Sorting and processing waste

This page sets out the main hazards from sorting or processing waste and explains how operators can reduce the risks.

Materials recovery facilities (MRFs)

Materials recovery facilities (MRFs) can play an important role in reducing the amount of waste sent to landfill sites. The recyclable waste is typically separated into:

glass (not in all feedstock)
aluminium and steel cans
paper
cardboard
plastic bottles and packaging
other, non-recyclable residual material

Ergonomics

Conveyor belts are used in a range of industries to move materials. Using these systems in the workplace can reduce the risks of musculoskeletal disorders (MSDs) by avoiding the need for excessive repetitive bending, lifting and carrying.

In MRFs conveyor belt workstations (picking stations) should be properly designed to ensure operators do not excessively lean, stoop, twist, or over-reach, since these repetitive movements can themselves lead to musculoskeletal injury.

Factors to consider when assessing the risk of MSDs in a task at a conveyor include:

workplace layout
size and height of the conveyor
type, throughput and height of material
how material is handled

HSE has guidance on conveyor belt workstation design.

Noise

Most MRFs have processes which emit high noise levels exceeding the 80dB(A) and 85dB(A) levels at which employers are required to take action under the Control of Noise at Work Regulations.

You can find detailed guidance on noise in MRFs which explains:

equipment in an MRF likely to expose workers to excessive noise levels
suggested reasonably practicable controls

There is also general guidance on HSE's noise website.

Fires

Fires involving waste materials have the potential to cause significant harm. There is guidance from the Waste Industry Safety and Health Forum (WISH) on Reducing fire risk at waste management sites.

The guidance includes advice for operators on ensuring sorting systems help to reduce the likelihood and frequency of fires at solid waste management sites.

Occupational hygiene implications

The processes involved during recycling at MRFs can generate organic dust, which may lead to exposure to airborne micro-organisms and their toxic by-products. This may cause health problems in workers who are involved in handling waste.

Employees working in MRFs can potentially be exposed to general airborne dust above the level where it is considered a substance hazardous to health (10 mg/m³ as an 8-hour time-weighted average). There is also potential for exposure to agents which are known to have harmful effects on human health such as fungi, bacteria and endotoxins.

HSE has general guidance on dust in the workplace.

What you need to do

As a dutyholder, you should take the health issues associated with exposure to dust and airborne microorganisms into consideration, assess the risk and determine the control measures required. You should ensure you have:

suitable and sufficient
risk assessments under the Control of Substances Hazardous to Health Regulations
adequate welfare and hygiene facilities
a risk-based health surveillance programme
control of inhalation exposure to hazardous substances by the effective use of general ventilation, local exhaust ventilation (LEV) and the appropriate use of respiratory protective equipment (RPE)
training and supervision

An HSE research report is available in the National Archives on Occupational hygiene implications of processing waste at MRFs.

Other risks at MRFs

You should have controls in place to manage other risks at MRFs:

transport – including vehicle movements, poor site layout and control, reversing and visibility issues. There is a risk of collisions if moving plant/vehicles and pedestrians are not adequately segregated
machinery – including systems to control the risks associated with maintenance, cleaning and repair operations
slips and trips – including failure to control material spillages
work at height, such as during cleaning, maintenance and repair activities, and the sheeting and unsheeting of vehicles

There is also guidance on disposal of aerosols, which explains how they should be disposed of safely at MRFs.

Find out more

There is detailed WISH guidance on the design and safe operation of MRFs.

Waste electrical and electronic equipment

The Waste Electric and Electronic Equipment Regulations became law in 2014 and the scope of the Regulations was extended in January 2019 and again in 2025 to cover further categories of electric and electronic equipment (Schedules 3 and 4 of the Regulations have more information).

Treatment of waste electrical and electronic equipment (WEEE)

As a result of the complex mix of product types and materials, some of which are hazardous (including arsenic, cadmium, lead, mercury and certain flame retardants), WEEE recycling poses a number of health risks that need to be adequately managed.

For example, workers can be exposed to substances released during processing (such as mercury released from fluorescent tubes, lead and phosphorous pentachloride as a result of breaking cathode ray tubes). If effective measures are taken to control exposure to mercury and lead then normally the control of exposure to other hazardous substances should also be adequate.

