A Brewery Safety Manual provides written occupational safety and health programs, procedures, and responsibilities for craft breweries, production breweries, brewpubs, microbreweries, and other businesses involved in commercial brewing and beer production.
Brewery employees may work with grain-handling equipment, mills, mash tuns, brew kettles, fermenters, bright tanks, pumps, piping systems, boilers, refrigeration equipment, canning and bottling lines, kegging equipment, forklifts, pallet jacks, cleaning chemicals, compressed gases, and other potentially hazardous equipment and processes.
Employees may also be exposed to carbon dioxide, oxygen-deficient atmospheres, hot liquids and steam, hazardous energy, chemicals, pressure systems, combustible dust, confined spaces, wet floors, heavy material handling, noise, and repetitive work.
Because breweries vary considerably in size and operation, the safety manual should reflect the brewing processes, equipment, packaging systems, chemicals, utilities, storage areas, and employee exposures actually present.
The contents of a Brewery Safety Manual should reflect the brewery’s actual operations.
A small craft brewery may need a different combination of programs than a large production brewery containing automated grain handling, milling systems, multiple fermentation vessels, boilers, refrigeration systems, packaging lines, forklifts, warehouses, laboratories, and extensive cleaning and sanitation operations.
Depending on operations, the manual may address:
Programs should be selected according to the work actually performed, hazards present, equipment used, and applicable safety requirements.
An effective Brewery Safety Program establishes responsibilities and procedures for identifying workplace hazards, controlling hazardous energy, protecting employees from carbon dioxide and chemical exposures, safely operating brewing and packaging equipment, and correcting unsafe conditions.
Management should provide employees with the equipment, safeguards, training, PPE, and resources necessary to perform their assigned work safely.
Managers and supervisors should:
Employees should follow established procedures, use required safeguards and PPE, report unsafe conditions, and operate only equipment for which they have received appropriate training and authorization.
Brewery operations should be evaluated to identify hazards associated with brewing, fermentation, packaging, sanitation, maintenance, warehousing, and material handling.
Hazard assessments may consider:
Assessments should be reviewed when equipment, processes, chemicals, production methods, or brewery layouts change significantly.
Periodic safety inspections can help identify unsafe conditions and verify that established procedures are being followed.
Inspections may include:
Identified deficiencies should be documented and corrected in a timely manner.
A Job Safety Analysis (JSA/JHA) can be used to evaluate higher-hazard brewery activities and establish appropriate controls before work begins.
JSAs/JHAs may be appropriate for:
The JSA/JHA should identify task steps, hazards associated with each step, and controls necessary to perform the work safely.
Carbon dioxide is a significant brewery hazard because it is generated during fermentation and may also be stored and used for carbonation, packaging, and dispensing.
CO2 can accumulate in enclosed or poorly ventilated areas and can create dangerous employee exposures.
Potential accumulation areas may include:
Brewery procedures should address carbon dioxide sources, ventilation, monitoring where appropriate, alarm response, employee training, and emergency procedures.
Employees should understand that carbon dioxide can create a hazardous atmosphere even when oxygen measurements alone do not indicate an oxygen-deficient atmosphere.
Fixed or portable carbon dioxide monitoring may be appropriate where hazardous concentrations could develop.
Monitoring systems should be selected and located according to the hazards and characteristics of the area.
Where CO2 alarms are provided, employees should understand:
Employees should not ignore or intentionally disable carbon dioxide alarms.
CO2 cylinders, tanks, regulators, piping, valves, and associated equipment should be installed, used, and maintained appropriately.
Cylinders should be secured against falling or being knocked over.
Employees should report damaged equipment, leaks, abnormal pressure conditions, or other suspected problems.
Bulk CO2 systems should be protected against unauthorized adjustment and physical damage where appropriate.
Fermentation can release substantial quantities of carbon dioxide.
Ventilation and monitoring needs should be evaluated according to the brewery’s equipment, production volume, room configuration, and other relevant conditions.
Employees should understand that visible vapor, odor, or other sensory warning should not be relied upon to determine whether a hazardous CO2 concentration is present.
