Brewery Hazards and Methods for Reducing Risk

1. Brewery Hazards and Methods for Reducing Risk Presented by Andrew Dagnan, CHMM GOSH Conference March 11, 2015

2. DISCLAIMER • This is just a basic overview of brewery hazards and methods to reduce risk and/or to ensure regulatory compliance. • While every effort has been made to assure the information provided herein is complete and accurate, it is not intended to take the place of published rules, statutes, regulations or your responsibility concerning the use of proper procedures. The contents of these tools may not be relied upon as a substitute for your responsibility to incorporate the most current text or information. • The Master Brewer’s Association of the Americas (MBAA) does not assume any responsibility for omissions, errors, misprinting or ambiguity contained within this publication and shall not be held liable in any degree for any loss, or injury, caused by such omissions, errors, misprinting, or ambiguity in presentation. • If legal advice or other expert assistance is required, the services of a competent professional person should be sought.

3. Agenda • Importance of Safety • Hazards overview and control methods • Proactive Risk Reduction • Safety Committees • Job Hazard Analysis (JHA) Overview • Near Miss reporting

4. Risk Reduction Why focus on safety? Compliance • Many hazards present in breweries • Similar to other hazardous manufacturing • Reuters Data from OSHA Records 2009 - 2012 • At least 4 deaths in US craft brewery • 2 deaths at large breweries that brew 10x more beer • Nearly 4x more safety violations at craft breweries • Safety oversight at smaller companies worse than statistics show • Injuries may not be reported Business Impacts

5. Risk Reduction Why focus on safety? Compliance • Occupational Health and Safety Administration (OSHA) • Federal & State OSHA • General Duty Clause • Must provide a safe and healthy place of employment • Example regulations: • Hazard Communication, Confined Spaces, Hazardous Energy Control, PPE, Fall Protection, Powered Industrial Trucks Business Impacts

6. Risk Reduction Why focus on safety? • Save money! • Reduce financial impact of injuries and illnesses • Reduced insurance and workers comp. costs • Equipment down time • Product loss • Brand equity • More effective/efficient work practices & procedures • Sustainability Compliance Business Impacts

7. Brewery Hazards Ergonomics Walking and Working Surfaces Falls Chemicals Confined Spaces Forklifts Machinery / Moving Parts Electrical Thermal Pressure CO2 And More!

8. Repetitive motions Ergonomic Hazards Lifting: malt bags, moving hoses Awkward postures Leaning / reaching / bending Forceful grips Source: www.lni.wa.gov:

9. Ergonomic Hazards (cont.) • National Institute of Occupational Safety and Health (NIOSH) study: Ergonomic and Safety Climate Evaluation at a Brewery – Colorado (2011) • Some conclusions from the study: • Employees at increased risk for upper extremity (shoulder and wrist) Work-related Musculoskeletal Disorders (WMSDs) • Employees exposed to combination of ergonomic risk factors • Survey indicated that 50% of employees felt safety training received was not adequate and safety procedures in place don’t work

10. Ergonomic Hazards – Controls • Reduce / Eliminate lifts • Automate processes • Keg robots • Hoists / lifts • Conveyors • Bulk (silos, super sacks) • Two-person lifts • Training on proper lifting • Employee stretching program

11. Wet / slippery floors Walking and Working Surfaces - Hazards Trip hazards (e.g., hoses) Tight spaces Improperly stacked items Tools and other items left out Uneven surfaces

12. Ergonomic Hazards – General Controls • Redesign tools / areas within appropriate heights • Above knees, below shoulders • Height adjustable tools / tables • Training • Rotate employees • Encourage micro breaks • Encourage employees to report injuries and near misses

13. Walking and Working Surfaces – General Requirements • Keep workplaces clean, orderly, and sanitary • Keep floors as clean and dry as possible • Keep aisles clear and free of obstructions that could create a hazard • Ensure aisles are wide enough where mechanical handling equipment is used

14. Walking and Working Surfaces – Controls • Marking aisle ways • Implement general housekeeping procedures • Keep aisles, stairs, and platforms free of clutter • Store materials properly • Store items on shelves safely and securely • Cleanup spills immediately • Monthly walk-throughs looking for hazards • Non-slip surface coating on floors

