My Faith in Corporate Whisky – Restored……

Last week I was supposed to have done a tour to nearby Glenkinchie Distillery, but at the last minute the tour company advised they had to cancel due to the fact I was the only one who had signed up.

Last evening, sitting at my hotel desk writing a term paper on the use of Near Infrared Reflectance Spectroscopy as a tool to help malting companies, an email popped up advising that there would be a Glenkinchie tour today (Oct 13th).

Early this morning, I made my way into Edinburgh and found the tour office. Soon enough the bus arrived and we all boarded. The driver announced that straight away we would be heading to Glenkinchie – a Diageo owned distillery.

What ??????? Oh….no….here we go again I thought. I very nearly got off the bus and called it quits…My Blair Athol experience of earlier in the week was just that bad !

When we arrived at Glenkinchie we were met by our tour guide Gavin and sure enough there were the words I was dreading…” sorry folks, but this is a working distillery, so no cameras allowed…”.

But, Gavin turned out to be extremely knowledgeable and he had a very good presentation manner. And…he answered my questions – even the tough technical ones. At the end, there was none of the Blair Athol high pressure sales crap (as I encountered earlier this week) where you were more or less told what the dram of Scotch tasted like. Gavin was very good and he reminded us that we would all taste something different depending on our taste buds.

To that end…the Glenkinchie 12 year old aged in ex-Bourbon and finished in sherry butts gave me a great big beautiful face-full of fresh raspberries & black currants. Very nice!!

I went so far as to ask Gavin what Diageo products he enjoys when at home. His answer again was very forthright. He apparently drinks Dailuaine Single Malt and Benrinnes Single Malt. He have me a wee taste of both and wow! – I was hearing choirs of angels sing. Needless to say, a bottle of each is coming back to Canada with me. And no, I will not share if you come to visit. You can drink my home-made Bourbon aged 12 months in oak. I will take care of the 15 and 16 year old Dailuaine and Benrinnes.

As I was about to leave, I was introduced to one of the managers on site. I took the time to tell him of my miserable Blair Athol experience. I thanked him for being open with questions and I thanked him for a great tour. I asked Gavin for some corporate photos that I can use in my Workshops and presentations. I hope (fingers crossed, breath held…) that Gavin can find me some.

I am glad I went on today’s tour. My faith in Diageo has been restored. I look forward to visiting other Diageo sites on my next study trip to Heriot Watt in February 2018.

Oh…and by the way…the following photo is of Kinchie Burn, the wee creek from whence some of the distillery water is taken from.

Edradour Distillery – You Gotta Tour Here !

Spending a busy week in Edinburgh holed up in the Library at Heriot Watt University working on assignments for my M.Sc. program. But all work and no play is a bad thing, so I took the time the other day for a couple distillery tours.

Not wanting to get dragged around on a tour bus with other tourists, I contacted Paul Mclean at Mclean Tours and arranged for a private driver / tour guide. Costly? Yes. Worth it? Indeed – worth every pence that I paid. I highly recommend Paul’s company for distillery tours. If possible, ask to see if Andy is available to be your guide and driver.

Our first stop was Edradour near the village of Pitlochry. 30 years ago when I took up Whisky drinking in a serious way, Edradour was my first ever Scotch. I had a great time being toured around by tour guide John and he was very accommodating to me when he found out I was an M.Sc. student at Heriot Watt.

This tiny ( by current corporate standards) makes only 100,000 Liters a year. No wonder I cannot find it in Canada anymore. The mash tank is the old cast iron design from the 1800s. The lautered mash is cooled in a Morton chiller from 80 C to 18 C. The fins shown in the photo following have creek water flowing through them to act as the coolant. The fermenter is made of 3 inch thick Oregon Pine planks. No glycol cooling on this fermenter ! The ferments start at 18 C and at the peak of temperature, the tank is only at 32C, so no harm occurs to the yeast. Distillation is in 2 steps – a wash still run and a spirits still run, 3600 Liters size and 2100 Liters size respectively. In the Distillery Workshops I drive home the point that less surface area in a still allows more heavy molecular weight alcohol molecules to pass into the final distillate. These then take extra time to mature, but they also generate more flavor ( distillates in Scotland usually come off these goose neck stills at 68-70%). Contrast this to Canadian Whiskies where the distillates come off the still at 95%. This then demands the addition of artificial things to make the Canadian Whisky suitable for the customer to mix with Coke. ( I need to be careful here…I may end up wanting to work for one of these big boys when I get the M.Sc. done). But, I digress.

