Recycling Safety Manual

What Should a Recycling Safety Manual Include?

The contents of a Recycling Safety Manual should reflect the recycling operations actually performed.

Depending on the facility, the manual may address:

• Recycling safety responsibilities.
• Hazard assessments.
• Job Safety Analysis (JSA/JHA).
• Safety inspections.
• Traffic and vehicle safety.
• Mobile equipment.
• Forklifts.
• Loading and unloading.
• Tipping floors.
• Conveyors.
• Sorting lines.
• Balers.
• Compactors.
• Shredders.
• Machine guarding.
• Lockout/Tagout.
• Unexpected machine startup.
• Material handling.
• Sharp objects.
• Needlestick hazards.
• Lithium-ion batteries.
• Lead and other metals.
• Hazard Communication.
• Chemical exposure.
• Fire prevention.
• Personal Protective Equipment.
• Respiratory Protection.
• Noise.
• Heat and cold stress.
• Ergonomics.
• Confined spaces when applicable.
• Emergency response.

Programs should be selected according to the material stream, processes, machinery, mobile equipment, and actual employee exposures.

Recycling Safety Program

An effective Recycling Safety Program establishes responsibilities and procedures for identifying workplace hazards, preventing employee injuries and illnesses, maintaining safe equipment, controlling hazardous energy, and safely handling recyclable materials.

Management should provide employees with appropriate equipment, engineering controls, PPE, training, supervision, maintenance resources, and safe work procedures.

Managers, supervisors, and designated safety personnel should:

• Identify and evaluate workplace hazards.
• Maintain applicable written safety programs.
• Conduct periodic safety inspections.
• Maintain machinery and equipment.
• Establish traffic-control procedures.
• Provide appropriate PPE.
• Evaluate employee chemical and physical exposures.
• Investigate workplace incidents.
• Correct unsafe conditions.
• Provide required employee training.
• Maintain applicable records.

Employees should follow established procedures, use required PPE, inspect equipment, remain alert to mobile-equipment hazards, and promptly report unsafe conditions, injuries, exposures, equipment defects, fires, spills, and other workplace hazards.

Recycling Hazard Assessments

Hazard assessments should consider:

• Materials received.
• Processing equipment.
• Employee tasks.
• Vehicle movement.
• Chemicals.
• Noise.
• Dust.
• Fire hazards.
• Sharp objects.
• Biological hazards.
• Ergonomic demands.

Potential hazards may include:

• Moving machinery.
• Unexpected equipment startup.
• Vehicle traffic.
• Falling material.
• Crushing.
• Cuts and punctures.
• Needlesticks.
• Batteries.
• Chemical exposure.
• Heavy metals.
• Dust.
• Noise.
• Slips and falls.
• Manual material handling.

Assessments should be reviewed when operations, equipment, material streams, or work practices change significantly.

Job Safety Analysis (JSA/JHA)

A JSA/JHA can be used to evaluate higher-risk recycling activities.

Potential JSAs may address:

• Clearing conveyor jams.
• Baler operation.
• Compactor operation.
• Shredder maintenance.
• Sorting-line work.
• Battery handling.
• Scrap-metal processing.
• Loading and unloading.
• Forklift operation.
• Tipping-floor activities.
• Cleaning machinery.
• Lockout/Tagout.
• Confined-space entry.

The analysis should identify job steps, hazards, required controls, PPE, and employee responsibilities.

Recycling Safety Inspections

Periodic inspections should evaluate workplace conditions and equipment.

Inspection areas may include:

• Receiving areas.
• Tipping floors.
• Sorting lines.
• Conveyors.
• Balers.
• Compactors.
• Shredders.
• Loading areas.
• Forklift routes.
• Battery storage.
• Chemical storage.
• Scrap piles.
• Walkways.
• Maintenance areas.
• Emergency equipment.

Identified deficiencies should be corrected in a timely manner.

Traffic Safety

Recycling facilities may have constant interaction between:

• Collection trucks.
• Tractor-trailers.
• Roll-off trucks.
• Front-end loaders.
• Forklifts.
• Skid steers.
• Yard equipment.
• Employees on foot.

Traffic-control procedures should establish safe routes, operating expectations, pedestrian controls, and communication methods.

