Workplan 2013-14 – Hotspot Inspections at Material Recovery Facilities (MRFs)

Open Government Status

Fully Open

Pubication date

29/03/13

Review date

29/09/14

Author Unit/Section

DCEO/OPSTD/Agriculture, Waste and Recycling Sector/Waste and Recycling Team

Target Audience

HSE Inspectors dealing with waste and recycling activities

Summary

This explains the waste and recycling hotspots intervention programme for 2013-14, which is the targeted inspection of 75 Material Recovery Facilities (MRFs - also known as Material Reclamation Facilities or Material Recycling Facilities), ie 25 per FOD geographical division.

Introduction

The waste and recycling industry is considered to be high risk based on its health and safety performance. MRFs typically present a wide range of health and safety issues and the purpose of this initiative is to:

• improve intelligence about prevailing standards at MRFs.
• improve intelligence about prevailing standards at MRFs
• increase inspector awareness of and competence to inspect MRF health and safety issues
• have a positive impact upon the persistently high rates of serious and fatal accidents and incidence of ill health across the industry

Action

The Waste and Recycling Team will supply Heads of Operations in FOD’s three geographical divisions with a central list of known MRFs for the start of the 2013-14 work year.

FOD Divisional Intelligence Officers (DIOs) should use this ‘central MRF list’, local knowledge and relevant COIN information to prepare ‘local MRF lists’ highlighting:

• local ‘poor performers’
• sites ‘not recently visited’ (ie never visited or last visited over three years ago)
• small enterprises or micro-businesses (ie businesses with less than 50 and 10 total employees respectively)

DIOs may use further indicators to help identify ‘poor performers’ such as:

• Category A premises (based on Inspection Rating Scores)
• Previous enforcement – notices, prosecutions
• RIDDOR accident and incident history
• Complaints
• Intelligence from visiting officers
• Intelligence from other enforcement agencies – notably Environment Agency, Police etc
• Adverse Insurance Reports (AIRs)
• Electrical Safety Quality and Continuity Regulations (ESQCR) notification

FOD inspectors dealing with the waste and recycling sector should:

• Plan and carry out 25 MRF inspections per FOD geographical division during 2013/2014 based on their local MRF list
• Carry out reactive work at MRFs (i.e. complaints and accident investigations) as normal

See Organisation section for details

Background

Waste management and recycling is a rapidly growing industry. Its overall employee accident rate is around 4½ times greater than the Great Britain all industry average and its fatal accident rate around 17 times the average for all industries.

• Waste and recycling: Work related injuries and ill health

MRFs can be run by micro-businesses, small enterprises, local authorities or major private contractors. They are specialised plants that receive, separate and prepare recyclable materials for onward transport and further processing. They can be sorting and segregating recyclables from municipal/household or commercial/construction/industrial waste.

The recyclables go through various processes, mainly mechanical and some manual, to maximise recovery. MRFs may use a range of technologies to sort recyclables by their physical and chemical properties including:

• shape
• size
• weight
• magnetism and;
• light absorption

Further information is provided at HSE Waste Management and Recycling webpage.

Organisation

Targeting

Inspectors should focus, in the first instance, on any sites that are identified locally by DIOs as ‘poor performers’ or ‘not recently visited’. Priority should be given to MRFs known or suspected to be run by micro-businesses or small enterprises.

Whenever possible, visits should not target organisations included in the:

• Inspection intervention with local authorities (see SIM 03/2010/04)
• National lead inspector (NLI) interventions for Waste &Recycling.  (see SIM 03/2012/09)

If a visit is necessarily planned to an MRF run by an organisation subject to NLI intervention then the relevant lead inspector(s) should be contacted beforehand and kept informed of any significant outcome (see SIM 03/2012/10 for contact names).

MRF inspections should target the following:

• workplace transport
• machinery safety, especially guarding and isolation procedures for cleaning, blockage clearing and maintenance
• work at height, especially to access machinery for cleaning, blockage clearing and maintenance
• COSHH, especially dust and bio-aerosols
• noise
• MSDs/ergonomics, especially at picking stations
• migrant & temporary/agency workers, especially communication and training
• worker involvement
• welfare

See the References section below for further information.

Timing

The work should take place throughout 2013/2014.

Resources

FOD Geographical Divisions SaNE, Central and Southern should undertake 75 MRF inspections in total.  This anticipates that each will carry out 25 MRF inspections.

37.5 days total contact time has been allocated for this work based on 75 visits at 0.5 days contact time per visit. This does not take into account any follow up time for enforcement, etc.

The nature of MRFs means that inspections are intended for B3 inspectors; although more experienced B4s might also be deemed suitably competent. Specialist inspector support may be required, especially where follow up and enforcement action is proposed.

Recording & Reporting

COIN

All cases/service orders should be linked/related to COIN Master Case 4310616, set up specifically for this work so that the impact of the initiative can be monitored.

COIN narrative reports should provide a summary of inspection findings under the headings:

• workplace transport
• machinery safety
• work at height
• COSHH
• noise
• MSDs/ergonomics
• migrant & temporary/agency workers
• worker involvement
• welfare

Dashboard

FOD Divisions should provide narrative summary reports via the quarterly Dashboard reporting process including:

• numbers of MRFs visited
• enforcement action (notices and prosecutions); and
• any other interesting issues identified

Other feedback

Inspectors should advise the Waste and Recycling Team directly if they find:

• examples of especially good or extremely poor practice
• any other notable issues

Preferably with copies of relevant photographs, letters, notices, etc.

The Waste and Recycling Team will produce a summary report in 2014-15 quarter 1.

Health & Safety

Inspectors must wear high visibility clothing and appropriate footwear at all MRF inspections.

Further References

HSE food manufacture website:

• HSE’s waste and recycling website
  • Processing/sorting
  • Materials Recycling Facilities
  • Disposal and energy from waste
  • Occupational health
  • Safety topics
  • Training
• Waste Industry Safety and Health Forum (WISH) Good Practice Guidance
• Guidance for Regulators Information Point (GRIP) – Waste and recycling
• Inspection Topic Packs.  The following may prove useful:
  • Workplace transport
  • Work at height
  • Musculoskeletal disorders (MSDs)
  • Noise
  • Migrant Working
• Consulting and involving your workforce
• Working in Great Britain from overseas
• WRAP website

Contacts

Agriculture, Waste and Recycling Sector, Waste Management and Recycling Team.