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Hi All, I'm working with my city officials so I can get started up and am having some road blocks that I'd like to ask everyone about. 1) Are any of you being forced to have a separate enclosed "controlled area" for your finished packaged products? My officials are insistent that I do so. I've been to several different distilleries and have never seen this. 2) Is there an exemption in the IFC or IBC for bottled products? I have the one for spirit in barrels and I could swear I've seen a bottle exemption mentioned on other threads but I searched through and couldn't find it. 3) Is all of your equipment UL listed? I wasn't aware of this stipulation, is this common or is my city just being extra strict? Are there any ways around this? 4) They are currently trying to classify me as an M occupancy, I know in most cases distilleries are F-1. Should I roll with it and go with M occupancy or correct them to F-1? Thanks in advance for the help and input!
Hi Our building inspector has asked me to hook up an explosion proof fan to an ethanol vapor meter. I have both and ready to install but first he wants to know what the ifc and ibc say about the volume of air that need to be remove if there is a build up of vapors that would trigger the system. Can anyone help me with a quote referencing on or both of these publications. Thank You
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 and requirements. 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 that 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 your State's interpretation 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 (OSHA) rated for moving ANY high proof containers.