Facility Traffic Plan

A facility traffic plan may address:

• Vehicle entrances and exits.
• One-way travel.
• Speed limits.
• Pedestrian walkways.
• Restricted areas.
• Backing.
• Loading areas.
• Tipping areas.
• Parking.
• Signage.

Traffic patterns should be designed to reduce unnecessary interaction between pedestrians and moving equipment.

Backing Safety

Backing vehicles and mobile equipment can create severe struck-by hazards.

Where practical, facilities should minimize unnecessary backing.

Drivers and operators should evaluate the backing path before movement.

Spotters, cameras, alarms, or other controls may be used where appropriate.

Spotters

Where spotters are used, operators and spotters should agree on signals before movement begins.

Spotters should remain visible and avoid positioning themselves between moving equipment and fixed objects.

Operators should stop if communication with the spotter is lost.

Pedestrian Safety

Employees on foot should remain alert to moving trucks and equipment.

Pedestrian procedures may include:

• Designated walkways.
• Restricted equipment zones.
• High-visibility apparel.
• Eye contact with operators.
• Crossing controls.
• Prohibitions against walking behind backing equipment.

Employees should avoid equipment blind spots.

Tipping Floor Safety

Material recovery and recycling facilities may receive large volumes of material on tipping floors.

Potential hazards include:

• Collection trucks.
• Front-end loaders.
• Falling material.
• Unstable piles.
• Sharp objects.
• Dust.
• Fires.
• Hidden hazardous materials.

Access should be limited to employees whose duties require entry.

Tipping Operations

Drivers should follow facility instructions before unloading.

Employees should remain clear of:

• Raised bodies.
• Moving tailgates.
• Dumping material.
• Mobile equipment.
• Unstable piles.

Employees should not walk behind or beneath raised truck bodies unless the equipment is appropriately secured and the task requires access.

Mobile Equipment

Recycling facilities may use:

• Front-end loaders.
• Skid steers.
• Excavators.
• Grapples.
• Material handlers.
• Yard tractors.
• Other mobile equipment.

Only trained and authorized employees should operate equipment requiring specialized qualification.

Equipment Inspection

Mobile equipment should be inspected before use according to company procedures.

Employees should report:

• Brake defects.
• Steering problems.
• Alarm failures.
• Tire damage.
• Hydraulic leaks.
• Lighting defects.
• Visibility problems.

Unsafe equipment should be removed from service when necessary.

Forklift Safety

Forklifts and other Powered Industrial Trucks may be used for:

• Moving bales.
• Loading trailers.
• Handling pallets.
• Moving containers.
• Transporting materials.

Only trained and authorized employees should operate Powered Industrial Trucks.

Forklift Pedestrian Safety

Forklift operators should:

• Maintain controlled speed.
• Sound the horn where appropriate.
• Watch for pedestrians.
• Slow at intersections.
• Maintain clear visibility.
• Avoid carrying loads that obstruct safe travel unless operating in reverse is appropriate.

Pedestrians should stay outside designated equipment paths whenever possible.

Loading and Unloading

Loading and unloading can expose employees to:

• Vehicles.
• Forklifts.
• Falling material.
• Dock edges.
• Shifting loads.
• Material-handling hazards.

Procedures should reflect the type of vehicle, material, and equipment being used.

Trailer Safety

Before powered equipment enters a trailer, employees should verify that:

• The trailer is secured.
• The trailer floor is capable of supporting the load.
• Dock equipment is properly positioned.
• Adequate lighting and clearance exist.

Damaged trailers should not be entered until their condition has been evaluated.

Conveyors

Conveyors are widely used to move recyclable materials through sorting and processing operations.

Potential hazards include:

• Nip points.
• Rotating parts.
• Belts.
• Chains.
• Pulleys.
• Falling material.
• Unexpected startup.

Required guards should remain in place during operation.

Conveyor Guarding

Employees should be protected from accessible moving parts and pinch points.

Guards should not be removed or bypassed except under controlled maintenance procedures.

Damaged or missing guards should be reported promptly.

Clearing Conveyor Jams

Employees should not reach into or climb onto operating conveyors to clear jams.

When servicing or maintenance exposes employees to hazardous energy, appropriate Lockout/Tagout procedures should be followed before work begins.

Conveyor Crossings

Employees should use designated conveyor crossings where provided.