For disassembly operations, treatment facilities should comply with the minimum requirements specified in the Defra guidance on best available treatment recovery and recycling techniques and treatment of waste electrical and electronic equipment. That guidance document is from the Department for Environment, Food and Rural Affairs (Defra) and is in the National Archives. It includes the standards for treatment, recycling and recovery of materials from WEEE.

For shredding operations, treatment facilities may not be required to remove these components and substances. This depends on the size and type of technology used, although some hazardous components and substances must be removed in advance to avoid risks to health and safety and damage to equipment.

The Waste Resources Action Programme (WRAP) have good practice guidance on:

Guidance on specific substances/components

The Defra guidance on available treatment recovery and recycling techniques (in the National Archives) includes reference to specific substances and/or components of waste electrical equipment.

These include fluids, mercury-containing components, asbestos, lead and refractory ceramic fibres.

Guidance on other WEEE hazards

You can find HSE guidance on other hazards linked to WEEE recycling:

machinery safety – some WEEE recycling plants use a wide variety of machinery/equipment as materials are treated including crushing, grinding, conveying, baling, compacting and palletising machines
MSDs from manual handling – some WEEE items, white goods (fridges/freezers) in particular, can be heavy, but even some TVs can weigh over 25kg. When stacking items of WEEE, white goods can also create MSD risks (for stability, stacks should be no more than 3 times the height of the minimum base dimension as a rule of thumb)
work-related upper limb disorders – can be caused by repetitive movements, for example when remove wiring looms
cuts and abrasion risks etc – caused by knives used to remove antibreak coatings on florescent lamps, or sharp edges on items as they are being dismantled, or if they are broken
electrical safety – particularly if any element of refurbishment is being carried out consider electrical testing issues
fire and explosion risks – for example from hydrocarbons and ammonia in fridges and freezers, or polystyrene which is flammable, batteries (once removed from WEEE products, these should be stored in appropriately labelled containers to prevent any potential fire risk)

Scrap and metal recycling

Recycling scrap and metal is a hazardous operation and can lead to serious injuries and ill health. While the risks are not unique to this industry, they need to be well managed in order to ensure the health and safety of your workers.

If your site allows access for members of the public or traders to drop material off, for example, you will need to consider how to keep them safe.

There is also the potential for scrap metal to be contaminated with hazardous or flammable substances, or to contain unexpected items such as batteries, aerosols or cylinders which need careful management.

The main risks in the scrap and metal recycling industry include:

Radioactive contamination

There is a potential for radioactive materials to be found in consignments of scrap metal and it is important that risks of ionising radiation are managed sensibly to protect workers and the public.

The Ionising Radiations Regulations 1999 (IRR99) Approved Code of Practice (ACOP) will apply in circumstances where radioactive contamination is found in scrap metal.

As an employer, if your general risk assessment indicates that radioactive contamination is likely, you need to:

ensure there are arrangements for checking and testing any monitoring system and action plans covering required procedures in the event of the discovery of radioactive contamination in scrap metal (including source characterisation, recovery, temporary storage arrangements and source disposal, availability of hand-held radiation monitoring equipment)
appoint radiation protection advisers (RPAs) to help implement these procedures
provide workers with sufficient information, instruction and training to ensure they are able to implement the above procedures
have a system in place that will enable the return/isolation of loads suspected of containing contamination in accordance with relevant regulatory requirements

Scrap metal dealer licence applications

Under the Scrap Metal Dealers Act and related Regulations, local authorities (councils) are responsible for determining the suitability of applicants and issuing of scrap metal dealers’ licences.

Trade associations

The main trade associations dealing with this industry include the British Metals Recycling Association, and the Motor Vehicle Dismantlers Association.

Find out more

HSE’s website on radiation

Safety in the storage and handling of steel and other metal stock

Safely disposing of an LPG cylinder

End-of-life vehicles

The End-of-Life Vehicles Regulations (ELV Directive) require all vehicles to be processed to ensure potential pollutants such as fuel, oils, brake fluids and other liquids are removed, collected and stored.

Operators must ensure depollution of vehicles is carried out in a way that both controls environmental risk (under the ELV Directive) and the risks to the health and safety of those working in the industry (under the Health and Safety at Work etc Act).

