University of Michigan Tax-Free Alcohol Policy and Procedures Procurement, storage and use of Tax-Free 190 and 200 Proof Ethyl Alcohol I. Date: 1/30/07 Responsible Department: Contract Management Purpose This section outlines policy and procedures regarding the acquisition, use, storage, and control of tax-free ethyl alcohol on campus, in compliance with applicable regulations of the Internal Revenue Code. II. Policy A. Responsibility 1. Contract Administration is responsible for the acquisition and issuance of tax-free alcohol to campus departments. 2. Each U-M Department shall assign responsibility for control and issue of ethyl alcohol to no more than two persons (one is preferred). The department custodian shall maintain complete, accurate, up-to-date records of all alcohol received and issued. It is the responsibility to monitor, manage, and verify that its custodian(s) are following Internal Revenue Code procedures. B. Distribution 1. No issue shall be made of quantities that exceed the stated monthly requirement for a given user (using department). Requests for more than 25 gallons must be submitted in writing and approved by U-M DPS Fire Inspector and the U-M OSEH Department 2. Alcohol shall be used only on the premises and not be transported to any location other than a University building on a University campus. Document last updated: June 4, 2015 C. Storage 1. The using department shall provide locked storage space adequate in size and construction to provide adequate ventilation and in a suitable location. The storage space must be secured by a cylinder-type lock or a substantial padlock. The hinges must be recessed when the door is closed, or the hinge pins must be altered in such a manner that they cannot be removed. The key of this storage area must be in the sole possession of the person responsible for dispensing alcohol. 2. The “Conditions of Use of Tax-Free Alcohol,” Exhibit A, shall be posted in a conspicuous place within the locked storage area. 3. The U-M DPS Fire Inspector and the U-M OSEH Department are responsible to approve storage areas for tax-free alcohol. U-M DPS Fire Inspector and the U-M OSEH Department are responsible to notify Strategic Contract Management when storage areas are approved or denied. D. Use 1. Tax-free alcohol shall be used only for scientific, medicinal, and mechanical purposes. 2. Under no circumstances may tax-free alcohol be used for beverage purposes, or in any food product, or in any preparation used in preparing beverage or food products. 3. Departments are also prohibited from: a. selling tax-free alcohol, b. using tax-free alcohol in the manufacture of any products for sale, or c. selling any product resulting from the use of taxfree alcohol. E. Containers 1. The U-M DPS Fire Inspector and the U-M OSEH Department have limited the use of 5 gallon and 55 gallon containers of tax-free alcohol. Departments are encouraged to purchase one-gallon and pint containers. 2. Metal 5 gallon and 55 gallon containers are approved shipping containers for tax-free alcohol from the distributor. Plastic is no longer an approved container. Orders placed to the distributor after January 29, 2007 will be for metal containers. Document last updated: June 4, 2015 3. Plastic containers are approved shipping containers from the distributor for pints and gallons of tax-free alcohol. III. Procedures A. Authorization 1. Department Heads are responsible to designate a custodian(s) allowed to procure tax-free alcohol and to verify that the quantities requested, intended usages, and the custodian’s actions meet Internal Revenue and UM requirements. 2. Department Heads are responsible to monitor the purchases of tax-free alcohol charged to their departmental shortcodes and chartfields. If the Department suspects unauthorized purchases, the Department Head is responsible to contact Strategic Contract Management immediately and provide supporting documentation. B. Purchase 1. Ethyl alcohol is ordered from the University of Michigan’s designated Strategic Supplier. Current procurement procedures are posted in the supplier page. Departments must use the “U-M Requisition for Tax-Free Alcohol Form.” 2. Departments are required to verify all tax-free alcohol deliveries and sign for the shipment. Without signatures, the distributor returns the tax-free alcohol and the Department is billed for the tax-free alcohol. 3. A limited number of Departments and storage facilities are approved to order and store 55-gallon drums of taxfree alcohol. Written authorization is required from the U-M DPS Fire Inspector and from U-M OSEH Department before orders are fulfilled. If a lab passes inspection, the U-M DPS Fire Inspector and a U-M OSEH Representative will forward their approval to the Manager of Strategic Contract Administration. Document last updated: June 4, 2015 C. Effacing and disposal of alcohol containers Effacing of all alcohol containers immediately after emptying is required by Section 22.33 of the Code of Federal Regulations. Individuals responsible for the control of alcohol within the department must assure that each bottle, can, and carton is effaced in such a manner as to remove all traces of information pertaining to the contents. D. Record keeping Designated department custodians must keep a record of all receipts and disbursements of tax-free alcohol ordered, delivered to, used, and disposed of by their departments. Departmental records are subject to audit any time by request of Contract Management, Federal Internal Revenue Service, or other authorized University Departments. IV. References and Related Policies A. B. U.S. Code of Federal Regulations, Title 27, Part 22 U-M Standard Practice Guide Purchasing 507.01 – General Policies and Procedures Document last updated: June 4, 2015