Employees should not climb over, under, or through moving conveyors unless specifically designed access is provided.

Sorting Lines

Manual sorting operations can expose employees to:

• Sharp objects.
• Needles.
• Broken glass.
• Chemicals.
• Batteries.
• Repetitive motion.
• Awkward postures.
• Dust.
• Moving conveyors.

Employees should be trained to recognize materials that require special handling.

Hand Sorting

Employees should avoid blindly reaching into piles or containers where sharp or hazardous objects may be hidden.

Appropriate gloves and other PPE should be selected based on the hazards present.

Sorting-Line Ergonomics

Repetitive sorting can contribute to musculoskeletal stress.

Potential controls may include:

• Appropriate working height.
• Reach-distance reduction.
• Job rotation.
• Rest periods.
• Workstation design.
• Mechanical sorting.
• Adjustable platforms.

Balers

Balers compress recyclable materials into dense bundles.

Potential hazards include:

• Crushing.
• Pinch points.
• Moving components.
• Unexpected startup.
• Material ejection.
• Wire hazards.

Employees should receive equipment-specific training.

Baler Guarding

Required guards, gates, and interlocks should remain functional.

Employees should not bypass safety devices.

Defective safety devices should be reported and corrected.

Baler Jam Clearing

Employees should not enter or reach into hazardous areas of a baler while energy is present.

Lockout/Tagout should be used when servicing, maintenance, or jam clearing exposes employees to hazardous energy.

Baler Wire Safety

Bale wire and strapping can create:

• Cuts.
• Punctures.
• Stored-energy hazards.
• Eye injuries.

Employees should use appropriate tools and PPE when installing or removing wire or strapping.

Compactors

Compactors may expose employees to severe crushing hazards.

Employees should not enter compactor chambers or other hazardous areas unless required procedures for hazardous-energy control have been completed.

Safety interlocks and guarding should not be bypassed.

Trash and Recycling Compactor Safety

Employees should be trained in:

• Controls.
• Emergency stops.
• Loading procedures.
• Prohibited entry.
• Lockout/Tagout.
• Jam-clearing procedures.

Unauthorized employees should not operate compactors.

Shredders and Size-Reduction Equipment

Shredders, crushers, grinders, and other size-reduction equipment can create hazards involving:

• Rotating machinery.
• Flying material.
• Noise.
• Dust.
• Unexpected startup.
• Fire.

Machine-specific safety procedures should be established.

Shredder Feeding

Employees should remain outside hazardous feed zones.

Material-feeding equipment should be used where appropriate to reduce direct employee exposure.

Employees should not use hands or feet to force material into operating machinery.

Machine Guarding

Recycling facilities may use machinery with:

• Belts.
• Pulleys.
• Chains.
• Sprockets.
• Gears.
• Shafts.
• Cutting equipment.
• Crushing equipment.

Required guards should protect employees from moving machine hazards.

Lockout/Tagout

Unexpected startup of recycling machinery can cause severe or fatal injuries.

Applicable hazardous-energy control procedures should be followed during servicing and maintenance.

Energy sources may include:

• Electrical.
• Mechanical.
• Hydraulic.
• Pneumatic.
• Gravity.
• Stored pressure.

Energy-Control Procedures

Before servicing begins, employees should:

• Identify energy sources.
• Shut down equipment.
• Isolate energy.
• Apply required locks or tags.
• Release or restrain stored energy.
• Verify isolation.

Equipment should not be returned to service until appropriate release procedures are completed.

Clearing Jams and Blockages

Jam clearing should be treated as servicing or maintenance when employees may be exposed to unexpected startup or hazardous energy.

Employees should not assume equipment is safe merely because the controls have been turned off.

Energy should be physically isolated when required.

Scrap Metal Recycling

Scrap-metal recycling may involve:

• Ferrous metals.
• Aluminum.
• Copper.
• Lead.
• Stainless steel.
• Automotive scrap.
• Other metals.

Hazards can include sharp edges, heavy materials, machinery, metal fumes, toxic metals, and fire.

Sharp Metal Hazards

Employees handling scrap metal may be exposed to:

• Cuts.
• Lacerations.
• Punctures.
• Eye injuries.

Appropriate gloves, clothing, eye protection, handling tools, and mechanical equipment should be used.

