Spring is around the corner! It’s a great time of year to look at your safety training to ensure your employees are protected and the brewery is in OSHA compliance. Talk with your production folks to plan a “safety training calendar” in order to conduct training sessions during lower production cycles of the brewery. It’s a great best practice to plan training ahead (and who doesn’t like a little bit of structure?). Here are some applicable OSHA standards to start off but more standards may apply pending on the operation, hazards, and location of your facility:
- Forklift (Powered Industrial Trucks)*
- Fall Protection
- Confined Space*
- Hazard Communication
- Personal Protective Equipment (PPE)
- Portable Fire Extinguishers*
- Welding and Cutting
- Machine Guarding
- Compressed Gases
- Ladders and Stairways
*Note: Some standards have a reoccurring assessment or training component even if hazards remain the same such as: portable fire extinguishers (annual training -CFR 1910.157(g)(2)), powered industrial trucks (3 year eval and permit renewal – CFR 1910.178(l)(4)) , confined spaces (annual review of permits/process – CFR 1910.146(d)(14), lockout/tagout (periodic inspection annually – CFR 1910.147(c)(6)(i)) etc.
Well, it’s time to get back to the grind after a nice holiday break. It’s also a time for fresh starts and goal-setting for a new year. It can be tricky to set safety goals in advance – sometimes it’s difficult to quantify how many incidents and accidents were prevented, or will be prevented. However, there are some solid ways to set attainable goals for safety in your workplace. Here some tips to set a tone for a very productive and safe year:
Think of safety goals as two categories – Quantitative (numbers) and Qualitative (how are you going to achieve that number?)
For example, start with your company’s injury rate, a quantitative goal – can it be lowered? What about the number of safety inspections – can the amount be increased? What about the number of employees participating in your safety program? All great ways to lay out quantitative metrics.
Okay, you have a number. Now think, how is your company going to get to that number? Is it by an emphasis program (ie. PPE usage), increased training, increased audits? Come up with a statement outlining concrete steps or strategies to hit that quantitative metric. Plan a timeline to carve the metric into smaller chunks that you can target to meet on a regular basis (monthly or quarterly). Measure how well you are performing to that goal, and determine ways to change the game if you’re falling behind your targets.
Look at the low hanging fruit
Are there incidents happening over and over again or is your facility not in compliance with an OSHA standard? Are you so perfect, you can’t stand yourselves? Think of the future with an aging workforce – is it time to implement ergonomic programs to prevent injuries? What about implementing a behavioral based safety program?
My best advice: include employees in the goal setting process
Hopefully, you have some ideas brewing in your head. Setting a safety goal that is not achievable can be a huge drag for the rest of year and can also bring the overall effectiveness of your safety program down. Employees can give great feedback, and involvement and can also motivate participation in strategies to achieve the safety goals.
Falls from heights is one of the number one reasons workers are killed on the job and the most cited violation by OSHA. Fall protection requirements can be easily overlooked in a brewery operation. Areas to look around for fall risks are:
- Mezzanines (if someone is on the mezzanine receiving a load when the railing is removed).
- Scissor lifts – workers always should be tied off when working from the platform (think catapult – things in motion want to stay in motion)
- Climbing to higher heights (leaving the ladder)
Keep in mind calculating fall distance when planning for a job needing fall protection. For instance, a shock absorbing lanyard is a poor choice in areas where fall distance is short. The worker would most likely hit the ground before the lanyard would engage. Miller Fall Protection has a great tool to calculate the fall distance and help choose the best protection:
Attached is a list of the OSHA general industry standards indicating fall protection requirements (ie. manlifts, guarding floor openings, ladders, PPE, etc). Remember state by state plans may even have more stringent rules.
Yes, it is November and October is typically fire safety month (to correspond with the Great Chicago Fire of 1871) but it’s never too late to review fire safety. Here are a few tips:
#1: Do the Opposite – Teach your employees how to shut off the fire suppression system. Seems odd, but if a shower head gets knocked by the mast of a fork truck, it’s a good thing to know to minimize damage. Label the shut offs and shoot a short video with iMovie. It’s a great idea to show this process to new hire employees, and to review it annually with everyone.
#2: Train Annually – Did you know employers providing portable fire extinguishers for employee’s use in the workplace need to provide initial training and annually thereafter? Ask the company that maintains your fire extinguishers to put aside some the extinguishers that have just fallen below the recharge line so that your employees can practice discharging them.
#3: Give a tour of your facility to your fire department – A tour for the fire department gives first responders a lay of the land so that they aren’t entering your facility as a complete unknown if there is ever an emergency. And, it can create relationships you can leverage to help with your internal safety training.
OSHA Fact Sheet on Fire Prevention
OSHA’s Training Requirement of Portable Fire Extinguishers
Although developing a safety culture takes a great deal of effort and time, here are some tips to get your brewery on the right track:
Tip # 1 – Open communications with employees
Give employees an open way to communicate safety issues. Don’t wait for employees to tell you. Ask questions at production meetings, such as, “I noticed safety glasses are not being worn, any reason why?” When asked, employees will tell.
Tip #2 – Be an example
There is nothing worse than telling someone else what to do, then not following the same rules. Not cool.
Tip #3 – Be positive
When correcting a safety behavior, be positive first, then point out a way to improve. Nobody likes getting a lecture on the job.
Tip #4 – Care
The whole reason for creating a safety culture is because you care about your employees, and employees should care about the people working around them. Encourage employees to speak up when they see risky conditions or behavior. Point out that this will save someone from getting injured, and give them the ability to hold their kids or pet their dog when they get home.
The early bird registration for the Chicagoland Safety, Health & Environmental Conference ends tomorrow. Conference is in Naperville, Sept. 21-24th. There are many applicable sessions to the brewing industry. Here are some of my suggestions:
- Sept. 22nd – Process Safety Management (PSM) – My two cents -this is the most cited standard by OSHA among breweries.
- Sept. 22nd- Administrating a Respirator Protection Program
- Sept. 23rd – There is an App for that! Using your smart device to improve EHS performance – Went to this session before, it was amazing!
- Sept. 24th – Combustible Dust
To register go to: http://cshc.us/
Hope to see some brewery folks there!
What the heck is the number 312120??? It’s the NAICS (North American Industry Classification System) code for breweries. OSHA compiles citation and injury data for different industries using NAICS codes, then makes the data available to the public.
From October 2013 through September 2014, $141,960 in penalties were issued to breweries for OSHA related violations. Now that is a lot of beer down the drain! Over $100,000 of the penalties issued were violations of the Process Safety Management Standard.
To check OSHA stats such as citation and injury data for breweries (NAICS code: 312120), go to: