Industry Guide·OSHA Compliance·12 min read·Updated March 2026
Breweries and wineries are not industries most people associate with occupational hearing loss — but they should be. Production floors in both industries are filled with equipment that routinely generates noise at or above OSHA’s 85 dBA action level: keg washers, can seamers, carbonation systems, grape crushers, bottling lines, refrigeration compressors, and pressure washing operations are all common contributors. For any brewery or winery where noise monitoring shows employee exposures at or above 85 dBA TWA, OSHA’s full hearing conservation program requirements at 29 CFR 1910.95 apply — regardless of company size.
Soundtrace serves breweries and wineries as their hearing conservation program professional supervisor, combining on-site audiometric testing, noise monitoring data, and REAT-based HPD fit testing into a single unified worker profile — managed entirely through the Soundtrace cloud portal.
85 dBA
OSHA action level — the TWA that triggers HCP enrollment and audiometric testing requirements
90–102 dBA
Typical noise range for can seamers and keg washers — the two loudest brewery noise sources
All sizes
OSHA 1910.95 applies to every brewery and winery — no small employer exemption
The Compliance TriggerNoise monitoring is not optional if there is reason to believe exposures may reach 85 dBA. A brewery or winery that has not conducted a noise survey and cannot demonstrate that production workers are below the action level is already behind on compliance — not just on the HCP elements themselves.
Why Hearing Loss Risk Is Real in Beverage Production
The beverage alcohol industry — craft and commercial alike — has historically underinvested in occupational hearing conservation relative to industries like manufacturing, construction, and mining. This is partly a perception problem: breweries and wineries are associated with craft, hospitality, and sensory experience, not industrial noise hazards. But the production floors of both industries contain equipment categories that generate sustained noise levels well above OSHA’s action level.
Enclosed production spaces compound the problem. Concrete floors, stainless steel tanks and vessels, hard walls, and minimal sound absorption create highly reverberant acoustic environments where equipment noise reflects and accumulates. A grain mill, a keg washer, and a refrigeration compressor operating simultaneously in an enclosed brewery can produce a combined ambient level substantially higher than any individual source would suggest.
The workers most at risk are not the brewmaster or the cellar master — it is the production workers who spend full shifts in proximity to filling lines, keg handling areas, and cleaning operations. These are typically the lowest-paid workers in the facility, and they often have the least awareness of the cumulative hearing risk they face.
Brewery Noise Sources and Typical Levels
Noise levels in breweries vary significantly by equipment model, age, production rate, and facility acoustics. The following are representative ranges based on occupational hygiene literature and OSHA compliance data for the food and beverage manufacturing sector. Actual levels at any specific facility require measurement.
90–102
dBA
Keg washers and keg sanitizers
Among the loudest and most sustained noise sources in a production brewery. High-pressure spray, valve actuation, and metal-on-metal contact produce broadband noise with significant low-frequency content. Workers performing keg handling adjacent to washer operations receive high continuous doses.
90–102
dBA
Can seamers and can fillers
Rotary can seamers produce impact and machine noise that can exceed 100 dBA at operator positions. Conveyor systems feeding and discharging the seamer add additional steady-state noise. Canning line workers are among the highest-noise-exposed employees in a craft brewery.
90–100
dBA
Grain mills (two-roll, four-roll, hammer mill)
Milling grain generates both impact noise from grain-roller contact and high-frequency noise from motor and drive components. Enclosed mill rooms concentrate noise levels. Hammer mills are generally louder than roller mills at equivalent throughput.
85–95
dBA
CO2 carbonation and tank purging systems
High-pressure CO2 flow generates broadband hiss at venting and pressure relief points. Workers who regularly purge tanks, connect gas lines, or operate carbonation stones are exposed during these operations. Duration of exposure per task is typically short but may accumulate across a shift.
85–95
dBA
Refrigeration compressors
Large glycol chilling systems and ammonia refrigeration compressors produce sustained broadband noise. Workers in or near the compressor room for maintenance, monitoring, or adjacent work receive continuous exposure from this source. Levels depend heavily on compressor type, age, and vibration isolation.
