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Jun 08, 2022 View:

Food Product

Ok all you scientific guys and girls out there here is the question. Is 95% ABV considered a food product or would it be defined as something else? If something else what would it be defined as? Here is why the question. Our local state boiler inspector told me that I could not have my steam come in direct contact with product. I inject the steam directly into my mash kettle, which we have been doing for the last 4 years. It seams there was a micro BREWERY south of me in Durango that was doing this but that product was of course not DISTILLED, big difference! I can see where anything in the water would still remain in the beer, but not if the beer or wash was then distilled removing almost all of the impurities. Coop


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to begin, "Is 95% ABV considered a food product or would it be defined as something else?". Our distillery is a registered food processing plant in addition to our fed/state DSP. however ,we just addressed a similar "situation" recently (actually, yesterday). In a nutshell, the issue was initiated by our liability insurance underwriter, and to abbreviate literally 5 weeks of back-and-forth, they were concerned with the life cycle of the 95% ABV product we had in our facility...(specifically tails and what we were doing with them beside distilling and drinking). In the end, the 95% ABV product is, by our insurance underwriter and subsequently the state DEP, considered a hazardous material because of the flammability, even though it's technically a food product safe for human consumption. They (the ins company and DEP) reached this conclusion by referring to the MSDS for concentrated ethanol. Because the term "hazardous material" entered the conversation, it reach an entirely new level of ridiculous, but i'll leave those details for another thread. Point I'm trying to convey, I'm afraid that due to the concentration of the material, there is a potential for your situation to leave the "food" realm and enter the "hazardous material/waste" realm which is accompanied by it's own set of in-stone regulations and sometimes mandatory minimum requirements....

second, the fact that a boiler inspector is injecting (no pun intended) his opinion into what is or isn't food safety is concerning, but also typical of government. This guy's "jurisdiction" is clearly dictated somewhere, he has an official capacity to inspect and regulate certain things, but not others. Is there a chance he's offering an opinion that may seem official, but in the end, is completely outside of his area? We too have a steam boiler (though not injected into the product), our first inspection took 20 minutes, he recommended a different style safety switch of some sort, then came back to reinspect and moved on. Point being here, are you sure this guy's opinion official and binding, or is he essentially talking out of his butt?

third, we walked down the path when exploring setup options that involved a large Bavarian Holstein system that included a steam injected mash tun. I was under the assumption, and seem to remember asking them specifically, if there was a special boiler required for injecting the steam created directly into the process material. This is completely based off of my recollection from over 5 years ago, but i thought for sure there was a special type of boiler or system that made this step "safe". I'm not sure I'd be so confident with just assuming the distillation would take care of any mechanical oils that could be transferred from the boiler steam to any product that's being made for human consumption

sorry for if my feedback is troubling, i'm looking forward to hearing from the field that there is ultimately nothing to worry about here.

Best of luck,

-Scott


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There are filters you can put on the steam line being directly injected that render this type of operation safe. We were required to have them and as I recall they are pricey.


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I imagine there are at least 2 grades of steam.

There is the stuff that goes around and around in a closed loop transferring heat from one place to another. This would slowly become contaminated with metal and oxides etc. You would not want to inject that into your product.

Then there is an open circuit where water is fed into a boiler and steam comes out, no recirculating.

What is the difference between this system and a hot water heater? I am sure your steam guy would say it is OK to add hot water, so why not steam?

What type of boiler do you have coop?


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At the bottom of this link, there is a food grade compliant steam filter. Couldn't you just put that in-line prior to your mash tun?

I think this is what Guy is talking about. Others I have seen are just as expensive and more. I believe the brewing guys use these for sanitizing kegs...or something.

Oh...almost forgot. I assume Vendome or Carl could tell someone what other folks are doing.


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Hello Pete, I have a low pressure Burnam steam boiler. 280000 btu input fired by natural gas. Simple system with 5 safety switches. Three low water cutoffs two boiler temp shutoffs. Mash Kettle uses 2 to 2.5 psi and my still uses about .25 to .4 bars.

I did not see the link for the steam filter John?


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I believe the main concern with direct steam injection is boiler feed water chemicals, used to protect the boiler some of these chemicals are very nasty , however there are food grade ones available or you can use indirect steam injection.


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Our water is the purest in the state. The only thing it contains is enough chlorine to satisfy health department. I have activated carbon filters to take out the un wanted chlorine. All from snow melt into the lakes then into the pipeline. Coop


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Ask him to cite which regulation he's referring to.... ask politely, and tell him that you want to make sure you comply. If he can't do it, you're in the clear.

