Safety on Tap! – Part 3

Safety on Tap!
Chapter 3 – Confined Space Safety
By Terry Botts
Occupational Health & Safety Consultant

Confined Space entries are probably one of the most violated practices that take place daily in the craft brewing industry.  As a safety professional, having had the opportunity to tour well-established craft beer producers, I have found many have little or no training to be able to conduct a proper and safe confined space entry.  Some did not even have equipment to test the atmosphere of the spaces they were requiring employees to enter.

Confined Spaces are abundant and common throughout both large and small Craft Breweries.

Larger Breweries have Health and Safety Departments.

For the most part the larger players in the brewing industry have comprehensive safety programs, policies, and procedures with a support staff to provide training, manage and enforce the programs.  Due to their size and visibility to state and federal agencies, strict compliance to OSHA is a normal part of doing business.

Craft Breweries and confined space entry compliance.

First, regardless of the size of the craft brewery, strict compliance to state and federal OSHA regulations relating to confined space entry must be followed. Failing to do so can cause financial burden to your business in penalties and fines, but most importantly could cost someone their life.

confined-space-entry_02 confined-space-entry_03

What is a confined space?

According to OSHA a confined space is an area or place that has the following three characteristics:

  • Large Enough to Enter and Work
  • Limited Openings for Entry and Exit
  • Not Designed for Continuous Worker Occupancy

A space must meet all three of these criteria to be classified as a confined space.

Classification of Confined Spaces.

There are two types of confined spaces; Non-Permit and Permit required. How can you determine one from the other?

Non-Permit Confined Spaces do not have:

  • A hazardous atmosphere
  • Engulfment hazard
  • Internal configuration hazard
  • Or any other recognized hazard.

Permit required confined spaces have the potential to have any or all of the  conditions listed above.

If all possible hazards can be eliminated prior to anyone entering a confined space, then and only then a permitted space may be reclassified to a non-permit required confined space.


What is considered an entry?

Any time a part of the body passes through an opening into a confined space it is considered an entry. Something as simple as reaching into a tank or sticking your head into a hatch opening to inspect a vessel is considered an entry.

Why is this so important?

Let’s face it, there is no possible way a craft brewery can produce a finished product without having at least one or several confined space entries occurring during the brewing process.

In 2011 OSHA Investigations identified 188 deaths in confined spaces:

  • 146 atmospheric hazards
  • 42 mechanical hazards

NIOSH studied 55 Confined Space incidents involving 88 deaths.

  • Only three of the victims were trained

Two of every three people who die in a confined space, were not the original entrant.

According to OSHA from 2005-2009 in 28 different states there were a total of 481 confined space entry fatalities. This averages to about 1.85 fatalities per week or about 1 fatality every 4 days. This data covers incidents with at least one fatality or death, and do not include incidents that only resulted in serious injuries or illnesses.

Out of the 481 deaths, 298 of these occurred during construction, cleaning or repairing activities.

It should be noted that 83 of the deaths were individuals in management positions.

Most of the deaths (294) were caused by physical hazards, while surprisingly, hazardous atmospheres only accounted for 160 deaths.

29 CFR 1910.146 Permit-Required Confined Spaces.

What do I need?

To be safe your business needs to understand the requirements.  A qualified person needs to access the facility and identify and label all the known confined spaces. Written policies and procedures must be developed for each piece of equipment.  Also, employees need to be trained on the specific procedures prior to any entry activity; if respirators are required other issues need to be addressed prior to an employee being allowed to use it.  The list goes on and on.

State and Federal requirements.

To get an idea of what is required go to the department of labor’s website and research section 29 CFR 1910.146 Permit-Required Confined Spaces.  From there you will find the following topics and what every employer is required to have:

  • Policy
  • Definitions
  • Responsibilities
  • Procedures
  • Contractor requirements
  • Employee Training
  • Permit System
  • Alternate Procedures
  • Rescue Plan
  • Confined Space Workplace Evaluation

All of the above is required to be in place prior to anyone entering a confined space.

Where to get help

If you have no one with the expertise to develop these policies and procedures and conduct the necessary training, reach out to a Health & Safety Consulting firm to assist you with these issues.  Remember non-compliance is not an option.

