Distillery Safety Manual

What Should a Distillery Safety Manual Include?

The contents of a Distillery Safety Manual should reflect the distillery’s actual operations.

A small craft distillery may need a different combination of programs than a large facility containing automated grain handling, milling systems, fermentation vessels, multiple stills, bulk alcohol storage, barrel warehouses, boilers, refrigeration systems, bottling lines, forklifts, laboratories, and extensive cleaning and sanitation operations.

Depending on operations, the manual may address:

• Distillery safety responsibilities.
• Hazard assessments.
• Safety inspections.
• Job Safety Analysis.
• Flammable liquids and ethanol.
• Flammable-vapor control.
• Distillation and still safety.
• Fire and explosion prevention.
• Ignition-source control.
• Hazardous locations.
• Bonding and grounding.
• Pressure systems.
• Carbon dioxide.
• Confined spaces.
• Grain and malt handling.
• Combustible dust.
• Lockout/Tagout.
• Machine guarding.
• Hot liquids and steam.
• Cleaning and sanitation chemicals.
• Hazard Communication.
• Personal Protective Equipment.
• Barrel handling and storage.
• Bottling and packaging.
• Forklifts and pallet jacks.
• Manual material handling.
• Slips, trips and falls.
• Electrical safety.
• Noise.
• Emergency procedures.

Programs should be selected according to the work actually performed, hazards present, equipment used, materials handled, and applicable safety requirements.

Distillery Safety Program

An effective Distillery Safety Program establishes responsibilities and procedures for identifying workplace hazards, controlling flammable liquids and vapors, preventing fires and explosions, protecting employees from carbon dioxide and chemical exposures, controlling hazardous energy, safely operating distillation 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:

• Identify distillery and process hazards.
• Evaluate flammable-liquid and vapor hazards.
• Control potential ignition sources.
• Conduct appropriate workplace inspections.
• Evaluate carbon dioxide exposures.
• Evaluate tanks and vessels for confined-space hazards.
• Maintain machinery and safeguards.
• Establish hazardous-energy-control procedures where required.
• Maintain chemical-handling procedures.
• Coordinate production, barrel, packaging, sanitation, and maintenance activities.
• Provide appropriate PPE.
• Train employees before assigning hazardous work.
• Correct unsafe conditions.
• Investigate incidents and near misses.
• Follow up on corrective actions.

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.

Distillery Hazard Assessments

Distillery operations should be evaluated to identify hazards associated with fermentation, distillation, alcohol transfer and storage, barrel operations, bottling, sanitation, maintenance, warehousing, and material handling.

Hazard assessments may consider:

• Flammable liquids and vapors.
• Ignition sources.
• Hazardous electrical locations.
• Static electricity.
• Pressure and overpressure.
• Carbon dioxide accumulation.
• Oxygen-deficient atmospheres.
• Confined spaces.
• Hot liquids and steam.
• Hazardous energy.
• Moving machinery.
• Grain dust.
• Combustible dust.
• Cleaning chemicals.
• Wet and slippery floors.
• Manual material handling.
• Forklift traffic.
• Noise.

Assessments should be reviewed when equipment, processes, chemicals, production methods, or facility layouts change significantly.

Distillery Safety Inspections

Periodic safety inspections can help identify unsafe conditions and verify that established procedures are being followed.

Inspections may include:

• Stills and distillation equipment.
• Fermentation vessels.
• Pumps and piping.
• Alcohol-transfer systems.
• Bulk storage.
• Barrel-storage areas.
• Ventilation systems.
• Electrical equipment.
• Bonding and grounding.
• Grain-handling equipment.
• Mills.
• Machine guards.
• Bottling and packaging equipment.
• Carbon dioxide systems.
• Chemical storage.
• Floors and drainage.
• Forklifts and pallet jacks.
• Fire-protection equipment.
• Emergency equipment.
• Exit routes.

Identified deficiencies should be documented and corrected in a timely manner.