Heavy Scrap

Heavy or irregular scrap should be moved with appropriate mechanical equipment.

Employees should avoid standing beneath suspended or unstable material.

Scrap stacks should be maintained to reduce collapse hazards.

Lead Exposure — When Applicable

Recycling certain metals, batteries, electronics, or other materials may expose employees to lead.

Where lead exposure may occur, the employer should evaluate employee exposure and comply with applicable requirements.

Controls may include:

• Process enclosure.
• Local exhaust ventilation.
• Housekeeping.
• Hygiene facilities.
• PPE.
• Respiratory protection.
• Exposure monitoring.
• Medical surveillance.

Cadmium — When Applicable

Certain batteries, electronics, coatings, and scrap metals may contain cadmium.

Where occupational exposure may occur, applicable controls should be established.

Employees should not assume that scrap materials are free of toxic metals merely because they appear clean.

Metal Cutting

Torch cutting, grinding, and other metal-processing activities can generate:

• Fumes.
• Sparks.
• Flying particles.
• Noise.
• Fire hazards.

Appropriate ventilation, PPE, fire prevention, and hot-work controls should be used.

Electronics Recycling

Electronic waste may contain hazardous materials and components.

Potential hazards may include:

• Lead.
• Cadmium.
• Batteries.
• Mercury.
• Sharp components.
• Dust.
• Broken glass.

Employees should receive training appropriate to the electronics being handled.

Battery Hazards

Recycling facilities may encounter:

• Lead-acid batteries.
• Lithium-ion batteries.
• Nickel-cadmium batteries.
• Other battery types.

Battery hazards may include:

• Electrical energy.
• Corrosive electrolyte.
• Toxic metals.
• Fire.
• Explosion.
• Thermal runaway.

Facilities should establish procedures for identifying, segregating, handling, and storing batteries.

Lithium-Ion Batteries

Lithium-ion batteries can present significant fire hazards if they are:

• Damaged.
• Crushed.
• Punctured.
• Short-circuited.
• Exposed to heat.
• Improperly stored.

Employees should be trained to recognize lithium-ion batteries and follow facility procedures for handling them.

Battery Segregation

Where practical, batteries should be identified and separated from material streams before they enter equipment that could crush, shred, or puncture them.

Damaged or suspect batteries should be isolated according to facility procedures.

Battery Storage

Battery-storage areas should consider:

• Separation.
• Fire hazards.
• Electrical contact.
• Physical damage.
• Damaged batteries.
• Emergency access.

Storage practices should reflect the battery types present.

Battery Fire Response

Employees should understand the facility’s procedures for responding to battery fires or thermal events.

Emergency procedures should address:

• Alarm.
• Evacuation.
• Fire-department notification.
• Area isolation.
• Specialized response procedures.

Employees should not perform emergency response beyond their training and protection.

Needlestick and Sharps Hazards

Recycling workers may encounter improperly discarded:

• Hypodermic needles.
• Syringes.
• Lancets.
• Broken glass.
• Razor blades.
• Other sharp objects.

Employees should avoid reaching blindly into material.

Needlestick Prevention

Potential controls may include:

• Mechanical sorting.
• Appropriate gloves.
• Tools.
• Employee training.
• Safe retrieval procedures.
• Appropriate sharps containers.

Employees should never intentionally compress material by hand where hidden sharps may be present.

Needlestick Response

Employees who experience a needlestick or other potentially contaminated sharps injury should:

• Stop work.
• Wash the affected area.
• Report the incident immediately.
• Obtain prompt medical evaluation.

Procedures should provide access to medical evaluation during all operating shifts.

Used Oil and Chemical Recycling

Facilities handling used oil, solvents, chemicals, or contaminated containers should evaluate:

• Chemical hazards.
• Fire hazards.
• Incompatible materials.
• Vapor exposure.
• Spill hazards.

Employees should follow established chemical-handling procedures.

Hazard Communication

Recycling facilities should maintain an applicable Hazard Communication Program for hazardous chemicals used or encountered in the workplace.

The program should address:

• Chemical inventories.
• Safety Data Sheets.
• Labels.
• Employee training.
• Non-routine tasks.

Employees should know how to obtain hazard information.

Unknown Materials

Recycling facilities may receive containers or materials with incomplete or inaccurate information.

