BC Craft Brewers should make the time to read the new regulations Section 4.43.1 regarding racking in their breweries. They came into effect on January 1, 2018. My intention here is to give you a bare-bones understanding of the new requirements on this topic and outline your obligations defined by them. In the very least, take a few moments from your very busy schedules to read this.
Notably, these regulations do not state requirements from other sources like municipal bylaws, building codes and seismic provisions, and employers are expected to meet these requirements as well. (Seismic requirements)
Definitions – Considerable verbiage is used in these regulations to define, “What is a Rack?” It is important to note that if you are using anything “other than manual means” to load or unload your racking, this new regulation applies to you. It is specifically noted that “shelving and display fixtures used for retail purposes” are excluded. I have a concern that some of you have very significant racking in your retail space, barrels and casks, and this is addressed to some degree in the above linked document, it is somewhat ambiguous when racking is only for display. I would recommend assuming that such racking will fall within the regulations, better safe than sorry.
Subsection 4.43.1 (1)The new requirements apply to steel storage racks on retail floor of some businesses, such as Costco warehouses, Rona, Home Depot, and other similar stores selling tiles and carpets, where customers are selecting items off pallets on or around the storage racks.
Installation – It is the employer’s obligation to ensure that racking is installed with the “specifications and instructions of the manufacturer, or a professional engineer” and that while its rated capacity need not be posted directly on each rack it must be “posted in the general vicinity of the storage racks and the workers must know where it is posted so it can be referenced as needed.”
Subsection (4) obligates the employer to ensure a qualified person follows the instructions of the manufacturer or engineer to install/uninstall storage racks. The employer could fulfill their responsibility by ensuring the qualified person has the instructions prior to the installation or uninstallation.
If any structural modification or reconfiguration of the rack has taken place it should have been done with the involvement of the manufacturer or a professional engineer. A considerable amount of ink was used to define “Qualified Person for Installation/Uninstallation of Storage Racks” and I urge you to read the entire missive.
Loading and Unloading – The regulation states that: the employer should obtain instructions for safely loading, unloading and maintaining the storage rack from either the manufacturer of the storage rack or a professional engineer and [and that] these instructions must be readily available in the workplace to workers.
Conversations with WorkPlaceBC have clarified that this would include (this is not a full list) such things as loading and unloading order or pattern, (eg. top to bottom), weight distribution, and “full load” distribution.
Required Postings – As stated above, you are obligated to have load capacities posted. As well, you are required to have the manufacturer’s instructions for the correct loading and unloading process for each rack type.
These postings don’t have to be on each rack, just “in the general vicinity of the storage racks and the workers must know where it is posted so it can be referenced as needed.”
I will be working on these racking instructions as we learn each manufacturer’s requirements. I have completed Barrel Racks for your use and please check the Resources page of this site for anything new.
Inspection & Maintenance – The regulation states that the employer must ensure that the racks are regularly inspected and maintained, and a record must be kept of these inspections and maintenance.
The employer must ensure that, with respect to the storage rack,
(a) regular maintenance is done, and
(b) wear, corrosion, damage, missing or incompatible parts, and signs of fatigue are repaired or replaced in accordance with the specifications and instructions of the manufacturer or a professional engineer.
The upshot of this is that if you installed your own racks you should have them inspected by a professional engineer. Regardless of whether they were professionally installed or not, you should add “rack inspection” to your monthly or quarterly Occupational Health & Safety Inspection checklist and any deficiencies and corrective actions should be noted. The 14 page WorkSafeBC document linked above provides an outline for the creation of a “Storage Rack Inspection Form” and I urge you to adopt it, if not specifically then add it in spirit.
