How Can I Keep my Craft Brewery Employees Safe?

When dreaming of brewing the best craft beer, you likely have not considered how dangerous the brewing industry can be. However, routine slips and falls, unsecured kegs, and strained backs due to heavy lifting are only the beginning of safety concerns. While popular belief is that Occupational Safety and Health Administration (OSHA) standards only apply to certain types of businesses, there are some minimum standards all companies must follow. Here are the top six OSHA violations commonly faced in the beer brewing industry and how you can protect your employees and avoid these violations.

Permit-Required Confined Spaces

Spending time cleaning, servicing, and maintaining the insides of fermenters, grain silos, masher tuns, and kettles is a typical daily or weekly activity for most breweries. These activities are also of great interest to OSHA inspectors. They frequently cite breweries for failure to provide safety guidelines and rules for those employees who work in these spaces. All confined spaces must be clearly labeled, so your employees do not accidentally enter a restricted area or space.

Employee Protection: 

Before entering a confined space, employees must receive an entry permit signed by the entry supervisor. In addition, these employees must obtain the necessary training before entering these spaces, and a written permit program must be available on-site.

If you can, remove any potential hazards from the area such as hazardous atmosphere, unnecessary objects, and/or chemicals.

General Duty Clause

OSHA guideline Section 5a1 requires employers to provide a workplace "free from recognized hazards that are causing or are likely to cause death or serious harm." As a result, brewers can receive a general duty clause citation for transporting heavy materials such as kegs, bags of grain, and other raw materials. 

Employee Protection: 

• Train your employees on proper lifting techniques.
• Provide tools and equipment to help employees lift heavy materials and train employees on how to operate this equipment safely. A lack of formal and practical training on this equipment can also cause a "Powered Industrial Trucks" violation and citation.
• Ensure the same employees are not always doing the heavy lifting.

Process Safety Management of High Hazardous Chemicals

There are several chemicals commonly used by brewers that are classified as highly hazardous chemicals by OSHA. This list includes ammonia (commonly used in refrigeration), hydroxide, nitric acid, and iodine-based chemicals. These chemicals can cause a variety of health issues such as irritation or they may be carcinogenic. They can also cause physical hazards such as corrosion or they are highly flammable.

If these chemicals are not properly controlled, the potential for an accidental release can create a disaster for employees and employers. Therefore, brewers must prevent or minimize the release of these toxic, reactive, flammable, or explosive chemicals.

Employee Protection: 

• Provide written process safety information (PSI) or have a material safety data sheet (MSDS) for each hazardous chemical. This sheet includes exposure health effects, employee protection, and spill/clean-up protocols. It also includes proper handling, storage, or use of the chemical.
• Train employees on these new or existing processes.
• Investigate and document any incidents involving these chemicals, retaining records for five years.

Hazard Communication

Not only do brewers need a safety plan regarding hazardous chemicals, but they also need to communicate to their employees about them and where they are kept.

Employee Protection: 

• Create a hazard communication plan making employees aware of any dangerous substances or environments within the brewery.
• Thoroughly label any chemicals and provide an MSDS to accompany each chemical.
• Train employees on controlling and monitoring chemicals appropriately.

Lockout/Tagout (LOTO) – The Control of Hazardous Energy

There are a lot of large start-up machines that are essential to the brewing process and these machines need regular maintenance and repair. Due to the fast-paced nature of many businesses, it is easy to cut safety corners in conducting maintenance and repair. However, cutting those corners leads to severe accidents and hefty OSHA fines. Therefore, take the time for safety.

When employees are repairing or working on these machines, shut them down and lock them out. It is essential to prevent accidental start-ups and unintended releases of stored energy. Moreover, during this shutdown, it is a good practice to check for unguarded machinery and run a quick overview to ensure all guards are in place and secure.  

Employee Protection: 

• Create a LOTO program, including authorized energy control devices to lock or tag equipment for easy identification and verification.
• Train employees on your LOTO program.

Eye and Face Protection

Over the last few years, there has been a considerable focus on using Personal Protective Equipment (PPE). It is the low-hanging fruit of OSHA citations and the easiest ticket to prevent. Although the focus has been mainly on the healthcare field, PPE is also essential to breweries. Many have received citations for the lack of proper gear for employees who handle boiling water or chemicals.

Employee Protection: 

• Provide employees with the correct PPE, including coveralls, gloves, eye protection, respiratory protection, face shields, and/or full-face masks.

These brewery OSHA safety violations can cause employee injuries and even deaths. While OSHA violations at breweries more than doubled between 2010 and 2015, recordable injuries and illnesses were on a downhill trend industry-wide. Incidents fell a drastic 22.5 percent from 2016 to 2017. In 2020, 2.1 per 100 brewery employees' nonfatal occupational injuries and illnesses were recorded. 

Knowledge is Power

There is a lot on your plate as a brewery owner and operator. Thankfully, many resources are available to help you on your process improvement journey. OSHA offers a small business handbook that contains a wealth of information, including self-inspection checklists and health and safety assistance for small business owners. In addition, the Brewers Association provides written programs and training to its members free of charge. You can find out more information on their OSHA resources hub.

There is Money in Workplace Safety

The costs of an injury are high. According to OSHA's Safety Pays program, a brewery operating at a 25 percent profit margin that experiences one laceration incident could expect:

• $21,872 for direct costs.
• $24,059 for indirect costs.
• $45,931 in total costs, thus requiring;
• $96,236 in additional sales to cover indirect costs, and
• $183,724 in sales to cover the total costs of the incident.

The minimum fine for a serious OSHA violation is $14,502 per violation. 

Make Safety An Investment

Just as your equipment, location, and talent pool are all investments you make upfront, so is the safety of your employees. A safety manager is a great way to ensure your employees work in a safe environment. Safety managers with manufacturing experience are well-trained in health and safety management. They can implement safety practices, advise on creating Standard Operative Procedures (SOPs), audit safety procedures, perform safety inspections on-site, perform training, and develop future Environmental Health and Safety programs. 

To reduce costs, consider hiring a safety consultant if you do not have the budget up front for a safety manager on your payroll. An occupational safety consultant will also have the manufacturing experience and know-how to get your safety program running. Consultants can also monitor your safety program and provide tools, direction, and training. Additionally, safety consultants have vast resources to help brewery operators manage and deal with health and safety issues that may occur at your workplace. 

How are you going to make great beer and comply with OSHA standards? Contact us at Beer Law HQ for a free consultation, and let us help you make the safest environment possible for you and your trusted employees.