Brewers and others concerned:
Purpose. This circular is issued to inform you about the notice of proposed
rule making published in the Federal Register for November 21, 1970, which
would amend the beer regulations, 26 CFR Part 245, with respect to beer meters.
Background. Industry Circular No. 68-31 discussed meter testing and encouraged brewers to make arrangements, subject to the approval by the Director,
Alcohol, Tobacco and Firearms Division, for meter tests by meter manufacturers,
testing laboratories, or other testing authorities. Certain brewers have
requested and received approval for such testing, and the results have been
satisfactory. Consequently, we determined it would be feasible to discontinue
the testing of brewers' beer meters by internal revenue officers and make the
brewer responsible for maintenance of the accuracy and reliability of his meters.
Approval of testing procedures. The proposed regulations would require
brewers to make arrangements for such tests, adjustments, and repairs as may
be required to maintain meters in such a manner that they accurately and
reliably measure and record beer metered for packaging and bottling. Also,
under the proposed regulations, the frequency of meter tests, and the equipment used and procedures employed in testing meters, would be subject to
approval by the assistant regional commissioner. The brewer would submit an
application which would detail the method by which it is proposed to maintain
the accuracy and reliability of each metering system to be used for the
measurement of beer, and list the make, model, and serial number of each
meter to be so used. If the assistant regional commissioner is satisfied as
to the adequacy of the proposed method and, as applicable, the reliability
of the testing authority, he will approve the application.
In anticipation that the proposed rule making will be adopted, it
would be to your advantage to start making arrangements for the testing of
your meters and having your test methods approved.
Meter tests. In developing your testing procedures, the controlling requirements for meter tests should be that the variation established by an approved
test is not greater than 0.5% (plus or minus), that meters are tested at
their normal operating rate of flow, and that this rate of flow is within
the rate and accuracy limitation of the test equipment.
Generally, meters should be tested by the comparative volume method.
However, comparative volume tests by use of a test meter would not necessarily
be required. The comparison of the meter reading with a volume determined
in an accurately calibrated (prover type) tank may, under proper conditions,
provide an equally acceptable means of volumetric testing.
Comparative volume tests of high speed electronic meters might be
conducted as infrequently as annually and be supplemented by more frequent
electronic circuitry tests, while lower speed positive displacement meters
should be tested at least once every three months unless experience has
shown these meters maintain their accuracy for extended periods of time.
Tests of electronic circuits, while basically similar, will vary as to
specifics with various makes and models of turbine and magnetic meters.
You may wish to consult with representatives of your meter manufacturer
in connection with proposed tests of this nature.
Tests might be conducted by State, county, or local testing
authorities; meter manufacturers; recognized testing laboratories;
brewer's personnel capable of making meter tests and meter adjustments;
and ocher persons. Your testing procedures should identify who will test
Inquiries. Your Assistant Regional Commissioner, Alcohol, Tobacco and
Firearms, will be glad to advise you in respect of any questions or
problems regarding the testing of meters and any other matter arising
in respect of the proposed regulations. Any such inquiry should refer
to this Industry Circular number.
Rex D. Davis,
Alcohol, Tobacco and Firearms Division