A Foundation For Safety Programs

John A. Legler

For many years the waste and recycling industry has expressed a desire to produce a comprehensive update and revision to the Washington, D.C.-based National Solid Wastes Management Association's (NSWMA) 1989 "Manual of Recommended Safety Practices"- and now it's here.

Late in 1997, a proposal was presented by the Waste Equipment Technology Association (WASTEC) - which along with NSWMA is part of the Environmental Industry Associations (EIA), Washington, D.C. - to the Environmental Research and Education Foundation (EREF), Washington, D.C., with the hopes of initiating a project to fulfill the industry need for comprehensive and updated information about the changes in equipment technology, applicable regulations, facility design and even the nature of the waste stream. EREF provided a grant to match the funding commitments of the three initial program sponsors: WASTEC, EIA and Waste Management Inc., Houston.

The first five sections of the new "Manual of Recommended Safety Practices," including the introduction, manual use, general safety knowledge, core safety practices and a section on the collection, containment, handling and transportation of wastes and recyclable materials, was unveiled at WasteExpo in Dallas in June 1999.

The manual will be updated with new and revised sections about once a year, as additional funding is raised and consensus is reached within the advisory committee. The next update is targeted for WasteExpo 2000, and will include sections on transfer stations, landfills and materials recovery facility (MRF) operations.

This manual represents a coordinated effort of manufacturers, distributors and consultant members of WASTEC, as well as waste service company safety professional members of the NSWMA. These industry experts provided resources and peer review through the EIA Joint Safety Advisory Committee.

The 1998 edition of this manual was drafted by two safety professional contractors, Gerald Van Beek, president of SACOM Inc., Houston, and David Malter, president of Malter Associates, Downers Grove, Ill., in cooperation with John A. Legler, executive vice president of WASTEC, who also serves as EIA's lead safety expert.

Industry Safety To understand the importance of this manual, it first is important to understand that the modern waste and recycling industry is an increasingly complex technical operating environment. New methods continually are being devised to responsibly collect, transport, contain, process, treat and dispose of discarded or spent materials. These methods use both tried and true technologies and procedures, which have been the mainstay of traditional operations and high technology devices for both specific wastes and combinations and systems.

The need to increase efficiency in recycling and composting also has initiated the advent of technologies, many from other material handling industries. Additionally, many aspects of today's industry resulted from environmental regulatory mandates.

There are three major sources of normative safety guidelines, which affect the industry at the national level. Knowledge of these requirements is essential to worker safety at every level, including most senior management, safety professionals and managers, line supervisors who have safety responsibilities, all the way to vehicle drivers, equipment operators, crews, maintenance and other personnel who conduct the day-to-day line activity of the industry.

* The Department Of Transportation (DOT) issues regulatory standards for the design and construction of commercial motor vehicles, requirements for licensing and certification, rules for motor vehicle operations, inspection and equipment operations, as well as requirements for the transportation of certain materials.

* The Occupational Safety and Health Administration (OSHA) provides safety norms for general industry, construction and maritime operations, covering general safety program requirements and mandatory standards to control specific hazards.

* The industry itself engages in "self regulation" by developing consensus safety standards under the Accredited Standards Committee Z245 (ASC Z245), which is accredited by the American National Standards Institute (ANSI). EIA has served as the secretariat for ASC Z245 for more than 27 years. Although consensus standards are voluntary in nature, they are used extensively by regulators in interpreting safety performance and should be considered as critically essential.

The regulatory focus of the new manual lies with federal requirements. State transportation and workplace safety regulations often follow the federal rules, but they can and do differ in some significant ways from the federal government's edicts. Thus, researching and evaluating state regulations should be considered an integral part of incorporating this information into a corporate or local safety program.

In addition to these normative requirements, a number of other safety resources play a part in achieving a high level of safety performance. These documents incorporate technical information and other knowledge bases with mandatory performance standards to form a program that systematically addresses the safety challenges that are inherent in any waste or recycling operation.

These additional resources include:

* Corporate safety policies and procedures;

* Sample regulatory compliance guides;

* Operations and maintenance manuals for equipment and systems;

* Commercially available training products and programs; and

* Safety and health professionals and consultants.

There are many sources for this type of information. However, most of them are generic and may not address the operating environment inherent to the waste and recycling industry.

Building Bridges The EIA's "Manual of Recommended Safety Practices" attempts to provide a curriculum and a resource file as a basis for waste management entities and technology producers to construct their safety programs, as well as learn about the hazards that must be addressed in designing equipment and systems for the industry. It also can be used as a training program for developers to use in constructing relevant and meaningful education for the industry.

Far more than a stand-alone product, this new manual attempts to integrate the expertise of various engineering, safety, supervisory and management professionals throughout the industry. And, it is intended to be a bridge among the various disciplines whose combined practices provide a rich framework of both theory and practical experience into a meaningful, effective and relevant curriculum.

In theory and practice, it is essential that workers in an increasingly complex technical world have an excellent safety foundation. Today's technology and systems are flexible enough to handle a variety of material types and sizes. Because of this, the safe and efficient operation of these technologies requires that supervisors and line employees make situational-based decisions. If employees do not understand the rationale behind these decisions, or if they lack a safety-related focus, these decisions may lead to a significant increase in hazards. Thus, this manual seeks to prepare waste and recycling industry workers to identify the situations that could cause accidents, control options that are available to them and choose the most effective course.

Industry standards provide the benchmarks for the safe performance of technology. Regulatory standards are the result of statistical research into the causes of frequently experienced or highly dangerous hazards. Science often conflicts with reality when line supervisors are confronted with the realities of collecting, transporting and handling a constantly variable variety of materials in unusual geographic, weather and logistical situations. But by using the expertise of the various disciplines, including experienced operational managers, the manual seeks to promote information that will enhance, rather than hinder operational efficiency, within the bounds of sound science.

The key factor in the safety equation is the employer - large or small, public or private, technically complex or simple. Because modern waste and recycling management systems involve the integration of equipment, technologies and methods specific to an operation, operations management bears the most critical role in safety in the industry.

Even if suppliers provide all of the required technical and safety related information, even if the equipment is designed and manufactured to safety standards, or even if the best training products and information are available, all is for naught if the employer breaks the chain of information that ultimately must lead to the line employee.

Management must seek to stay current with regulations, standards and other safety related information. It also must monitor and modify the safety performance of its operations so that they continue to address problems and use the experiences of others to avoid repeating mistakes.

Industry safety is the result of a cooperative effort.The manual seeks to provide a "game plan" to assist a team of management and professionals in being successful. Just as management must select the right equipment, it also must make the right choices from the many excellent sources of safety related information, training products and expertise that are available.

Employers also must realize that as important as it is to communicate safety related information to line supervisors and employees, it also is critical to communicate safety benchmarks and operational requirements to other entities which are part of the product and operational chain.

The "Manual of Recommended Safety Practices" is available from the EIA publication sales office for $50 for members and $150 for non-members. Call toll-free (800) 424-2869. EIA also is seeking sponsorships to fund completion of the remaining targeted sections and to update the manual continually. To help support this project, contact John A. Legler, executive vice president, WASTEC, 4301 Connecticut Ave. NW, Washington, DC 20008.