CAL/OSHA’s Must-Have Document

CAL/OSHA November 12, 2025

CAL/OSHA’s Must-Have Document

CAL/OSHA’s Must-Have Document: Why Your Written HAZCOM Plan is Non-Negotiable

North Coast wineries are centers of precision, blending art and science to craft world-class vintages. But behind the beautiful barrel rooms and crush pads lies an industrial environment where hazardous materials—from caustic cleaners and concentrated acids to fermentation aids—are used daily.
For operations involving these chemicals, Cal/OSHA’s regulations are crystal clear: A Written Hazardous Communication Plan (HAZCOM Plan) isn’t optional; it’s the law.
At Epsilon Consulting, we find that many wineries have the components—the Safety Data Sheets (SDSs) and basic training—but lack the essential, unifying blueprint that Cal/OSHA demands. Here’s why this written plan is vital for your compliance and worker safety.
The Legal Foundation: 8 CCR §5194
The requirement for a written HazCom Plan is explicitly laid out in Title 8, California Code of Regulations (8 CCR) §5194. This standard mandates that every employer with hazardous chemicals in the workplace must develop, implement, and maintain a comprehensive written program.

For a Cal/OSHA inspector, the HAZCOM Plan is the first document they ask for. It serves as your organization’s proof that you have a structured, effective system in place, rather than relying on ad-hoc or undocumented procedures.
The Absence of a Written Plan is an Automatic, High-Severity Violation.
More Than Just a Binder: The HazCom Blueprint
Your written HAZCOM Plan must describe, in detail, how your winery addresses the “Right to Know” for your employees. It must cover three key areas that tie all your chemical safety efforts together:
1. Chemical Inventory and Labeling
The plan must detail who is responsible for maintaining the chemical inventory and how you ensure all primary and secondary containers are properly labeled. This includes temporary tanks or transfer lines used during sanitation cycles. It must describe your system for verifying that every chemical on your property has a current, matching SDS.
2. SDS Accessibility
The plan must clearly state the location and method for providing employees immediate access to the SDSs for every hazardous chemical they may encounter during their shift. This is critical for all shifts. Whether it’s an electronic system, a dedicated computer, or a hard-copy binder, the plan must define the procedure.
3. Formal Employee Training
This is where the written plan proves its worth. It must describe the format, content, and frequency of HAZCOM training. This includes:
• Training for new hires and seasonal staff before they handle chemicals.
• Annual refresher training for all personnel.
• Training in newly introduced chemicals or revised procedures.
• Crucially, the training must cover how to interpret SDSs and container labels, not just where to find them.
Why a Generic Template Fails in the North Coast AVA
Wineries often rely on basic, downloaded templates for their safety programs. This can be a major compliance trap because the HAZCOM Plan must be site-specific and effective.
• Unique Chemical Mixtures: Your winery uses specific cellar chemicals, different cleaning protocols for stainless steel vs. oak, and unique processes (like filtering or Pressing) that generic templates don’t account for.
• Seasonal Staffing: The plan must explicitly address how temporary or harvest staff, who may speak different primary languages, receive effective and documented training.
• Non-Routine Tasks: When Cal/OSHA auditors check the plan, they look for procedures covering non-routine tasks, such as confined space entry (like cleaning a fermentation tank) or mixing concentrated chemicals for solution preparation. These specific tasks must be addressed in the written HAZCOM program.
Protect Your Employees, Protect Your Operation
The risk of non-compliance goes beyond fines. An inadequate HAZCOM plan directly contributes to worker injury and illness. By establishing a formalized, written plan, you are not only satisfying regulatory mandate but also:
• Reducing the likelihood of chemical accidents.
• Ensuring rapid, correct emergency response.
• Demonstrating management’s commitment to safety.
Don’t leave the core of your chemical safety program unwritten. Epsilon Consulting specializes in creating customized HAZCOM plans that seamlessly integrate with your existing winery operations, ensuring you meet the stringent requirements of Cal/OSHA 8 CCR §5194.
Michael Long, Manager Epsilon Water LLC – Epsilon Consulting
• Phone: 707-333-9167
• Email: michael@epsilonwater.com
• Website: epsilonwater.com

water compliance September 24, 2025

When the Rain Comes

When the Rain Comes: How North Coast Harvest Activities Impact Wastewater Treatment

For North Coast wineries, late summer and early fall are a flurry of activity. The air is filled with the sweet scent of fermenting grapes, and the energy is palpable as crews work around the clock to bring in the harvest. It’s a critical time for winemaking, but it also marks a significant period for a winery’s environmental operations, particularly its wastewater treatment system.

At Epsilon Water LLC/Epsilon Consulting, we’ve seen firsthand how the volume and composition of process wastewater change dramatically during this period. Understanding these changes is crucial for a smooth and compliant harvest, especially as we head into the wet season.

The Harvest Wastewater Challenge

Grape harvest activities generate a high volume of process wastewater from a variety of sources:

Crush Pad Operations: Washing and cleaning equipment, bins, and floors.
Pressing and Fermentation: Spills, tank cleaning, and sanitizing.
Barrel and Tank Maintenance: The heavy use of water for flushing and preparing vessels for new juice.

This wastewater isn’t just a high-volume flow; it’s also high strength. It’s loaded with solids, sugars, and organic matter (measured by biochemical oxygen demand, or BOD). This puts an immense strain on a wastewater treatment system, which is designed to handle a consistent load. During harvest, the system has to work overtime to keep up with the fluctuating and often extreme surges.

The Upcoming Rainy Season

The challenge doesn’t end when the last grape is picked. The transition from harvest to the rainy season adds another layer of complexity. For many wineries that rely on land application for wastewater disposal, the start of the rains can shut down their irrigation fields. Once the soils are saturated, no more treated effluent can be applied, forcing the winery to rely solely on its storage capacity.

If the wastewater system has not been operating at peak efficiency during harvest, or if it was simply overwhelmed by the high-strength flows, the stored effluent may not be fully treated. This can lead to a few critical issues:

Storage Pond Capacity: If the treatment system can’t process the harvest wastewater quickly enough, storage ponds may fill up before the rainy season begins, creating a risk of spills or unpermitted discharges.
Compliance Risks: Unpermitted discharges to nearby creeks or streams can lead to significant fines and regulatory action from agencies like the Regional Water Quality Control Board.
Odor Issues: High concentrations of untreated organic matter in a full pond can create foul odors, which is a nuisance to neighboring properties and a compliance issue.

Our Recommendations for a Proactive Approach

To prepare for this double-whammy of harvest intensity and winter rains, we encourage North Coast wineries to be proactive.

Optimize Your System Now: During harvest, monitor your wastewater system daily. Adjust aeration, nutrient levels, and flow to ensure your treatment process is as efficient as possible.
Monitor Your Storage: Keep a close eye on your storage pond levels. If you see them rising faster than anticipated, it’s a red flag that your treatment system isn’t keeping pace.
Prepare for a Controlled Shutdown: As the first significant rains are forecast, make a plan to shut down your irrigation fields. This helps protect the soil structure and ensures you are in compliance.
Have a Spill Plan Ready: Ensure your Spill Prevention and Emergency Response Plan (PW-SPERP) is up to date and that all staff are trained in it. This plan is your roadmap for handling any unexpected discharge events.

A successful harvest isn’t just about the quality of the wine; it’s about the health of your entire operation, from the vineyard to the wastewater system. By managing your treatment process effectively during this critical time, you can ensure a smooth transition into the winter and protect both your business and the environment.

Contact Epsilon Consulting today to discuss how we can help develop or enhance your winery’s wet weather preparedness.

Michael Long, Manager Epsilon Water LLC- Epsilon Consulting

Phone: 707-333-9167
Email: michael@epsilonwater.com
Website: epsilonwater.com

by Michael Long

water compliance August 28, 2025

A Toast to Compliance

A Toast to Compliance: Epsilon Consulting Delights Multi-National Wine Client with Expert PW-SPERP Development 🥂

The world of wine is one of passion, precision, and increasingly, stringent environmental stewardship. For multi-national wine companies with diverse portfolios, navigating complex regional regulations is a continuous challenge. Epsilon Consulting recently partnered with a prominent multinational wine corporation at one of their wineries, to develop a comprehensive Process Wastewater Spill Prevention & Emergency Response Plan (PW-SPERP) for their North Coast AVA facility. We’re thrilled to share a recap of our collaborative efforts.

Navigating North Coast Regulations with Confidence

California’s North Coast AVA is renowned globally, but it also sits at the forefront of environmental regulation. This winery, a Tier 4 facility under the Statewide General Waste Discharge Requirements for Winery Process Wastewater, recognized the critical need for a robust and compliant PW-SPERP. This isn’t just about avoiding fines; it’s about protecting precious water resources, ensuring operational integrity, and upholding a commitment to sustainability.

