Brewery Safety: Principles, Processes, and People by Matt Stinchfield is the premier brewery safety book and a comprehensive guide to evaluating, educating, and executing safety measures and putting brewery staff, operations, products, and visitors first. The book is available at BrewersPublications.com and at national retailers beginning August 22.
Alongside creative and carefully crafted beverages, breweries of all sizes should uphold the value of safety. It’s the responsibility of all brewery employees to assess hazards, learn how to control or eliminate them, and document and train each other on the safest ways to perform tasks. It’s not just about government regulation; it’s also about maintaining the best brewery possible—for your beer, your staff, and your visitors.
The following is an excerpt from Brewery Safety: Principles, Processes, and People by Matt Stinchfield.
In the grand scheme of the hazard assessment (HA) process, probably the most challenging step is determining which hazard controls to use. What preventive and protective measures will you employ to reduce the totality of hazards that come with any brewery task? In fact, this step¬ isn’t as hard as you might think because earlier in the HA process you will have already out¬lined each task and identified possible haz¬ards for each step of the task.
WHAT ARE HAZARD CONTROLS?
Hazard controls are steps taken to reduce or eliminate any known or anticipated hazard that could cause harm to persons, equip¬ment, processes, or the environment. To select the best controls, you need to think about each of the possible hazards related to the task and come up with one or more solu¬tions to reduce or eliminate those hazards.
The hazards might be common, even ob¬vious, or they might be rare and more the¬oretical. Hazards have known attributes.
If you understand those attributes, you can select the best countermeasures.
It is important to understand what haz¬ardous energy transfer is involved. For in¬stance, if an ultraviolet light source can injure the eye, blocking the ultraviolet light from hitting the eye is an obvious solution. But to properly implement a hazard control requires more than that. Think creatively about how to block the light.
Does it involve shielding the light source or wearing special safety glasses, or is there a way to avoid using the ul¬traviolet light altogether? When you have decided which approach(es) you plan to use, then you have selected your hazard controls. The ultraviolet light example il¬lustrates how the best hazard control is to avoid the hazard altogether, but this is not always possible. In cases where the hazard remains, we need protection. In a brewery, you are necessarily going to have ladders and heavy bags of ingredients, and boiling liquids and asphyxiating gases.
Legally, it is up to the employer to learn what these hazards are and to minimize them.
SELECTION OF CONTROLS
Why we select some controls over others is based on a value equation. This equation, or rationale, considers the effectiveness and re¬liability of the control strategy, as well as the cost to implement it. We also have to rec¬ognize the severity of the hazard. Common hazards that cause loss of life warrant signif¬icant controls, even if they might never be called into use.
Prevention and Protection
As the saying goes, the best defense is a good offense. With hazard controls, the best way to reduce risk is to understand the hazard and preempt it before it can do harm. If you can manipulate the situation so that the hazard ceases to exist or the hazard cannot affect you, you have used prevention. If you accept that the hazard exists, or if you can’t do your job without the hazard being present, but you use con¬trols to lower the chance of a bad outcome, you have used protection.
Hierarchies of Control
There are numerous factors that play into the selection of a hazard control. How expensive is the control? Is it effective and reliable? Does it require workers to act in a precise way, to read a sign or a label, or to have specific training? Will people employ the chosen control strategy? Does the control impact the time or cost of a certain process? Who is legally responsible for safety?
One control may be cheap and easy, but does it have the reliability we want? Another could be expensive, effective, but require regular maintenance, for example. It could be that using these controls together pro¬vides the best chance of avoiding harm.
These sorts of questions have led safety professionals to create formulaic approach¬es to hazard controls, to try to make the selection of controls adhere to a system. Such a system, termed a hierarchy of con¬trols (HoC), is a starting point but not a panacea, for the very reason that we often choose two or more hazard controls to en¬sure safe operations.
The simplest view is that the employer pro¬tects the employee from whatever hazards exist in the workplace. This falls short on two fronts. If the employer is not keenly aware of workplace hazards and not suffi¬ciently motivated to keep them in check, the employee is bound to suffer. This view also runs contrary to OSHA’s original intent in the OSH Act, which clearly requires both employers and employees to work together to create a safe business.
OSHA’s Hierarchy of Controls
OSHA’s hierarchy of controls is widely cited and repeated throughout the entire global safety universe. Its principles pre-date the creation of the agency in 1970, going as far back as the 1930s. The OSHA hierarchy of controls is an effective way of prioritizing workplace controls, although it has been criticized by proponents of be¬havioral safety and effective safety culture, including this author.
Historically, standards agencies (includ¬ing OSHA) have taken the view that the employer is primarily responsible for work¬place safety, following the “control at the source” mantra. This approach views work¬place behaviors and personal protective equipment (PPE) as supplemental controls in the event that an engineering control fails while in use, cannot adequately reduce ex¬posure to within permissible limits during normal operations, or is currently not fea¬sible. A rendition of this typical hierarchy of controls is shown in Figure 1. In this view, protective actions taken by employ¬ees are seen as vulnerable to the vagaries of employee behavior and extenuating circum¬stances (e.g., pressure to meet productiv-ity targets, or discomfort caused by PPE). Thus, the employer will put hazard con¬trols into place, design with safety in mind, provide necessary engineering controls and PPE, and train the workforce. Some opin¬ions from organized labor unions go as far as to suggest that even partially relying on a worker acting safely constitutes dereliction of safety and fiduciary responsibility on the part of the employer.
Protective equipment and systems should, in theory, allow a worker to fo¬cus on production rather than worrying about their safety; their safety is largely seen to by the employer. Focusing mainly on these types of controls is to focus on hazard controls that are often capital-in¬tensive. If an employer is not living up to their end of the bargain, the workforce may not be prepared to protect them¬selves. An effective safety culture requires managers and employees to hold certain common beliefs, values, assumptions, feelings, and business systems for safety to really work.
One more criticism of the mainstream hierarchy of controls is how little value is given to the worker’s own volition. This self-determination to remain safe is often called safe work practices, but I like to think of it as “thoughts and actions”—hazard con¬trols that do not require equipment or other institutional controls.
A safety system where the worker is given a little more credit for avoiding hazards on their own can exist, but it relies heavily on the tenets of an effective safety culture. There are lots of behavioral pitfalls; we could even consider these to be behavioral hazards. A good safety culture has to overcome these behavioral haz¬ards, just as it would with physical and chem¬ical hazards in the workplace. Safe behavior is due to an individual’s training, experience, and mentoring, but it will require manage¬ment support, healthy communication, ac¬countability, and a high level of participation.
Put brewery staff, operations, products, and visitors first.
A good safety program will make your brewery the best brewery possible—for your beer, your staff, and your visitors.
Employees face hazards in every area of the manufacturing environment. From physical trauma to chemical irritations, biological hazards to psychosocial risks, Brewery Safety: Principles, Processes, and People covers how to train staff and prevent accidents. Evaluate, educate, and execute safety-conscious measures to ensure that the working environment, welfare of staff, and the quality of your products are first and foremost. Important chapters on brewery culture, measurements, and systems are also included.
Author Matt Stinchfield has been part of the Brewers Association’s Safety Subcommittee since 2013, including four years as chair. He has served as safety ambassador for the Brewers Association and hosted countless trainings and seminars to educate and inspire brewery owners all over the United States.
Purchase Brewery Safety: Principles, Processes, and People at BrewersPublications.com or your favorite bookseller today.