Job Safety Analysis (JSA/JHA)

A Job Safety Analysis (JSA/JHA) can be used to evaluate higher-hazard distillery activities and establish appropriate controls before work begins.

JSAs/JHAs may be appropriate for:

• Grain handling.
• Milling.
• Mash operations.
• Distillation.
• Still startup and shutdown.
• Alcohol transfer.
• Tank cleaning.
• Confined-space entry.
• Chemical transfer.
• Barrel handling.
• Bottling-line operation.
• Jam clearing.
• Equipment maintenance.
• Forklift operation.
• Loading and unloading.

The JSA/JHA should identify task steps, hazards associated with each step, and controls necessary to perform the work safely.

Flammable Liquids and Ethanol

Distilleries handle ethanol at concentrations capable of producing flammable vapors.

Procedures should address the receipt, processing, transfer, storage, packaging, and handling of flammable liquids according to the conditions present.

Potential hazards include:

• Liquid releases.
• Flammable vapor accumulation.
• Static electricity.
• Open flames.
• Hot surfaces.
• Electrical ignition sources.
• Hot work.
• Overpressure.
• Equipment failure.

Employees working with flammable liquids should understand the hazards and applicable precautions for their assigned work.

Distillation and Still Safety

Distillation concentrates alcohol and combines flammable ethanol vapors with heat, making the distillation area a particularly important part of the Distillery Safety Program.

Stills and associated equipment should be operated within established temperature and pressure limits.

Procedures should address:

• Startup.
• Normal operation.
• Shutdown.
• Process monitoring.
• Abnormal conditions.
• Pressure control.
• Vapor releases.
• Emergency shutdown.
• Maintenance.
• Restart after maintenance.

Employees should understand the conditions that require a process to be stopped or placed in a safe condition.

Still Startup and Shutdown

Stills should be started and shut down according to established operating procedures.

Before startup, employees should verify that applicable:

• Covers and access points are secured.
• Valves are properly positioned.
• Piping and connections are ready for operation.
• Required safeguards are functional.
• Pressure-control devices are available.
• Maintenance work has been completed.
• Personnel are clear of hazardous areas.

Abnormal pressure, temperature, leaks, or other unexpected conditions should be promptly evaluated.

Pressure and Overpressure

Stills, vessels, piping, and other distillery equipment may contain pressure generated by steam, heat, pumps, compressed gases, or the production process.

Pressure systems should be operated within appropriate limits.

Pressure-relief devices and other safeguards should be maintained as appropriate.

Employees should not loosen fittings, open access points, or disconnect equipment until pressure has been safely relieved.

Equipment should not be operated when known defects could compromise pressure integrity.

Flammable Vapor Control

Distillery operations should be designed and operated to minimize unintended releases and accumulation of flammable vapors.

Controls may include:

• Closed transfer systems.
• Ventilation.
• Appropriate process equipment.
• Vapor control.
• Leak prevention.
• Spill containment.
• Vapor monitoring where appropriate.
• Ignition-source control.

Employees should promptly report alcohol odors, leaks, damaged equipment, unusual process conditions, or other indications of a possible release.

Ignition-Source Control

Potential ignition sources should be appropriately controlled where flammable liquids or vapors may be present.

Potential ignition sources include:

• Open flames.
• Smoking.
• Electrical equipment.
• Static electricity.
• Hot surfaces.
• Heaters.
• Welding.
• Cutting.
• Grinding.
• Sparks from tools or equipment.

Activities capable of introducing an ignition source into a hazardous area should be evaluated before work begins.

Hazardous Locations

Areas where flammable gases or vapors may create a fire or explosion hazard should be evaluated to determine applicable electrical-location requirements.

Electrical equipment and wiring in classified locations should be suitable for the location and hazard.

Employees should not introduce unapproved electrical equipment, portable heaters, tools, or other potential ignition sources into areas where they are not appropriate.

Bonding and Grounding

Static electricity can become an ignition source during certain flammable-liquid transfer operations.

Bonding, grounding, or other appropriate static-control measures should be used where required by the operation and equipment.

