While many companies have embraced safety as a part of the corporate culture, some organizations still fall short. David Biderman, general counsel of the National Solid Wastes Management Association (NSWMA) and the leader of the organization's safety efforts, says that while the industry's safety record is improving on a year-over-year basis, a disproportionate number of fatalities and accidents involve the facilities of smaller waste companies.

Each year the federal Bureau of Labor Statistics calculates incident rates for all North American Industry Classification System (NAICS) codes to determine an organization's safety performance. As awareness has increased in facilities, incident rates have gone down. For example, in 2003, NAICS code 562, which covers waste management and remediation services, recorded a total recordable incidents rate (TRIR) of 8.3 and a days away and restricted time (DART) rate of 5.7. By 2005, the TRIR for the code had declined to 7.1 and the DART rate to 4.7.

To calculate your company's rate, refer to www.osha.gov.

Elements of an Effective Program

The first step in any safety program is to perform a hazard assessment of all facilities, including people, equipment and processes. Any hazards identified should be addressed by the “hierarchy of safety”: eliminate, minimize, protect against and train about.

Following is a general facility safety checklist:

• Make sure there is adequate PPE for all employees, visitors, suppliers and contractors. These items include hardhats, visibility vests, safety glasses, safety shoes and/or gloves.

• Perform lockout/tagout procedures. For instance, these need to be performed when clearing jams and during maintenance.

• Make sure all fire exits are free of obstructions and open freely.

• Establish non-smoking policies and hot work (any flame-producing activity) permit programs to prevent fires.

• Ensure that all safety guards are in place on belts, gears, motors and rotating shafts.

• Keep stairs and walkways clear.

• Observe tipping floor operations. Only one person should be out of and within six feet of the truck. No one should be closer than 15 feet to any mobile equipment.

• Observe traffic flows, speed and patterns throughout the facility.

• Watch fork truck and loader operations. Pay close attention to speed, seat belts, back up alarms and general operations.

• Observe conveyors, and make sure there is no walking, standing or stepping on the belt unless it is locked and tagged out.

• Check bale storage area for integrity, height and distance from walking areas.

Furthermore, companies need to be aware of — and in full compliance with — OSHA regulations for the following items, which result in the highest number of citations against MRFs:

• Bloodborne pathogens
• Confined space entry
• Dust mask
• Emergency action plan
• Energy control (lockout/tagout)
• Fall protection
• Fire prevention plan
• Hazard communication
• Hearing conservation
• Machine guarding
• PPE
• Powered industrial trucks
• Respiratory protection

Moving Forward

Through the American National Standards Institute (ANSI), the recycling industry is setting standards for which companies will, in the absence of applicable OSHA regulations, ultimately be held accountable. Companies that still floor sort need to rethink their business and incorporate best industry practices into their corporate culture.

“Companies who haven't yet made the commitment to reducing worker exposure should provide basic safety training to employees and then enforce their safety rules,” Biderman says. “ANSI standards for collection, MRFs and containers provide a blueprint for quality safety training, and NSWMA supplements that information through its weekly safety newsletter, videos and regional training sessions.”

Owners and managers who aren't fully committed to employee safety should get serious now — before a serious accident occurs.

Susan Eppes is president of Houston-based EST Solutions Inc., a safety consulting firm.

RECYCLING HAZARDS

Hazards common to the recycling industry include:

• Fires caused by arson, contractors doing hot work in the facility, hot loads, mechanical failure, and smoking in non-designated areas
• Accidents caused by equipment — generally trucks, forklifts or bucket loaders — running over people
• Serious injuries from balers, compactors or processing equipment occurring during maintenance activities
• Minor cuts and bruises, slips, trips and falls