OG Status:

Fully open

Author Section:

Waste and recycling section, manufacturing sector, Policy Group.

Target Audience

HSE inspectors covering manufacturing and services industries.

Summary

This SIM alerts inspectors to planned inspection campaign within the waste and recycling industry during 2009/10. Inspections should be targeted at skip-hire operations and commercial waste/recycling collections in busy high street and pedestrianised shopping areas.

Purpose

To deliver a programme of FOD inspections in 2009/10 to cover the issues relevant to skip hire and high-street collections. Inspections should be undertaken to ensure compliance with generic and industry specific guidance covering transport, falls from height and machinery safety issues.

Justification

The waste and recycling industry has an overall accident rate at least 4 times greater than the UK average and a fatal accident rate at least 10 times the average. It is not possible to identify the specific accident rates for these two specified activities, but they have accounted for 30% (12) of fatalities in the preceding 3 years.

Inspection of skip hire provides FOD inspectors with the opportunity to visit predominantly locally based SME companies on activities which have not previously been targeted.

Inspection of commercial waste/ recycling collections from pedestrianised shopping areas will concentrate on vehicle reversing and provides the opportunity (if relevant) to investigate areas of co-operation and co-ordination with other duty-holders. In many pedestrianised shopping areas service vehicles are permitted access within discrete times (early morning). Whilst this reduces or eliminates risk during the rest of the day, it does create a significant risk of collection vehicles coming into contact with pedestrian operators and members of the public at these specified times.

Audience/industry

Skip hire operations: site operators, managers and drivers.

Collection of commercial waste/ recycling: contract managers, drivers and those in control of the pedestrianised area.

Activities required

Band 3/4 FOD inspector to carry out site visits to assess the management and operation of risk control measures. The majority of the divisional time allocated to the waste/recycling work stream should be devoted to these inspection activities. For local planning purposes we would not expect either type of visit to take more than 0.5 contact days to conduct.

Timing

Visits can be made any time within the work year 2009/10.

Diversity

Inspectors should be aware of who (in terms of diversity e.g. men, women, disabled etc) is the target group in the sector they are dealing with. Give consideration to, and factor into the approach, any issues that may surround this audience such as literacy issues, English as a second language and disability (access needs).

The Diversity pages give more information on these areas.

Further information

Inspection pro formas are provided at appendix 1 [Word 83.5KB] and appendix 2 [Word 52.5KB] and further information is given in appendix 3 and appendix 4.

Initial enforcement expectations and model notices on waste specific issues to follow. In the meantime, there is supporting material on transport issues in the Workplace transport topic pack [PDF 840KB]

Please return completed pro formas to Lisa Weston, HSE, Phase 1, Government Buildings, Ty Glas, Llanishen, Cardiff, CF14 5SH.

Contact

For further information please contact Colin Mew, Manufacturing Sector, Government Buildings, Ty Glas, Cardiff, CF14 5SH. VPN 511 3063 tel 02920 263063.

Appendix 1

• Inspection pro forma for skip hire inspections [Word 83.5KB]

Appendix 2

• Inspection pro forma for collection of commercial waste and recyclables from pedestrianised areas [Word 52.5KB]

Appendix 3 Inspection of skip hire activities

Targeting

Using the waste management licences and waste carriers registers held on the Environment Agency’s website will list many skip hire operators by town and postcode. Alternatively, local trade directories can be used. Inspectors should concentrate on activities at the yard or transfer station as opposed to the point of collection of the waste. Experience has shown that the majority of accidents occur in these situations.

The manufacturing sector holds a list of skip hire companies that was drawn up in 2001.

Specific issues

Site transport arrangements:  the majority of accidents in this industry are related to workplace transport. Site layout, control of the site, organisation of vehicle movements, vehicles and competence of drivers are key issues that have featured in fatalities. See:

• Workplace transport inspection pack [PDF 840KB]
• Safe transport in waste management and recycling facilities [PDF 186KB]
• Safe use of skip loaders (INDG378) [132KB]
• Skip and container safety in waste management and recycling [PDF 211KB]
• Hook loader vehicles: Applicability of LOLER
• Preventing runaway skip lorry incidents (SIM 03/2004/20)
• Sheeting and unsheeting

Machinery Safety: A variety of static machinery can be found within skip hire operations as the materials are treated. These can include trommels, other screening units with troughed conveyors and crushers. Failure to provide, use or maintain guarding is a significant risk to workers safety. 