Connections should be maintained and inspected as appropriate.

Employees should not intentionally bypass required static-control systems.

Alcohol Transfer

Transfer of spirits or other alcohol-containing liquids should be performed using equipment appropriate for the product and process.

Before transfer begins, employees should verify:

• Correct source and destination.
• Hose and piping condition.
• Secure connections.
• Appropriate valve positioning.
• Available capacity.
• Applicable bonding or grounding.
• Spill-control measures.

Employees should monitor transfers as appropriate and respond promptly to leaks or abnormal conditions.

Pumps, Piping and Hoses

Pumps, piping, hoses, valves, and fittings should be compatible with their intended service and maintained in safe condition.

Employees should inspect equipment as appropriate for:

• Leaks.
• Deterioration.
• Damaged fittings.
• Loose connections.
• Abnormal vibration.
• Other conditions that could affect safe operation.

Pressure should be appropriately relieved before disconnecting equipment.

Bulk Alcohol Storage

Bulk alcohol tanks and associated equipment should be protected from leaks, overfilling, physical damage, and inappropriate ignition sources.

Procedures may address:

• Tank condition.
• Venting.
• Overfill prevention.
• Transfer operations.
• Spill containment.
• Access control.
• Bonding and grounding.
• Fire protection.
• Emergency response.

Employees should promptly report suspected leaks or abnormal tank conditions.

Spill Prevention and Response

Distilleries should establish procedures for foreseeable spills involving ethanol, spirits, chemicals, oils, fuels, and other materials.

Employees should understand:

• How to report a spill.
• When they may safely clean it.
• Ignition-source restrictions.
• Required PPE.
• Appropriate cleanup materials.
• Disposal requirements.
• When evacuation or emergency assistance is necessary.

Flammable-liquid spills should be treated as potential vapor and fire hazards.

Fire and Explosion Prevention

Fire and explosion prevention should be a major component of distillery safety.

Controls should address the combination of:

• Flammable liquids.
• Flammable vapors.
• Heat.
• Electrical equipment.
• Static electricity.
• Hot work.
• Combustible materials.
• Grain dust.
• Process pressure.

Employees should understand that prevention requires both controlling releases of flammable material and controlling potential ignition sources.

Fire Protection

Fire-protection equipment should be selected and maintained according to the hazards present.

Fire extinguishers and other equipment should remain accessible.

Employees expected to use portable fire extinguishers should receive applicable training.

Employees should understand when evacuation rather than attempting to fight a fire is the appropriate response.

Hot Work

Welding, cutting, brazing, grinding, and other hot work can create particularly serious hazards around ethanol and flammable vapors.

Hot-work procedures should address:

• Authorization where appropriate.
• Removal or protection of combustible materials.
• Flammable-liquid and vapor hazards.
• Atmospheric conditions where applicable.
• Fire extinguishing equipment.
• Fire watch requirements when applicable.
• PPE.
• Post-work monitoring where necessary.

Hot work should not proceed when flammable conditions make the work unsafe.

Carbon Dioxide Safety

Carbon dioxide is produced during fermentation and may also be stored or used during distillery operations.

CO2 can accumulate in enclosed, low, or poorly ventilated areas and create dangerous employee exposures.

Potential accumulation areas may include:

• Fermentation rooms.
• Tank areas.
• Cellars.
• Pits and low areas.
• CO2 storage areas.
• Other inadequately ventilated locations.

Procedures should address carbon dioxide sources, ventilation, monitoring where appropriate, alarm response, employee training, and emergency procedures.

Employees should understand that carbon dioxide itself may need to be measured where hazardous concentrations can develop.

CO2 Monitoring and Alarms

Fixed or portable carbon dioxide monitoring may be appropriate where hazardous concentrations could develop.

Where CO2 alarms are provided, employees should understand:

• What the alarms mean.
• Required response actions.
• When to evacuate.
• Who should be notified.
• Restrictions on reentry.
• Emergency procedures.

Employees should not ignore or intentionally disable atmospheric alarms.