Comprehensive Planning, Actionable Insights

Epsilon Consulting approached the PW-SPERP development for this Winery with a meticulous eye, leveraging our in-depth understanding of process wastewater sources, collection systems, treatment, storage, and disposal. Our work was focused on transforming regulatory demands into practical, site-specific solutions.

Key areas where our plan delivered immediate value and actionable insights included:

Pond Liner Integrity: Identifying the need for critical integrity testing on existing clay pond liners from 1998, a compliance requirement under the Winery Order.
Nutrient Management Planning: Highlighting the absence of a Nutrient Management Plan (NMP) for their 9-acre Land Application Area and recommending its urgent development for sustainable land application.
Enhanced Monitoring & Alarms: Pinpointing gaps in comprehensive wastewater monitoring and recommending the installation of alarms for out-of-spec parameters and high flow rates to prevent exceedances.
Operational Procedures (SOPs): Recognizing the need for formal, written Standard Operating Procedures that explicitly incorporate spill prevention and emergency response steps.
Spill Response Equipment: Recommending the acquisition of larger-scale, water-specific spill kits to bolster existing response capabilities.
Diversion Pathways: Collaborating to identify and document temporary diversion pathways for effective spill containment beyond primary systems.

A Partnership for Ongoing Sustainability

For a multi-national entity, consistency in environmental management across its facilities is vital. The PW-SPERP developed for this winery not only ensures compliance with this specific North Coast AVA site but also strengthens the overall environmental management framework for the larger organization. Our ongoing annual review process ensures the plan remains dynamic, adapting to operational changes and evolving regulations.

Is Your Winery Prepared?

Just like here, every winery, regardless of size, must navigate California’s stringent water quality regulations. An effective PW-SPERP is an investment in your winery’s future – protecting your operations, your reputation, and our planet’s most precious resource.

Don’t leave compliance to chance. Contact Epsilon Consulting today to discuss how we can help develop or enhance your winery’s Spill Prevention & Emergency Response Plan.

Michael Long, Manager Epsilon Water LLC- Epsilon Consulting

Phone: 707-333-9167
Email: michael@epsilonwater.com
Website: epsilonwater.com

water compliance August 13, 2025

Protecting the Pour: Drinking Water Management & Compliance for North Coast AVA Wineries

August 13, 2025

In the heart of California’s North Coast AVA, the pursuit of exceptional wine is inextricably linked to the purity and availability of water. While irrigation and winemaking processes command much attention, the equally critical, yet often less discussed, aspect for wineries is drinking water management and compliance. Ensuring safe, reliable potable water for your employees, tasting room visitors, and residential staff isn’t just a best practice; it’s a legal obligation and fundamental to your winery’s health and reputation.

At Epsilon Water/Epsilon Consulting, we specialize in helping North Coast AVA wineries navigate the specific challenges and evolving regulations surrounding their drinking water supplies.

Understanding Your Drinking Water Sources

For many North Coast wineries, drinking water comes from one of two primary sources:

Private Wells: Many rural vineyards and wineries rely on groundwater pumped from private wells. This self-supplied water carries specific responsibilities for ensuring its quality and compliance.
Public Water Systems: Wineries located within municipal boundaries or served by a community water provider receive potable water that has already undergone treatment and monitoring. However, even then, internal plumbing and usage practices remain important.

This post will primarily focus on the considerations for wineries using private well water for drinking, as these operations bear the full burden of ensuring potable standards.

Evolving Regulations & Their Impact on Winery Drinking Water

California’s regulatory landscape is dynamic, with significant shifts directly impacting drinking water management, even for private systems:

1. The Sustainable Groundwater Management Act (SGMA) and Well Integrity

While often associated with agricultural pumping, SGMA’s primary goal is long-term groundwater sustainability, which inherently includes the aquifers supplying private drinking water wells.

How SGMA impacts your drinking water well:

Water Level Stability: GSPs (Groundwater Sustainability Plans) aim to prevent “chronic lowering of groundwater levels” by 2042. This directly addresses the risk of private drinking water wells going dry, a devastating scenario for any winery property.
Quality Protection: GSPs also focus on preventing “degradation of water quality.” This is crucial for drinking water, as it means local Groundwater Sustainability Agencies (GSAs) are developing plans to protect aquifers from contaminants that could render well water unsafe for consumption.
Monitoring Requirements: Depending on your basin, you may see new or enhanced groundwater monitoring requirements, which can indirectly inform you about the health of your drinking water source.
Well Permitting & Management: SGMA is leading to more stringent permitting for new wells and potentially increased scrutiny on existing wells, all aimed at protecting the overall groundwater basin from overdraft and quality issues.