Employees should not open, drain, mix, crush, or process unknown chemicals without appropriate evaluation and authorization.

Suspect materials should be isolated and reported.

Incompatible Materials

Chemicals and materials that can react dangerously should be segregated.

Employees should not combine unknown liquids or chemicals.

Spill Prevention and Response

Facilities should establish procedures for foreseeable spills involving:

• Fuel.
• Oil.
• Chemicals.
• Battery electrolyte.
• Hydraulic fluid.
• Other hazardous materials.

Employees should know how to report and isolate spills.

Employees should not perform emergency response beyond their training and available protection.

Fire Prevention

Recycling facilities can accumulate large quantities of combustible materials.

Potential fire hazards may involve:

• Paper.
• Cardboard.
• Plastics.
• Wood.
• Batteries.
• Flammable liquids.
• Dust.
• Hot work.
• Equipment overheating.

Fire-prevention procedures should reflect the facility’s materials and processes.

Material Pile Fires

Employees should monitor material storage for conditions that may increase fire risk.

Access for emergency responders should be maintained where appropriate.

Smoking and ignition sources should be controlled according to facility procedures.

Hot Work

Welding, cutting, grinding, and similar work can ignite recyclable material.

Before hot work begins, employees should evaluate:

• Combustible material.
• Flammable liquids.
• Batteries.
• Dust.
• Hidden combustibles.
• Nearby processing operations.

Hot-work authorization and fire-watch procedures should be used where appropriate.

Combustible Dust — When Applicable

Certain recycling processes may generate combustible particulate material.

Where combustible dust hazards may exist, the employer should evaluate the materials and processes and establish appropriate controls.

Potential controls may include:

• Dust collection.
• Housekeeping.
• Ignition-source control.
• Equipment design.
• Ventilation.

Dust Exposure

Processing recyclable material can generate airborne dust.

Dust may contain:

• Paper fibers.
• Soil.
• Metals.
• Silica-containing material.
• Biological contaminants.
• Other substances.

Employee exposure should be evaluated according to the materials processed.

Respiratory Protection

When respirators are required, the facility should maintain an appropriate Respiratory Protection Program.

Applicable elements may include:

• Hazard evaluation.
• Respirator selection.
• Medical evaluation.
• Fit testing.
• Training.
• Inspection.
• Maintenance.
• Program evaluation.

Personal Protective Equipment

PPE should be selected according to employee hazards.

Depending on operations, PPE may include:

• Safety glasses.
• Goggles.
• Face shields.
• Gloves.
• Cut-resistant gloves.
• Protective footwear.
• Hard hats.
• High-visibility apparel.
• Hearing protection.
• Respiratory protection.
• Protective clothing.

Employees should receive training regarding required PPE use and limitations.

Hand Protection

Hand injuries can result from:

• Sharp metal.
• Broken glass.
• Wire.
• Needles.
• Machinery.
• Batteries.
• Chemicals.

Gloves should be selected according to the actual hazard.

No single glove provides protection against every recycling hazard.

Eye and Face Protection

Eye or face protection should be used where employees may be exposed to:

• Flying particles.
• Metal fragments.
• Chemical splash.
• Battery electrolyte.
• Dust.
• Grinding.

Face shields should supplement primary eye protection when both are required.

Protective Footwear

Recycling employees may be exposed to:

• Heavy materials.
• Sharp objects.
• Vehicle traffic.
• Slippery surfaces.

Footwear should be appropriate for the hazards present.

High-Visibility Apparel

Employees exposed to vehicle or mobile-equipment traffic should use high-visibility apparel when required by the hazard assessment or site procedures.

High visibility does not replace the need for traffic separation and safe equipment operation.

Noise Exposure

Recycling equipment may generate substantial noise.

Potential sources include:

• Balers.
• Shredders.
• Crushers.
• Conveyors.
• Mobile equipment.
• Metal processing.
• Compactors.

Employee exposure should be evaluated where hazardous noise may be present.

Hearing Conservation

Where employee exposure reaches applicable thresholds, required Hearing Conservation measures should be implemented.

These may include:

• Noise monitoring.
• Audiometric testing.
• Hearing protection.
• Training.
• Recordkeeping.

Manual Material Handling

Employees may lift or move:

• Boxes.
• Containers.
• Bags.
• Scrap.
• Electronics.
• Batteries.
• Other recyclable materials.