This means a number of challenges need to be risk assessed and controlled including:

petrol recovery from end-of-life vehicles
oil recovery from vehicle shock absorbers
detonation of airbags

Petrol recovery

Petrol is one of the pollutants that needs to be recovered, stored and dispensed by those who process end-of-life vehicles. The average vehicle processed contains 10 litres of fuel, creating a serious health and safety risk from fire and explosion, particularly with petrol driven vehicles.

It is essential that those processing vehicles have equipment and working practices that can properly control the potential risks of petrol draining. For example, the following working practices can help avoid skin contact:

maintaining the seal when draining until all petrol has been drained
maintenance of equipment to ensure effective seals
use of powered tool supports to avoid the need to work directly under fuel tanks when draining
wearing disposable gloves
changing any clothing that becomes impregnated with petrol, immediately
immediately washing any area that comes into contact with petrol
good personal hygiene

WISH have guidance on recovering petrol from end-of-life vehicles.

Common concerns about end-of-life vehicles

The vehicle depolluting industry, manufacturers, HSE and the Environment Agency (EA) have provided the following responses to common concerns around working on end-of-life vehicles.

Can I work under a vehicle while it is on the forks of a lift truck?

No, the vehicle must be secure to work on. Using a solid rig is the usual way of achieving this, ensuring that it is capable of supporting all foreseeable loads and is compatible with the lifting equipment used to deliver the vehicle to the rig.

Do I have to use a proprietary depolluting rig?

No, neither the EA nor health and safety legislation require the use of a proprietary system. The operator can use any appropriate system which is most suited to their operation, so long as it enables the operator to depollute the vehicle safely in both environmental and health and safety terms.

Is there an approved method for recovering petrol?

No, again the requirements are both to recover and do so safely, it is for the operator to identify the most appropriate way of achieving this.

Does airbag detonation damage operators hearing?

Yes, the very high noise levels generated when detonating airbags can present a real and immediate risk to hearing. This risk is increased the closer the operator is to the vehicle and particularly if the vehicle windows are missing.

A simple control measure is to run the detonator control to a sound insulated refuge/booth from which the operator can detonate the airbags. You will need to assess the operation to ensure that controls are adequate to protect both those involved in the operation and others in the area.

Does every airbag need to be detonated?

You must do everything possible to detonate or remove airbags. However, there may be exceptional circumstances in which safety would be compromised, examples could include contact with body fluids or sharps remaining in the vehicle. In cases where airbags are not detonated or removed, the waste transfer note should highlight the presence of explosive devices.

There is more detailed guidance on storing and handling airbags and seat belt pretensioners safely.

How do I depollute a vehicle contaminated with blood, body fluids, hypodermic needles etc?

These vehicles do present a biohazard. However, in most cases you should be able to simply avoid the risks:

Do not sit in any vehicle assessed as being suspect. Needles can be hidden in upholstery
Lean into the passenger compartment to pull the bonnet release – if this could expose you to risk of contact with biohazards then the bonnet can be prised open from outside the vehicle
Do not recover any needles
Where unacceptable risks of contact with biohazards remain, then the particular depollution operation should be omitted and this should be noted on the waste transfer note

What protective clothing do I need to wear?

Use footwear with toe protection to protect from falling objects. If it is likely that you may step on sharp objects then the footwear should have a protective sole-plate.

Eye protection is necessary as you will be removing parts above your head and it is likely that materials will be ejected.

Hearing protection may be needed if it is not reasonably practicable to achieve control by other means.

Suitable overalls and gloves should be worn to protect your skin. They should protect against the risks from:

oils, fluids and fuels absorbed into the body through the skin
highly flammable fuels. Anti-static footwear and fire-retardant/resistant overalls should be provided and worn if draining fuels

The fluids you are dealing with are likely to be toxic and/or flammable and can soak into some clothing materials. Personal protective equipment should be kept clean to prevent the contaminant fluids being held against your skin.

You can protect the environment and control the health and safety risks in the workplace at the same time. HSE will advise on health and safety matters and the Environment Agency can advise on the environmental aspects of the ELV Directive.

Main trade associations

The main trade associations for end-of-life vehicles are the British Metals Recycling Association (BMRA), Liquid Gas UK and the Vehicle Recyclers' Association (VRA).

