OSHA’s Regional Emphasis Program (REP) for the beverage manufacturing industry has been ongoing since 2019. If you have yet to be inspected, it is likely just a matter of time, and being informed and prepared can make a huge difference in the outcome.
All breweries in Colorado should be prepared to be inspected. To assist in that preparation, here are some quick tips and takeaways:
1) Participation in CSU’s Occupational Health and Safety Consultation Program is highly encouraged. It is FREE and, while it does not formally exempt you, if you are on the waiting list or in the middle of the review process, OSHA will often postpone their inspection until that is completed.
2) Be prepared when OSHA shows up. They will show up unannounced and require access in a timely manner. Have a plan for who should be called (if not present) to accompany the inspector. There is a great publication by the Brewers Association titled “Surviving an OSHA Inspection” which outlines specific steps.
2) Top concerns for our industry are confined spaces, forklifts, occupational noise exposure and ergonomics.
3) Participation in OSHA’s SHARP program (designed for small employers with less than 250 employees) and fulfillment of its requirements can exempt an employer from an OSHA inspection for a limited time.
4) Be educated on the requirements. If you are not already an expert on workplace safety, spend some time learning. We have compiled some great resources to help get you up to speed at the end of this post.
OSHA presentations regarding the REP have become commonplace at industry events, such as the annual Brewer’s Summit. We strongly recommend you take advantage of these talks and ask questions. The folks from OSHA are extremely helpful and forthcoming. Their intention is to inform and protect us, not entrap. Please utilize them and the resources provided below
Resources:
• Sign-up for CSU Occupational Health and Safety Consultation program
• Info on OSHA’s SHARP program
• BA’s Best Practice for the Management of Confined Spaces in Breweries
• BA’s Best Practice for the Management of Powered Industrial Trucks
• BA’s Best Practice for Surviving an OSHA Inspection
• BA’s Best Practice for the https://www.brewersassociation.org/best-practices/safety/protective-clothing-for-brewery-workers/
• Sample Safety and Health programs from OSHA
• MBAA safety resources, including templates and safety meeting topics