At Edradour, the distillate is aged in ex-bourbon and / or ex-Sherry casks. There is a limit to how often these used casks are re-used. And so there should be a limit, for wood only has so much wood sugar in it to help the Whisky. Again, contrast this to more corporate producers who re-use the casks many, many, many times over.

My favorite ( and I have some in my suitcase…) is 15 yr old, finished in Italian barolo wine casks. And no, I will not be sharing – so stay away !

After Edradour, we went 2 minutes up the road to Blair Athol Distillery. Owned by Diageo, this was corporate to the core. Everything our tour guide Jill uttered was carefully scripted – I dare say by the top dogs at head office. Photography was forbidden. My technical questions were avoided and evaded. I was dis-heartened to say the least. What would be wrong with a couple pics and a few straight answers to some serious questions. Anyhow, guess which Scotch I WILL NOT be bringing home with me!

This tight lipped, stuffy corporate attitude at Blair Athol really ruined my day. As I think about it more deeply, I suppose this corporate attitude is what is driving the craft movement around the world. So sad that the “suits” at head offices just don’t get it…

Anyhow, back to the Library now to do more research into yeast metabolic pathways and also beer spoilage microorganisms.

I plan to tour a few more non-corporate distilleries in February when I am back here. And – yes it will be Paul McLean and his crew that will be taking me around.

Cheers

When is Lactobacillus Your Best Friend ?

In the world of brewing and distilling, great care is taken to eliminate bacterial critters such as lactobacillus from pumps, hoses and tanks. Such bacteria will compete head to head with yeast for access to the fermentable sugars. The net result can be a reduced alcoholic yield and some weird off-flavors in the fermented beer or spirits wash.

But, lactobacillus can work in your favor. As I like to say, 80 million Germans cannot all be wrong. Nor can 50 million South Koreans!

Take the situation of cabbage. Cabbage naturally contains small amounts of glucose sugar (chemical formula C6H12O6). Cabbage also contains naturally occurring amounts of lactobacillus. Smash up the cellular structure of the cabbage and add a bit of salt to help the effort and the lactobacillus will start to feast on the available sugars to generate sour lactic acid. The process will be slow, perhaps a month or more in duration.

The net result will be soured cabbage. The Germans call it sauerkraut, the South Koreans call it kimchi. In the German case, often some caraway seed is added for extra flavor. The Koreans add hotter stuff to give kimchi some zip. In addition. this anaerobic lactic acid fermentation can generate some unique esters which provide additional flavor and aroma.

The process is very simple. Get some heads of cabbage from the local farmers market. Remove the outer leaves. Shred the cabbage on a mandolin ( I bought mine at Wal Mart). Using a piece of wood ( I used a wooden axe handle from the hardware store), stamp, tamp and otherwise smash the cabbage to break the cellular structure. As you do this, add salt (I only use seal salt) and caraway seed to taste. Once done smashing and seasoning. place a plate on top of the shredded, seasoned mess of cabbage that you have in a pail ( I used an old stock pot ) and weigh the plate down with a heavy object ( I used the lid from my cast iron casserole dish). Leave in your garage for about 30 days. You can check it every week of you wish and you will start to notice the familiar scent of sauerkraut developing over time.

After 30 days, place the sauerkraut into glass jars and keep in the fridge for up to 4 months. You can freeze it of you wish, but doing so will kill off the lactic pro-biotics which are beneficial to your health. When I eat the kraut, I do not cook it as I do not want to damage the pro-biotics. I heat it very gently to warm it only.

So, there you go…..lactobacillus can be your best friend. Happy kraut-making !

Alcohol – now a commodity item

This week I had the distinct pleasure of touring the North West Bio Energy ethanol plant in Unity, Saskatchewan.