All that you need is a simple cleanable steam filter from McMaster-Carr. They are indeed used for steam sanitizing kegs, John. You can't use a liquid sanitizer for kegs, so you just use a few pounds of steam before the beer is filled into the keg. The steam needs to be clean so that you don't get any carry over of salts. Think of what your blow down water looks like, and then imagine that gunk getting mixed with your beer.

Look here under "sanitary steam fliter", page 362. You'll want a Y strainer and a basket strainer upstream, and you'll want to disassemble and inspect the entire assembly at least monthly.

http://www.mcmaster.com/#steam-filters/=epbd3w

IMHO, coop, I'd put one in regardless of what the inspector says. If you have a unexpected change in the makeup of your water supply (and therefore steam), you could get some off flavors in your distillate.

Hope this helps.


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Thanks Todd, I was the town building inspector for 7 years in my past life. I have ask him to bring me code # and not just that paragraph but the entire section. There are always exceptions to each and every code depending on what you are doing. It makes no sense at all to me because after making the alcohol which I had analyzed =====you put water back into it. I also have a state water license along with a waste water license as I was also the public works director for our town also. Coop


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Hello Pete, I have a low pressure Burnam steam boiler. 280000 btu input fired by natural gas. Simple system with 5 safety switches. Three low water cutoffs two boiler temp shutoffs. Mash Kettle uses 2 to 2.5 psi and my still uses about .25 to .4 bars.


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No it does not Pete, I recirculate no steam at either my Still or my Mash Kettle. Steam from steam jacket on still never touches product just condensates and goes down the drain. Steam for mash kettle is injected directly in to cooking mash and becomes part of the total water in it. Boiler has a high and low limit shut off along with the other safety devices. Coop


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Pete, not to steal Coop's thread, but if the steam recirculates around the still and then goes into the mash, what's the problem with that?

Todd, do you use direct injection or a jacket?


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Combination of simple hot water for most mashing, and jacket for corn mashing. I don't like direct injection of steam for mashing. Too many potential negatives.


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Pete, not to steal Coop's thread, but if the steam recirculates around the still and then goes into the mash, what's the problem with that?


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For a simple open circuit steam injection what are some specific negatives?

As you may have noticed, on a different thread, I am considering a steam injection into a small continuous still.

As far as I know that how they all work!

What would Coop's inspector think of that?


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My still is not direct steam injection it has a steam jacket that surrounds the still, about 1/2 is jacketed. The bottom half of course. I have blow down drains on my still and it is both drained when cool and blown down under pressure twice a month. I do not think I would ever want a still that has direct steam mixing into my fermented mash as for sure heavy concentrated minerals would taint the alcohol. Especially if my water supply was from a ground water source. Like well water. The boiler inspector said sense my still was jacketed and no steam comes into contact with product it was ok the way it is. Coop


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Ask him to cite which regulation he's referring to.... ask politely, and tell him that you want to make sure you comply. If he can't do it, you're in the clear.

All that you need is a simple cleanable steam filter from McMaster-Carr. They are indeed used for steam sanitizing kegs, John. You can't use a liquid sanitizer for kegs, so you just use a few pounds of steam before the beer is filled into the keg. The steam needs to be clean so that you don't get any carry over of salts. Think of what your blow down water looks like, and then imagine that gunk getting mixed with your beer.

Look here under "sanitary steam fliter", page 362. You'll want a Y strainer and a basket strainer upstream, and you'll want to disassemble and inspect the entire assembly at least monthly.

http://www.mcmaster....filters/=epbd3w

IMHO, coop, I'd put one in regardless of what the inspector says. If you have a unexpected change in the makeup of your water supply (and therefore steam), you could get some off flavors in your distillate.

Hope this helps.


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For a simple open circuit steam injection what are some specific negatives?


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I agree Phil. There are many people on this forum that help a great deal. Todd, in particular, has been very helpful to me along the way. There are also several people that I also speak with off the site.


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so it seems that there are two types of steam injection:

1)www.pdhonline.org/courses/k109/k109content.pdf Pharmaceutical steam

2) http://www.pickheaters.com/pick_sanitary_heater.cfm Which I would call in-line injection or a sort of heat exchanger used to quick cook a product including a mash for spiritual work.

I would think that no matter what kind of physical filter you might put on the output of your "regular" boiler that it would contaminate the product...at least my steam is horrible smelly stuff

You might be able to use the heat exchange type of heater to create flash steam that you could inject directly into the mash.....this might be de-mineralized water to keep from building up calcium and other organics in the water or maybe using RO water as a source of "clean" water for steam to use as a fast heat source to steam out flavors in your Bavarian Holstein or Christian Carl....that's what that odd small diameter port is used for on the large diameter drain to "steam" herbals and such on the tray in your helmet....and/or to quickly bring the still charge to temp for conventional distilling....energy being much more costly in Europe than Texas or North Dakota.