OSHA Safety Requirements for Breweries

brewing tanks

"It's all fun and games until someone loses an eye" is an old saying from Ancient Rome. The only rule during wrestling matches was, "No eye gouging." Everything else was allowed. The only way to be disqualified was to poke someone's eye out.

The same thing applies to brewing beer. “It’s all fun and games until someone is overcome by CO2” might be an appropriate phrase. At craft brew trade shows, we’ve spoken to dozens of people who have either succumbed to carbon dioxide in a beer tank or they know someone who has.

Most of the time it’s told as a funny story. The sudden shortness of breath is quickly followed by dizziness. The worker jumps back from the tank and hopes no one notices. Occasionally someone passes out, only to wake up on the floor surrounded by fellow workers who shrug it off as a rite of passage for all brewers. Of course, no one tells the owner. It was a stupid mistake, it was embarrassing, and it’s a lesson not soon forgotten.

co2 safety meter

I recently asked a friend who is a brew master at a local micro-brewery about the subject. His first response was, “we can’t afford brewery safety equipment.” When I said a pocket CO2 meter only cost $249, he shrugged.

“We only have 6 tanks,” he said. “I’m the only one who goes into them, and I know which ones can kill me.”

If I was a brewery owner, I’d shudder if one of my employees said this.

CO2 is only one aspect of brewery safety. Craft brewers and micro-brewers are increasingly finding themselves accountable - and liable - for Occupational Safety and Health Administration (OSHA) brewery safety regulations.

According to a recent article in Craft Brewing Business, OSHA is increasingly aggressive in enforcing workplace safety requirements on employers. In 2016 they placed approximately 700 breweries on a “bad actor list.” Once you’re on the list, you can plan on significantly more OSHA visits and increased fines.

Classifying employees as independent contractors doesn’t necessarily relieve the brewery owner of liability. While self-employed individuals are not technically covered by the OSHA Act, "Employers cannot evade their responsibility by claiming that workers on a job site are independent contractors" according to a 2016 ruling by an OSHA Administrative Law Judge.

Gabriel Sierra, managing director of Prometrix Safety Consulting says the most common OSHA violations include lockout/tagout and confined spaces accidents. Both these kinds of accidents can happen in breweries where high levels of CO2 can occur.

In addition to personal safety, some local municipalities have added the OSHA CO2 TWA (time-weighted average) exposure limits to bulk CO2 storage safety alarm specifications. To meet this requirement, CO2Meter offers the RAD-0102-6 which includes an alarm that meets OSHA requirements. For more detail on OSHA compressed gas standards see this article.

OSHA Requirements for Breweries

If you own a micro-brewery, here’s what you need:

  1. Safety data sheets (SDS, formerly MSDS) on all gas and liquids used in the brewery.
  2. Instruction in OSHA regulations relating to ergonomics, walking and working surfaces, fall protection, confined spaces, powered industrial trucks, chemical safety and personal protective equipment.
  3. A written (and tested) emergency evacuation plan, confined space protocol and chemical safety plan.
  4. Know and follow OSHA injury reporting regulations.
  5. Develop a process that allows employees to report safety concerns and incidents to the owner without fear of retaliation.
  6. Regular safety meetings and training for employees that address all of the above.

For many breweries, the plan can be completed by working with a Safety consultant in combination with the insurance company. Brewers may even be eligible for lower cost insurance once all safety protocols have been completed.

For breweries where money is tight, a good place to start is the free online brewery safety training courses sponsored by the Brewer’s Association. These courses are not only free, but provide testing and certification that proves you or your employees have been trained on safety related issues. In addition, they have a Q&A section where common issues are addressed.

Note these courses are paid for by the members of the Craft Brewers Association, of which CO2Meter is an industry member.

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