15. Fall Protection – General Requirements • Generally…fall protection required when working at heights above 4 ft. • Elevated work platforms • Handrails with a midrail • 4” toeboard • Guard openings with a swing gate • Stairways • Usable width of ≥22 in. with slip-resistant treads • Angled between 30 - 50 degrees • Railings on open sides of exposed stairways, if ≥ 4 steps

16. Fall Protection – Prevention

17. Fall Protection – Prevention

18. Confined Spaces • Confined Space: • Large enough to bodily enter and perform work • Limited means of entry or exit • Not designed for continuous human occupancy • Permit Required Confined Space • “Permit Space” • Confined space with hazards

19. Confined Spaces (cont.) • Permit Space: confined space which meets any of the following: • It has or has the potential to contain a hazardous atmosphere • It has a material that could engulf the entrant • It has an internal configuration which could trap or asphyxiate • It has any other recognized serious safety or health hazard(s) that can inhibit an Entrant’s ability to self-rescue

20. Confined Spaces (cont.) • In general, it is safe to assume that most brewhouse tanks are Permit Spaces • Brewhouse tanks have various hazards including: hot liquids, chemicals, CO2, moving parts, loose grain, etc. Source: www.soundbrew.com

21. Confined Spaces – Entry Methods • “Entry” = any body part crosses plane of opening • Only enter if absolutely necessary!! • Create non-restricted access (e.g., add stairs or walkway) • Perform tank inspections from outside space • Clean-in-place (CIP) systems • Add to tanks without entering • Design area for human occupancy

22. Prevent Entry Alternate Entry Permitted Entry Permit Spaces – Entry Methods • Only enter if absolutely necessary!! • Method for entering permit space without an entry permit • Eliminate or control hazards before entry • Reduced requirements • Permit system with preplanning, assigned personnel roles, rescue services, etc. • Most requirements

23. Powered Industrial Trucks (PITs) • Mobile, power-propelled truck used to carry, push, pull, lift, or stack materials • AKA: forklifts, pallet trucks, rider trucks, forktrucks, or lift trucks Source:forklifts.hyundai.eu

24. Instability due to overloading or unstable stacking PIT Hazards Instability due to compact design Obstructions or pedestrians in pathway Collisions with other forklifts or pedestrians Source: www.craftbrewingbusiness.com

25. PITs – Requirements / Controls • Written program & documented training • Daily inspections (each shift if 24-hour facility) • Various truck requirements including maintenance, design, ratings, etc. • Never load a PIT outside of its rated capacity • Safe Operation • Use seat belt • Lower load before moving • Be aware of surroundings • Use mirrors • Drive slowly

26. PITs – Requirements / Controls (cont.) • Designate areas / aisle ways • Inspect pallets before moving • Train all employees on safely working around PITs • High-visibility vests in PIT areas • Hazard lights/alarms • Limit access to PIT areas

27. Chemical Safety – Common Chemicals • Caustics: sodium hydroxide, sodium hypochlorite • Acids: phosphoric, nitric, iodophor, and peracetic acid • Gases: CO2, oxygen, ammonia, ozone • Flammables: isopropanol, aerosols • Oils & lubricants • Refrigerants • Glues Source: www.reflexallen.com

28. Chemical Safety – General Requirements • Written Hazard Communication program • Training • Storage: Cabinet or containment pallet • Separate incompatible chemicals • Label all chemical containers • Have MSDS for each chemical

29. Hazard Communication Changes • U.S. adopted UN standard for labeling and communicating chemical information • Referred to as the “Globally Harmonized System (GHS)” • MSDSs renamed SDSs (Safety Data Sheets) • New SDS format will be implemented over next several years • Updated labeling requirements • Additional training requirements

30. Personal Protective Equipment (PPE) • PPE = last line of defense • Only use PPE if cannot use engineering or administrative controls • Documented program and training • Selection, use, maintenance, limitations, when to change, etc. • Hazard assessments of tasks • Provide PPE • Separate programs for respirators & hearing protection

31. Noise – Hearing Protection • Breweries can be very LOUD! • Must have a Hearing Conservation Program if employee noise exposures meet or exceed an 8-hour time weighted average (TWA) of 85 dbA • If hearing protection is needed, follow all requirements such as the following: • Control noise levels • Provide hearing protection • Provide annual audiometric testing • Provide training