Fermentation Areas

Fermentation can release substantial quantities of carbon dioxide.

Ventilation and monitoring needs should be evaluated according to production volume, equipment, room configuration, and other relevant conditions.

Employees should not rely on odor or other sensory warning to determine whether a hazardous atmosphere is present.

Confined Spaces

Distilleries may contain fermenters, stills, tanks, vessels, pits, silos, and other spaces that require evaluation under applicable confined-space requirements.

Each potentially confined space should be evaluated according to its configuration and hazards.

Where a space meets the definition of a permit-required confined space, procedures should address:

• Hazard evaluation.
• Entry authorization.
• Atmospheric testing.
• Isolation.
• Ventilation.
• Attendants.
• Communications.
• Entry equipment.
• Rescue and emergency procedures.
• Employee training.

Employees should not enter tanks, stills, or other spaces until the entry has been appropriately evaluated and authorized.

Tank and Vessel Entry

Tank and vessel entry can expose employees to carbon dioxide, oxygen deficiency, ethanol vapors, cleaning chemicals, mechanical hazards, heat, residual materials, 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:

• Hazardous-energy isolation.
• Draining and cleaning.
• Atmospheric testing.
• Ventilation.
• Chemical control.
• Temperature control.
• Entry permits.
• Attendant procedures.
• Rescue provisions.

A vessel should not be considered safe for entry merely because it has been emptied or rinsed.

Confined-Space Rescue

Emergency rescue should be planned before permit-required entry begins.

Employees should not make an impulsive entry into a tank or other potentially hazardous atmosphere to rescue a coworker.

Rescue arrangements should reflect the configuration of the space, potential hazards, entry method, and ability to provide timely assistance.

Grain and Malt Handling

Distilleries using grain may receive, store, mill, convey, and process corn, barley, rye, wheat, or other feedstocks.

Potential hazards include:

• Dust.
• Moving equipment.
• Augers and conveyors.
• Mills.
• Heavy lifting.
• Falling material.
• Slips and trips.

Employees should follow established grain-handling procedures and remain clear of moving equipment.

Grain Mills

Grain mills and associated feed equipment can create caught-in, crushing, entanglement, and dust hazards.

Required guards should remain in place.

Employees should follow appropriate shutdown and hazardous-energy-control procedures before performing servicing, maintenance, or other work exposing them to hazardous movement.

Combustible Dust — When Applicable

Milling and transferring grain can generate combustible dust under certain conditions.

Distilleries should evaluate their feedstocks, equipment, dust-generation potential, building configuration, and ignition sources to determine whether a combustible-dust hazard exists.

Where applicable, controls may address:

• Dust collection.
• Housekeeping.
• Dust accumulation.
• Ignition sources.
• Electrical equipment.
• Hot work.
• Preventive maintenance.
• Grain-transfer equipment.

Combustible-dust precautions should be based on actual operations and conditions rather than assuming every distillery has the same hazard.

Lockout/Tagout

Employees performing servicing or maintenance may be exposed to electrical, mechanical, hydraulic, pneumatic, thermal, gravitational, pressure, or other hazardous energy.

Where Lockout/Tagout requirements apply, hazardous energy should be isolated and controlled before servicing or maintenance begins.

Equipment requiring evaluation may include:

• Mills.
• Augers.
• Conveyors.
• Pumps.
• Mixers.
• Stills.
• Packaging equipment.
• Bottling lines.
• Refrigeration equipment.
• Boilers.
• Other powered machinery.

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.

Machine-Specific Energy Control

Where required, energy-control procedures should identify the specific energy sources and isolation methods for the equipment being serviced.

Stored energy such as pressure, heat, gravity, or compressed gas should be controlled before work begins.

Employees should verify effective isolation before beginning covered servicing or maintenance.

Machine Guarding

Mills, augers, conveyors, pumps, bottling equipment, motors, drives, and other distillery machinery 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.

Hot Liquids and Steam

Mash operations, distillation, cleaning, and utility systems can expose employees to hot liquids, steam, heated vessels, and hot surfaces.

