ATF Ruling 94-4

The Bureau of Alcohol, Tobacco and Firearms (ATF) has been asked whether heptane may be used as a substitute denaturant in lieu of toluene in Specially Denatured Alcohol Formula No. 2-B and if alpha terpineol may be used as a substitute denaturant in Specially Denatured Alcohol Formula 38-B.

Under the authority of 27 CFR 21.91, the Director, ATF, may authorize the use of substitute denaturants where the substitution will not jeopardize the revenue. Heptane is currently approved as a substitute denaturant for rubber hydrocarbon solvent in SDA Formula 28-A. Alpha terpineol has similar specifications to those of pine oil, N.F. XII, which is an approved denaturant for SDA 38-B.

Held: (1) Heptane, provided it meets the specifications described below, may be substituted as a denaturant for toluene, benzene or rubber hydrocarbon solvent in SDA Formula 2-B, 27 CFR 21.33, on an equal quantity (1: 1) basis.

Examples of the authorized uses of SDA Formula 2-B are (1) as a solvent in the manufacture of petroleum
products; and (2) as a raw material in other ethyl esters.

Specifications

1. Distillation range. No distillate should come over below 200ºF and none above 211ºF.

2. Odor. Characteristic odor.

Distilled spirits plant proprietors may produce SDA 2-B using the following formulations:

To every 100 gallons of alcohol add:

One-half gallon of benzene, gallon of rubber hydrocarbon solvent, gallon of toluene or gallon of heptane.

Held: (2) Alpha terpineol, provided it meets the specifications described below, may be substituted as a denaturant for any of the oils or substances currently listed in 27 CFR 21.65 for SDA Formula 38-B.

Examples of the authorized uses of alpha terpineol in SDA Formula 38B are as a solvent in the manufacture of mouthwash, colognes or

toilet water.

Specifications

1. Boiling point @ 752mm 218.8º-219.4ºC

2. Density @ 15º 0.9386

3. Refractive Index @ 20º 1.4831

Distilled spirits plant proprietors may produce SDA 38-B using the following formulations:

To every 100 gallons of alcohol add:

Ten pounds of any one, or a total of 10 pounds of two or more, of the oils and substances listed in 21.65 now including alpha terpineol.

For each article made with SDA Formula 38-B, manufacturers are required to list the denaturants used when filing ATF Form 5150.19, Formula and/or Process for Articles Made With Specifically Denatured Spirits. Therefore, manufacturers currently using SDA Formula 38-B who plan to use alpha terpineol are required to revise their formulas to reflect that fact and submit them to ATF for approval. However, manufacturers currently using SDA Formula 2-B who plan to use the substitute denaturant, heptane, are not required to file new formulas for articles.

27 CFR 21.33 Formula No. 2-B 27 CFR 21.65 Formula No. 38-B