The raw material used is wheat and the wheat is ground in a disc mill to a fineness not too far different from what any craft distiller would use. But, that was where the similarities ended. The plant employs 4 mash / fermentation vessels that are each about 400,000 Liters in volume (yes you read that number correctly !!). The yeast used is a specially cultured strain of S. Cerevisiae similar in many ways to what craft distillers use, except this stuff spins off daughter cells faster than normal which means a 36 hour ferment will consume all available fermentable sugars in the mash tank. The contents of a completed mash are transferred to a beer well holding tank which feeds the distillation process. The distilling is accomplished by way of 8 columns and the net result is 96% ethanol. In fact, some 75,000 Liters a day of ethanol. The vast majority of this product gets sent to gas refineries. The next time you pull up at the pump and the label on the pump says this gasoline may contain up to 10% ethanol, now you know where the ethanol comes from. To produce fuel grade ethanol, the 96% stuff is passed through a molecular sieve to remove water and make it 99% ethanol. More and more, North West Bio Energy is sending 96% ethanol to custom blending and bottling plants in the USA where it is proofed to 40% and bottled under the guise of “craft distilled” Vodka. There is one plant in the USA that is doing work similar to the one in Unity and it is owned by MGP Products in Lawrenceburg, Indiana. You like Tito’s Vodka? Well, it is just 96% ethanol from Indiana. You like Ketel One? Yep – Lawrenceburg, Indiana. In Canada, you like Banff Ice Vodka? Yep – Unity, Saskatchewan. You like Highwood Rye Whisky? – which Highwood proudly says is based on Wheat distillate with Rye blended in. Yep – Unity, Saskatchewan.

We have now crossed the rubicon as it were, the point of no return. Alcohol is now a commodity and the spoils of victory will go to he who can make it cheapest. Want to be a craft distiller? Go ahead…bust your ass grinding grain and cooking mash. Some guy down the street is going to start making Vodka using the distillate from Unity, Saskatchewan. While you are too busy to get out and sell your product because you are enslaved to a mash tank, the guy down the road who is using Unity’s distillate will have plenty of time to get out and sell his product. In this commoditized game, he wins, you lose.

For the past several years, I have taken a hard stance against craft people who use NGS. But, even crusty old stalwarts like me can soften up. Thanks to this week’s tour of Unity, Saskatchewan I have now come to accept the commoditization of alcoholic spirits. I don’t necessarily agree with it, but I now accept it.

Each month I hear the same mis-guided enthusiasm from people in our Distillery workshops. They say ” yep – gotta make Whisky, Gin and Vodka!!”. My message to them is now going to be made more clear. Whisky, Gin and Vodka are commodities. If you want to be a craft distiller, you need to make variations of these products that are not currently and may never be commoditized. And that is fodder for a future blog post…

Barley – 2 Row and 6 Row

Brewers and distillers will find themselves most likely using 2-Row malted Barley in their beer or spirits making efforts. But there is another type of barley called 6-Row and it is still available to use, although it is sometimes difficult to source.The question that then arises is, what is the difference between 2-Row and 6-Row barley? The answer can be found by learning about the plant physiology of barley. As the barley plant begins to sprout and emerge from the soil, it starts to develop a stalk from which leaves form. This formation then leads to the ear structure forming. The central component in the ear is the rachis. Along the shaft of the rachis are nodes. From each nodal point, 3 spikelets emerge. The nodes behave such that if a grouping of 3 spikelets form on the right side of the rachis, then the next group of 3 will form on the left side. And so on, and so on. Generally the middle node is the fertile one and will produce a fruit (called a barleycorn). This means that at each grouping of 3 spikelets there will be one kernel of grain. Due to the alternating pattern of the spikelets, this will give a kernel on the left and right side of the rachis. This is a 2 row barley. If all 3 spikelets are fertile, then you will get clusters of 3 kernels on each side of the rachis. This is what is termed a 6 row barley. The following diagram taken from the Powerpoint slides I use when delivering Distilling Workshops illustrates the above concepts. If you can find some 6 row barley, give it a try in some beer or in a mash for spirits distillation. It has a slightly different taste profile than 2 row owing to slightly different lipids (fatty acids) in the outer layers of the kernel.

The American 3-Tier Alcohol System

Here in Canada, craft distillers are lucky in that in most jurisdictions you can hand-deliver a case of your product to pubs, bars and restaurants. Not so in America where the 3 Tier system dictates that the craft distiller must pass his product to a wholesaler who in turn places the product with retail end users.

Buy why? Where did this all come from? I recently stumbled upon a white paper that explained all that to me. In a nutshell – it goes like this.