Procedures should address:

• Opening valves.
• Disconnecting hoses.
• Transferring hot liquids.
• Opening vessels.
• Steam systems.
• Cleaning operations.
• Appropriate PPE.

Employees should verify system conditions before opening piping, fittings, or equipment that may contain hot or pressurized material.

Boilers and Steam Systems — When Applicable

Distilleries using boilers or steam systems should maintain 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.

Cleaning and Sanitation

Cleaning and sanitation may expose distillery 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 safely be performed under normal operating conditions and when equipment must be shut down and hazardous energy controlled.

Cleaning Tanks and Stills

Cleaning tanks, stills, and vessels may involve clean-in-place systems, spray devices, chemicals, hot water, manual cleaning, or entry into the equipment.

Procedures should address:

• Chemical hazards.
• Flammable atmospheres.
• Carbon dioxide.
• Temperature.
• Pressure.
• Unexpected equipment movement.
• Confined-space requirements.
• PPE.
• Spill response.

Employees should not enter a vessel merely because it has been drained or rinsed.

Caustics, Acids and Sanitation Chemicals

Distilleries may use caustic cleaners, acids, sanitizers, and other chemicals capable of causing skin burns, eye injuries, respiratory irritation, or other health effects.

Employees should:

• Follow label and Safety Data Sheet precautions.
• Use required PPE.
• Follow established dilution procedures.
• Avoid unauthorized chemical mixing.
• Use appropriate transfer equipment.
• Maintain container labels.
• Report leaks and damaged containers.

Chemical Transfer and Dilution

Chemical transfer and dilution should be performed in a manner that minimizes splashing, spills, and employee exposure.

Employees should follow manufacturer instructions and established procedures.

Appropriate eye, face, hand, and body protection should be used based on the hazard.

Emergency Eyewash and Shower

Where employees may be exposed to corrosive materials requiring immediate flushing, suitable emergency washing facilities should be readily available as required.

Access should remain unobstructed.

Employees should know the location of emergency eyewash and shower equipment and how to use it.

Hazard Communication

Employees exposed to hazardous chemicals should receive appropriate information and training.

The Hazard Communication Program should address applicable:

• Chemical inventories.
• Safety Data Sheets.
• Container labeling.
• Employee information and training.
• Non-routine tasks.
• Contractor communication.

Employees should understand how to obtain and use Safety Data Sheets.

Personal Protective Equipment

PPE requirements should be based on workplace hazard assessments and employee tasks.

Depending on the work performed, PPE may include:

• Safety glasses or goggles.
• Face shields.
• Chemical-resistant gloves.
• Heat-resistant gloves.
• Protective footwear.
• Chemical-resistant clothing.
• Hearing protection.
• Other task-specific protection.

PPE should be appropriately selected, maintained, and used.

Eye and Face Protection

Employees performing chemical transfer, hose disconnection, cleaning, pressurized operations, or other tasks that create splash or impact hazards should use appropriate eye and face protection.

A face shield should not automatically be considered a substitute for required primary eye protection.

Hand Protection

Hand protection should be selected according to the specific hazard.

Different distillery tasks may require protection from:

• Chemicals.
• Heat.
• Cuts.
• Abrasions.
• Cold.
• Sharp packaging materials.

Employees should understand the limitations of the gloves provided.

Respiratory Protection — When Applicable

Engineering and other feasible controls should be used where appropriate to control airborne hazards.

When respirators are necessary to protect employees, the distillery should maintain an appropriate Respiratory Protection Program addressing applicable requirements 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.

Barrel Handling

Barrels are heavy and can create crushing, pinch-point, rolling, stacking, and ergonomic hazards.

Mechanical handling equipment should be used where practical.

Employees should:

• Keep hands and feet clear of pinch points.
• Control barrels during movement.
• Use appropriate barrel-handling equipment.
• Avoid standing in the path of uncontrolled rolling barrels.
• Ensure stored barrels are stable.