Breweries may contain tanks, fermenters, mash tuns, kettles, vessels, pits, silos, and other spaces that require evaluation under the applicable confined-space requirements.
Each potentially confined space should be evaluated based on its configuration and hazards.
Where a space meets the definition of a permit-required confined space, the brewery should establish appropriate entry procedures addressing:
Employees should not enter tanks or other spaces unless entry has been appropriately evaluated and authorized.
Tank and vessel entry may expose employees to carbon dioxide, oxygen deficiency, cleaning chemicals, hot surfaces, steam, residual product, mechanical hazards, and restricted entry or exit.
Before entry, applicable hazards should be identified and controlled.
Depending on the vessel and work being performed, controls may include:
Emergency rescue from tanks and vessels should be planned before permit-required entry begins.
Employees should not make an impulsive entry to rescue a coworker from a potentially hazardous atmosphere.
Rescue arrangements should reflect the configuration of the space, potential hazards, entry method, and ability to provide timely assistance.
Brewery employees performing servicing or maintenance may be exposed to electrical, mechanical, hydraulic, pneumatic, thermal, gravitational, pressure, or other hazardous energy.
Where the Lockout/Tagout standard applies, hazardous energy should be isolated and controlled before servicing or maintenance begins.
Equipment requiring evaluation may include:
Simply pressing a stop button or using a normal operating control may not adequately isolate hazardous energy.
Only appropriately trained and authorized employees should perform work requiring Lockout/Tagout.
Where required, energy-control procedures should identify the specific energy sources and isolation methods for the equipment being serviced.
Procedures should address appropriate shutdown, isolation, verification, servicing, and restoration to service.
Stored energy such as pressure, heat, gravity, or compressed gas should be controlled before work begins.
Mills, augers, conveyors, packaging machinery, pumps, motors, drives, and other brewery equipment may create caught-in, caught-between, crushing, cutting, or amputation hazards.
Required guards and safeguards should remain installed and functional.
Employees should not remove, defeat, bypass, or intentionally interfere with required safeguards.
Equipment with missing or defective safeguards should be removed from service when necessary until appropriate protection is restored.
Handling malted barley, wheat, and other brewing ingredients may expose employees to dust, lifting hazards, moving equipment, and falling materials.
Procedures should address:
Employees should avoid placing hands or tools into moving grain-handling equipment.
Grain mills and associated feed equipment can create caught-in, crushing, entanglement, and dust hazards.
Guards should remain in place during operation.
Employees should follow appropriate shutdown and energy-control procedures before performing servicing, maintenance, or other work that exposes them to hazardous machine movement.
Processing and transferring grain can generate combustible dust under certain conditions.
Breweries should evaluate their ingredients, equipment, dust-generation potential, building configuration, and ignition sources to determine whether a combustible-dust hazard exists.
Where applicable, controls may address:
Combustible-dust controls should be based on the actual hazard rather than assuming every brewery has the same dust-explosion potential.
Good housekeeping is particularly important in breweries because grain, packaging debris, broken glass, liquid spills, hoses, and other materials can create hazards.
Employees should:
Brewing operations can expose employees to hot wort, hot water, steam, heated vessels, and other thermal hazards.
Employees should understand the potential for severe burns from liquid, steam, and hot surfaces.
Procedures should address:
Employees should verify system conditions before opening piping, fittings, or equipment that may contain hot or pressurized material.
Brew kettles and mash tuns can expose employees to hot liquids, steam, hot surfaces, chemical residues, and confined-space hazards.
Employees should follow established procedures for operation, cleaning, maintenance, and entry.
Access platforms, stairs, and work areas around vessels should be maintained in safe condition.
Employees should not enter a kettle, mash tun, or similar vessel until the space has been evaluated and applicable entry requirements have been satisfied.
Breweries may use pressurized fermentation vessels, bright tanks, piping, compressed gases, and other pressure-containing equipment.
Pressure systems should be operated within appropriate limits and maintained in accordance with their design and applicable requirements.
