Craft beer means good times – but that doesn’t mean that running a brewery is all fun and games. Making your brewery a safe place is good for your bottom line, great for your workers, and outstanding in keeping you in OSHA’s good books. Here are three of the most frequently cited OSHA violations in craft breweries and practical tips to keep your brewery compliant:
1. Confined Space Safety
Brewers often work within fermenters, mash tuns, kettles, and grain silos – spaces that fit OSHA’s definition of “confined spaces.” These areas have limited entry/exit points and aren’t designed for continuous occupancy, posing risks like hazardous atmospheres or engulfment.
How to Avoid Violation:
- Develop a written program: Implement a comprehensive “Permit-Required Confined Space” program. This should identify and evaluate potential hazards, outline atmospheric testing procedures, and include instructions for emergency rescue.
- Issue entry permits: Before any employee enters a permit-required confined space, ensure they receive and understand a signed entry permit from an entry supervisor.
- Provide thorough training: All employees who may enter or supervise entry into confined spaces must receive specialized training on safe practices, hazard recognition, and emergency procedures.
- Ventilate and monitor: Before entry, thoroughly ventilate confined spaces and continuously monitor atmospheric conditions for oxygen levels, flammable gases, and toxic substances.
2. Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147)
Maintenance and servicing of brewing equipment – from bottling lines to pumps and agitators – can be extremely dangerous if machinery unexpectedly starts up or releases stored energy. Lockout/Tagout (LOTO) procedures are designed to prevent such incidents.
How to Avoid Violation:
- Establish a LOTO program: Create and implement a detailed written program that outlines procedures for controlling all forms of hazardous energy (electrical, mechanical, hydraulic, pneumatic, etc.).
- Develop machine-specific procedures: Don’t rely on generic LOTO. Each piece of equipment should have its own written, step-by-step procedure for shutting down, isolating energy sources, and verifying de-energization.
- Train and authorize employees: Only authorized employees, trained in the specific LOTO procedures for each machine, should perform servicing or maintenance. All affected employees must also understand LOTO and the prohibition against restarting locked-out equipment.
- Utilize proper devices: Ensure employees have and use appropriate lockout devices (e.g., padlocks, hasps) and tagout devices (e.g., tags indicating who applied the lock). These devices must be standardized within the facility.
3. Hazard Communication (29 CFR 1910.1200)
Breweries utilize a variety of chemicals for cleaning, sanitation, and other processes (acids, caustics, sanitizers). OSHA’s Hazard Communication Standard ensures employees are aware of the chemical hazards they work with and how to protect themselves.
How to Avoid Violation:
- Maintain a written HazCom program: Develop and regularly update a written hazard communication program that details how your brewery manages hazardous chemicals.
- Ensure proper labeling: All chemical containers, including secondary containers like spray bottles, must be clearly labeled with product identifiers, hazard warnings, and the name and address of the chemical manufacturer or importer.
- Provide Safety Data Sheets (SDS): Keep Safety Data Sheets (formerly MSDS) for every hazardous chemical on site, readily accessible to all employees at all times. These 16-section documents provide critical information on chemical properties, hazards, safe handling, and emergency procedures.
- Conduct comprehensive training: Train employees on the hazards of the chemicals they use, how to read and understand labels and SDS, proper handling procedures, personal protective equipment (PPE) requirements, and emergency response actions (like first aid and spill cleanup). Training should occur upon initial assignment, when new hazards are introduced, and periodically as needed.
By proactively addressing these common OSHA violations, craft breweries can foster a safer work environment, protect their employees, and ultimately, brew better beer with greater peace of mind.
For more than 30 years, Beall Financial and Insurance Services, Inc., has been helping corporations and individuals protect their most important assets. The agency’s client base covers a spectrum of niche businesses, such as craft breweries, that require specialized insurance packages and knowledge. With offices in California and Indiana, Beall Financial and Insurance Services serves clients nationwide.