Mechanical equipment should be used where appropriate.

Employees should avoid unnecessary manual handling of excessively heavy or unstable material.

Ergonomics

Recycling work may involve:

• Repetitive sorting.
• Lifting.
• Bending.
• Reaching.
• Twisting.
• Pushing.
• Pulling.

Workstations and work methods should be evaluated to reduce unnecessary physical stress.

Slips, Trips and Falls

Potential hazards include:

• Loose material.
• Debris.
• Wet surfaces.
• Oil.
• Ice.
• Uneven pavement.
• Hoses.
• Cords.
• Packaging materials.

Walking-working surfaces should be maintained in safe condition.

Housekeeping

Good housekeeping is especially important where loose recyclable materials can accumulate rapidly.

Work areas should be maintained to prevent:

• Blocked exits.
• Trip hazards.
• Fire loading.
• Restricted emergency access.
• Excessive dust accumulation.

Employees should clean according to established procedures.

Material Storage

Recyclable material should be stored to reduce hazards from:

• Collapse.
• Rolling.
• Falling.
• Fire.
• Blocked access.
• Interaction with mobile equipment.

Material piles should be managed according to their stability and characteristics.

Bale Storage

Bales should be stacked and stored to reduce the risk of collapse.

Employees should remain clear of unstable bale stacks.

Damaged or poorly formed bales should be handled cautiously.

Compressed Gas Cylinders — When Applicable

Recycling facilities may receive discarded cylinders or use cylinders during maintenance and processing.

Cylinders should be:

• Identified.
• Appropriately stored.
• Protected from damage.
• Segregated as necessary.

Unknown cylinders should not be cut, crushed, punctured, or processed without appropriate evaluation.

Pressurized Containers

Aerosol cans, propane cylinders, fire extinguishers, and other pressurized containers may create hazards if crushed or shredded.

Facilities should establish procedures for identifying and segregating these materials where necessary.

Confined Spaces — When Applicable

Recycling facilities may contain confined spaces such as:

• Pits.
• Tanks.
• Hoppers.
• Vessels.
• Certain equipment interiors.

Spaces should be evaluated according to their actual configuration and hazards.

Where permit-required confined spaces exist, applicable entry procedures should be followed.

Equipment Pits

Employees should not enter equipment pits or similar spaces unless hazards have been evaluated and appropriate entry procedures established.

Potential hazards may include:

• Machinery.
• Atmospheric hazards.
• Falls.
• Restricted access.
• Stored energy.

Organic Material Recycling — When Applicable

Facilities processing food waste, yard waste, wood waste, or compost may have additional hazards.

Potential hazards include:

• Biological exposure.
• Dust.
• Heavy equipment.
• Heat.
• Confined spaces.
• Hydrogen sulfide.
• Carbon monoxide.
• Oxygen deficiency.

Procedures should reflect the materials and processes used.

Composting Operations

Employees working around composting processes should be trained regarding:

• Mobile equipment.
• Material piles.
• Dust.
• Biological materials.
• Heat.
• Atmospheric hazards.

Employees should not enter enclosed or confined process areas without appropriate hazard evaluation.

Heat Stress

Recycling employees may work outdoors, in unconditioned buildings, or near heat-producing equipment.

Heat-illness prevention procedures should consider:

• Drinking water.
• Rest.
• Cooling.
• Acclimatization.
• Workload.
• Environmental conditions.
• PPE.

Employees should understand signs and symptoms of heat illness.

Cold Stress

Outdoor collection, yard, and processing work may expose employees to:

• Cold temperatures.
• Wind.
• Snow.
• Ice.
• Wet conditions.

Employees should use appropriate clothing and safe work practices.

Severe Weather

Outdoor recycling operations may be affected by:

• Lightning.
• High winds.
• Severe storms.
• Flooding.
• Snow.
• Extreme heat.
• Extreme cold.

Procedures should identify when work should be suspended and where employees should seek shelter.

Collection Operations — When Applicable

Companies that collect recyclable material may face additional hazards involving:

• Traffic.
• Backing vehicles.
• Repeated entry and exit from trucks.
• Manual lifting.
• Sharp objects.
• Slips and falls.
• Weather.

Collection procedures should reflect the routes, vehicles, and material handled.