Pressure-regulating devices, gauges, valves, and relief devices should be maintained as appropriate.
Employees should not loosen fittings or open equipment until pressure has been safely relieved.
Hoses used for product transfer, cleaning, hot water, steam, chemicals, or compressed gases should be appropriate for their intended service.
Employees should inspect hoses and connections as required and report damage, deterioration, or leaking fittings.
Connections should be secured appropriately before pressure is applied.
Cleaning and sanitation are essential brewery operations but may expose employees to chemicals, hazardous energy, hot water, pressure, wet floors, and machinery.
Cleaning procedures should address the equipment and hazards involved.
Employees should understand when routine cleaning can be safely performed under normal operating conditions and when equipment must be shut down and hazardous energy controlled.
Tank cleaning may involve clean-in-place systems, spray devices, chemicals, hot water, manual cleaning, or entry into the vessel.
Procedures should address:
Employees should not enter a tank merely because it has been drained or rinsed.
Breweries commonly use caustic cleaners, acids, sanitizers, and other chemicals that may cause skin burns, eye injuries, respiratory irritation, or other health effects.
Employees should:
Chemical transfer and dilution procedures should minimize splashing, spills, and employee exposure.
Employees should understand the correct order and method for mixing or diluting chemicals according to manufacturer instructions and established procedures.
Appropriate eye, face, hand, and body protection should be provided based on the hazard.
Where employees may be exposed to corrosive materials requiring immediate flushing, suitable emergency washing facilities should be readily available as required.
Employees should know their locations and how to use them.
Access to emergency eyewash and shower equipment should remain unobstructed.
Employees exposed to hazardous chemicals should receive appropriate information and training.
The Hazard Communication Program should address applicable:
Employees should understand how to obtain and use Safety Data Sheets.
PPE requirements should be based on workplace hazard assessments and employee tasks.
Depending on the work performed, PPE may include:
PPE should be properly selected, maintained, and used.
Employees performing chemical transfer, hose disconnection, cleaning, pressurized operations, or other tasks that can create splash or impact hazards should use appropriate eye and face protection.
A face shield should not automatically be treated as a substitute for required primary eye protection.
Gloves should be selected according to the specific hazard.
Different brewery tasks may require protection from:
Employees should understand the limitations of the gloves provided.
Engineering and other feasible controls should be used where appropriate to control airborne hazards.
When respirators are necessary to protect employees, the brewery should maintain an appropriate Respiratory Protection Program addressing required elements such as respirator selection, medical evaluation, fit testing, training, inspection, and maintenance.
Respirators should not be used as a substitute for appropriate confined-space controls or emergency procedures.
Packaging lines may expose employees to moving machinery, conveyors, pinch points, broken glass, compressed air, noise, repetitive work, and hazardous energy.
Employees should:
Conveyors should be appropriately guarded and maintained.
Employees should not climb over, crawl under, ride, or reach into moving conveyors unless the system is specifically designed for the activity and appropriate procedures are followed.
Emergency stops and other safety devices should remain accessible and functional where provided.
Packaging jams should be cleared according to established procedures.
Employees should not reach into hazardous areas of operating machinery unless the task has been evaluated and can be performed safely.
When jam clearing exposes employees to unexpected startup or hazardous energy, applicable Lockout/Tagout procedures should be followed.
Keg filling, cleaning, moving, stacking, and storage can expose employees to pressure, chemicals, moving machinery, manual-handling hazards, and pinch points.
Employees should follow established procedures for kegging equipment and should keep hands clear of automated equipment.
Kegging machinery should be appropriately guarded and maintained.
Full and empty kegs can be heavy and awkward.
Mechanical handling equipment should be used where practical.
Employees should:
Brewery employees may handle grain bags, kegs, cases, chemical containers, packaging materials, cylinders, and other heavy or awkward loads.
Employees should evaluate loads before lifting and obtain assistance when necessary.
Mechanical assistance such as carts, hand trucks, pallet jacks, lifts, or other material-handling equipment should be used where appropriate.
