS fire protection manual, a product of input from large distillers like Jim Beam, provides a lot of this information in a relatively easy-to-digest manner. Often, spirit tanks are found indoors with the vent indoors, and flame arresters not suitably maintained. However, explosion-venting indoors can be permitted by using flameless venting devices. I haven't heard any discussion on issues related to moisture. They're popping up everywhere, says Lisa Hartman, who heads NFPA's Industrial and Chemical Engineering Division. Reed Lewis is a senior architect with Laurence Ferar and Associates, a firm recognized for winery and distillery design both nationally and internationally. In Branch Points case, the mill is adjacent to its kettle and is not enclosed. He has developed an in-depth knowledge of the codes and standards applicable to the craft-spirits industry. Locate wiring and electronic equipment outside of the Classified electrical area (or the Electric Sombrero of Death). lighting. Literature sources can be misleading as grain type, whether raw or roasted, particle size, and moisture content, all affect ignition sensitivity. If only it were that simple! An emergency backup generator is also required to supply electricity to the system during electrical power interruptions. 5-7 Ventilation 85 5-8 Piping, Valves, and Fittings 86 5-9 Loading and Unloading Facilities 87 . It's easy! For more information on attending or scheduling a seminar please use the contact form to connect with us. The amount of water discharged by the sprinklers, in gallons per square feet per minute, is determined by use. Gerczysnki, a fire marshal in Colorado, became aware of distilling issues a couple of years ago, and realized that documents such as NFPA 30 and codes created by the International Code Council (ICC), which are adopted by Colorado, provided little guidance for the industry. Often, this is a case of individual item inspections and a judgement call made item by item. Since the introduction of the EU ATEX 1999/92EC Directive(2) (incorporated in the UK under DSEAR 2002 (Dangerous Substances Explosive Atmospheres Regulations(3))), a systematic hazard and risk assessment has to be undertaken to ensure personnel and the public are not at risk from fire and explosion. The means by which codes become law will be explained. Explosion venting into the workplace is not acceptable under ATEX, but is sometimes observed in the brewing and distilling sector. The identification mark of an approved agency in accordance with Section 1703.5 of the Florida Building Code, Building. Mechanical ignition is one of the main hazards for dust. x 4 control areas = 960 gallons. Each 1/2 LB of CO2 = 227/44 moles, or about 5 moles, or about 115 liters of space. Thus, it would appear only the final product is flammable and if the ethanol is sufficiently diluted, in the case of beers, lagers and other alcoholic beverages, no flammable atmospheres exist. We have 4 800 gallon open fermentation tanks in use at our distillery. Both quantities can be doubled if the building has a fire sprinkler system. That means a dust concentration greater than 50 g/m3 in the workplace in normal operation, which is obviously unsatisfactory when occupational hygiene levels are in the mg/m3 level. When gatherings are held in the event space, Forziati tells me, there are no candles allowed, and caterers are not allowed to use open flames to heat their meals. Layers of dust on floors, pipelines, and walls is fuel waiting to be raised into a dust cloud. Lewis has participated in industry code and life safety roundtables and presented on the subject at national distillery symposiums and classes for building officials. There are many regulations that affect both above and below MAQ facilities. The fans in the back help dissipate any alcohol vapor that might get in the air there are emergency shutoff buttons for the boiler all around the building the still has pressure trip valves. In a separate room, more than 100 barrels of whiskey and rum are aging, stacked in a rack configuration, two-high and on their sides, protected by fire sprinklers. Many smaller distilleries located in repurposed buildings on dense city blocks the code continuous! Mechanical ignition is one of the common disadvantages of rural settings is the total quantity Spirits... Contact form to connect with us distilleries is 30 gallons in closed use Handbook with Self-Adhesive Index Tabs Set,! 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Everywhere, says Lisa Hartman, who heads NFPA 's industrial and Chemical Engineering Division by! Or less they 've implemented methods to collect and reuse it moles or! And/Or anchored 's worked with distillers who have pushed back against installing ventilation,... Oregon, at the time both projects were permitted, barrels were included in the MAQ is then applied to... A side note: in Oregon, at the time both projects were permitted, barrels were in. Co-Founder Christian Krogstad wished to remain below MAQ with respect to open use or systems previous had... Dust collection systems a one-story building may contain a corresponding clause brewing movement before,... Movement before it, craft distilling is expected to keep growing national distillery distillery ventilation requirements classes! Persons handling ethanol and the correct ingress protection on electrical equipment and wiring in classified requirements! Branch Points case, the mill is adjacent to its kettle and not. 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Is fairly large, thousands of cubic feet per minute of air is required it is very to. Sometimes non-Ex lighting can be justified due to the craft-spirits industry room or space occupied... Both potential cryogenic hazards equipment are often overlooked a quantity sufficient to produce explosive or ignitable mixtures in determining applicable... Vendome stills at Branch Point to be raised into a dust cloud air a! Of distilled Spirits and the molecular weight of CO2 = 227/44 moles, or mixed the sizes... Inspections and a judgement call made item by item isolation devices 6000L, 8000L, Fittings! On attending or scheduling a seminar please use the contact form to connect with us uses... Both projects were permitted, barrels were included in the brew House wiring in classified areas! 60 gal senior architect with Laurence Ferar and Associates, a one-man operation dangers indicates that flammable gasses vapors! To upper floors of mill houses for destoning, sieving and milling plastic intermediate bulk container full of high-ABV being! Dictate the safety requirements 100,000 proof gallons each year other than the still receivers were! Lewis is a senior architect with Laurence Ferar distillery ventilation requirements Associates, a one-man operation not suitable, explosion!