I've actually seen a few of these wine loss events happen over the years at different wineries and definitely the bulk of the activity happens frantically as the scene originally unfolds. Cellar crew scrambling madly to catch the wine spraying out from the tank and re-direct it into another one to minimize the overall loss as much as possible. A pretty incredible event to watch to see the crew spring into action and coordinate their efforts to manage the chaos as best as possible.

But what about afterwards? After the frenzy has died down, wine gallons have gone down the drain, and the rest have been relocated into other tanks/vessels? Do you know what details need to be sent to the TTB to inform them of the wine loss?

There is a specific procedure that you'd want to follow in the event of a substantial loss resulting from the type of scenario I mentioned above. Just like your winery will file a claim for the loss with their insurance company you'll also file a claim with the TTB describing many of the same details.  They want to know because those wine gallons down the drain represent lost revenue to them & they want an explanation for that.

The TTB's requirements for submitting the claim form (form # 5620.8 by the way) are within 6 months of the accident. That's a pretty hefty time allowance if you ask me- which can tend to mean the longer you wait to file it the bigger the chances many of the details they require are forgotten.

Here are just some of those details:

• Full description of how the accident occurred
• Details of the wine in the tank, tank #, tax class/alcohol, wine blend, start gallons
• Volume of wine lost, volume of wine saved if any and where it went. (Into a new tank or put in with another blend)

​Essentially all of this information would come directly from a combination of your current inventory records plus the after details supplied to you by the cellar crew who were out there "in the spray" so to speak.

Unpredictable events like this because of their nature can leave wineries at a loss for more than just the gallons of wine. Not knowing that they need to also record and report it to the TTB makes sure they aren't caught at another loss by any inquiries from the TTB.        

Here's a link to the form :  http://www.ttb.gov/forms/f56208.pdf.     They also offer a tutorial for it on their website.

After you've relocated your AP to a new site and are planning to bottle some wine you may qualify to use one of your existing COLAs from wines previously bottled at your original AP location. (So in other words no need to submit a new label approval) Basically here are the steps to qualify for this:

(1) The new winery site you move your AP to must still be in the same state

(2) The label for the wine you are about to bottle must only have allowed changes to it. Here is a link to that list:

 http://www.ttb.gov/labeling/allowable_revisions.shtml

To give you an idea what this entire scenario might look like say you've recently relocatd your AP that was hosted at a winery in Napa to another winery also located in Napa. (FYI,yYou don't have to still be in the same city, just the same state) You are now planning to bottle the next vintage of a wine you produce each year. Take a look at the label you plan to put on that wine and compare it side by side to your already existing label approval from the last bottling. Look for any changes between the two. Take note of what those changes are and then see if any of them show up on that updated list from the TTB. 

Chances are you may be fine & not need to take the time to file for a new label approval, which these days can save you over a month's worth! (see the most recent info from the TTB on their label approval turnaround times: http://www.ttb.gov/labeling/labeling-resources.shtml

The TTB has already received closer to 70,000 label approval applications so far this year. They'd really like to shrink that number, and their most recent updates in allowable changes is a good one to be familiar with to help them do just that AND save both them & you some time in the process.

The class is Winery Compliance and Recordkeeping (VWT 275) and runs for 6 weeks on Monday nights from 7 til 10. Sounds like a fun thing to do with your summer right?!

But really- we'll be covering the A to Z of winery compliance, from getting a TTB permit to what records to keep, what reports to file, what taxes to pay and the details around labels and label approval. All of that in a QUICK 6 weeks. I've been teaching this class since 2006 and love the interaction that I get mixing with folks from across the wine biz: winemakers, enologists, cellar crew, lab techs, growers, tasting room staff, office staff, & general interested parities who show up in the room. 

So if you've been struggling with figuring out all that TTB stuff your winery is required to be maintaining, from weigh tags to work orders to completing the 702- then this class is for you. It's also for you if your're someone who has thought about getting into the compliance area of the winery business. Taking this class will give you a great broad overview of all the pieces in the process that wineries must be on top of- and you'll get a good idea whether or not it is a fit for your personality. (It really does take a certain type)

If you're wondering about more specific details on what the class covers- feel free to send me an email: ann@winecompliancealliance.com

Otherwise- I look forward to meeting next month and helping make sense of the maze-like world that compliance often is.