OSHA Violations in The Beer Brewing Industry

Confined Space Permit Issues

Violation Background

During the beer brewing process, employees are required to regularly clean and maintain equipment such as fermenters, silos, brewhouses, and mash wheels. These spaces are often confined and meet the definition of "confined space" under OSHA regulations.

Compliance Requirements

1.Space Assessment: Companies must inspect and test the workplace to determine if there are any permit-required confined spaces (PRCSs).

2.Hazard Warning: Employers must clearly warn employees upon discovery of a PRCS.

3.Written Plan: If entry into a PRCS is necessary, a detailed written permit plan must be in place, including

(1)Monitoring of atmospheric conditions within the space

(2)Development of an emergency response plan.

4.Employee Training: Employees entering PRCSs must receive appropriate training.

5.Entry Permit: Employees must obtain a signed entry permit from an immigration supervisor before entering a PRCS.

General Duty Clause Violations

Violation Background

Breweries frequently handle heavy raw materials, such as kegs and grain bags. Because OSHA has not yet established specific ergonomic standards, breweries may be cited for violations of OSHA's General Duty Clause.

Compliance Measures

• Employee Training: Teach and remind employees proper lifting techniques.

• Equipment Investment: Provide appropriate lifting tools (e.g., forklifts) and ensure employees are trained in their use.

• Work Arrangements: Create shift schedules so that multiple employees share lifting responsibilities.

Process Safety Management of Hazardous Chemicals

Regulatory Requirements

OSHA has published the "Process Safety Management of Hazardous Chemicals Standard" (29 CFR 1910.119), which requires companies to:

• Comply with PSM standards

• Maintain appropriate documentation regarding the use and handling of hazardous chemicals

Common Hazardous Chemicals in Breweries

• Carbon dioxide

• Oxygen

• Ammonia (used for alcohol oxidation and refrigeration)

• Various alkaline cleaning chemicals

Control of Hazardous Energy (LOTO) Violations

Violation Background

Lockout/Tagout (LOTO) violations are one of the most common citations issued by OSHA each year.

Compliance Measures

• Develop a LOTO plan that protects against all hazardous energy sources (electrical, hydraulic, gravity, thermal, etc.)

• Develop written procedures covering the control of hazardous energy sources

Eye and Face Protection Violations

Background of the Violation

Small craft breweries can easily overlook proper personal protective equipment (PPE), particularly face and eye protection.

Compliance Requirements

1.Provide appropriate PPE, including:

• Workwear

• Gloves

• Goggles or full-face shields

2.Ensure employees use appropriate equipment when handling boiling water or toxic chemicals

Comprehensive Compliance Recommendations

• Procedure Preparation: Develop and document procedures that comply with current regulations.

• Employee Training: Schedule employee training on these procedures.

• Record Updates: Keep safety records up to date.

• Plan Review: Regularly review your plan and update procedures before new regulations take effect.

Other Relevant Regulations

• Alcohol Regulations: Comply with national and state laws and local regulations.

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

• Environmental Impacts: Plan for wastewater, waste disposal, and air emissions management in advance according to local regulations.

By systematically implementing these safety measures, breweries can avoid OSHA violations and penalties while creating a safe work environment for their employees, protecting product quality, and safeguarding their reputation.