Words by: Ian Wisniewski
Photography by: Dan Malpass - Health & Safety sign at the Diamon Distillery, Guyana
It starts with a beautiful dream: create an amazing drinks brand, launch it to great acclaim and become the latest success story. But turning this dream into reality requires an extensive ‘to do’ list: establish and equip the premises, obtain all the licenses, hire the right staff, develop the branding, and so on. Every aspect is vital, but there’s also one fundamental factor. Health & Safety.
The regulations are stringent and extensive, which is hardly surprising as plenty of things can go wrong in a distillery. "Health & Safety is something you can't skimp on, as the potential effects are catastrophic, including fire and explosions, and directors are liable for any injury to staff, so you could go to jail," says Jamie Baxter, a UK based master distiller and consultant.
As Health & Safety regulations play such a vital role, where do you start ? Order the latest edition of a fully comprehensive Health & Safety Manual ?
"It would be a lot easier if there was such a manual, but there isn't, and it's up to each distillery to find out what's required. We have a dedicated Health & Safety officer who works on-site and writes up a risk assessment of each process, then we divide each process up and risk assess each smaller section. We have a procedure in place to deal with every eventuality," says Laura Davies, the distiller and distillery manager at Penderyn.
Alex Wolpert, founder of East London Liquor Company, adds another perspective, "It's always about finding best practice which is also economically viable. This has to be tailor-made as distilleries and the production methods used vary. But as well as complying with all the legalities, it's also about using common sense."
Needless to say, there are various sources of information.
"There's a whole industry out there who will provide risk assessment and advice, but it has to be done by someone who is sufficiently qualified, and it's a significant cost. The onus is on each distillery to carry out risk assessments, and to have records of this. If something goes wrong your risk assessment will be scrutinised," says Jamie Baxter.
Health & Safety concerns begin at the very beginning, with various safeguards incorporated into the initial concept.
"You have to try and predict any possible risks, and as you can't remove every possible risk you have to minimise it. You can design out a lot of potential problems at the beginning of the project, using a good architect and good suppliers," says Jamie Baxter.
During the build there are some very important visitors who monitor progress and compliance.
"HMRC visit the site throughout the building process, and once everything is completed, HMRC and your insurance company have to sign you off, before you can go into production," adds Alex Wolpert.
Once the distillery is built some 'interior design' is required; not of the decorative, colour co-ordinated kind, but the Health & Safety kind.
"We had different zones within the distillery assessed for danger points, which an external company came in to do for us. Zoning in the distillery is very technical, and we received a huge file with diagrams, defining each zone and stipulating which activities couldn't be done in these zones, and which activities were safer, and the safety clothes required," says Laura Davies.
With regulations specifying exactly how various roles should be conducted, staff training is of course vital to ensure that every procedure is understood and followed. And as every distillery has its own individuality, the range of training is 'a la carte' rather than a set menu.
"In larger distilleries the distilling and bottling process is generally more automated than in smaller distilleries, where more of the process tends to be manual, so smaller distilleries may require different aspects for training, and you might for example have to rotate staff more frequently to reduce the repetitive nature of a particular role," says Jamie Baxter.
Needless to say, implementing Health & Safety is a huge responsibility for a distillery manager, and also for each member of staff who must uphold these regulations.
"Production staff are trained in the operating procedures, and also receive a written version as part of the training, with new staff accompanied by a supervisor for the first 2-3 months. Even after the training period staff receive a regular tool-box talk, which is a 15 minute informal briefing on the shop floor, about electrical risks for example. This helps to keep everything at the forefront of their minds," says Laura Davies.
The subject of electrics certainly needs to be thought about; continuously.
"It's important to minimise electrics in a distillery, and if electrics have to be there they need to be protected, as electrics are a potential source of ignition. This can be as simple as someone switching on a socket and creating a spark, which can potentially ignite alcohol vapours in the air and cause an explosion," says Jamie Baxter.
Clearly, alcohol vapour is a serious concern, though this is only one of a long list of possible issues.
"Alcohol vapour is potentially the most harmful as it's more explosive than alcohol itself. And when staff are working in an enclosed space they can be overcome by alcohol fumes. Similarly, in the fermentation rooms a significant by-product of the process is carbon dioxide, so it's vital to have carbon dioxide monitors to ensure it's safe for people to be there. And if you're milling grain then any spark can cause the dust from milling to explode, which means dust extraction is essential," says Jamie Baxter.
In addition to the threat of explosions, being prepared for the possibility of fire is another vital precaution.
"All staff, wherever they are working in the company, undergo a fire safety course, with some receiving extra training as fire marshals and they are responsible for evacuating the distillery. South Wales Rescue Service comes in periodically to do a survey, to check for example that we have the right signage in case we need to evacuate the distillery, and also to familiarise themselves with the lay out of the distillery in case they need to come here," says Laura Davies.
Anticipating possible risks is of course an essential safeguard, as is running continual checks to confirm that everything is as it should be. One great advantage of technology and computerisation is that each stage of the production process can be monitored, continually, on a screen. However, for all its advantages, technology also has its limitations. A computer or alarm system can indicate a problem, but can't fix it.
"Good quality equipment incorporates a lot of safety features, but if something's not right, it's up to a member of staff to sort it out. Everything in our distillery is manually operated, for example when we take the spirit cut. It's a very hands on approach, and everything depends on the level of care and attention from trained staff," says Alex Wolpert.
Another vital aspect of production is maintenance and cleaning the equipment. As you'd expect, regulations also stipulate exactly how such practicalities should be approached.
"Some things can only happen when I'm present, such as cleaning the mash tun which is a manual job, and as this is a confined space staff require training before being allowed to do this. There's also a procedure in case someone has to be helped out, or removed from the mash tun. As the mash tun is cleaned using a caustic solution staff need to take significant precautions in case of any spillage, this includes protective clothing, safety shoes, bump caps, gloves, eyewear and face masks. If a cleaning product was spilled access to that area would be restricted while it was being dealt with," says Laura Davies.
Similarly, maintaining or updating any distillery equipment is subject to Health & Safety procedures.
"Every time any new kit comes in you have to do another risk assessment and change the procedures connected with this. An external agency gives us guidance on any points we're not sure of, and also updates us on any changes to the regulations," says Laura Davies.
Jamie Baxter adds, "If you want a fitter to come in to do some welding you have to do a risk assessment before anything can be done."
A bottling line is another vital stage in the production process, particularly as the combination of alcohol and glass means the possibility of breakage and spillage.
"If a glass bottle shatters there are usually sharp fragments which can fly a long way, so eye protection is necessary. Another key concern is glass fragments ending up in a bottle and being sent to consumers," says Jamie Baxter.
Storage facilities, whether for bottled product or for ageing casks, also have particular requirements. An ageing warehouse, for example, requires a certain level of ventilation to deal with alcohol vapours evaporating from casks. And while there's still an element of manual work in a warehouse, various jobs can be done using fork-lift trucks. Needless to say, wherever there is moving machinery safety measures are required.
It's clear that running a distillery means devoting a significant amount of time and energy to Health & Safety regulations. Moreover, when a distillery manager goes home at the end of the day that's not the end of the responsibility.
"Any accidents must be reported immediately to me. We produce 24/7 and I take phone calls during the night if there's an operational issue. I'd prefer to answer the phone at 2am in the morning rather than to get in at 9am and find we've lost 7 hours production because someone was worried about waking me up," says Laura Davies.