85–95
dBA
Canning and bottling line conveyors
Conveyor chains and drives, combined with can-on-can and bottle-on-bottle contact, produce sustained noise that may not peak as high as the seamer but persists throughout the line operator’s full shift. Cumulative dose from conveyor noise alone frequently reaches action-level TWA for workers stationed on the line.
90–105
dBA
Pressure washing and CIP (clean-in-place) operations
High-pressure water at spray nozzles, combined with metal tank and floor surfaces, generates high-level broadband noise. CIP operations are often performed at shift boundaries when other production is idle, concentrating noise exposure into the workers assigned to cleaning duties.
The Enclosed Environment MultiplierBrewery production spaces are designed for sanitation, not acoustics: concrete, stainless, and tile surfaces are all highly reflective. A single noise source at 90 dBA in an open field is a different exposure than the same source in an enclosed, reverberant brew house or canning room where reflections from every surface add to the direct-path level. Area monitoring in the actual work environment — not just measurement of individual equipment — is essential to accurately characterize worker dose.
Winery Noise Sources and Typical Levels
Wineries have a different noise profile than breweries — more seasonal, with the highest exposures concentrated during harvest and crush. Outside of harvest, ongoing cellar operations, bottling, and facility maintenance continue to expose workers to moderate but potentially action-level noise.
88–98
dBA
Grape crushers and destemmers
Mechanical destemmers and crushers operate at sustained high noise levels during harvest. Workers managing grape intake — receiving, sorting, and feeding the crusher — are exposed to both the crusher noise and the noise of bin dumpers, conveyors, and related handling equipment operating simultaneously.
85–96
dBA
Bottling and labeling lines
Similar to brewery bottling, winery bottling lines produce noise from fillers, corkers or cappers, labelers, and conveyors. Glass bottle contact generates higher-frequency impact noise than cans. Workers who operate these lines for full shifts are among the highest-dose-exposed winery employees outside harvest.
85–96
dBA
Must pumps and wine transfer pumps
Centrifugal and peristaltic pumps used for must transfer, racking, blending, and barrel filling generate sustained motor and fluid-handling noise. Workers performing pump operations for extended periods accumulate noise dose proportional to the duration of those tasks within their shift.
90–102
dBA
Pressure washing and tank cleaning
As in breweries, high-pressure wash-down of fermentation tanks, presses, and crush pads is among the loudest single-task exposures in a winery. Harvest cleanup operations at the end of each crush day can produce high-intensity exposures for the workers assigned to sanitation duties.
84–92
dBA
Refrigeration and temperature control systems
Barrel rooms and tank farms maintained at cold temperatures require sustained refrigeration. Compressors and air handling units in or adjacent to working areas contribute continuous background noise that accumulates across the shift for cellar workers.
82–92
dBA
Barrel washing and barrel handling equipment
Barrel washers use hot water and steam injection that generates sustained noise. Barrel racks and forklifts operating in reverberant barrel rooms create additional ambient noise from material handling and motorized equipment.
How OSHA 1910.95 Applies to Breweries and Wineries
Breweries and wineries operating as employers in general industry are subject to 29 CFR 1910.95 in full. There is no sector-specific exemption and no small-employer carve-out. The applicability trigger is simple: if employees are exposed to noise at or above 85 dBA TWA (the action level), the employer must implement a hearing conservation program.
The compliance sequence follows the standard 1910.95 framework:
- Noise monitoring under 1910.95(d): Conduct a noise survey whenever there is reason to believe employee exposures may equal or exceed the action level. For a brewery or winery with keg washers, can seamers, crushers, or high-pressure cleaning operations, there is always reason to believe exposures may reach the action level — which means monitoring should not wait for an OSHA inspection to prompt it.
- HCP enrollment under 1910.95(c): Enroll all employees whose TWA meets or exceeds 85 dBA in the hearing conservation program.
- Audiometric testing under 1910.95(g): Provide baseline audiograms within 6 months of enrollment, followed by annual audiograms.
- HPD provision under 1910.95(i): Provide hearing protectors at no cost to all enrolled employees, with selection options and proper fitting.
- Annual training under 1910.95(k): Train all enrolled employees annually on noise effects, HPD use and care, and audiometric testing purpose.
- Recordkeeping under 1910.95(m): Maintain noise monitoring and audiometric records for the required retention periods.
