Workplan 2016/17: Inspection of Local Authority (LA) household waste and recycling collections
- Open Government Status
- Fully Open
- Publication date
- Review date
- Guidance owner
- OPSTD/Agriculture, Waste and Recycling Sector/Waste and Recycling Team
- Target Audience
- FOD inspectors and Divisional Intelligence Officers (DIOs) dealing with Local Authorities (LAs) and waste and recycling
This describes an on-going programme of inspections to LA waste and recycling collection activities (in England, Scotland and Wales) to assess health and safety standards. It applies to all Local Authorities (LAs) whether the service is delivered in house or contracted out.
This work programme is a continuation of the intervention with LA waste and recycling services in 2015/16. A programme of inspections of LAs took place between 2009 and 2014 which focused on their roles as client and service provider in the procurement of waste and recycling services. This initiative aims to:
- further improve health and safety standards during collection of household waste and recycling
- reduce the incidence of injury, ill health and days lost in the waste and recycling industry
- maintain a regulatory presence within LA waste and recycling services following the LA intervention that took place between 2009 – 2014 which focused on their roles as client and service provider in the procurement of waste and recycling services
- focus on the most commonly identified areas for improvement by inspectors which have been published in "Summary of HSE's inspection initiative of household waste and recycling services"
- enable inspectors to assess whether LAs have learned and applied lessons from the previous inspection initiative, especially where the collection service is contracted out.
- use the guidance provided by the Waste and Recycling Sector Team to identify in every LA whether the waste and/or recycling service is:
- create a master case for every LA inspection and if necessary an inspection case for the contractor/s.
B3 and B4 inspectors should:
- refer to the master case to identify whether the LA
- contracts out the service. If so, contact with both contractor and LA should be made during the inspection phase
- operates in partnership with other LAs (shared services). If so, the activities may only need to be inspected in one LA, but a note should be made in all LA master cases.
- inform NLIs of their intention to visit and of any significant issues raised with contractors who are part of the NLI initiative (National Lead Inspector (NLI) interventions with significant waste and recycling companies. 2016/17 refers).
- carry out inspection and record in accordance with current work recording instructions (COIN/DO IT). See “Reporting and Recording” for further details.
- focus attention on the issues identified in the “Organisation” subsection of this document. The online inspection proforma should also assist inspectors (See Appendix 1 for a blank hard copy of the proformas which can be used on site).
- enforce in accordance with HSE’s Enforcement Policy Statement and Enforcement Management Model
- follow up the role of the LA as client where significant failings are found at sites that are contracted out (especially monitoring arrangements, service procurement and service management).
- complete the online inspection proforma(Waste and Recycling Team will attach a copy of the completed proforma to the LA master case).
- advise the Waste and Recycling Team about any issues of particular note (e.g. instances of good or extremely poor performance), with photographs, copies of letter/NOC/Notices.
Waste management and recycling is considered high risk based on its relative health and safety performance. For example, over the five years to 2014/15, the rate of fatal injury to workers in W&R was on average about 11 times the rate for all industries while the rate of all self-reported non-fatal injuries in W&R was about twice that for all industries and of a similar order to the non-fatal injury rate seen in the agriculture and construction sectors. The rate of all self-reported work-related illness is also higher in the W&R industry compared to the average rate across all industries (figures based on HSE official statistics)
- Collection and sorting activities account for a significant proportion of the injury and ill-health in the industry.
- The responsibility for making arrangements for the collection of household waste and recycling rests with LAs.
- A previous inspection initiative (2009 to 2014) focused on the role of local authorities (LAs) when procuring and managing municipal (household) waste and recycling contracts; and/or (where applicable) delivering and managing in-house waste and recycling services.
- The initiative started in 2009 with the development and promotion of guidance “Procuring and managing waste services”. The inspection phase took place between October 2010 and March 2014. 99.5% (378 out of 380) of relevant LAs were inspected during the inspection phase.
- The summary findings are available on HSE’s website.
- This inspection initiative provides the opportunity to:
- target the areas for improvement identified in the summary findings
- identify if there has been an impact on health and safety standards due to changes in the way waste and recycling is being collected. For example due to:
- mergers of LA waste services
- increasing separation of recycling at the kerbside (use of kerbside collection vehicles)
- handling multiple streams (green, kitchen, residual and a wide range of recyclables)
There are 380 LAs that provide municipal (household) waste and recycling collection services either directly or indirectly through contractors.
- SaNE 79
- Central 152
- Southern 159
However there are approximately 40 LAs that are in a waste partnership with other neighbouring authorities for the collection of waste and/or recycling. Only one visit may be necessary if a partnership is inspected.
DIOs should note that visits completed in 2015/16 are identified on the spreadsheet provided by the Waste and Recycling Sector.
Early evaluation of this initial phase of follow up visits in 2015/16 has indicated higher material breach rates where services are contracted out. DIOs should continue to refer to the spreadsheet and instructions provided by the Waste and Recycling Sector for targeting in 2016/17.
Inspectors should focus on the following issues at the site inspection:
- Manual handling
- Route risk assessment*
- Vehicle and bin lifts
- Worker involvement
- Contractor management (including the role of the LA as client)
* Topics most commonly identified as areas for improvement by inspectors in the previous initiative.
- The online inspection proforma (see Appendix 1) will also act as an aide memoir for inspectors.
For further details see the WISH guidance
Inspections should be carried out any time between 1 April 2016 and 31 March 2017.
It is anticipated that 1 day of site time per intervention will be required (this may cover more than one LA where LAs work in partnership)
This does not take into account DIO activity, follow up (e.g. enforcement) time, reactive work or any input that may be required from specialist inspectors.
It is expected that inspections will be carried out by B3 inspectors. However, more experienced B4s may also be deemed suitably competent.
Recording and reporting
- complete record ratings and notes in the inspection case
- relate the LA inspection case to the contractor case if the service is contracted out
- complete the online inspection proforma (Waste and Recycling Team will attach a copy of the completed proforma to the LA master case note).
- report back to NLIs if the collection service is run by one of the NLI companies listed in OG ????? and there are significant issues found.
Inspectors are also encouraged to share with the Waste and Recycling Sector Team any issues of particular note (eg particular instances of good and extremely poor performance, with photographs, copies of letter/notices, etc.)
The Waste and Recycling Sector Team will use the proformas, enforcement action data (material breaches, notices and prosecutions) and overall rating scores to produce a final summary report in 2017/2018.
Findings will be communicated to inspectors via internal briefings and the industry via press articles, web pages and through the Waste Industry Safety and Health (WISH) forum.
Health and Safety
Inspecting household collection activities has potential to expose HSE staff to health and safety risks. Inspectors should refer to HSE’s guidance for visiting staff on the intranet.
There are particular risks due to vehicle movements. Inspectors must wear high visibility clothing and appropriate footwear at all times and should ensure drivers and operators are aware of their presence.
Hearing protection may also be required, particularly if glass is being recycled.
English may not be the first language of some collection operatives.
Frequently asked questions
HSE’s waste and recycling website. Selected sub-sites include:
Vulnerable Workers, Agriculture, Waste and Recycling Sector - Waste Management and Recycling Team, HSE Cardiff office.
Appendix 1: Copy of online inspection proforma