---

To: Directors of Environmental Health/ Chief Environmental Health Officers of London, Metropolitan, District and Unitary Authorities and Chief Executives of County Councils.

For the attention of: Environmental Services /Trading Standards /Fire Authorities /Other

This circular gives advice to local authority enforcement officers

---

SUPERMARKET SITES - THE DANGERS ASSOCIATED WITH THE COLLECTION AND DELIVERY OF PAPER RECYCLING BINS

INTRODUCTION

1 This circular has been produced by the Local Authority unit in conjunction with the Polymers and Fibres Sector, the British Recovered Paper Association and the Independent Waste Paper Processors Association (the main trade association's representing the companies collecting paper for recycling). Following a number of recent accidents, some fatal, concerns have been expressed about the safety of drivers and others when exchanging compacted paper 'recycling' bins from supermarket outlets.

BACKGROUND

2 Recovered paper and waste management companies are contracted to collect paper and cardboard from supermarket and elsewhere for recycling. This can involve:

• Loading waste packaging material onto vehicles for return to distribution centres for compacting and baling, or
• The exchange of bins attached to fixed Hydraulic Compactor units located on retail sites

This circular mainly concentrates on the hazards associated with the exchange of bins attached to compactor units. However similar problems exist during all "recycling" activities, notably those found in supermarket car parks.

3 Changing a compactor unit is complicated and takes some time. Throughout the exchange process, drivers, supermarket staff and customers can be at risk. Accidents, some fatal, have occurred. The main risks are:

• Crushing injuries caused by being trapped between the vehicle and the bin, compactor unit or other fixed part of the building. Large vehicles have blind spots and rear vision can often be very restricted;
• Entrapment in moving machinery on the compactor or vehicle. Compactors and other machinery needs to be isolated before staff work on or near them;
• Contamination from the waste material, particularly "stick injuries" from discarded hypodermics etc.

Other risks include damage to other vehicles and to the fabric of the building. Food and other organic material can also be found amongst the paper and card placed in the bin for recycling and this can attract vermin and lead to additional problems during the sorting operations at the waste company's site.

4 It is essential that the recovered paper contractor and the supermarket management communicate regularly and agree safe systems of work for this operation. All personnel, drivers and staff must be properly trained and supervised and whenever the operation is underway members of the public must be excluded from the area.

ENFORCEMENT APPROACH

5 Officers should expect the find the following precautions:

• A risk assessment identifying the risks associated with the activity completed by whoever controls the skip collection area i.e. retail/supermarket management or the site owner in conjunction with the skip provider.
• A communication protocol, setting out whom the driver must report to on arrival at the site. This should be the retailer's representative responsible for compactor units and exchanges and should include procedures to follow in an emergency or after and accident.
• A housekeeping policy covering the area surrounding the compactor bin and backed up by regular checks to ensure clear access for vehicles and staff. Food and other contrary material should be regularly removed from the area.
• A safe system of work covering the bin exchange procedure, including means to segregate and control pedestrian movement, and clear roles and responsibilities for all staff concerned.
• Physical safeguards should include; guide rails to assist the positioning of bins in relation to compactor units - this will help eliminate damage to plant and equipment and remove the need for a banksman to direct the reversing operation; lock-off mechanisms that isolate the compactor during the exchange process; appropriate signs or notices; High -visibility clothing for those involved; vehicle speed restrictions.
• Maintenance procedures should be developed to cover the compactor unit, including isolation systems - particularly to prevent tampering and repair damage. Maintenance records should be available.
• Training should be provided for all staff involved and regularly reviewed and updated as required. Training records should be available.

6 The site operator should ensure that all policies, procedures and safeguards are properly implemented and supervised by a responsible person. Spot checks should be made to ensure the systems are operating as designed.

7 Further advice may be obtained from the BRPA and HSE Paper and Printing Sector Group, via Enforcement Liaison Officers.

[back to top]