Top Six OSHA Violations in the Beer-brewing Industry
As more and more craft brewers emerge and expand their workforce, employers in the brewing industry are realizing their own unique responsibilities to protect their employees.
1. Permit-required Confined Space EntryBrewing requires personnel to clean and repair fermenters, silos, kettles, and mash turns. These are often small enough spaces to be considered confined spaces under OSHA regulations. Managers should assess these spaces to determine if they meet such guidelines.
If workers must enter a space that fits the definition of a Permit-Required Confined Space (PRSC) to perform their duties, employers must post warnings to inform employees and maintain a written permit-required space program. This program should include additional employee training, monitoring atmospheric conditions within the space, and establishing an emergency rescue plan.
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2. General Duty ClauseOSHA’s General Duty Clause is well known because it ensures managers provide a workplace “free from recognized hazards that cause or are likely to cause death or serious physical harm.” However, this also includes ergonomic hazards such as heavy kegs or sacks of grain.
Brewing managers can easily overlook the dangers of heavy lifting. In order to comply with OSHA regulations and protect their employees, managers should ensure workers are properly trained on correct lifting techniques, invest in lifting equipment (such as forklifts), and ensure lifting responsibilities are delegated to multiple employees.
3. Safety Management of Hazardous ChemicalsThe complex chemistry involved in the brewing process requires many potentially hazardous chemicals that fall under the Process Safety Management (PSM) of High Hazardous Chemicals standard. These chemicals could be carbon dioxide, oxygen, and ammonia in order to oxygenate the alcohol and properly refrigerate it. Moreover, brewers may use a wide range of basic or alkaline chemicals to clean equipment.
OSHA’s PSM regulations specify how businesses must safely manage these and many other highly hazardous chemicals. It is also important for companies to keep documentation on how these chemicals are managed and how workers are trained in the event of an OSHA inspection.
4. Lockout/Tagout (LOTO)Breweries need a lot of large, start-up machinery to mix, ferment, and carbonate beverages. Employees must be trained on how to prevent accidental start-ups and unintended releases of stored energy, which falls under OSHA’s LOTO guidelines.
Employee training is a crucial component of any brewer’s comprehensive energy control program. This LOTO program must also include the use of authorized energy control devices to lock or tag equipment so employees can easily verify if energy has been effectively isolated.
5. Hazard CommunicationHazard communication guidelines ensure employees are made aware of any dangerous substances or environments. This includes making chemical safety information easily accessible by labeling chemicals and identifying spaces that house hazardous chemicals. Breweries should include these practices in their hazard communication plan as well as training workers on how to properly monitor the presence of chemicals.
6. Eye and Face ProtectionBecause craft breweries are often small operations, it is easy to overlook proper Personal Protective Equipment (PPE), especially for face and eye protection. However, OSHA often cites breweries for PPE infractions when workers handle boiling water or toxic chemicals without the proper gear.
According to OSHA regulations, businesses must provide the right PPE to protect their workers. For breweries, this might include coveralls, gloves, goggles, or full-face masks.
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