Barrel Storage and Warehouses

Barrel racks and storage systems should be maintained in stable condition.

Storage arrangements should consider:

• Rack condition.
• Stable placement.
• Forklift access.
• Pedestrian routes.
• Fire protection.
• Emergency access.
• Flammable-liquid hazards.

Employees should not climb barrel racks unless a system is specifically designed for access.

Bottling and Packaging

Bottling, labeling, capping, case-packing, and palletizing equipment can expose employees to moving machinery, conveyors, pinch points, broken glass, compressed air, repetitive work, and hazardous energy.

Employees should:

• Keep guards in place.
• Follow operating procedures.
• Stay clear of moving equipment.
• Use established procedures for jams.
• Report defective safeguards.
• Follow applicable energy-control procedures during servicing or maintenance.

Broken Glass

Broken bottles can create serious cut and puncture hazards.

Employees should use appropriate tools and PPE when cleaning broken glass.

Broken glass should not be picked up with bare hands.

Damaged containers should be disposed of according to established procedures.

Conveyor Safety

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.

Jam Clearing

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.

Manual Lifting and Material Handling

Distillery employees may handle grain bags, barrels, cases, chemical containers, cylinders, packaging materials, 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.

Ergonomics

Barrel handling, case handling, bottling, palletizing, ingredient handling, and other repetitive production activities can create ergonomic stress.

Potential risk factors include:

• Repetitive motion.
• Heavy lifting.
• Awkward postures.
• Forceful exertion.
• Excessive reaching.
• Prolonged standing.

Workstations, equipment, work practices, and material-handling methods should be evaluated and improved where practical.

Slips, Trips and Falls

Wet floors are common in production and sanitation areas.

Water, spirits, mash, chemicals, hoses, drains, packaging materials, and other conditions can create slip and trip hazards.

Employees should:

• Clean spills promptly.
• Control hoses and cords.
• Maintain clear walkways.
• Use warning signs or barriers when necessary.
• Report damaged flooring and drainage problems.
• Wear appropriate footwear.

Walking-Working Surfaces

Floors, stairs, platforms, catwalks, ladders, and other walking-working surfaces should be maintained in safe condition.

Elevated work areas around tanks and production equipment should have appropriate fall protection where required.

Employees should not climb on tanks, piping, barrel racks, or other surfaces not designed for access.

Forklift/PIT Safety — When Applicable

Distilleries 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:

• Operator training and evaluation.
• Pre-use inspections.
• Load capacity.
• Stability.
• Pedestrian safety.
• Traveling and turning.
• Barrel and pallet handling.
• Loading and unloading.
• Dock and trailer operations.
• Battery charging or fueling.
• Equipment maintenance.

Powered industrial trucks used in or near areas where flammable vapors may be present should be appropriate for the location and conditions.

Pallet Jack Safety

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.

Warehouse and Storage Safety

Finished products, barrels, ingredients, packaging materials, chemicals, and other materials should be stored securely.

Storage procedures should address:

• Stable stacking.
• Rack condition.
• Aisle clearance.
• Forklift traffic.
• Falling objects.
• Chemical compatibility.
• Flammable-liquid hazards.
• Emergency access.
• Fire protection.

Loading Dock Safety

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 distillery personnel.

Loading and Unloading

Employees loading and unloading ingredients, barrels, cases, packaging materials, and other products should remain aware of vehicle movement, unstable loads, pinch points, and material-handling hazards.

Alcohol loading or transfer operations should also address applicable flammable-liquid and static-control precautions.

Electrical Safety

Electrical equipment, cords, plugs, panels, motors, pumps, and controls should be maintained in safe condition.

Electrical installations in locations where flammable gases or vapors may be present should be evaluated for applicable hazardous-location requirements.

Employees should not use damaged electrical equipment.

Only qualified or otherwise authorized personnel should perform electrical work requiring specialized knowledge or training.

Noise

Mills, compressors, bottling lines, conveyors, pumps, and other distillery equipment may create significant workplace noise.

Employee noise exposure should be evaluated where necessary.

