Earlier today, the Brewers Association submitted responses to OSHA’s questions following the July 1 hearing on proposed Heat Injury and Illness Prevention regulations at which vice president of government affairs Marc Sorini testified. In summary:

• Brew kettles pose comparatively low risks unlike high-heat industrial heat sources. While some of the largest more sophisticated brewers may measure radiant heat directly, most brewers do not and instead only measure the radiant heat within their brewing systems.
• Regarding employee breaks, nearly all breweries have temperature-controlled spaces such as dedicated break rooms or public-facing taprooms. The BA suggests revising OSHA’s proposed “as needed” break language to a clearer, more objective standard based on sound industry practices and reasonableness. This would provide clarity and prevent a de facto strict liability standard.
• A mandated two-hour break schedule for very small breweries is not feasible as operations often hinge on one worker managing time-sensitive processes. Many members already rely on OSHA’s model safety plans, while larger breweries usually maintain proprietary ones.
• Breweries can reasonably monitor temperatures every two hours since temperature tracking is already integral to the brewing process. Most breweries rely on wall thermometers for indoor readings and online weather services for outdoor conditions.
• Most members have ice makers or freezers, especially those offering food service. Packaging-only breweries may not have these for food service purposes, but since they tend to be larger most would at least have an ice maker in a break room.

In conclusion, the BA and its members are committed to worker safety and welcome practical, industry-tailored guidance to help them accomplish that goal.

Read the BA’s Full Comments