Repetitive packaging, keg handling, palletizing, ingredient handling, and other brewery tasks can create ergonomic stress.
Potential risk factors include:
Workstations, equipment, work practices, and material-handling methods should be evaluated and improved where practical.
Wet floors are common in brewery production and sanitation areas.
Water, beer, wort, chemicals, hoses, drains, packaging materials, and other conditions can create slip and trip hazards.
Employees should:
Floors, stairs, platforms, catwalks, ladders, and other walking-working surfaces should be maintained in safe condition.
Elevated work areas around tanks and brewing equipment should have appropriate fall protection where required.
Employees should not climb on tanks, piping, shelving, or other surfaces not designed for access.
Employees should use appropriate ladders or access systems for elevated work.
Ladders should be inspected and used according to established procedures.
Employees should not use makeshift climbing devices or climb brewery equipment to reach elevated areas.
Breweries using forklifts or other powered industrial trucks should maintain an appropriate Powered Industrial Truck Safety Program.
Only trained and authorized employees should operate powered industrial trucks.
The program should address:
Manual and powered pallet jacks should be operated according to their design and manufacturer instructions.
Employees should maintain control of loads, keep hands and feet clear of wheels and pinch points, and maintain visibility while moving materials.
Only appropriately trained employees should operate powered equipment.
Finished products, ingredients, packaging materials, chemicals, kegs, pallets, and other materials should be stored securely.
Storage procedures should address:
Loading docks can expose employees to trucks, forklifts, pallet jacks, dock edges, unstable loads, and pedestrian traffic.
Procedures should address vehicle movement, trailer access, dock edges, material handling, pedestrian routes, and communication between drivers and brewery personnel.
Employees loading and unloading ingredients, packaging materials, kegs, and finished products should remain aware of vehicle movement, unstable loads, pinch points, and material-handling hazards.
Appropriate equipment should be used for heavy or awkward loads.
Electrical equipment, cords, plugs, panels, motors, pumps, and controls should be maintained in safe condition.
The wet environment present in many breweries makes appropriate electrical installation, maintenance, and work practices particularly important.
Employees should not use damaged electrical equipment.
Only qualified or otherwise authorized personnel should perform electrical work requiring specialized knowledge or training.
Mills, compressors, packaging lines, conveyors, pumps, and other brewery equipment can create significant workplace noise.
Employee noise exposure should be evaluated where necessary.
Engineering or administrative controls should be considered where appropriate.
Where employee noise exposures trigger applicable requirements, the brewery should maintain an appropriate Hearing Conservation Program.
The program may include exposure monitoring, audiometric testing, hearing protection, training, and recordkeeping.
Compressed air should be used only for appropriate purposes and according to established procedures.
Employees should not direct compressed air at themselves or other people.
Compressed air used for cleaning should comply with applicable requirements and should not create additional dust or exposure hazards.
Compressed gas cylinders should be appropriately stored, secured, handled, and protected from damage.
Employees should use suitable regulators, fittings, and connections for the gas and service involved.
Damaged cylinders, valves, regulators, or connections should be removed from service as appropriate.
Breweries may use glycol, ammonia, or other refrigeration systems.
Safety procedures should reflect the refrigerant, system size, equipment, and employee exposures present.
Employees who operate or maintain refrigeration equipment should receive appropriate instruction.
Emergency procedures should address potential refrigerant releases where applicable.
Breweries using ammonia refrigeration should evaluate the quantity and process to determine which regulatory requirements apply.
Facilities with covered processes should maintain the required Process Safety Management program.
Even where a system is not subject to PSM, appropriate procedures for operation, maintenance, emergency response, and employee protection remain important.
Breweries using boilers or steam systems should maintain the equipment according to applicable requirements and manufacturer instructions.
Only appropriately trained or authorized employees should operate or service boiler equipment.
Employees should be protected from hot surfaces, steam releases, pressure, and hazardous energy.
Maintenance and repair may involve welding, cutting, brazing, grinding, or other hot work.
Procedures should address:
Hot work near grain dust, flammable materials, or process equipment requires particular attention.
