OG status:

Fully open

Author unit/section:

Manufacturing sector, Waste and Recycling

Target audience:

HSE Inspectors covering manufacturing and services industries.

Summary

This SIM advises Inspectors of the publication of the HSE/WISH guidance note “Safe waste and recycling collection services” (WASTE 23) and how it should be used by industry and by HSE inspectors. The guidance covers route specific risk assessments and control measures that may be identified by assessment.

Purpose

This SIM aims to advise inspectors of the guidance, its content, implications for the industry and use by Inspectors when dealing with dutyholders.

Collection activities account for the largest proportion of accidents within the waste and recycling industries. As part of its work to help industry improve performance the Waste Industry Safety and Health (WISH) Forum has published this guidance to address the hazards encountered during collection operations. The guidance reinforces the need to carry out risk assessment, identify control measures and implement those measures. It does not create any new requirements. However, the manufacturing sector is concerned about the level of detail that might be applied to assessments and the potential to over assess individual rounds. The guidance and this sector information minute have been issued to assist the industry and HSE inspectors achieve a pragmatic and proportionate interpretation of the requirement to risk assess work activities.

It must be stressed only the courts can give an authoritative interpretation of the law.

Message

Inspectors should use the guidance to promote the sensible use of risk assessment, resulting in clear and unambiguous risk control measures that will be used. Service providers (local authorities and waste collection organisations); service planners; managers; drivers and collection workers should all have valuable experience and views to contribute in devising safe systems of work and inspectors should consider the contribution of each at the following levels:

• Strategic decisions
• Generic assessments
• Route specific assessments and
• Dynamic assessment.

The overall purpose of undertaking route risk assessment is to ensure that operational staff are provided with a safe collection route and clear instructions on its safe operation. This applies to regular drivers and collection workers as well as relief/ casual/ agency/ new staff.

Activities required

During inspection and investigation inspectors should look for evidence of risk assessment of collection activities being applied at the four levels given above. Examples would include:

Strategic

When considering collection strategies health and safety issues such as vehicle design, receptacle type and material specific issues (e.g. noise and glass collections) should be assessed.

Generic

Assessment of issues common across the collection activities of a dutyholder can reduce the assessment workload and ensure effort is concentrated on site specific significant risks. Common topics may include manual handling; slips and trips; management/ monitoring; competence; violence to staff, dealing with “hung up” bins; selection of personal protective equipment; needle stick injuries and ill health. These control measures may be communicated to collection staff in general instructions and training.

Route specific 

Each route will have specific hazards that require individual assessment and bespoke control measures. Examples may include route planning to eliminate/ reduce reversing, avoidance of time sensitive areas such as schools around the start/ finish of the school day, determining which roads are suitable for single side or double side collection, avoidance of long distance carrying of loads and location specific hazards such as low overhead cables, staircases/ steps, poor lighting and aggressive dogs. As these control measures are route specific they can be communicated to drivers and staff on the daily route cards or other route information systems within the vehicle. Route cards/ sheets are already widely used to provide staff with details of “assisted collections” and “previously missed bins.”

Dynamic

Drivers and collection staff should have the ability and authority to react to changing conditions, taking action to ensure the health and safety of themselves and others. Examples may include changing weather conditions, temporary road works and mechanical breakdowns.  

The need to undertake risk assessment has the potential to be misinterpreted as a burdensome requirement. The emphasis of this guidance is to achieve risk control before a collection activity is operational and then ensure that workers are provided with route specific control measures and the ability to use them.

Initial enforcement expectation

Where inspectors find evidence on individual rounds of absent or inadequate control measures that may put workers and others at risk of serious injury (e.g. no safe reversing systems or inappropriate use of double side collections) then the initial enforcement expectation will be to issue a Prohibition or Improvement Notice as appropriate. It is recommended that initially any action is directed at the specific collection route whilst obtaining action across the service/ contract is ensured by other methods within a reasonable timescale.

Where inspectors find evidence of absent or inadequate risk assessments the initial enforcement expectation is an Improvement Notice.  It is recommended that inspectors use enforcement or other methods to seek evidence of suitable and sufficient assessment of named routes and then agree with dutyholders a programme of work to assess all routes.

Timing

The guidance note was published in April 2009.

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

The guidance: Safe waste and recycling collection services [272KB] was published in April 2009 and the Sector will continue to promote it with the trade media and stakeholder groups.

Contact

Chantal Nicholls, VPN 511 3012 Waste Management and Recycling (Manufacturing Sector), Cardiff.