32. Respiratory Protection • May need to use respiratory protection during tasks such as the following: • Milling • Cleaning-up grain dust • Pouring diatomaceous earth (DE) • Complete air monitoring to determine need • If needed, follow all respiratory protection requirements including: • Written program and training • Fit test • Medical evaluation • Cleaning / Maintenance

33. Head Protection – Bump Caps • Head injuries (e.g., bumps, minor cuts) common • Bump caps are an easy way to reduce minor cuts, bumps, bruises, etc. is to use bump caps • Some look / feel like a regular baseball cap • Can get hats with built-in bump cap or hat inserts Source: www.grainger.com

34. Lockout / Tagout (LOTO) – Control of Hazardous Energies • Prevent injury to employees working with hazardous energies • Example situations to use LOTO: • Permit required confined space entry • Remove a guard or bypass a safety device • Perform maintenance on automatic starting equipment • General Requirements • Written program with equipment specific procedures • Training • Equipment: ID tags and locks that are uniquely keyed for each individual

35. Thermal Hazards • OSHA Requirement • Cover or guard steam & hot-water pipes within 7 ft. of floor or working platform or within 15 in. of stairways, ramps, or fixed ladders to prevent contact • Example Controls • Steam and hot water pipe insulation • Label hot surfaces • Written procedures for employees • Training: Ensure employees familiar with systems • PPE: long sleeves and pants, safety glasses, and gloves Source: www.labelmaster.com

36. CO2 Safety • Ensure adequate ventilation throughout brewhouse • Even in large rooms, CO2 can accumulate • Monitors / Alarms • Area monitors/alarms • Personal O2 / CO2 monitors • Develop protocols for evacuations, posted at each monitor • Train employees on alarms and evacuation procedures • Ensure monitors are calibrated

37. Keg Safety • Brewers Association Performance Guidelines for Refillable Kegs (2014) • Never alter or tamper with safety devices • Never tamper with keg valve • Systems connected to kegs should have a pressure regulator and pressure relief valve • Maintain pressure, temperature, volume, and flow settings on wash/fill equipment according to the manufacturer • Only use kegs from your own brewery • Inspect kegs, sankey valve, steel ball, and o-ring

38. Safety Meetings / Committees Job Hazard Analysis (JHA) Reporting Near Misses Proactive Approach to Reducing Hazards

39. Safety Meetings / Committees • Safety meetings or committees required based on company size • Use meetings to identify and eliminate hazards • Discuss accidents and near misses, develop recommendations, and assign actions • Empowers employees to speak-up and share responsibility in maintaining a safe workplace • Creates and promotes a safety culture

40. Job Hazard Analyses (JHA) • JHA: Technique used to review tasks to identify hazards before they occur. • Job: A typical “job” includes numerous “tasks” • Good for observing and eliminating hazards and meeting regulatory requirements • Can also be called a Job Safety Analysis (JSA)

41. JHA Process • Prioritize tasks • Review procedures, manuals, and/or applicable safety documentation • Observe work to learn the task • Take numerous pictures • Complete JHA documentation • Develop recommended controls • Prioritize recommendations • Assign actions to reduce/eliminate hazards • Use JHAs for training

42. Elimination / Substitution JHA Process – Reducing Hazards Engineering Control Administrative Control • Implement controls based on the following hierarchy: PPE

43. Report Near Misses • Encourage employees to report EVERYTHING, no matter how small • Helps to eliminate/reduce hazards before accidents actually occur • Helps build a strong safety culture • Encourage reporting everything, don’t punish employees for it

44. How to Learn More • Brewing Engineering and Plant Operations, MBAA Practical Handbook for the Specialty Brewer, Volume 3 • Industry safety committees • MBAA Safety Committee • Brewers Association Safety Committee • Contact your insurance carrier and/or vendors

45. How to Learn More (cont.) • MBAA Brewery Safety Committee • Website coming soon which will contain: • Written program examples • Example “toolbox talks” • Q&A section • And more!

46. Summary • Breweries have many hazards • Be proactive!! • Report, track, and investigate accidents and near misses • Documentation / program writing important for compliance • Encourage a healthy safety culture