For additional information Contact LCI at call us at 804-340-6085

Safety on Tap! – Part 2

Safety on Tap! – Chapter 2
By Terry Botts
Occupational Health & Safety Consultant

In general industry the health hazards associated with C02 are well known and well documented.  After visiting dozens and dozens of craft breweries, unfortunately, in most cases the dangers of C02 are either unknown or just ignored.  Because of this, people continue to die needlessly in tragic and totally avoidable accidents in breweries throughout the world.

C02 tanks are often placed in cramped, out-of-the-way spaces that would easily pose a place for leaks to go undetected and allow a hazard to lay in wait.

C02 tanks are often placed in storage rooms and enclosed spaces where a leak could lead to disaster.

Properties and effects of CO2

C02, a colorless, odorless by-product of the fermentation process, is extremely hazardous and can kill in two ways: either by displacing oxygen or as a toxin. Exposure to levels as little as .5% volume C02 is a serious toxic health hazard and concentrations greater than 10% volume C02 can be fatal.

C02 is heavier than air and collects at the bottom of tanks, cellars, confined spaces, containers, low lying areas and can even spill out of fermenting tanks and sink to the brewery floor, where it forms deadly, invisible pockets.  Because C02 is completely odorless and colorless, there is no physical indication or warning of danger until it is usually too late.

Safety precautions

Wort tanks, fermentation tanks, beer mixing tanks, silos, walk in coolers and other identified confined spaces are easily accessible – it is rare for them to be fitted with safety interlocks. For this very reason rigorous safety procedures should be in place and always followed. Employers are responsible for assessing the risks these areas pose to their employees and undertaking measures to eliminate them.  Having the required written Respiratory Protection, Lockout/Tagout and Confined Space entry programs and procedures along with proper training is critical to manage the dangers.

Walk-in coolers can be a death trap to unsuspecting workers.

Gas Detection

Both portable and fixed CO2 detectors, alarms and ventilation fans can be used in CO2 monitoring in breweries. Fixed systems typically comprise one or more detector “sensors” connected to a separate main control panel.  If a ”sensor“reads a dangerous CO2 level, extractor fans are automatically triggered and sirens or visual beacons can also be activated to warn workers to vacate the area. This sort of installation is suited to larger spaces like cellars and storage areas.

Portable compact units are required in confined space work where fixed detectors cannot be installed. The portable units should be easy to use and proper training should take place prior to issuing an employee a portable gas detector. Combining one or more sensors with powerful audible and visual signals to warn when pre-set gas levels are reached, compact portable detectors are easily carried in a confined space, ensuring that pockets of high CO2 concentration are not missed.

gas-meter    ventilation-fan
Portable gas detectors and ventilation fans are part of the arsenal in fighting atmospheric hazards in the workplace.

How to get there

Not taking C02 dangers seriously leads to unnecessary, avoidable workplace deaths.  Having the required written Health & Safety programs, policies, procedures and training in place will give you all the tools to manage this occupational hazard.

If you are a business owner and don’t know what to do or where to turn, contact an Occupational Health and Safety consulting firm.  A good Safety Consultant can help a Craft Brewer develop and manage their required Health & Safety programs.

About the Author:
Terry Botts is a business and safety consultant with over 25 years’ practical experience in the Manufacturing, Construction and more recently craft brewers industry. Terry is an Occupational Hearing Conservationist and an Authorized OSHA Outreach Instructor and can provide OSHA 10 & 30 Hour General Industry and Construction Outreach Training programs. Terry has been developing comprehensive safety programs, conducting site safety inspections, and delivering specialized safety training for a wide range of business clients since 2005.

Safety on Tap! – Part 1

Safety on Tap! – Part 1
By Terry Botts
Occupational Health & Safety Consultant

With the explosion of craft breweries across the nation, an explosion in brewery workplace accidents or incidents is also equally happening. Regrettably, little attention is paid to the required safety programs, record-keeping, training and policies by most small craft breweries until one of two things happens, a serious incident or accident occurs or the business gets a surprise visit and is cited by state or federal OSHA.


