Re: Re: Alcohol storage

[Guest guest]

Is Perfumers alcohol treated this way as well??

vr

dw

[Guest guest]

We've spent considerable time with alcohol purchasing/storage regs;

hopefully all relevant information will be archived. Perhaps the following

will be helpful. Your state regulations may be slightly different from

Washington, however, all state requirements will adhere to federal laws.

My corporation holds a Class 2 special permit which has to be renewed

annually with the state Liquor Control Board. It applies to the purchase of

industrial alcohol (distilled ethyl alcohol generally produced for other

than beverage purposes, CDA completely denatured alcohol, SDA Specially

Denatured Alcohol and proprietary solvent blends). The permit states the

quantity of alcohol we can purchase and our intended use. We have increased

the amount every year and we are now at 25 gallons per year. Our stated

industrial use is: perfume, cosmetic, herbal extract manufacturing. To

qualify for a Class 2 permit requires that you are a person or business

engaged in a mechanical or manufacturing business, or in scientific pursuits

including medical, dental and veterinary. This permit and our corporate

resale license allows us to purchase through the state up to the declared

annual quantities at wholesale prices and waive WA state sales tax, however

to obtain a waiver for federal excise tax requires IRS tax exemption such as

government agencies, educational organizations, laboratories, hospitals,

etc. In addition to our type of permit, persons or companies using alcohol

for consumption are required to have a Class 5 permit for manufacture of

food or beverages.

Alcohol is widely used in manufacturing, and state regulators will not be

surprised by an application from a perfume manufacturer. At least, I had no

difficulty when we applied in the early 90's. To order directly from a

supplier (such as Alchemical Solutions in Oregon), I simply call a

purchasing services number at the state and inform them of the supplier,

type of alcohol and quantity I wish to purchase. They forward the

appropriate paperwork to the supplier and I pay through the state (insuring

that all federal taxes are collected). I believe that most states do cover

in " industrial use " applicable regulations for perfumery. Just as herbal

extracts, tinctures and flower remedies are widely manufactured in the US, I

don't think you will find any extraordinary scrutiny when you apply, this is

all the same industrial use for manufacturing. Any time you are purchasing

alcohol for the purpose of manufacturing and sales, you will need to be

legally permitted no matter how little or great your purchases. If you are

only making perfumes as a hobby, you need not worry, but you may not have

access to good high-grade alcohol.

I am expected to know and abide by all safety regulations and rules set

forth, both federal and state. In brief, the state informs: " Material

Safety Data Sheets are available from the Liquor Purchasing Division or the

Alcohol Supplier on request. In general, the customer for high proof,

industrial pure ethyl alcohol must keep in mind that: (1) This product is

not sold as or intended to be used as a beverage alcohol. It is illegal to

do so. (2) Ingestion of pure ethyl alcohol at or near full strength is

extremely hazardous and may result in death. (3) This is a flammable product

and should not be exposed to a heat source. (4) Proper precautions should

be observed in the handling, storage, security and use of this product.

Consult local fire codes for storage information. " I did not receive any

special instructions, nor were we submitted to inspection, the year that we

increased purchases to more than 5 gallons, nor have we been required for

anything more now that we are at the current level of purchase. They could

require this, I am sure, but I suspect it would be the local fire department

who makes the actual inspection. I am aware that the FDA, also, can ask for

an inspection of our facility at any time and that we are also required to

abide by their " good manufacturing practice " . This is a whole 'nother set

of rules and regulations.

Perhaps JoAnne could share the legalities of the state of California. The

suggestion to contact the Small Business Administration is a good one for

finding your way around all applicable local and federal requirements for

any business. If your forte doesn't extend into the business acumen

necessary for the success of your business endeavor, this is a good place

for mentoring on all levels for growing your business.

Be Well,

Marcia Elston http://www.wingedseed.com

" Give thanks for a little and you will find a lot. " Hausa Saying from

Nigeria