Find out more

Safe use of petrol in garages

Using electric storage batteries safely

Safe working with LPG-fuelled motor vehicles

Used engine oil

Disposal of aerosols

For mixed waste processed at a materials recovery facility (MRF), as far as possible, only aerosols derived from the domestic waste stream should be handled. At the MRF, aerosols can be baled, flattened or shredded but this must only be done where appropriate precautions are in place.

The British Aerosol Manufacturers Association (BAMA) provides guidance on the collection and processing of ‘empty’ or ‘near empty’ cans by local authorities when processed through MRFs.

When disposing of full or partly full aerosol canisters in bulk, they need to be treated as hazardous waste and disposed of safely. It is also recommended that aerosols from the commercial waste stream be directed to specialist recycling facilities.

Composting – recycling biodegradable waste

The main risks in waste and recycling in composting are from:

transport, including vehicle movements, falls during sheeting operations, poor site layout and control, reversing and visibility issues. There is a risk of collisions if moving plant/vehicles and pedestrians are not adequately segregated
machinery, including system failures to control the risks associated with shredders, conveyors and bagging operations
slips and trips, including failure to control material spillages
musculoskeletal injury from manual handling
dermatitis caused by poor handling practices and inadequate welfare facilities
bioaerosols – a natural process in which micro-organisms break down waste material

Health risks from collecting and handling green waste

When green waste is left, microbes grow quickly in the warm, moist environment. Collecting and handling green waste creates bioaerosols (microbes suspended with dust in the air) and these are breathed in when working.

Repeated inhalation of compost bioaerosols in large concentrations has been shown to trigger the immune system, and could lead to:

a short-term, flu-like reaction (inhalation fever)
longer-term ill health such as developing asthma, bronchitis or extrinsic allergic alveolitis (similar to farmer's lung disease)

Once a person has become sensitised, subsequent exposure to even a smaller quantity can trigger the allergy.

HSE funded research into processing household waste has shown that workers in close proximity to waste composting processes could be exposed to bioaerosols between 10 and 1,000 times greater than in ambient air (explained further in our risk zone summary).

What you should do as a dutyholder

Compost bioaerosols are a substance hazardous to health as defined by the Control of Substances Hazardous to Health Regulations (COSHH). Although they have no occupational exposure limits, they are potential respiratory sensitisers. Regulation 7(1) of COSHH requires that exposure to substances hazardous to health is prevented or, where this is not reasonably practicable, adequately controlled.

As a dutyholder, you should take the health issues associated with bioaerosols into consideration, assess the risk and determine the control measures required.

Where your assessment has established that bioaerosol exposure may pose a potentially significant risk to the health of your workers:

identify areas of your waste handling facility where bioaerosols are likely to be greatest
identify processes or activities that are most likely to create bioaerosols (for example, turning actively composting material, screening composted material) – don't forget that equipment maintenance may create aerosols as well
consider local conditions that might increase bioaerosol exposure, for example weather conditions that might increase exposure and when certain activities could be avoided if that is practical
identify the workers that will be involved in these activities

Controlling exposure

Potential exposure can be controlled by changing the work process to minimise the generation of bioaerosols, or possibly by managing temperature and moisture levels in the compost to reduce dustiness.

Introducing control measures may also be applicable, such as:

exhaust ventilation to prevent exposure
using adequate filters on the air intakes of vehicles such as tractors used to move compost
using personal protective equipment such as adequate and suitably fitted respiratory protective devices when working in areas close to where bioaerosols are generated

The greatest risk of exposure, justifying the control measures described above, are when workers are in close proximity to compost being handled (within 30 metres). Being further away when working outside means exposure levels will be greatly reduced and require less stringent control, but they may still be above background levels.

Where composting takes place in enclosed facilities, operators should ensure suitable ventilation systems (forced or otherwise) are provided that ensure suitable dilution of bioaerosols and biogases such as carbon dioxide (as well as provision of sufficient oxygen). Monitoring of contaminants such as bioaerosols and carbon dioxide will demonstrate if control systems are effective.

There is more information on Environment Agency permit conditions for waste (on GOV.UK).