Hand sorting using vehicle assistance: There have been several fatalities resulting from inadequate control of mechanical shovel movements during hand picking of waste/ recyclables from heaps (totting). See:

• Hand sorting of recyclables (totting) with vehicle assistance [PDF 151KB]

Other issues

There are a number of other topics which can be explored during visits. These include:

• Welfare (toilets, washing facilities, rest rooms etc)
• Orphaned compressed gas cylinders [PDF 634KB]
• Handling of asbestos or other hazardous waste.

Recording visits

The inspection pro forma at appendix 1 [Word 83.5KB] should be completed and returned to the manufacturing sector (Lisa Weston, Cardiff Office). Contacts should be recorded on COIN as normal, no keywords are required.

Inspector competence

No specific training or competence is required to undertake these visits.  The inspection pro forma and listed guidance material covers the relevant areas.

The manufacturing sector can provide briefings to groups of inspectors where necessary.

Health and safety

Inspection of skip hire companies has potential to expose HSE staff to risks to their safety.

There is a significant risk on site due to vehicle movements. Inspectors should ensure that they are accompanied on their visit by site management and that drivers are aware of their presence. Inspectors must wear high visibility clothing at all times. When observing ‘totting’ of vehicle movements inspectors should be in a safe position away from the vehicle’s operating area, the driver should be aware of your presence at all times and you do not place yourself in blind spots or other areas where vehicles may collide with you.

Inspectors should be aware of and comply with HSE’s policy on lone working

Appendix 4 Inspection of commercial waste/ recycling collection activities in pedestrianised areas

Targeting

Use of local knowledge to identify pedestrianised shopping areas to which collection vehicles have access. This will normally be in early morning/ late evening.

Liaison with other bodies

Site owners/ operators may need to be involved to ensure safe access to commercial premises is provided whilst reducing the risk to members of the public. 

Specific issues

On many UK pedestrianised high streets there is a period in early morning and late evening when large goods vehicles and other service vehicles are permitted to use the areas. These vehicles have access to the areas at the same time as commuters are traveling to work. Inspectors should examine the controls in place to prevent waste/ recycling vehicles coming into contact with pedestrians. 

Safe operating procedures for driving the collection vehicle in the area should be examined and there may be a need to discuss arrangements with site controllers to set standards, monitor and control those areas.

Collection organisations should be encouraged to examine the most appropriate time and place of collection with their clients. For example materials may be able to collected from points served by a recognised traffic route.

Specific issues of safe operation are:

• Access
• Reversing/manoeuvring
• Suitability of vehicles
• Training
• Sitting of pick up points

Other issues

There are a number of other topics which can be explored during visits. These include: liaison between the collection company and the client to arrange for collections at times; locations where there is likely to be least pedestrian access.

Large companies

Several large companies within the waste management industry have an HSE lead inspector or a lead inspector is in the process of being appointed. It is recommended that inspectors liaise with the named lead inspectors before visiting. Details can be found on the Pilot companies list under FOILE.

Recording visits

The inspection pro forma at Appendix 2 [Word 52.5KB] should be completed and returned to the manufacturing sector (Lisa Weston, Cardiff Office). Contacts should be recorded on COIN as normal, no keywords are required.

Inspector competence

No specific training or competence is required to undertake these visits. The inspection pro forma and listed guidance material covers the relevant areas.

The manufacturing sector can provide briefings to groups of inspectors where necessary.

Health and safety

Inspection of vehicle operations within a pedestrianised area has potential to expose HSE staff to risks to their safety.

Inspectors must wear high visibility clothing at all times. Inspectors should make drivers aware of their presence before approaching any vehicle.

Inspectors should be aware of and comply with HSE’s policy on lone working.