Engineering or administrative controls should be considered where appropriate.

Hearing Conservation — When Applicable

Where employee noise exposures trigger applicable requirements, the distillery should maintain an appropriate Hearing Conservation Program.

The program may include exposure monitoring, audiometric testing, hearing protection, training, and recordkeeping.

Compressed Air

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

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.

Refrigeration Systems — When Applicable

Distilleries 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.

Process Safety Management — When Applicable

Distilleries should evaluate their processes and quantities of flammable materials and other covered chemicals to determine whether Process Safety Management requirements apply.

Where PSM applies, the facility should maintain the required program.

PSM applicability should be determined from the actual process configuration, materials, quantities, storage arrangements, and applicable exemptions rather than assuming that every distillery is automatically covered.

Fire Prevention

Fire-prevention procedures should address the hazards present within the distillery.

Potential considerations include:

• Ethanol and spirits.
• Flammable vapors.
• Grain dust.
• Electrical equipment.
• Static electricity.
• Hot work.
• Boilers.
• Packaging materials.
• Chemical storage.
• Maintenance activities.

Fire extinguishers and other fire-protection equipment should remain accessible.

Emergency Action Plan

Employees should understand procedures to follow during foreseeable distillery emergencies.

The Emergency Action Plan may address:

• Fire.
• Explosion.
• Flammable-liquid release.
• Carbon dioxide release.
• Chemical spill or release.
• Refrigerant release.
• Pressure-system failure.
• Medical emergencies.
• Severe weather.
• Power failure.
• Evacuation.
• Shelter-in-place.

Employees should understand alarm methods, exit routes, assembly areas, and emergency reporting procedures applicable to their workplace.

Emergency Exits and Egress

Exit routes should remain accessible and reasonably free of obstructions.

Barrels, pallets, cases, 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.

First Aid and Medical Emergencies

Distilleries 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 injuries may include burns, chemical exposures, cuts, strains, eye injuries, and injuries involving machinery, pressure, or material handling.

Laboratory Safety — When Applicable

Distilleries performing laboratory or quality-control testing should evaluate hazards associated with laboratory chemicals, glassware, compressed gases, heating equipment, and other laboratory activities.

Laboratory procedures should reflect the type and extent of testing actually performed.

Hazardous Waste — When Applicable

Distilleries 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.

Contractor Safety

Outside contractors may perform electrical, mechanical, boiler, refrigeration, construction, tank, fire-protection, or other specialized work within the distillery.

Contractor coordination should address relevant workplace hazards and applicable safety procedures.

Particular attention should be given to contractor activities that could introduce ignition sources into flammable-liquid or vapor areas.

Tasting Room Safety — When Applicable

Distilleries operating tasting rooms or other public hospitality areas should evaluate hazards associated with employees working directly with customers.

Potential considerations include:

• Slips and falls.
• Broken glass.
• Material handling.
• Cleaning chemicals.
• Emergency procedures.
• Workplace violence.
• Security.
• Food service where applicable.

Production and hazardous-process areas should be appropriately protected from unauthorized public access.

Delivery and Vehicle Operations — When Applicable

Distilleries operating delivery or company vehicles should establish appropriate vehicle-safety procedures.

Programs may address:

• Authorized drivers.
• Vehicle inspections.
• Seat-belt use.
• Distracted driving.
• Backing.
• Loading and securement.
• Delivery-site hazards.
• Accident reporting.

Working Alone — When Applicable

Employees working alone during distilling, fermentation, maintenance, laboratory work, opening, closing, or other activities may face increased risk during emergencies.

Procedures should address communication, emergency assistance, and hazards associated with the work being performed.

Higher-hazard tasks should be evaluated to determine whether working alone is appropriate.

Distillery Safety Training

Safety training should reflect each employee’s assigned work and exposure.