Fire-prevention procedures should address the hazards present within the brewery.
Potential considerations include:
Fire extinguishers and other fire-protection equipment should remain accessible.
Employees should understand procedures to follow during foreseeable brewery emergencies.
The Emergency Action Plan may address:
Employees should understand alarm methods, exit routes, assembly areas, and emergency reporting procedures applicable to their workplace.
Exit routes should remain accessible and reasonably free of obstructions.
Kegs, pallets, packaging materials, hoses, carts, and other equipment should not block required emergency exits or exit access.
Employees should report damaged exit doors, emergency lighting, or exit signs.
Breweries should establish procedures for obtaining prompt medical assistance.
Employees should understand how to report an injury, summon emergency assistance, and locate first-aid supplies.
Potential brewery injuries may include burns, chemical exposures, cuts, strains, eye injuries, and injuries involving machinery or material handling.
Procedures should address foreseeable spills involving chemicals, product, oils, refrigerants, and other materials.
Employees should understand:
Breweries generating hazardous waste should identify and manage the waste according to applicable requirements.
Employees responsible for handling hazardous waste should receive appropriate information and instruction.
Breweries performing laboratory testing should evaluate hazards associated with laboratory chemicals, glassware, compressed gases, heating equipment, microbiological work, and other laboratory activities.
Laboratory safety procedures should reflect the type and extent of testing actually performed.
Outside contractors may perform refrigeration, electrical, mechanical, construction, tank, boiler, or other specialized work within the brewery.
Contractor coordination should address relevant workplace hazards and applicable safety procedures.
The brewery and contractor should exchange appropriate hazard information when required.
Breweries operating taprooms or public hospitality areas should evaluate hazards associated with employees working directly with customers.
Potential considerations include:
Production areas should be appropriately separated from unauthorized public access.
Breweries operating delivery vehicles should establish appropriate vehicle-safety procedures.
Programs may address:
Employees working alone during brewing, cellaring, maintenance, laboratory work, opening, closing, or other activities may face increased risk during emergencies.
Where employees work alone, procedures should address communication, emergency assistance, and the hazards associated with the work being performed.
Higher-hazard tasks should be evaluated to determine whether working alone is appropriate.
Safety training should reflect each employee’s assigned work and exposure.
Depending on operations, training may address:
Training should be provided before employees independently perform tasks requiring specific knowledge or skills and repeated when required or when circumstances indicate retraining is necessary.
New employees may be unfamiliar with brewery processes, equipment, chemicals, carbon dioxide hazards, and emergency procedures.
Orientation should address:
Additional supervision should be provided when appropriate until employees demonstrate the ability to perform their assigned work safely.
Breweries can use JSAs/JHAs to document safe work procedures for recurring higher-hazard tasks.
Potential Brewery JSAs/JHAs include:
Short safety meetings can reinforce safe work practices and address current workplace concerns.
Potential topics include:
Depending on brewery operations, additional safety programs may be necessary for:
These programs should be included when employee activities or workplace hazards make them applicable rather than automatically adding programs unrelated to the brewery’s operations.
A useful Brewery Safety Manual should reflect the actual workplace rather than simply combining generic manufacturing safety policies.
A production brewery with automated grain handling, large fermenters, packaging lines, ammonia refrigeration, forklifts, laboratories, and warehouse operations may require substantially more safety programs than a small craft brewery with a limited brewing system and manual packaging operations.
The manual should consider:
Selecting the appropriate programs creates a manual that is comprehensive without filling it with procedures unrelated to the employer’s operations.
A Brewery Safety Manual can be developed around the specific brewing processes, equipment, packaging systems, utilities, chemicals, and employee exposures of the business.
The finished manual may incorporate applicable programs for carbon dioxide, confined spaces, Lockout/Tagout, machine guarding, chemical safety, PPE, grain handling, packaging equipment, material handling, forklifts, emergency procedures, and other hazards present within the operation.
This provides brewery employers with a practical safety manual organized around the work their employees actually perform.