In the 1930s, when it became apparent that President Roosevelt was intending to repeal Prohibition, one John D. Rockefeller moved swiftly. Rockefeller was a tee-totaller and very opposed to the evils of drink. He used a sum of his own money and hired two people to compile a report on how to control alcohol. The report was ultimately titled “Toward Liquor Control”. The two people whom he hired to write the study were Raymond Fosdick and Albert Scott. Together they traveled across the USA, across Canada and through Europe talking to Governments about alcohol.

Rockefeller then used his influence in Washington to make sure politicians read the report. What emerged from his efforts was the 3-Tier system of liquor distribution. Such is the Rockefeller influence.

Throughout the ensuing decades, this report has come under fire and the 3-Tier system has been challenged in law courts. The argument most often used in courts was the Commerce Clause in the US Constitution. However, in the case of alcohol, the social bias adopted by the judges on benches was one of – let’s not treat alcohol as a commodity that is freely and openly traded. The Commerce Clause was regarded as “dormant” in the case of alcohol. All of this came to a head in the 2005 case of Granholm v. Heald. The Supreme Court ruled that individual States cannot offer special treatment to craft wineries. This line of legal thought has now been extended to craft distilleries by the look of it. In other words – if it is good enough for ABC Craft Distilling then it also applies to Jack Daniels and Smirnoff and all the other big boys. This explains why some States are so reticent to ease up on arcane restrictions that are hobbling craft distillers. They can’t ease up and give special treatment to craft for fear of being off-side re: Granholm v. Heald.

Get set for more challenges though. The big commercial distillers are intent on getting their product into big box stores (Wal Mart, Costco etc..) without going through the 3-Tier wholesaler middleman. The big boys want distilled alcohol to trade like a commodity item, not like the socially abhorent demon drug that it is made out to be now.

You can be rest assured that right now some lobbyist is having dinner with some politician in Washington and the 3-Tier system is being discussed. I am not sure what will happen to craft distillers if the big boys can somehow sidestep around the 3-Tier system and get product into big box stores cheaper. The Wal Mart model for everything from floor cleaner to cans of tomato sauce says that when things trade like commodities usually the small maker of said products gets squeezed pretty hard.

Booze-Infused Ice Cream

Looking for a unique treat to see you through the rest of Summer? How about booze-infused ice cream?

Here is the procedure I followed recently to make my own.

In a small bowl, collect the yolks of 3 eggs. Add some sugar to this bowl. I used 3/4 of a cup, but you can reduce that if you wish. Mix/whisk the contents of this bowl together.

At my local grocery store, there was coconut milk in cans from Thailand. In the refrigerated section they also had larger containers of what they were calling Coconut Beverage – which to me looked like coconut milk, so that’s what a bought. Besides it was cheaper in price…

In a saucepan on the stove, add 2 cups of Coconut Milk/Coconut Beverage.

To the saucepan add 1 cup of Half & Half cream.

Add 1/2 tsp Vanilla

Toss in a wee pinch of salt.

Slowly heat the saucepan. As the liquid gets warmer, take a few Tablespoons of it and add it to the egg/sugar bowl. This is called “tempering” and serves to slowly raise the temperature of the yolk/sugar mix to prevent the yolk from cooking.

Slowly dribble the warmed, tempered yolk/sugar mix into the heating contents of the saucepan. All you are looking to do is bring the saucepan to a low simmer (not a boil). Stir frequently as the saucepan heats.

At the simmer point, turn off the heat and place the saucepan in the fridge to cool.

Once cooled, add 5 Tablespoons of your favorite booze. I used some coffee / maple syrup Moonshine I had sitting on my shelf. Stir well.

Now, place the saucepan in the freezer. Every 30-45 minutes, open the freezer and stir the contents of the saucepan. After a couple hours, you will notice that the liquid is starting to set and firm up.

After several more hours, it will indeed have set up and you have booze-infused ice cream. No fancy ice cream making machine. Just a bowl, a saucepan and a freezer. That’s all !

If you are looking for a creamier version, consider using more cream and less coconut milk.

Enjoy !!

Has the Bubble Burst ?