Who Must Be Enrolled in the HCP
HCP enrollment is determined by measured noise exposure, not by job title or work area. For a brewery or winery, the following worker groups are the most likely candidates based on typical exposure patterns:
| Worker Group | Primary Noise Sources | Typical Enrollment Status |
|---|
| Canning/bottling line operators | Seamer, filler, conveyor, labeler | Commonly at or above action level; monitor and enroll |
| Keg handling and washing staff | Keg washer, CO2 purging, keg conveyor | Frequently at or above action level; monitor and enroll |
| Cellar workers / production generalists | Multiple sources across shift | Variable; personal dosimetry required to determine |
| Crush and harvest crew (wineries) | Crusher/destemmer, pumps, pressure washing | High likelihood during harvest; seasonal enrollment may apply |
| Maintenance technicians | All production equipment during repair and PM | Monitor; may exceed action level depending on tasks and duration |
| Grain millers (breweries) | Mill, augers, conveyors | Commonly at or above action level; monitor and enroll |
| Tasting room / hospitality staff | Minimal production exposure | Generally not enrolled; confirm with monitoring if adjacent to production |
Do Not Assume Based on Job TitleA cellar worker whose tasks on a given day include a full shift of pressure washing and keg washing has a very different noise dose than a cellar worker whose day is spent racking barrels and taking gravity readings in a quiet barrel room. Personal dosimetry — monitoring the actual worker as they perform their actual tasks — is required to properly characterize exposure for workers with variable daily tasks.
Required HCP Elements: What Breweries and Wineries Need in Place
Written hearing conservation program
OSHA expects employers to have a written HCP document that identifies the program’s scope, responsible parties, monitoring procedures, audiometric testing protocol, HPD selection, training schedule, and recordkeeping system. For a small craft brewery, this does not need to be lengthy — but it must exist and accurately reflect what the facility actually does.
Noise monitoring current relative to operations
The noise survey must be updated whenever a change in production, process, or equipment may result in new or increased exposures — per 1910.95(d)(3). For breweries and wineries that upgrade canning lines, add new fermentation capacity, change cleaning protocols, or modify production rates, the monitoring record must be reviewed and re-monitoring conducted where the changes may affect worker dose.
Audiometric testing with professional supervisor review
Annual audiograms must be reviewed by a physician or audiologist (the professional supervisor) who evaluates STS findings, makes work-relatedness determinations when exposures cross the 300 Log threshold, and documents follow-up actions. For small breweries and wineries that do not have in-house occupational health resources, this review is typically provided by the audiometric testing vendor’s licensed audiology team.
HPD selection appropriate for actual noise levels
HPD selection must provide adequate attenuation for the measured noise levels, derated per OSHA Appendix B. A worker at a 95 dBA canning line who is issued an earplug with an NRR of 22 may not be adequately protected once the Appendix B derating is applied. HPD adequacy should be verified against the actual measured TWA for each enrolled job category.
Annual training in a language employees understand
Many brewery and winery production workforces include significant numbers of Spanish-speaking workers. Training must cover all four required topics under 1910.95(k)(2) in a language the employee understands — English-only training does not satisfy the requirement for workers who cannot comprehend it.
Seasonal Workforce Considerations
Wineries in particular employ large seasonal workforces during harvest and crush. OSHA’s HCP requirements apply to temporary and seasonal workers the same as to permanent employees — if they are exposed at or above the action level, they must be enrolled in the HCP.
The practical challenge for seasonal workers is the audiometric testing timeline. Under 1910.95(g)(5)(i), the baseline audiogram must be provided within 6 months of first exposure at or above the action level (or within 1 year if a mobile test van is used and the worker has worn HPDs continuously since employment). For harvest workers employed for only 4–8 weeks, the baseline audiogram may not occur within the season — but the obligation to provide it exists, and it must be completed when the worker returns or within the applicable window.
Employers with annual returning harvest crews should maintain audiometric records year to year for returning workers and schedule baseline audiograms for newly hired seasonal workers as early in the season as feasible.
Seasonal Worker Best PracticeFor wineries with returning harvest crews, treat the beginning of harvest season as the trigger to complete or update audiograms for all returning enrolled workers. This collapses the scheduling challenge into a single annual event aligned with the operational calendar — and ensures that baseline audiograms for new hires are initiated at the start of their first season rather than deferred indefinitely.
