Colorado’s Federal OSHA office has announced it will begin targeted safety and compliance inspections of breweries beginning October 1. Visits will occur in 38 of the state’s 64 counties.
Breweries aren’t alone; other alcohol producers and soft drink businesses will be inspected in this Local Emphasis Program (LEP). The LEP is based on an uptick in employment numbers and injury/illness statistics across the sector.
Colorado breweries have been hearing about this LEP for over a year from the Colorado Brewers Guild, the Region VIII Federal OSHA office, and OSHA Consultation Services at Colorado State University.
We Eat First with Our Eyes…And So Do OSHA Inspectors
Here are a few suggestions that will set the right tone for an inspection. This list is based on known concerns for all breweries and previous Colorado OSHA inspections, but it is not a comprehensive list.
1. Assign a Representative to Meet the Compliance Officer
- The person should be knowledgeable about company safety policies and programs
- The person should know where to find training documentation
- The person should know the company’s rights during inspection
- Keep floors free of tripping hazards, puddles and clutter
- Stow tools and equipment when not in use; keep staircases clear
- Make sure storage areas are orderly; no heavy objects on walk-in cooler ceilings
3. Emergency Preparedness
- Have a first aid kit stocked and easy to access
- Have an emergency shower and eyewash easily accessible
- Have fire extinguishers and escape routes well-marked
4. Hazard Communication (HazCom)
- Ensure that your Safety Data Sheets (SDS) binder is up-to-date, visible, and available
- Have workers trained in correct handling of chemicals in use, including written documentation of training
- Make sure your brewery has a Written HazCom Program (Simple Template)
- Organize your chemical storage: have legible labels, with like stored with like, and spill containment
5. Personal Protective Equipment (PPE)
- Make sure PPE is in use and appropriate for tasks
- Confirm that PPE is properly maintained, stored, inspected, and replaced
- Focus on protection for eyes, hands, feet, and skin, plus hearing protection if noisy
6. Confined Spaces (CS) and Lockout/Tagout (LO/TO)
- Confirm that vessels are not entered unless you have either a permit program in place (fermenters, BBTs), or you have established written reclassification for brewhouse vessel entry
- Make sure your brewery has a Written CS Program
- Double check that LO/TO equipment and Energy Control Procedures (ECPs) are in use
- Ensure that your brewery has Written LO/TO Program (Minimum Standards), (Program template)
- Certify that they are only being operated by trained/certified operators
- Have training documentation on hand
(MORE: Best Management Practice for Surviving an OSHA Inspection)
Get Expert Advice
OSHA Consultation services are available through Colorado State University. Several breweries have reported consultation to be very helpful, and there may be time before you experience an inspection to receive these free services. Learn more.
The Brewers Association recognizes safety as a core value which increases worker health and well-being, improves quality, and reduces the cost of operation. Since 2013 the Safety Subcommittee has provided safety educational resources open to all.
Additional resources, including free, on-line brewery safety training and archives of past Craft Brewers Conference safety presentations.
Make Every Day a Safe Day.