At the moment, I am not having a pleasant or a magnificent week (despite the above exhortation). I can’t get any work done. Because all or almost all of TTB’s various online systems have been altogether unavailable for the past several days.
TTB provided plenty of advance notice, such as the above, explaining that all such systems will be down for maintenance during all or part of five consecutive days, from November 10th to November 14th. But still, this is an awfully long time for a critical system to be unavailable. I can not even imagine Amazon, Facebook, craigslist, or Gmail going down for a few hours, let alone a few days — without a firestorm. Is TTB’s system really a whole lot less crucial to the affected industries? Should the maintenance really take so long or happen so often? Can’t the government find a way to do maintenance in the background, without blocking thousands of regular users?
On a happier note, the systems do not seem to go down unexpectedly, or crash, very often at all, in our experience. This may be due in large part to careful and robust maintenance. But the scheduled maintenance occurs fairly often and for large blocks of time. I think it was just a few weeks ago that the system was down during the course of another multi-day period. Likewise, on a positive note, the systems are very good and provide a huge benefit, when they are up and running.
COLAs Online is down. I can’t search or look at COLAs. I can’t upload applications. I can’t receive approvals. I can’t see or respond to Needs Correction notices, in order to get approval or avoid a timeout. Dozens of urgent labels and scores of other labels need to sit idly, day after day, rather than begin their long march to approval.
Formulas Online is down. Permits Online is down. The Public COLA Registry is down (as touched upon above). These sites are not mere conveniences, luxuries or frivolities at this point. They are indispensable; federal law more or less requires thousands of alcohol beverage companies to use these systems massively and continuously. There is no realistic option to switch back to paper in the interim.
In related news about TTB Online, it is regrettable that, several weeks ago, TTB removed the ability to search permits and brewer’s notices from within the Public COLA Registry. There was a button to allow a search of, for example, all DSPs in Idaho — but the lookup is disappeared. This feature was enormously useful, and a set of old data (via the electronic reading room or FOIA) is not a good alternative. In recent weeks, many people have said TTB should fix any issues as may be necessary, but restore this functionality as soon as possible.
We encourage all readers to write in with their views. Perhaps Robert is just being a baby and should step away from the computer and go enjoy a long walk in the woods. Perhaps we should celebrate the 355-odd updays per year rather than curse the downtime. Or, perhaps the inconvenience is even more detrimental than what is described here.
Since all of the above issues have conspired to block me from doing any meaningful work, or seeking approval on the various beer labels stacking up in my inbox, I suppose I will go drink one beer, rather than seeking approval on another.
November 14, 2011, 9:15 am ET Update: The systems seem to be back up and running, as promised. Good! Sadly, this is still missing.
November 16, 2011, 9 pm ET Update: The system will go down again, over the coming weekend, as explained here. But at least it’s for a good reason, again with plenty of notice. Last weekend’s maintenance involved moving the servers to a lower cost environment, and next weekend’s maintenance will add flavor approvals alongside beverage formula approvals.
Peanut Butter Flavored Vodka
I am pretty sure Pyotr Smirnov never envisioned this. It is peanut butter flavored vodka. It is made by Terressentia Corporation of Charleston, South Carolina. Since I am in Charleston at this very moment, and getting hungry, this seemed like a fine time to feature this product.
Temperance has a similarly flavored product. It is surprising that TTB would allow it to be described as “Peanut Butter Vodka,” unlike the above, without the key term “Flavored” in the middle. TTB is usually more likely to allow terminology like Coconut Rum as compared to Coconut Vodka (partly on the theory that confusion could otherwise arise due to the fact that vodka could possibly be distilled from coconuts, but rum could not). No word yet on vodka distilled from peanuts.
Class & Type Must Stand Alone
In the above example, it is not sufficient to have VODKA on the front label. Or, the right size. In addition, it needs to be “separate and apart” from other matter. TTB has gotten more strict about this over the years. The above rejection is from a few days ago. The vodka label is from many years ago, to show the movement in the policy, or the enforcement of the policy.
TTB is quite concerned about word placement and proximity. For example, “absinthe” must appear next to other words, as here. Vodka may not, as above. It is important to understand the various proximity rules, because they can lead to unpleasant surprises, and because they extend from spirits to beer and wine. It is probably not okay to bury the word “chardonnay” amidst a sentence singing its praises. It is probably not okay, in most instances, to affix several words before and after BEER.
The rule can be difficult because it’s not always clear how much separation is required (A few spaces? A few line breaks?). It’s not always clear why some terms get treated differently (such as “Silver Rum” or “Cream Liqueur”). It is easy enough to add an extra class/type statement to the front label, to avoid any difficulties (such as adding VODKA to the above label, on its own line) — but only if you know the rule early enough.
Milky Wine with Hops (+ Fairies)
There is no shortage of things to be learned from wine labels. I must admit that, before seeing Moo Clu, I was without a clue about clurichauns, let alone how to party like one. The label and this site explains that clurichauns are like leprechauns but far more mischievous.
If you treat them well they will protect your wine cellar, however, if mistreated, they will wreak havoc on a home and spoil the wine stock. Occasionally [they] can be heard singing Irish folk songs in the wine cellars. The clurichaun is great to have around the house because he also protects your home from vandals and thieves. … They are impeccably dressed and well-groomed. … Except for a pink tinge about the nose, they perfectly resemble leprechauns in all their physical characteristics, but they never wear an apron or carry a hammer, nor do they have any desire to work.
Moo Clu is honey wine fermented with lactose, hops and natural flavors. Sometimes, it is a fine line among beer, wine and other beverages (such as kombucha, barleywine, etc.). Just as there can be a fine line amongst the various Celtic Fairies.
Toxic Libations
Has anyone tried these and lived to tell about it? Some people prefer the organic or biodynamic, Others, apparently, lean toward the toxic or deadly. It is nice to see TTB giving consumers some credit for being able to put things in context, and for recognizing that nobody will force them to buy either one of these products (unlike, say, health insurance or government).
Toxic Sludge is an ale made by Blue Point Brewing Company of Patchogue, New York. Jersey’s Toxic Waste, by contrast, is a distilled spirits specialty made by Strong Spirits, Inc., along with Line Brands of Long Branch, New Jersey. Michael Kanbar, of Strong, explains that Strong Spirits “is a contract bottling facility located in Bardstown, Kentucky, ‘The Distilling Capital of the World,’ and does both small and large runs and can handle specialty packaging projects.”
Beer with Style
On this label, the Nova Scotia heritage is pretty big and prominent. Even though the beer is made in downtown St. Louis.
The look is probably saved by the equally big reference to “style,” and the not so big reference to Missouri. Shock Top provides another example of the power of “style.” The label proclaims Belgian in medium-sized letters on the front label, and this is saved by the nearby reference to “style” — also on the front label of this other beer made in the middle of the U.S.
