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OSHA has made it clear that it will enforce its jurisdiction over the micro-distillers (DSPs) nation wide. Below is a URL for actions taken across the nation by OSHA that includes giants of the industry and micros such as Tuthilltown Spirits in New York. https://www.osha.gov/pls/imis/industry.search?p_logger=1&sic=&naics=312140&State=All&officetype=All&Office=All&endmonth=02&endday=27&endyear=2011&startmonth=02&startday=27&startyear=2016&owner=&scope=&FedAgnCode= What can you do: 1) Review OSHA rules in your state. There are FREE Federal and State level programs that can bring you into compliance and “protect” you from citations. Read the New York State documents below for further details. https://www.osha.gov/dcsp/smallbusiness/consult.html New York State has this program: Division of Safety and Health - DOSH - New York State Department of Labor: https://www.labor.ny.gov/workerprotection/safetyhealth/DOSH_ONSITE_CONSULTATION.shtm Oregon’s Fact Sheet: http://www.cbs.state.or.us/external/osha/pdf/pubs/fact_sheets/fs57.pdf 2) Do not assume that safety consultants working with OSHA rules will be able to give you effective advice on rules that relate to the operation of DSPs. DSPs are not “standard” manufacturing entities. They have unique requirements based on the explosive nature of ethanol and dust from grain operations. 3) Do not assume that your location, size, agricultural or rural location or ownership structure absolve your operation from compliance. Ethanol manufacturing is regulated despite the fact than many (all?!?!?) local code authorities have no understanding of the safety requirements you as an owner or employee need to resolve for compliance. Generally the lack of a local Authority Having Jurisdiction (AHJ) will mean your DSP will operate under State interpretations of Federal regulations. Each State has it’s own interaction/interpretation with Federal OSHA rules. 4) Join DISCUS (Distilled Spirits Council of the United States) and get this document read and conform to the guidance provided. http://www.discus.org/ Recommended Fire Protection Practices for Distilled Spirits Beverage Facilities Tuthilltown’s OSHA investigator used this document as the reference to cite Tuthilltown’s operation. In the absence of specific Federal OSHA guidance for beverage alcohol production (DSPs), expect that your OSHA investigator will defer to this document as the INDUSTRY STANDARD. Expect to be held to this guidance standard!!! 5) Do NOT assume that other CODE (NEC, IBC, etc.) authorities have no jurisdiction on your operation because you are agricultural, small, family/privately owned or just plain nice folks. 6) When you buy a forklift, make sure that it is safety rated for moving ANY high proof containers.
hello all; We are trying to get our licensing from our local fire marshal and I'm just wanting more information on best places to look. I've tried reading some of the threads here but most of them are a bit further down the road so it leaves me a little in the dust. I've been looking at NFPA 30 but I see many people referencing NFPA 400, and an F1 designation, plus some kind of barrel exception??? I'm having difficulty finding those documents online. I've also recently contacted DISCUS but waiting to hear still. Thanks in advance for any direction. Sean
Hi Guys, I'm currently researching ways that we can deal with solids for making whiskey in our still. To start and to keep our initial equipment costs down we are looking at getting a microbrewer friend of mine to custom make our wort for us. Eventually though we would like to do it ourselves and I'd like to know how other people are dealing with this. I would really like to ferment on the grain if possible and separate after. Production wise we're looking at 300-600 gallon batches once per day. Agitation does not seem possible because of the shape of our still aside from dragging a chain around the bottom but that doesn't seem very realistic. I'll attach a picture, the bottom where it would be direct fired is concave. Cheers, Connor