Food and beverage manufacturing sits at the intersection of multiple regulatory frameworks: OSHA workplace safety, FDA food safety, EPA environmental compliance, and often USDA oversight. A single facility may simultaneously manage ammonia refrigeration under Process Safety Management, preventive controls under FSMA, wastewater discharge permits under the Clean Water Act, and dozens of OSHA general industry standards. This guide covers the key EHS requirements facing food and beverage manufacturers and how EHS software built for the food and beverage industry helps organizations manage the complexity.
The EHS Challenge in Food and Beverage
Food and beverage operations face a uniquely broad set of EHS hazards spanning worker safety, food safety, and environmental compliance, all under intense regulatory scrutiny and public visibility.
These challenges demand an integrated approach. When food safety, workplace safety, and environmental compliance are managed in separate silos, gaps emerge between programs and violations multiply. Centralizing EHS management in a single platform eliminates those gaps.
OSHA Workplace Safety in Food Processing
Food and beverage manufacturing consistently ranks among the most hazardous industries, with injury and illness rates significantly above the national average. OSHA's most frequently cited standards in food processing include:
Lockout/Tagout (29 CFR 1910.147)
Food processing equipment, including mixers, grinders, slicers, conveyors, and packaging lines, must be isolated and de-energized before servicing. The standard requires a written energy control program, machine-specific lockout procedures, authorized and affected employee training, and annual periodic inspections of each procedure. Lockout/tagout violations are consistently among the top OSHA citations in food manufacturing.
Machine Guarding (29 CFR 1910.212)
Processing and packaging equipment with exposed moving parts, nip points, rotating components, and cutting or shearing mechanisms must have guards that prevent employee contact. Food plants face unique challenges because guards must be removable for sanitation while still providing protection during operation. Interlock guards that shut down equipment when opened are the preferred solution.
Permit-Required Confined Spaces (29 CFR 1910.146)
Tanks, silos, vats, pits, and process vessels are common in food and beverage facilities. Entry requires a written confined space program, entry permits, atmospheric testing, attendant staffing, and rescue provisions. Fermentation vessels present particular hazards due to oxygen displacement by carbon dioxide.
Hazard Communication (29 CFR 1910.1200)
Food plants use a wide range of chemicals including sanitizers, degreasers, caustics, acids, ammonia, and pest control agents. HazCom compliance requires a written program, safety data sheets (SDS) for every chemical, GHS-compliant labeling, and employee training on chemical hazards. Cleaning chemical exposure, particularly to quaternary ammonium compounds and chlorine-based sanitizers, is a leading cause of occupational illness in food processing.
Walking and Working Surfaces (29 CFR 1910.22-30)
Wet floors, grease, condensation, and temperature differentials make slips, trips, and falls the most common injury category in food and beverage plants. Compliance requires slip-resistant flooring, proper drainage, housekeeping programs, fall protection on elevated platforms and mezzanines, and guardrails on open-sided surfaces above four feet.
Ammonia Refrigeration: PSM and RMP Compliance
Anhydrous ammonia is the dominant refrigerant in food and beverage manufacturing due to its thermodynamic efficiency. When system inventory exceeds 10,000 pounds, OSHA Process Safety Management (29 CFR 1910.119) and EPA Risk Management Program (40 CFR Part 68) both apply. Ammonia releases are among the most frequently reported chemical accidents in the food industry.
PSM 14-Element Program
PSM requires facilities to implement all 14 management elements:
- Process hazard analysis (PHA) reviewed at least every five years
- Written operating procedures for normal, temporary, emergency, and startup/shutdown operations
- Mechanical integrity program covering vessels, piping, relief devices, controls, and ventilation
- Management of change (MOC) for any modification to equipment, procedures, or chemicals
- Pre-startup safety review for new or modified equipment
- Hot work permits for welding or cutting near ammonia systems
- Employee participation, training (initial plus every three years), and contractor management
- Incident investigation within 48 hours of any release or near miss
- Emergency planning covering the entire plant
- Compliance audits every three years
FDA Food Safety: FSMA and Preventive Controls
The Food Safety Modernization Act (FSMA), signed in 2011, is the most significant reform of U.S. food safety law in over 70 years. It shifted FDA's approach from responding to contamination events to preventing them. For food and beverage manufacturers, the key FSMA rules include:
Preventive Controls for Human Food (21 CFR Part 117)
Requires a written food safety plan developed by a Preventive Controls Qualified Individual (PCQI). The plan must include a hazard analysis identifying known or reasonably foreseeable biological, chemical (including radiological), and physical hazards; risk-based preventive controls such as process controls, allergen controls, sanitation controls, and supply-chain controls; monitoring procedures; corrective actions; and verification activities including environmental monitoring and supplier verification.
HACCP: The Foundation for High-Risk Products
Hazard Analysis and Critical Control Points (HACCP) remains mandatory for meat and poultry (USDA FSIS), seafood (21 CFR Part 123), and juice (21 CFR Part 120) processors. HACCP's seven principles, including hazard analysis, critical control point identification, critical limits, monitoring, corrective actions, verification, and recordkeeping, overlap significantly with FSMA preventive controls and with EHS risk assessment methodology. Integrating HACCP with broader EHS management eliminates duplicate effort.
