In late 2018, the Occupational Safety and Health Administration's (OSHA) Denver regional office announced it would begin targeting safety and compliance inspections of breweries. The increase of inspections is a result of the Local Emphasis Program (LEP). LEP is an enforcement strategy designed and implemented at the Denver regional office to address the growing number of breweries in the Colorado area. It is intended to address hazards that pose risks to workers in the office’s jurisdiction. LEP will focus on beverage manufacturing and includes soft drinks, bottled water, wineries, distilleries, and ice.
Hazard Statistics In Beverage Industry
The focus on the beverage manufacturing industry by OSHA is likely due to the alarming statistics on the hazards of working in this industry. According to the Bureau of Labor Statistics (BLS), in 2014 workers in the beverage manufacturing industry experienced higher injury rates than the national average. This includes hearing loss cases five times the national average. Musculoskeletal disorders in soft drink manufacturing occurs at a rate of 108.1 per 10,000 workers, while the national average is nearly a third of the beverage industry at a rate of 31.9 cases per 10,000 workers.
Hazards Specific to Beverage Industry
Most citations the beverage manufacturing industry receives are related to respiratory protection, hazard communication, control of hazardous energy, medical services and first aid, and personal protective equipment. Workers employed in craft beverage manufacturing are subjected to unique and significant hazards specific to their industry. Workers are often exposed to chemical hazards from working with chemicals that are caustic and acidic. Ergonomic factors also contribute to the endangerment of the health and safety of beverage manufacturing workers. Other hazards include hazardous noise, lockout/tagout, process safety management, and permit-required confined spaces.
Lock Out Tag Out
Dangers from industrial trucks and ergonomic hazards are concerns when products are packed and shipped. The Bureau of Labor Statistics supports this by indicating transportation incidents and overexertion and bodily reaction have had a higher rate of injury than the national average. Larger manufacturing facilities present other dangers due to their automated processes. Lockout-tagout (LOTO) programs are required for these facilities. This is the practice whereby certain procedures are put in place to protect employees from unexpected startup of machinery and equipment that would place them in danger. LOTO programs differ from each other, but most include the following steps: 1) develop, implement, and enforce an energy control program; 2.) notify all employees that may be affected by the equipment being unavailable’ 3.) shut down equipment properly; 3.) use lockout device designed specifically for equipment; 4.) Verify the lockout; 5.) Document lockout/tagout periodically; 6.) Provide proper training to employees. Effective implementation of LOTO is likely to prevent violations of one of the most frequently cited violations, the control of hazardous energy standard.
Chemicals pose a significant risk in brewing manufacturing facilities. Chlorine and ozone are often used to purify water at bottling plants before flavor is added. Compressed ammonia gas is used for refrigeration. Strong alkaline and acidic chemicals are used as cleaners, as well as manipulating the pH of solutions in the fermenting process. The fermentation process used when producing alcohol also creates a variety of byproducts that includes carbon dioxide, ozone, and diacetyl.
Personal Protective Equipment (PPE)
Many of the chemicals used and produced in the production of beer require workers use the proper personal protective equipment (PPE) to minimize their exposure and prevent negative impacts on their health. PPE for workers in the beer production industry include work boots and clothing to minimize exposure of body to corrosive chemicals, hot fluids, and physical hazards. The use of goggles or specialized glasses is also necessary to protect workers’ eyes from the splashing of chemicals and debris.
The Denver Regional OSHA Office intends to implement its LEP program through outreach and greater enforcement. Employers will be informed of the program by letters advising them hazards in their industry and encourage OSHA consultation services. All breweries should be prepared for inspections. Inspections include a comprehensive review of health and safety hazards in the establishment. This includes the inspection of manufacturing processes, storage of chemicals, packing and shipping areas, electrical equipment, storage areas, and quality control labs. Complaints, reports of dangerous activities, and fatalities will also be inspected on the premises. Respiratory devices are also used to prevent the inhalation of dangerous chemicals like ammonia and chlorine. Devices likes gas masks are necessary in beer production because combustible dust is produced when wheat and barley are processed. The type and extent of PPE used varies depending on the hazards present, equipment used, job-description, and size of beverage production.
Colorado Is A Beer State
Colorado is one of the largest beer producing states in the nation. It produces 1,522,834 barrels of craft beer each year and ranks sixth in economic impact in the state. The Colorado Department of Labor and Employment stated there was 7,800 workers in the beverage manufacturing industry in 2016. The beverage manufacturing industry increased 40% between 2011 and 2016.
The beverage industry has grown steadily over the last ten years. Greater enforcement of OSHA standards will likely mirror the quantity of beverage producing companies in the state. If you are a beverage employer and would like more information on the LEP program by OSHA, call Whitcomb Selinksy PC to protect your business.