Respiratory protective equipment

It is likely that such a risk assessment may require the routine use of respiratory protective equipment (RPE) so workers can avoid exposure to bioaerosols when:

shredding, turning, screening or moving composting material, or
leachate is either sprayed or transferred from one place to another

This precaution is likely to be required by anyone within 30 metres of such a procedure, and for 5 minutes afterwards. HSE's guidance on respiratory protective equipment at work, particularly the content on biological agents, will help you choose the right RPE. Suitably fitted RPE of P2 or P3 filtration is suitable for use against biological agents in terms of non-penetration of spores/cells through the filter material.

There is Defra funded research into bioaerosol emissions from waste treatment.

Effective use of vehicle cab air filtration systems on waste sites

If workers are in enclosed vehicle cabs during waste handling, HSE funded studies have shown this physical barrier should provide some protection from exposure to bioaerosols. However, a properly maintained cab air filtration system will be more effective.

There is HSE advice on maintenance and testing of vehicle cab filtration systems in COSHH Essentials G7: guidance for composting. The guidance is based on ideal good practice and you should consider the following in the context of the operations you are carrying out:

When choosing a vehicle for use on dusty waste management sites, opt for one with a cab air filtration system already fitted if possible, or consider retrofitting one
Air intakes for cab filtration systems should be away from dust sources so that the filters clog less quickly
Plan a maintenance schedule of filter removal, cleaning or replacement, the frequency of which is dictated by the dustiness of the conditions in which the vehicle is used. The schedule should also include visual examination for wear and tear damage to door and window seals. A checklist could be used to provide instructions
Remind staff of the importance of keeping doors and windows closed in the dustiest areas and regular cleaning of cabs to prevent dust build-up inside, and to report any signs of dust leakage

Risks to others and people living nearby

Bioaerosols are naturally present in the air, mainly soil-borne micro-organisms in airborne dust, so everyone is constantly exposed to them and mostly they pose negligible health risk.

Concentrations change depending on the weather, season and whether indoors or outdoors. Typical bioaerosol concentrations are greater in rural areas, because of nearby vegetation.

Because of the dilution effect in the open air, bioaerosol concentrations fall away rapidly with distance from compost being handled. HSE research on bioaerosol emissions from waste composting and the potential for workers' exposure shows that, by 100 to 200m away, the bioaerosol concentration has mostly returned to background levels.

Based on scientific evidence that bioaerosol levels from waste composting are reduced to background levels within 250 metres from source the EA in England and Wales currently operates a '250 metre limit' rule around composting sites to minimise the potential of bioaerosol exposure to nearby residents.

Even if people can smell a compost site they might not be exposed to bioaerosols. There is no reported evidence of significant increase in ill health in residents near composting sites in these situations. The lungs of a healthy person are capable of being exposed to relatively large concentrations of micro-organisms without ill effect.

Complaints about smell and other public nuisance issues should be made to:

your local authority environmental health department
Environment Agency in England
Scottish Environmental Protection Agency (SEPA) in Scotland

Risk zone approach

A 'risk zone' approach can be adopted to apply exposure controls proportionate to the likely level of bioaerosol exposure. The risk zone approach is summarised in the HSE research report on bioaerosol emissions from waste composting and the potential for workers’ exposure (in the National Archives).

Other health and safety issues associated with composting sites

There may be other biological hazards on composting sites, depending on the feedstock.

If sewage sludge is being used, there may be infectious bacteria and viruses present
If vermin on the site are not controlled, there is the risk of workers contracting leptospirosis (Weil's disease), a bacterial infection caused by exposure to contaminated rat urine. Good hygiene, including provision of adequate handwashing facilities, can reduce these risks You may find guidance for the construction industry on Weil's disease from rats useful
In enclosed buildings, other hazards include the build-up of biogas (carbon dioxide, hydrogen sulphide etc) from the biodegradation process and exhaust gases from the mobile plant and delivery and collection vehicles. If these are allowed to build up sufficiently they may cause an asphyxiation hazard. Enclosed buildings can also produce increased dust and volatile organic compounds exposure, potential thermal discomfort from excessive heat and humidity, poor visibility due to high moisture content in the atmosphere and odour

It is the responsibility of the site operator to identify potential hazards, make a suitable risk assessment and provide adequate protection to their workforce to control such risks.