Safety Programs not on the Radar

Unfortunately with craft breweries, as with many small businesses, OSHA compliance, along the required written health & safety plans, are items not even on the radar screens of these establishments.  Home brewers that go into business may know everything about brewing beer but for the most part, (with few exceptions), know little or nothing about safety and health regulations or their legal obligation to be compliant.

Craft breweries are actually micro-chemical-manufacturing plants. You would never expect a large chemical plant to operate without safety programs or training, or be allowed to put their employees at risk of injury would you? Of course not! Then why would you not think the same would apply to a smaller operation?  The hazards are the same.

Why focus on Safety?

Because OSHA requires all employers to provide a safe and healthy workplace. No exceptions.  There are so many hazardous conditions and operations present in brew houses across the country, I don’t know where to start: confined spaces, hazardous chemicals, gasses, thermal hazards, moving parts, slippery floors, noise, ergonomic issues, fire and respiratory concerns, the list goes on and on.

OSHA records show that, between 2009-2012, there were at least 4 deaths reported at craft breweries and 2 deaths reported in the larger breweries.

In 2013, 7 workers died in a confined space accident at a Corona Brewery.

Due to the lack of compliance in the Craft Breweries those figures could be worse than the statistics show because many incidents often go unreported. The lack of safety management plans and programs caused smaller Craft Breweries to receive nearly 4 times the number of safety violations compared to larger breweries.

Safety Saves Money

Focusing on safety also saves business money.  According to OSHA’s “Safety Pays Program” a brewery operating at a 25% profit margin experiencing only 1 serious burn injury can expect the following cost:

  • Direct Cost:  $37,389
  • Indirect Cost:  $41,127
  • Total Cost:  $78,516
  • Sales to cover indirect cost:  $164,511
  • Sales to cover total cost:  $314,064

The extent to which the employer pays the direct costs depends on the nature of the employer’s workers’ compensation insurance policy. The employer always pays the indirect costs. You can bet on one thing for sure “workers compensation” premiums will increase with claims being paid out. The prevention of one serious injury could more than cover the cost of your program.

Also don’t forget the minimum OSHA fine for a serious violation is $12,000.00.

Education and Understanding

Craft brewing industry owners need to be educated as to what programs they need and an affordable means to meet the challenges to becoming compliant.

A good place to start to determine the requirements is by reading the OSHA “Small Business Handbook” that can be found on the Department of Labor OSHA website.


How to get there

The challenge for most business owners not trained in Health & Safety management is they don’t know what to do with or how to manage all the material that is available to them no matter how well intended they may be.

In most cases hiring a safety manager is not in the budget, however there are other affordable options out there to fill the void. Outsourcing safety management by using a safety consultant is a great way to get safety development, management and program maintenance at an affordable cost.

The “Brewers Association” provides written programs and training materials to its members free of charge.  Unfortunately, not having someone trained in health & safety management makes all this material useless in making a business OSHA compliant. Breweries need more than “fill in the blanks” safety manuals and safety training videos to fully meet the regulations.

Safety Consulting Firms

An Occupational Safety Consultant with manufacturing experience can get the craft brewery safety program off and running and monitor the operation on an ongoing basis, making sure his client has the tools, direction and training to operate the business safely. Also, most consulting firms have resources available to handle a vast array of health and safety issues encountered in the workplace.

Fortunately, there are numerous occupational health and safety consulting firms located throughout the United States that can help craft brewers develop and manage their health & safety programs. Hiring a part-time safety consultant is an excellent economical way to develop and manage their safety program. Preventing and reducing employee injuries is just good business practice. The bottom line is having a legitimate, properly managed health & safety program is part of doing business and noncompliance is not an option.

About the Author:
Terry Botts is a business and safety consultant with over 25 years’ practical experience in the manufacturing, construction and more recently craft brewing industry. Terry is an Occupational Hearing Conservationist and an Authorized OSHA Outreach Instructor and can provide OSHA 10 & 30 Hour General Industry and Construction Outreach Training programs. Terry has been developing comprehensive safety programs, conducting site safety inspections, and delivering specialized safety training for a wide range of business clients since 2005.