Engineering and Administrative Controls
OSHA’s preference hierarchy places engineering controls above HPDs for long-term noise reduction. In beverage production, practical engineering controls that have demonstrated effectiveness include:
- Enclosures around keg washers and grain mills. Partial or full acoustic enclosures around high-noise equipment can reduce ambient levels in surrounding work areas by 5–15 dB, reducing worker dose without requiring HPD use for nearby workers who are not directly operating the enclosed equipment.
- Anti-vibration mounts for compressors and pumps. Vibration transmission from refrigeration compressors and transfer pumps to building structure amplifies ambient noise in adjacent spaces. Isolation mounts reduce this transmission path.
- Conveyor line speed and contact surface modifications. Reducing conveyor speed, adding plastic wear strips, or modifying contact surfaces between cans or bottles reduces the impact noise generated by container-on-container contact along canning and bottling lines.
- Administrative scheduling of high-noise tasks. Concentrating pressure washing, keg washing, and other high-noise operations into dedicated time windows — rather than running them simultaneously with other production — limits the number of workers exposed to peak noise levels at any one time.
- Separating high-noise operations from general production areas. Where facility layout permits, isolating grain milling, keg washing, and high-pressure cleaning to dedicated rooms with sound-isolating walls and doors reduces the area over which noise exposure is significant.
▶ Bottom line: Engineering controls reduce the population exposed and the dose received — and they generate fewer STS events over time than HPD reliance alone. Even modest reductions in ambient noise level can move borderline workers below the action level entirely, shrinking the enrolled population and the administrative burden of the HCP.
Frequently asked questions
Are breweries and wineries required to have a hearing conservation program?
Yes, if employees are exposed at or above 85 dBA TWA. Breweries and wineries operate equipment — including keg washers, can seamers, crushers, bottling lines, and compressors — that frequently exceeds this threshold. OSHA 29 CFR 1910.95 applies to all general industry employers regardless of size, and there is no beverage industry exemption.
What are the noisiest operations in a brewery?
Keg washers and can seamers are typically the loudest, with peak noise levels in the 90–102 dBA range at operator positions. Grain mills, pressure washing operations, and CO2 systems also commonly exceed the action level. Enclosed, reverberant production spaces amplify the cumulative noise level above what any single source would produce alone.
Do seasonal harvest workers at wineries need to be in the HCP?
Yes, if their noise exposure meets or exceeds 85 dBA TWA. Seasonal workers are not exempt from OSHA 1910.95 requirements. Workers exposed during crush and harvest operations — including crusher/destemmer operators, pump operators, and cleaning crews — should be monitored and enrolled if exposures meet the threshold. Baseline audiograms must be provided within the required timeframe.
Do tasting room staff need to be enrolled in the HCP?
Generally no — typical tasting room and hospitality work does not involve noise exposures at or above 85 dBA. However, tasting room staff who regularly work in or adjacent to active production areas should be evaluated through noise monitoring to confirm their actual exposure. Enrollment is based on measured exposure, not job title.
Does a craft brewery with fewer than 10 employees have to comply?
Yes. OSHA 1910.95 applies to all general industry employers regardless of size. A craft brewery with two or three production workers exposed above the action level must provide a hearing conservation program — noise monitoring, audiometric testing, HPDs, and annual training — the same as a large commercial brewery.
What hearing protectors are appropriate for brewery and winery workers?
HPD selection should be based on the measured noise level and the Appendix B derated NRR calculation for each job category. For workers at 90–100 dBA environments, standard foam earplugs or reusable earplugs with adequate NRR are typically sufficient when properly fitted. For workers at or above 100 dBA, higher-NRR devices or dual protection may be required. REAT fit testing verifies that the selected HPD provides adequate attenuation for the individual worker as they actually wear it.
HCP Built for Beverage Producers. Audiograms, Noise Data, and Fit Testing in One Place.
Soundtrace serves as the professional supervisor for brewery and winery hearing conservation programs, combining audiometric testing, noise monitoring, and REAT-based HPD fit testing into a single unified worker profile viewable in the cloud portal.
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