Yes, the time has come. Under the new OSHA recordkeeping rules, employers must submit the information from their completed 2016 Form 300A (Summary of Work-Related Injuries and Illnesses) to OSHA electronically by December 1, 2017.
Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses. Most breweries are considered manufacturing with the NAICS code 312120 and therefore would be required to report if they have 20 employees or greater. Please check the NAICS code for your establishment with the OSHA chart to see if your facility is required to report.
The Injury Tracking Application should be available using this link August 1st. OSHA states establishments of 20-249 employees should take no longer than 20 minutes to complete the electronic form.
Happy Brew Year!!! How’s your safety program going? The beginning of the year is a great time to sit down and really think about safety. Studies have shown for every $1 invested in safety the return is $3. So if your brewery hasn’t already taken safety seriously, now is the time to review your safety programs not just for OSHA compliance but to increase profitability of the brewery going forward.
Where to start? There are great resources and expertise out there. The Masters Brewers Association of Americas (MBAA) has a library of safety program templates, safety tool box talks (from forktrucks to alcohol consumption), and a “ask a safety team Q & A”. The Brewers Association has publications on best management practices (BMPs) for Confined Spaces, Personal Protective Equipment, and Powered Industrial Trucks. As well as a FREE online task specific safety videos (highly recommended).
For more info go to:
MBAA Brewery Safety:
Brewers Association Safety:
Cheers to safety in 2017!
Call OSHA? What? Yes! I tell all breweries starting out to call OSHA. OSHA offers free and confidential on-site consultation in all states across the country for small businesses. On-site consultation services are separate from enforcement and do not result in penalties or citations. However, businesses are required to correct serious job safety and health hazards which is agreed upon prior to consultation.
Using OSHA’s consultation service lowers injury and illness rates, ultimately saving both employers and employees. So go ahead and pick up the phone.
Going to the World Brewing Congress in August? The MBAA Brewery Safety Committee will be having a happy hour at the WBC in Denver, on Tuesday (8/16), from 5:30 – 6:45PM. The meeting will be held in the WBC Hospitality Suite.
Please stop by to chat with some of the Brewery Safety Committee members, or just network with others interested-in promoting safe brewing practices.
Going to the World Brewing Congress in Denver this year? A 10 hour General Industry safety class is being offered as a pre-conference course set up by the MBAA safety committee. Subjects covered will be Intro to OSHA, Walking and Working Surfaces, Life Safety, Health and Safety, Personal Protective Equipment, Noise, Forklifts, Ergonomics, and Hazardous Materials. The course will have a brewery focus. The attendees will received a 10 hour General Industry OSHA card at the end of the course.
I had an interesting conversation with fellow colleagues the other day about safety compliance being on display at breweries. Many breweries welcome the community into their facilities to educate folks about the operation and their products which is something you don’t see in other industries. Some tap rooms are located in the middle of the facility or the brewery can be seen behind a clear wall, also as a form of making a connection with the community. At the same time, breweries run the risk of being viewed by regulators at any given time.
Here are some compliance issues found at breweries and are very easy fixes:
Issue #1: Cylinders are not properly chained and fire extinguisher is blocked.
Issue #2: Far left spray bottle is not labeled.
Issue #3: Fire extinguisher is blocked
Issue #4: Ensure proper stacking overhead (sorry for the headshot in the pic (:)
Breweries regardless of size need to be on top of safety more now than ever with their popularity. The community connection is what I love about this industry and I never want that to go away.
If you have not used a Loss Control Specialist from your insurance company, now is a great time to do so at your brewery. Most workers’ compensation insurance policies “bake in” costs for a Loss Control Specialist (LCS) to come to your facility annually. This person can audit your facility for safety issues, help troubleshoot safety problems, and review your safety programs. The key to using these services is to be prepared and target your areas of concern. Here are a few tips to get the most out of using your Loss Control Specialist:
Tip #1: Document your list of questions and issues beforehand
The Loss Control Specialist has questions of their own that they are required to have answered when they arrive. You may get so caught up in their agenda that you forget to ask your own questions.
Tip #2: Prep with your LCS ahead of time and have operations ready to go to demonstrate any known issue
If any of your concerns require monitoring equipment, let your LCS know ahead of time. Many times I would use my LCS for ventilation issues, so having them bring the right equipment like a velometer was helpful.
Tip #3: Ask what other industries are doing as a best practice
Your LCS has experience across a variety of operations and can usually share some creative solutions with you.
Tip #4: Ask about OSHA trends and new regulations
The LCS should be educated in new regulations coming out that may impact your operations.
Tip #5: Ask when your insurance policy will be up for renewal
Sometimes, when your policy is up for renewal, the insurance company may try to keep you as a happy customer by allowing the Loss Control Specialist to do extra monitoring or training. It’s always great to ask.
Remember, your Loss Control Specialist is there to help guide you as a limited resource. The insurance company provides a set amount of hours for you to utilize an LCS each year. The LCS is not meant to be your sole safety resource, but they definitely carry a wealth of information to help manage risk and improve safety at your brewery.