In the 5-day distilling Workshops, I like to show the parabolic growth curve of craft distilling start-ups. I repeatedly caution that as a former stock broker, I am wary of things that go parabolic. I point out, usually to glazed-over eyeballs in the room, that the cheap-money, stupid-money Central Bank policies of the current time are fueling all things parabolic. Back in the 60’s and 70’s we had various fads. Today, fads have been replaced by short term parabolic bubbles all fueled by easy credit. With the stroke of a pen right now, I could mortgage my house. With one phone call I could drain my investment accounts. With that money in hand, I could easily find some flimsy financial institution to lend me even more. I could then go on to launch a craft distillery. Experience? Recipe development? Marketing strategy? Hell – who needs any of that when you have a bagful of money!

I am not then shocked to see on average two craft distillers a month in the USA going under. I watch the discussion forums on-line and it pains me to see people obviously going through angst as they liquidate equipment and even barrels of product. The bubble has burst. The wave has crashed over the bow.

So what to make of it all?

My message is simple. A bursting bubble is a good thing.

Remember way back in the 90’s when the Nasdaq tech bubble broke? Did all tech firms go under? No – they did not. The smart ones actually benefited by acquiring the assets of the failures. Remember the 2008 sub-prime mortgage implosion? Remember the more recent oil price implosion? In both these cases, the smart players who saw the trend changing were able to capitalize on the failures of the weak players.

And so it shall be with craft distilling.

Thinking about starting a craft distillery are you? Good! Now – relax and take a breath. Your timing is fortuitous. The urgency for fast action is off.

Take the time to develop recipes. Take a 5 day course! Take the time to develop a sound marketing plan and brand image. Look for used equipment that is being liquidated. Even if you have to store it for a while somewhere – no worries. The craft beer brewing movement went through a multi-year pause in the late 90’s as the first parabolic wave broke. Then, the marketplace caught up, the consumer became more savvy and a new phase of growth unfolded.

I suspect we will see something similar in craft distilling. There will be now a multi-year pause in net numbers of craft distilleries. Th weaker players with their poor recipes, poor websites, poor brand image and inferior equipment will be flushed away like grain kernels down a floor drain. But, the strong will survive. The consumer will catch up and eventually a new growth wave will unfold. To those aspiring new entrants that properly prepare for this new wave – the benefits will be many. It is just unfortunate that so many rushed in so fast on this initial parabolic wave and are now getting hurt. But, such is the nature of our fast money, stupid money economy. As the old saying goes….caveat emptor.

Craft Distilling – What is It?

In the 5 Day Distilling workshops that I am involved with, I waste little time on Day #1 in posing a philosophical question to the class. The question – “What does it mean to be a Craft Distiller?”.

As the week progresses, answers slowly start to materialize. By week-end, the consensus emerges that a Craft Distiller is a person creating something unique that a customer typically would not find on offer from one of the big, multi-national purveyors of distilled spirits.

This inevitably then leads to the very tricky subject of commercial alcohol or as it is often called Neutral Grain Spirit (NGS). Are you a craft distiller if you make use of NGS that comes from a large ethanol distillery such as Commercial Alcohols in Tiverton, Ontario or Western Bio-Fuels in Unity, Saskatchewan? Tough question.

Various Provinces in Canada have already dealt with this issue, while some have given it a wide berth. British Columbia, for example, says to be a craft distiller you must manufacture your alcohol from B.C. grown agricultural goods. So – that’s pretty clear. NGS is not allowed at the craft level. Alberta has placed a limit on how much NGS a craft distillery can employ and I do reckon that amount to be 20% of your distillery output. Manitoba and Ontario have also placed similar limits. Quebec allows for exclusive use of NGS to make craft distilled products, although they are now tightening the noose as it were with tax incentives to those who manufacture their alcohol from Quebec grown agricultural produce. The Maritime Provinces to the best of my knowledge do not have clear policies yet on the use of NGS.

And this brings us back to Saskatchewan where I continue to draw fire from the craft community for comments I leveled a couple years ago in which I made it clear that I was opposed to the use of NGS at the craft level. In fact, it seems fair to say that I am downright reviled in Saskatchewan for this NGS position. Good thing I have thick skin. You see, Saskatchewan allows for the full use of NGS by craft distillers. What prompted this policy shift, I do not know and I doubt that I will ever be enlightened on the matter by the good folks at SLGA.

I also seem to be drawing heavy artillery bombardment of late from one particular craft distillery in Saskatoon for my open encouragement that people contemplating becoming craft distillers ought to practice making alcohol at home first. This is a position that I will not recant any time soon. The irony of this situation is the image on the front cover of my self-published textbook that I use in my classroom teachings bears the image of this very distillery! This book continues to sell all over the world and thus de-facto is providing free, very positive, publicity to this distillery. I even use products from this distillery in my classroom tastings and people comment very warmly on how well their products taste. Maybe it is time for a change of artwork on the textbook cover? Maybe time to revamp my tasting lineup?

