OSHA Violations in The Brewing Industry

As more craft breweries emerge and expand their workforces, employers in the beer industry are increasingly aware of their unique responsibility to protect their employees. The U.S. Occupational Safety and Health Administration (OSHA) requires businesses to comply with specific health and safety standards and imposes penalties on craft breweries for various violations. As a brewer, you have a responsibility to maintain the highest safety standards for your employees and customers.

Permits Required for Confined Space Entry

Breweries require personnel to clean and repair fermentation tanks, silos, mixing kettles, and mash wheels. These spaces are often small and, under OSHA regulations, could be considered confined spaces. Companies should inspect and test their workspaces to determine if any qualify as a Permit Required Confined Space (PRCS). If a PRCS is discovered, employers must warn employees.

The Right Approach

• Companies should inspect and assess their workplaces to determine if any spaces are considered permit-requiring confined spaces (PRCSs).

• Employers must identify potential hazards in PRCSs by providing warnings.

• If business operations require employees to enter PRCSs (e.g., areas of a brewery), the company must develop a written permit-requiring space plan. This plan should include monitoring atmospheric conditions within the space and developing emergency response plans.

• Employers must provide employees with appropriate training to prepare for PRCSs.

• Finally, employees should obtain an entry permit signed by an immigration officer before entering and/or working in a PRCS.

General Duty Clause

Brewers often transport heavy barrels, sacks of grain, and other raw materials. Because the Occupational Safety and Health Administration (OSHA) hasn't established specific ergonomic standards, breweries could be subject to penalties under OSHA's General Duty Clause, which requires employers to provide a workplace "free from known hazards that will or will likely cause death or serious injury."

How to Avoid This Violation

• Training - Employees need to be taught and reminded of proper lifting techniques.

• Invest in and provide appropriate tools and equipment (such as forklifts) for lifting heavy objects, and ensure employees are trained in their use.

• Consider creating a work schedule that allows multiple employees to share lifting duties. For example, if grain must be transported early in the morning, multiple workers can be assigned to work in shifts.

Process Safety Management of Hazardous Chemicals

To ensure a safe and healthy workplace, the U.S. Occupational Safety and Health Administration (OSHA) has issued the Process Safety Management (PSM) Standard for Hazardous Chemicals (29 CFR 1910.119), which contains hazard management requirements related to processes using hazardous chemicals. Companies are not only required to comply with the PSM standard but also to maintain appropriate documentation regarding the use and handling of any hazardous chemicals.

The complex chemical composition of the winemaking process inevitably includes a variety of hazardous chemicals subject to the PSM standard. These chemicals include carbon dioxide, oxygen, and ammonia, which are used to oxidize the alcohol and maintain its refrigeration. Additionally, winemakers may use a variety of alkaline chemicals for cleaning equipment.

Hazardous Energy Control

Lockout/Tagout (LOTO) violations are among the most common citations issued annually by the Occupational Safety and Health Administration (OSHA). Employers must follow specific LOTO regulations and procedures to protect employees from the accidental start-up of machinery and equipment.

How to Avoid This Violation

• Develop a LOTO plan to protect employees from all hazardous energy sources, including electrical, hydraulic, gravity, and thermal.

• Develop written procedures covering the control of hazardous energy.

Eye and Face Protection

Due to the small size of craft breweries, it's easy to overlook proper personal protective equipment (PPE), especially face and eye protection. However, the U.S. Occupational Safety and Health Administration (OSHA) frequently accuses brewery workers of violating PPE regulations by handling boiling water or toxic chemicals without proper equipment.

According to OSHA regulations, businesses must provide appropriate personal protective equipment to protect their employees. For breweries, this may include overalls, gloves, goggles, or full-face shields.

Comply with Regulations

Don't let negligence drain the time and energy you could use to grow your brewery. Make safety your top priority.

First, develop and document procedures that comply with current laws and regulations. Schedule employee training on these procedures and keep safety records up to date. Review your plan before new laws take effect and be prepared to update your procedures.

Stay Compliant

Remember to stay informed and comply with other relevant regulations:

• Alcohol Regulations: Any business that produces or sells alcoholic beverages must comply with national and state laws and any local regulations.

• Good Manufacturing Practices: Establish purchasing and production standards and quality management practices that comply with federal, state, and county regulations and standards.

• Environmental Impacts: Plan ahead to manage wastewater, waste disposal, and air emissions according to your local regulations to maintain compliance.