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As a Consultant, I’m often asked what exactly I have to offer. My gut feeling is to say: “everything!”, but my therapist would probably push back on that.
Joking aside, I love this question because it has many different answers – I’m fortunate enough to work with nano-distilleries that produce 10 proof gallons per year all the way up to gigantic GNS plants outputting 100 million proof gallons per year. Having worked in DSPs as Lab Director and Production Manager, I had to wear many hats and solve lots of problems. Coupled with consulting for many years, I have gained relevant experience in almost everything that a beverage distillery can do.
And, if I can’t help you, I can certainly refer you to someone who is qualified and trustworthy. All referrals from Fx5 Consulting are uncompensated, so you never have to worry about a conflict of interest.
Still with me? Here’s some examples of how I help distilleries like yours every day.
Interpret and apply complex regulation to specific scenarios
If you’ve ever tried to read 27 CFR 19 independently, I’m willing to bet that you found it obtuse. Clear direction in the form of “you may do this, you may not do that…” is hard to come by. In many instances, you can only determine that something is prohibited by stitching together multiple different sections and definitions in the CFR. A great example of this is covered in another blog post, Can you “Keg” Ready-to-Drink Cocktails at a Distilled Spirits Plant?
Here’s a typical consulting inquiry: a DSP exports bottles to another country and then needs to receive some of the product back (e.g. due to product quality issues). They were trying to understand the tax ramifications of this transaction, and I was able to provide guidance that allowed them to move forward with confidence.
Another Import/Export question from a client led me to create a blog post: Are you reporting your Imported Spirits correctly?
After focusing on Distilled Spirits compliance for 6+ years, I have a good mental rolodex of the CFR. I can avoid pitfalls and common misinterpretations; I also know through experience which sections are actively enforced, and I can cross-reference and recite definitions off the top of my head. These hard-won abilities can save you time, money and energy, allowing you to focus on the more profitable and fun parts of running a distillery.
Audits
I’m often asked to perform an “Internal Audit,” which is generally an on-site, three-day project during which I examine your physical plant, your documents and processes, as well as interviewing staff and analyzing labels and marketing materials. The scope is wide and covers all aspects of DSP regulation, including state-level regulations if requested. At the end of an internal audit, I deliver a list of compliance concerns, in order of likelihood to be enforced by TTB. One of the many great things about working for FIVE x 5 is that I get to see (in real time) exactly what TTB is out there enforcing, because of our large client base and the open relationships that I enjoy with so many of you.
I’m also able to perform a “Mock Audit”, which is a more limited audit that mimics the sort of investigation/audit that a TTB Investigator might perform. These audits are based on actual TTB investigations from recent history, ensuring that they are highly relevant and timely. Mock Audits are performed on-site or remotely, depending on the scope and requirements.
You are worth every penny we pay you and more!
–An audit customer at a large GNS plant
Addressing past reporting and recordkeeping obligations
While TTB generally requires you to hold on to your records for 3 years, there is no relief from the requirement to file Monthly Reports of Operations and Excise Tax returns (annual, quarterly or semi-monthly). Even if you’re 7 years behind on reporting, you still have to file ALL of the missing reports (yes, this refers to a real situation). When contemporaneous records weren’t kept, figuring out what transpired at a DSP in the past is a challenging mix of forensic (liquid) accounting and attention to detail, informed by years of experience working in production and compliance at DSPs. Few people have these skills, but I’m proud to say, “I can do that!”
High-touch/Consultative Implementations
Let’s say you’re a large distillery – you’ve found some success with your brands and sales are starting to scale up. Your paper and spreadsheet-based tracking is creaking under the weight of increased complexity, while also trying to serve management’s need for accurate reporting.
It’s clear: you need to move to a bespoke distillery management solution like DISTILL x 5.
However, change management at larger organizations is a challenge. This is especially true for operations that have undergone employee churn – institutional knowledge and history gaps are difficult to address.
For any distillery needing a higher-touch level of software onboarding, we offer White Glove Onboarding through the Consulting department. While our standard onboarding focuses on building your DISTILL x 5 system and utilization training, a White Glove Onboarding allows you to leverage my years of experience in compliant operations to holistically analyze your entire operation (not just the parts that touch software) and identify compliance or operational shortcomings.
If you are confident that you are compliant with all TTB and state regulations, and you have good internal recordkeeping and procedures, you’ll be fine with standard onboarding. But for distilleries that have compliance deficiencies (or just uncertainty), a White Glove Onboard is a great choice because you can address those issues before they become a codified part of your business operations.
You undersold him and he overdelivered. Thank you for the recommendation.
– A Texas customer
Advocating for you – distillers!
Last month, the California Department of Tax and Fee Administration held a “Taxpayer Rights” meeting and solicited feedback on tax collection and reporting. I suggested some updates to the form and collection process that will significantly reduce the hassle associated with monthly filings for the 500+ distilleries in the Golden State.
On the Federal side, I found a typographical error in the Code of Federal Regulations (27 CFR 30.41) and the TTB is presently working on publishing the correction.
These are small things, but I’m very grateful to work for an organization that allows me to prioritize customer advocacy in this way and make iterative improvements.
Are you ready to talk? I offer free 20-minute consultations – book yours, today!
