plan should identify the potential hazard, determine how it can be mitigated, and clarify who is responsible. Plans should be used by employees to understand the risks, and their mitigation, unique to their workplace, and by employers to document safety standards. Standard distilleries may have eight to twelve plans, although the final number will vary for a specific location.
STEP 3: TRAINING OSHA requires that every employee receive training on the potential risks inherent with each job activity, how to properly perform these activities, and how to respond in the event of a problem or injury. For certain activities training must occur at regular intervals and be documented.
STEP 4: IMPLEMENT, MONITOR
and
MAINTAIN
Consistent implementation is the core of all safety programs. Once a plan is deployed, a monitoring program must be established to ensure that it is being followed. Depending on the task, its monitoring may be simple or complex. It is not sufficient to merely tell employees that they need to follow certain protocols, you need to have a system in place for each task to ensure that standards are being followed consistently.
STEP 5: RECORD KEEPING Records need to be kept for all processes, training, implementation, and monitoring. Maintaining proper records for each employee’s training is essential in the event of a lawsuit or an investigation. Safety records must be kept for upwards of 30 years.
— For small distilleries the above process can be intimidating— but it’s easier than obtaining a DSP. For those wanting to handle everything in-house, OSHA’s website provides resources to identify risks by category (i.e. nearly all distilleries have manufacturing, storage and office facilities, many include tasting rooms) and outlines the standards that need to be met. More commonly, companies will utilize a consultant or subscription-based service to alleviate the administrative burden. Outsource compliance companies will provide all of the plans, training, monitoring and
WWW.ARTISANSPIRITMAG.COM
record keeping required for compliance. Since they utilize industryspecific libraries, modified for your specific facility, the cost of implementation is a fraction of trying to do it oneself. As distillery owners, the well-being of our employees and business is synergistic, not exclusive. OSHA compliance is a legal obligation, like TTB and IRS reporting. Since safety is a public concern, then anyone can file an anonymous complaint or request an investigation—be they a former disgruntled employee, competitor or concerned citizen. In addition to fines and penalties, willful negligence can expose the owners, officers and directors to personal liability and criminal charges. OSHA’s line of communication to other federal agencies often results in concomitant investigations by other agencies, including the IRS and TTB. As a result of this potential for undisclosed exposure, investors and potential buyers often leverage this information to discount a company’s valuation. Being able to show safety protocols, proof of training and historical records protects the company from litigation thus eliminating a key negotiating point during a business sale. In addition to maintaining corporate value, a strong safety program improves profitability both by increasing revenue and decreasing costs. Implementing standard processes increases efficiency and is the foundation of scalability. By removing ambiguity from core functions, staff productivity improves as effort becomes focused on execution rather than interpretation. Finally, risk management decreases downtime and employee absence, and when coupled with discounted insurance rates available to companies with compliant safety programs the result is significant cost savings. In conclusion, while compliance with the OSH Act is mandatory, implementation transcends risk mitigation and when systematically applied increases productivity, decreases operating costs and raises corporate valuation. With the availability of simple, off-the-shelf solutions from consultants and outsource companies there is no reason why your staff and visitors should not be provided with the safest environment possible. Robert Pignataro is President and CEO of American Compliance Systems. For more info, visit www.acs-safety.com or email rpignataro@acs-safety.com. R. Scott Winters is Founder of The American Spirits Exchange. For more info, visit www.AmericanSpiritsLtd.com or email Scott@AmericanSpiritsLtd.com.
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