TTB Online

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...

In recent weeks, TTB has implemented sweeping changes, with little attention from the media. Some of the changes are for the better, but many will make it substantially harder for beverage producers and importers to get things done. These changes will affect companies and products as profoundly as any other changes at this agency over the past few decades, no less than other big changes such as tax rates, the shift from ATF to TTB, the Part 13 revocation rules, the demise of caffeine alcohol beverages, or new Administrators. It is difficult to think of any law change or policy change with as much day-to-day impact on the regulated parties, and much of this was done with no opportunity for meaningful industry input.

1. The big changes begin way back in 2003, with the launch of COLAs Online, and pick up speed in the past year. Much of the change brought by COLAs Online is for the better. The system works well and frequently makes things faster and easier.
2. In late 2009, TTB slashed their availability for in-person visits. For many prior years or decades, it was relatively easy to meet with a regulator, in the labeling and formula division, any weekday from 10-noon or 1-3 (four hours a day). Beginning about...