Current Good Manufacturing Practices (cGMPs)
21 CFR Part 117 Subpart B establishes baseline cGMP requirements for all food facilities including personnel hygiene, building and grounds maintenance, sanitary operations, equipment design and maintenance, production and process controls, and warehousing and distribution. These requirements form the prerequisite programs upon which HACCP and preventive controls are built.
Environmental Compliance for Food Processors
Food and beverage manufacturing generates significant environmental impacts including high-strength wastewater, air emissions from combustion and refrigeration, solid waste, and chemical storage. Key EPA regulatory frameworks include:
Clean Water Act and Wastewater Management
Food processing wastewater is typically high in biochemical oxygen demand (BOD), total suspended solids (TSS), fats/oils/grease (FOG), and nutrients. Facilities discharging to surface waters need NPDES permits with effluent limitations. Facilities discharging to municipal sewer systems must comply with local pretreatment ordinances and EPA categorical standards. Dairy, meat, grain, canned fruit, and seafood processors have industry-specific effluent limitation guidelines under 40 CFR Parts 405 through 411.
Clean Air Act Permits
Boilers and process heaters for steam generation, ammonia refrigeration systems, grain handling and milling operations, roasting and drying processes, and VOC emissions from fermentation and packaging are all potentially regulated under Title V or minor source permits. Ammonia above 10,000 pounds also triggers EPA RMP under 40 CFR Part 68, running parallel to the OSHA PSM requirement.
Waste Management and EPCRA Reporting
Food processors must manage hazardous waste from laboratory operations, cleaning chemicals, and equipment maintenance under RCRA. Non-hazardous solid waste including food waste, packaging, and sludge requires proper disposal. EPCRA Section 312 (Tier II) reporting applies when ammonia or other listed chemicals exceed threshold quantities, and many food facilities must report under the Toxic Release Inventory (TRI) program.
Employee Training and Safety Culture
Food and beverage employees face overlapping training requirements from multiple regulatory agencies. An effective training program must cover:
OSHA-Required Safety Training
- Hazard communication (initial assignment plus when new chemicals are introduced)
- Lockout/tagout (authorized and affected employees, annual refresher)
- Confined space entry (entrants, attendants, supervisors)
- PSM/ammonia safety (initial plus every three years for covered processes)
- Personal protective equipment (proper use, care, and limitations)
- Emergency action plan and fire prevention (upon assignment and when plan changes)
- Powered industrial trucks (initial certification, evaluation every three years)
FDA/Food Safety Training
- PCQI certification for food safety plan development and oversight
- HACCP training for critical control point monitoring personnel
- Allergen awareness and cross-contact prevention
- Personal hygiene and cGMP requirements
- Sanitation and cleaning validation procedures
- Food defense awareness (intentional adulteration prevention)
Supply Chain Management and Supplier Audits
EHS compliance in food and beverage extends beyond the plant walls. FSMA's Preventive Controls rule requires supply-chain programs for raw materials and ingredients where the supplier's controls are necessary to prevent hazards. Foreign Supplier Verification Programs (FSVP) under 21 CFR Part 1 Subpart L require importers to verify that foreign suppliers produce food meeting U.S. safety standards.
Effective supply chain EHS management includes supplier qualification questionnaires, on-site audits (often using GFSI-recognized schemes like SQF, BRC, or FSSC 22000), ingredient certificates of analysis, allergen declarations, traceability systems meeting FDA's food traceability rule requirements, and corrective action tracking when supplier non-conformances are identified.
Best Practices for Integrated Food and Beverage EHS
Integrate Food Safety and Workplace Safety Programs
Rather than maintaining separate food safety and occupational safety silos, leading food manufacturers unify their inspection, audit, and corrective action programs. A single inspection platform can capture both food safety observations (sanitation deficiencies, allergen cross-contact risks, temperature deviations) and workplace safety observations (unguarded equipment, blocked exits, PPE non-compliance) in one walk-through.
Centralize Compliance Calendars
Food and beverage facilities face dozens of recurring deadlines: PSM compliance audits (every three years), PHA reviews (every five years), RMP resubmissions (every five years), NPDES permit renewals, Tier II reporting (annual by March 1), TRI reporting (annual by July 1), fire extinguisher inspections (monthly/annual), forklift evaluations (every three years), and FDA facility registration renewal (biennial). A compliance calendar prevents deadlines from falling through the cracks.
Implement Robust Incident Investigation
Both OSHA (PSM incident investigation within 48 hours) and FDA (preventive controls corrective actions) require investigation of incidents and deviations. A unified incident management system captures workplace injuries, near misses, chemical releases, food safety deviations, customer complaints, and environmental exceedances in a single platform with root cause analysis and corrective action tracking.
Leverage Mobile Technology
Production floors, warehouses, loading docks, and wastewater treatment areas all generate EHS data that must be captured in real time. Mobile EHS apps enable line-level employees to report hazards, complete inspections, document training, and access SOPs and SDS documents without leaving the production area.
Ecesis Food and Beverage EHS Software
Food and Beverage EHS
Industry-specific EHS management for food processors.
Inspections and Audits
Schedule and track food safety and workplace safety audits.
Incident Management
Investigate workplace injuries, releases, and food safety events.
Training Management
Track HACCP, PCQI, OSHA, and PSM training certifications.
Compliance Calendar
Consolidate PSM audits, permit renewals, and reporting deadlines.
Chemical Management
Manage sanitizer inventories, ammonia records, and SDS access.
