Over the past decade, craft brewed beer has enjoyed a boom in popularity. Unfortunately, along with all that growth also comes growing pains in the form of OSHA infractions. The Occupational Safety and Health Administration, which holds companies accountable to certain health and safety standards, sites craft breweries for a variety of infractions. Here are six of the most common violations craft breweries have been cited for, as well as ways they can better adhere to OSHA’s safety standards:
1. Permit-Required Confined Space entry
Properly maintaining brewing equipment requires brewers to clean and service fermenters, silos, mash tuns and kettles. Many of these small, cramped spaces fall within OSHA’s definition of a confined space: large enough and configured in a manner that an employee can enter to perform work; limited or restricted means of entry or exit; and not designed for continuous employee occupancy. OSHA often cites breweries for their failure to adhere to safe and proper practices associated with entering and working in confined spaces.
- Companies should inspect and evaluate their workplaces to determine if any spaces are Permit Required Confined Spaces (PRCS).
- Employers must properly identify PRCSs as potentially dangerous by posting warnings.
- If business operations require employees to enter PRCSs, as in the case of some areas in a brewery, the company must maintain a written permit-required space program. Among other things, elements of the program should include monitoring the atmospheric conditions of the space and establishing an emergency rescue plan.
- Employers must provide employees the proper training for entering PRCSs.
- And lastly, employees should receive an entry permit, signed by an entry supervisor, before entering and/or performing work in the PRCS.
2. General Duty Clause
Under its General Duty Clause, OSHA mandates that employers provide a workplace “free from recognized hazards that cause or are likely to cause death or serious physical harm.” That includes ergonomic hazards — not surprisingly in a craft brewery it is often necessary to move heavy kegs or lift sacks of grain, so breweries that fail to mitigate the dangers associated with heavy or improper lifting are frequently cited under the General Duty Clause.
- Training, training, training — employees need to be taught and frequently reminded of proper lifting techniques.
- Invest in and provide access to appropriate tools and equipment — such as forklifts — for lifting heavy items — and ensure employees are properly trained to use them.
- If possible, consider setting work schedules so lifting duties can be shared by multiple employees. For example, if sacs of grain have to be transported early in the morning, schedule multiple workers to cover that shift.
3. Process Safety Management of Highly Hazardous Chemicals
To help ensure safe and healthful workplaces, OSHA has issued the Process Safety Management (PSM) of Highly Hazardous Chemicals standard (29 CFR 1910.119), which contains requirements for the management of hazards associated with processes using highly hazardous chemicals. Businesses are required to not only comply with the PSM standard, but also to maintain proper paperwork regarding the use and handling of any hazardous chemicals.
Hazardous chemicals (particularly concentrated) are used in breweries for cleaning, sanitation and other uses. Common chemicals include acids (lo pH), bases (high pH) and flammable chemicals. Basic, or alkaline chemicals, are often used for cleaning equipment, tanks and packaging materials. Examples include sodium hydroxide, sodium hypochlorite and potassium hydroxide. Examples of acids, often used for similar tasks, are phosphoric acid, hydrochloric acid, nitric acid and iodine-based chemicals. Both basic chemicals and acids are corrosive to human tissue and can be particularly dangerous to the eyes. Proper PPE is important to ensure a safe working environment. If it is required to enter confined spaces, such as entering tanks for maintenance, it is critical that a proper hazard analysis is performed to determine any potential exposure to residual chemicals, whether airborne or in liquid form.
In addition to these chemicals, carbon dioxide, oxygen and ammonia are used for a wide range of processes, ranging from oxygenating the wort to cooling the facility. One of the key gases to monitor is the refrigerant ammonia. Ammonia is an efficient coolant that is particularly well-suited for use as a refrigerant in food and beverage processing, so breweries rely on the chemical to keep their supplies cold. Because ammonia is classified as a hazardous chemical, it is one of several chemicals used by brewers that is subject to OSHA’s PSM rules.
- Conduct a process hazard analysis. According to OSHA, a process hazard analysis is a “thorough, orderly, systematic approach for identifying, evaluating and controlling the hazards of processes involving highly hazardous chemicals.”
- Develop written procedures for the safe operating and maintenance of refrigeration systems.
- And specifically, in the event of an ammonia leak, don’t assume the chemical’s distinct odor will serve as an adequate early warning signal. A fixed gas detection device can accurately measure the concentration of ammonia at a specific location and quickly alert workers of changes in air quality. When paired with a controller, fixed gas detection systems can even be programmed to automatically shut down operations if air quality reaches dangerous levels.
To read more about ammonia, its dangers,and how to properly equip employees to work with it, go to Dräger: Ammonia Detection.
4. The control of hazardous energy (lockout/tagout)
When workers are tasked with performing maintenance on brewery equipment, the accidental start-up of machinery or unintended release of stored energy can present serious risks. A common OSHA citation involves “lockout/tagout” (LOTO) — that is the practices and procedures necessary to disable machinery or equipment so as to prevent the unexpected startup or release of hazardous energy while employees perform service or maintenance activities.
- Develop, implement and enforce a LOTO or energy control program.
- As part of the program, designate a worker to turn off and disconnect machinery or equipment from its energy source(s) before performing service or maintenance.
- Authorized LOTO devices should be used to lock or tag equipment to verify that the energy has been isolated effectively and prevent the release of hazardous energy.
5. Hazard communication
In addition to ammonia for refrigeration, breweries use a variety of chemicals, such as cleaning agents and sanitizing solutions. To ensure chemical safety, information about the identities and hazards of all chemicals should be available and understandable to workers. OSHA’s hazard communication regulations govern the manner in which companies label chemical hazards.
- Breweries should develop a hazard communication plan.
- Chemicals should be labeled completely and accompanied by safety data sheets.
- Train employees on how to properly handle and monitor the presence of chemicals.
Eye and face protection
It may seem obvious that brewery workers should wear Personal Protective Equipment (PPE) when working around hazards such as boiling water or toxic chemicals. Yet OSHA commonly cites breweries for failure to provide proper PPE for their employees. In a craft brewery, proper PPE might include coveralls, gloves, goggles or full face masks.
- To adhere to OSHA’s standards, breweries should provide workers proper eye and face protection.
While the craft brewing business has a reputation for being hip and fun, skillfully operating a brewery of any size requires a high degree of process knowledge, training and sophistication. As the industry grows and becomes more mainstream, it will be important that brewers educate themselves and their employees on proper safety practices. In doing so, they will not only avoid OSHA violations, but also protect their workers from injury.