The Health and Safety Executive recently put the waste and recycling industry on notice, announcing that it will begin unannounced inspections in the industry this week due to its higher-than-average fatality and injury rate. But the hazards present in waste management — including from machinery and transport — apply to a range of industries. Mike Sopp stresses the important role risk assessment can play in mitigating them.
The latest figures from the UK Government indicate that in 2014, the commercial and industrial sectors alone produced some 2.7 million tonnes of waste.
Under numerous pieces of environmental legislation, businesses have a duty of care to manage waste. The rationale is that this will ensure that waste is managed at all stages in such a way as to reduce waste, prevent risks to the environment and human health and to deter criminal behaviour.
In addition to environmental matters, waste can present various hazards when on commercial and industrial premises that if not managed correctly can impact not only on environmental but also health and safety compliance.
An appropriate risk assessment process will enable the duty holder to identify the risks associated with these hazards and implement the necessary risk control measures required to meet and manage compliance requirements.
Waste and hazards
Waste legislation and the duty of care aim to prevent or reduce the potential negative impacts associated with waste, particularly during storage, transportation and final disposal.
However, there are other hazards and associated risks on-site that may materialise if waste management arrangements are not implemented. These can include:
handling hazards associated with lifting and/or carrying waste materials
coming into contact with hazardous waste materials
waste storage in terms of fire risks both to the premises and surrounding premises
the movement of waste collection vehicles.
It is almost inevitable that waste will have to be handled at some stage. This clearly puts those involved with the activity at risk for musculoskeletal disorders (MSDs), eg when removing waste from the building into larger containers outside the premises.
In addition, there are risks of cuts and abrasions from sharp objects that may have been discarded (eg broken glass) as well as exposure to hazardous waste substances that could cause ill health or infection.
Fires in combustible or flammable waste can spread rapidly and produce significant heat and flames. In addition, the manner in which waste is stored can impact on other fire precaution measures such as escape routes.
The collection of waste may well involve the movement of large vehicles and/or waste containers on-site. The main hazards are:
persons being struck by or run over by vehicles/containers
persons being struck by something falling from vehicles/containers
containers overturning and hitting persons.
The need to consider such hazards in risk assessments is noted in relevant legislation and/or associated guidance. This includes a general requirement in the Workplace (Health, Safety and Welfare) Regulations 1992 to ensure that waste materials are not allowed to accumulate in a workplace except in suitable receptacles.
More specifically, L5, the Approved Code of Practice to the Control of Substances Hazardous to Health Regulations 2002 (COSHH), states that a suitable and sufficient assessment of the risk created by work activities should “take into account those substances which are… produced at the end of any process, eg waste, residues, scrap etc.”
Similarly, guidance to the application of fire risk assessments suggests that waste materials should be identified as a source of fuel.
Taking into account the hazards detailed above, determining and analysing the risks, then identifying the relevant risk control measures will require waste related matters to be “built-in” to the relevant risk assessment process for the hazard areas.
As part of the risk assessment of waste a number of issues must be considered as follows.
The types and quantities of waste materials to be produced.
The locations where accumulations of waste materials are assembled.
How and when the waste is to be removed to containers outside the building.
The types of containers to be used to store the waste.
Where the containers are to be located.
The frequency of collection of waste from these locations.
Depending on the type of waste, an assessment of the hazardous properties of the waste as part of the classification process may be needed. This will include identifying the chemical composition of the waste and then assessing hazardous properties through:
calculation, by referring to a concentration limit for a hazard statement code/s
testing, to prove whether a particular hazardous property is present or not
the safety data sheet, if the waste is a manufactured product whose composition has not changed for that specific product.
Once the waste factors have been identified, an assessment can be made as to the current handling, storage and disposal control measures that are currently being used, so as to determine if baseline best practice is being adhered to. A number of aspects should be critically examined with, for example, the following questions being addressed.
Waste handling. Are wastes handled in a safe manner with due attention to associated hazards? Are employees made aware of the hazards of the waste? Are loads kept low and mechanical aids utilised?
Containers. Are appropriate receptacles used for the storage of waste? Are the containers sensibly located? Are the containers suitably labelled? Do they have lids?
Waste segregation. Is waste segregated into appropriate categories? Are employees made aware of segregation requirements and arrangements?
Storage areas. How and where are the wastes stored? Are they stored away from premises and boundary walls? How long are wastes stored prior to collection?
Vehicle safety. Are traffic routes to and from the waste storage area separate from pedestrian routes? Are there set times for collection? Have traffic calming measures been employed?
Clearly the question set used to determine the baseline requirements should be based upon the specific site circumstances but guidance noted below will enable an appropriate question-set to be developed.
When considering the most reasonably practicable means of eliminating or reducing risks, before identifying specific risk-related controls, the organisation should look at:
preventing the waste being produced (in line with the waste hierarchy)
minimising the amount of waste produced, eg by extending the lifecycle of an asset or changing processes
whether the waste can be rendered less hazardous through chemical, physical or thermal treatment processes.
When reducing risks from the handling of waste materials, the usual procedures contained in the Manual Handling Operations Regulations 1992 should be adopted. The assessment may identify simple measures such as ensuring that internal waste containers are of a size that prevents an individual from lifting a large load, containers are designed to make handling easy and trolleys are provided to move waste around the site.
Where waste handling is likely to involve materials (and containers) that could cause injury through cuts and abrasions, thought will have to be given to as to whether the containers are appropriate and whether any form of personal protective equipment is required in the form of gloves or protective footwear.
Similarly, for wastes that are hazardous to health, the organisation may need to consider the use of personal protective equipment. However, the key is to prevent exposure through elimination of the hazard or, where this is not reasonable, the use of appropriate containers to transport and store the hazardous waste materials.
The type of container used to store waste should be suitable and sufficient in number. As with environmental requirements, containers should not allow the escape of any waste material, eg by being fitted with lockable lids.
Where certain wastes are incompatible, containers should be clearly labelled and staff made aware of the need to separate the substances or materials involved. Aerosols and flammable liquid containers, for example, should be kept separate from other forms of waste.
Arson risks are significant for waste materials. Guidance to the Regulatory Reform (Fire Safety) Order states that the responsible person should “develop a formal system for the control of combustible waste by ensuring that waste materials and rubbish are not allowed to build-up and are carefully stored until properly disposed of”. It may also mean having to provide containers that are made of non-combustible material.
In addition, thought will have to be given to security issues and the threat of arson, which may require waste containers to be situated in a secure, well-lit environment. As a general rule, waste should not be stored within 2m of the premises perimeter.
Finally, the organisation should be engaging with its waste collection contractor to plan the collection process. Typical measures to consider will be:
selecting a time and route for collection that minimises risks through the number of pedestrians present
ensuring the most appropriate vehicle is used for the type of site and waste
eliminating the need for the vehicle to reverse when collecting waste from site
planning waste collection schedules to ensure vehicles/containers are not overloaded
installing traffic calming measures to keep vehicles at slow speeds when on-site.
The following are available from Department for Environment, Food and Rural Affairs.
Guidance on the Legal Definition of Waste and its Application. A Practical Guide for Business and Other Organisations
Waste Duty of Care Code of Practice
The following are available from the Health and Safety Executive.
L5 Control of Substances Hazardous to Health. Approved Code of Practice and Guidance
HSG136 A Guide to Workplace Transport Safety
The following is available from the RISC Authority.
RC54 Fire Safety at Recycling Centres
Last reviewed 3 October 2017