2. The Vineyard Order (Waste Discharge Requirements): Protecting the Source

Adopted on June 12, 2025, by the North Coast Regional Water Quality Control Board, the Vineyard Order mandates practices to control sediment, nutrient, and pesticide discharges from vineyards.

How the Vineyard Order protects drinking water:

Reduced Contamination Risk: By minimizing the runoff of these substances, the order directly reduces the potential for them to infiltrate groundwater or contaminate surface water bodies that might serve as drinking water sources downstream.
Proactive Management: It encourages proactive vineyard management that benefits not just environmental health, but also the safety of water that could eventually reach a drinking water well.

3. Winery Process Water Regulations (Statewide Winery Order): Preventing Pollution

The Statewide General Waste Discharge Requirements for Winery Process Water, adopted January 20, 2021, regulates wastewater from winemaking.

How this regulation safeguards drinking water quality:

Direct Source Protection: This order aims to prevent process water (which can be high in organic matter, salts, and nitrogen) from degrading groundwater and surface water. For wineries relying on onsite wells for drinking water, preventing the contamination of shallow or deeper aquifers by process water is paramount.
Best Management Practices (BMPs): Implementation of required BMPs for managing wastewater (e.g., proper pond lining, controlled land application, spill prevention) directly minimizes the risk of harmful substances leaching into the ground and impacting drinking water wells.

Essential Drinking Water Management & Compliance for Wineries

For North Coast AVA wineries utilizing private wells for potable water, proactive management and strict adherence to safe drinking water practices are non-negotiable:

Regular Water Testing: This is the cornerstone of drinking water safety.
- Bacteriological Testing: Regular testing for coliform bacteria (indicators of potential fecal contamination) is crucial, especially after well maintenance, heavy rains, or any changes to the system.
- Chemical Analysis: Periodic testing for nitrates, inorganic chemicals (like arsenic, lead, chromium, perchlorate, which are naturally occurring in some California soils), and other potential contaminants is vital, especially given agricultural activities in vineyard areas.
- Certified Labs: All testing must be conducted by state-certified laboratories to ensure accuracy and compliance with California’s Title 22 Drinking Water Standards.
Wellhead Protection:
- Physical Barriers: Ensure wellheads are properly sealed and protected from surface runoff, animal intrusion, and chemical spills.
- Setbacks: Maintain appropriate setbacks from potential contamination sources like septic systems, waste discharge areas, and chemical storage.
Treatment Systems:
- If testing reveals contaminants exceeding Maximum Contaminant Levels (MCLs), appropriate treatment systems (e.g., filtration, disinfection, reverse osmosis) must be installed and maintained. Regular maintenance and monitoring of these systems are essential to ensure they remain effective.
Cross-Connection Control:
- Prevent any possibility of non-potable water (e.g., irrigation water, process water) mixing with your potable water supply through proper backflow prevention devices.
Employee Health & Safety:
- Ensure all staff have access to safe drinking water throughout the property. Provide clear information on water quality and any necessary precautions.
Emergency Preparedness:
- Have a plan in place for alternative drinking water sources in case of well contamination, power outages, or other emergencies.

Epsilon Water/Epsilon Consulting: Your Partner in Potable Water Security

Navigating the complexities of drinking water management and compliance can be challenging for busy winery owners. Epsilon Water/Epsilon Consulting offers specialized expertise to help you ensure the safety and reliability of your potable water supply:

Comprehensive Water Quality Assessments: We conduct thorough testing and analysis of your well water to identify potential contaminants and ensure compliance with state and federal drinking water standards.
Reporting Assistance: We guide you through any necessary and ongoing reporting requirements.
Treatment System Design & Optimization: If treatment is needed, we coordinate and facilitate effective solutions tailored to your specific water quality challenges.
Wellhead Protection & Best Practices: We advise on and help facilitate practices to protect your well infrastructure and prevent contamination.
SGMA & Regulatory Insight: We keep you informed about how broader water regulations impact your private drinking water sources, helping you stay ahead of compliance.

Your winery’s future is deeply rooted in the health of our environment and the quality of our water. Let Epsilon Water/Epsilon Consulting be your trusted partner in protecting this most precious resource.

Contact Epsilon Water/Epsilon Consulting today to ensure your winery’s drinking water is safe, compliant, and sustainable for generations to come.

Phone: 707-333-9167
Email: michael@epsilonwater.com
Website: www.epsilonwater.com