I have seen far too many people rush out of the 5 Day Distilling Courses and dive off the deep end of the pool. They end up buying sub-standard equipment and in many cases wrong equipment. And what’s worse, they end up producing sub-standard spirits that verge on undrinkable. What’s even more troublesome, they quickly find that they have amassed huge debt-loads and are faced with an uncertain financial future. Had these folks followed my advice and actually done some home experimentation, they very likely would have discovered that distilling was not for them. They could have avoided the precarious debt position they now find themselves in. On the flip side of this argument, those that have taken the 5 Day Course and have actually taken the time to play at home on a small still are now off to a glorious start producing some top-shelf products.

But – back to the main topic of NGS. I continue to grapple with the NGS question here in this Province that allows for its exclusive use. I have watched other jurisdictions and lobby groups also grapple with the issue. I have taken careful note as to how others have dealt with this thorny issue.

After much thought and careful consideration, as of here and now I would like to go on the record as saying… I am content with the use of NGS or any other 3rd party alcohol provided that the craft distiller in question makes open, honest, transparent explanation (when and if asked by a customer) as to the use of such alcohol. A little bit of open transparency won’t hurt you – will it? Explain to the inquiring customer that although the alcohol may have come from somewhere else, you the craftsman have taken it through additional processing steps and even some carefully created flavor formulation steps to produce a product that is otherwise unavailable from the big multi-national players. Keep the customer educated, and they will develop brand loyalty towards you and your craftsmanship abilities.

I would also like to go on record as saying…it is my strong wish that the regulators at SLGA take a page from the Quebec (RACJ) playbook and extend a small tax incentive to any craft distiller who manufactures alcohol from locally grown materials With the precarious budget situation in Saskatchewan these days, I am not holding my breath waiting for such a policy change. But – no harm in asking for it…

Readers of this blog post are invited to call me directly to openly and transparently discuss any of the above comments and positions.

Rum – Sidestepping the Canadian Definition

In the 5 Day Workshops I assist with at Urban Distilleries in Kelowna, BC we spend a chunk of time digging into the legal definitions for the various spirit types. For example, Rum is defined as being made from sugar cane and its products (ie molasses) and aged in small wood containers (less than 700 Liters in size) for 1 year. Obviously placing any distillate in a wooden cask will cause a coloration change in the distillate. So how then is White Rum created? My answer used to be that in all likelihood the casks being used were very old and quite spent. Any trace amounts of color change were then filtered out prior to bottling. But, I have found a more elegant way and Captain Morgan White Rum (marketing tagline = finest Caribbean Rum) is an example of this lawyer-assisted elegance. Captain Morgan appears to have sidestepped the CRC section 870 definitions and leaned towards the 2005 Spirit Drinks Trade Act. This Act says that if one imports Rum distillate from a Commonwealth Caribbean nation and blends it with other Rum distillate from another Commonwealth Caribbean nation and then proofs to a drinkable strength with water, the resulting product can be called Caribbean Rum. No mention of 1 year of aging is there? And what about the White Rums ( ie Lambs) that do not bear the moniker “Caribbean” but are White nonetheless. Sure, maybe these Rums are passed through old, spent casks. But, I have found a clever way to sidestep the issue here as well. The USA Rum definition is similar to that of Canada, except nowhere in the USA definition is there mention of aging in a wooden cask. So, if I were seeking to make White Rum for sale in Canada, I would distill it in the USA and proof it to a drinkable strength. My Canadian corporate entity would then bring the product into Canada. Simple.

I find it sad that our legislation has so many loopholes that favor the large corporations. I further find it sad that we have the CRC 870 definitions and the 2005 Spirit Drinks Trade Act working at cross purposes to each other. I would be curious to see what would happen to a small micro-distiller who tried to emulate the above described tactics being used by the big corporations. I somehow doubt all would end well. It is time in Canada to clean up and rectify the definitions. As I am on record as saying – I like the USA definitions in 27 CFR Chapter 4. They are clearly stated and there is no ambiguity. This framework is a good starting point for a Canadian definition overhaul.