Depending on operations, training may address:

• General distillery safety.
• Flammable liquids and vapors.
• Fire and explosion prevention.
• Ignition-source control.
• Carbon dioxide.
• Confined spaces.
• Lockout/Tagout.
• Machine guarding.
• Chemical safety.
• Hazard Communication.
• PPE.
• Hot liquids and steam.
• Grain handling.
• Combustible dust.
• Bottling equipment.
• Barrel handling.
• Forklifts and pallet jacks.
• Emergency procedures.

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 and Short-Service Employees

New employees may be unfamiliar with distillation processes, flammable-liquid hazards, equipment, chemicals, carbon dioxide, and emergency procedures.

Orientation should address:

• General safety rules.
• Flammable-liquid and vapor hazards.
• Ignition-source restrictions.
• Carbon dioxide.
• Department-specific hazards.
• Emergency procedures.
• Injury reporting.
• PPE.
• Equipment restrictions.
• Chemical safety.
• Slips and falls.
• Material handling.

Additional supervision should be provided when appropriate until employees demonstrate the ability to perform their assigned work safely.

Distillery JSA/JHA

Distilleries can use JSAs/JHAs to document safe work procedures for recurring higher-hazard tasks.

Potential Distillery JSAs/JHAs include:

• Grain handling.
• Mill operation.
• Mash operations.
• Still operation.
• Still startup and shutdown.
• Alcohol transfer.
• Tank cleaning.
• Confined-space entry.
• Chemical transfer.
• Barrel handling.
• Bottling-line operation.
• Forklift operation.
• Loading and unloading.
• Maintenance activities.

Distillery Toolbox Talks and Safety Meetings

Short safety meetings can reinforce safe work practices and address current workplace concerns.

Potential topics include:

• Flammable-liquid safety.
• Ignition-source control.
• Carbon dioxide.
• Confined-space awareness.
• Lockout/Tagout.
• Chemical handling.
• Hot liquids and steam.
• Preventing slips and falls.
• Barrel handling.
• Safe lifting.
• Machine guarding.
• Forklift safety.
• PPE.
• Emergency procedures.

Additional Safety Programs

Depending on distillery operations, additional safety programs may be necessary for:

• Process Safety Management.
• Respiratory Protection.
• Hearing Conservation.
• Fall Protection.
• Ladder Safety.
• Heat Stress.
• Cold Stress.
• Welding and Hot Work.
• Hazardous Waste.
• Spill Prevention and Response.
• Laboratory Safety.
• Vehicle Safety.
• Contractor Safety.
• Working Alone.

These programs should be included when employee activities or workplace hazards make them applicable rather than automatically adding programs unrelated to the distillery’s operations.

Building a Distillery Safety Manual

A useful Distillery Safety Manual should reflect the actual workplace rather than simply combining generic manufacturing or brewery safety policies.

A distillery with automated grain handling, multiple stills, substantial ethanol processing and storage, barrel warehouses, automated bottling, boilers, refrigeration, forklifts, and laboratory operations may require substantially more safety programs than a small craft operation with limited production equipment.

The manual should consider:

• Distillery size.
• Spirits produced.
• Fermentation and distillation processes.
• Ethanol concentrations and quantities.
• Stills and vessels.
• Pressure systems.
• Alcohol transfer and storage.
• Grain-handling equipment.
• Barrel operations.
• Bottling systems.
• Chemicals.
• Utilities.
• Warehousing.
• Material handling.
• Tasting-room operations.
• Delivery operations.
• Maintenance activities.

Selecting the appropriate programs creates a manual that is comprehensive without filling it with procedures unrelated to the employer’s operations.

Customized Distillery Safety Manuals

A Distillery Safety Manual can be developed around the specific distillation processes, equipment, flammable-liquid operations, storage systems, barrels, packaging equipment, chemicals, and employee exposures of the business.

The finished manual may incorporate applicable programs for flammable liquids, fire and explosion prevention, carbon dioxide, confined spaces, Lockout/Tagout, machine guarding, chemical safety, PPE, grain handling, barrel handling, forklifts, emergency procedures, and other hazards present within the operation.

This provides distillery employers with a practical safety manual organized around the work their employees actually perform.