Collection Vehicle Safety

Drivers should inspect collection vehicles before use and report safety defects.

Employees should remain clear of hazardous areas around moving collection equipment.

Riding positions should be limited to those designed and authorized for employee use.

Roadside Collection

Employees working near traffic should remain alert to approaching vehicles.

Potential controls may include:

• High-visibility apparel.
• Vehicle positioning.
• Flashing warning lights.
• Route planning.
• Traffic awareness.

Employees should avoid unnecessary exposure to active traffic lanes.

Collection Lifting Hazards

Repeated lifting and handling of containers and recyclable material may cause musculoskeletal injuries.

Mechanical lifting equipment should be used where available and appropriate.

Employees should report damaged containers and unusually heavy loads.

Maintenance Safety

Maintenance personnel may be exposed to:

• Hazardous energy.
• Machinery.
• Electrical systems.
• Hydraulic pressure.
• Elevated work.
• Welding.
• Chemicals.

Maintenance procedures should address the equipment and hazards involved.

Hydraulic Systems

Hydraulic systems should be depressurized and hazardous energy controlled before servicing.

Employees should not use hands to search for suspected high-pressure hydraulic leaks.

Damaged hoses and fittings should be replaced.

Electrical Safety

Electrical equipment should be maintained in safe condition.

Employees should report:

• Damaged wiring.
• Exposed conductors.
• Broken electrical enclosures.
• Defective receptacles.
• Damaged portable equipment.

Only appropriately qualified employees should perform specialized electrical work.

Welding, Cutting and Grinding

Maintenance and scrap-processing activities may involve welding, cutting, or grinding.

Procedures should address:

• Fire prevention.
• Ventilation.
• PPE.
• Compressed gases.
• Fumes.
• Sparks.
• Nearby combustible material.

Working at Heights

Employees may perform work on:

• Equipment.
• Platforms.
• Trucks.
• Machinery.
• Structures.

Appropriate fall protection should be provided where required.

Employees should use designated access points rather than climbing on machinery or material piles.

Ladders

Ladders should be inspected before use and selected according to the task.

Defective ladders should be removed from service.

Employees should maintain secure contact while climbing and avoid carrying loads that interfere with safe climbing.

Emergency Action Plan

The facility should maintain emergency procedures appropriate to its hazards.

Potential emergencies may include:

• Fire.
• Battery thermal event.
• Chemical release.
• Severe weather.
• Machinery incident.
• Medical emergency.
• Workplace violence.

Employees should understand alarms, evacuation routes, assembly areas, and reporting procedures.

Fire Emergency

Employees should know how to:

• Activate the alarm.
• Notify emergency responders.
• Evacuate.
• Report the location of the fire.
• Account for personnel.

Only employees designated and trained to use portable fire extinguishers should do so under the facility’s procedures.

Workplace Violence and Security

Recycling facilities may experience security hazards involving:

• Members of the public.
• Customers.
• Scrap sellers.
• Unauthorized entry.
• Theft.
• Disputes.

Procedures should address:

• Access control.
• Reporting suspicious activity.
• Cash-handling hazards when applicable.
• Emergency assistance.
• Employee security.

Employees should avoid escalating confrontations.

Working Alone

Employees working alone in isolated processing, yard, maintenance, or collection areas may face increased risk.

Procedures should provide practical methods for:

• Communication.
• Emergency assistance.
• Periodic contact.
• Reporting hazardous conditions.

First Aid

Appropriate first-aid resources should be available.

Recycling-related injuries may include:

• Cuts.
• Punctures.
• Needlesticks.
• Burns.
• Eye injuries.
• Strains.
• Crush injuries.
• Chemical exposure.

Employees should promptly report injuries and obtain appropriate medical evaluation.

Incident Reporting

Employees should report:

• Injuries.
• Near misses.
• Vehicle incidents.
• Equipment damage.
• Fires.
• Chemical exposures.
• Battery incidents.
• Needlesticks.
• Spills.
• Unsafe conditions.

Prompt reporting helps identify hazards before similar incidents occur.

Incident Investigation

Significant incidents should be investigated to determine:

• Immediate causes.
• Contributing factors.
• Root causes.
• Corrective actions.

Investigations should consider equipment, maintenance, procedures, training, supervision, facility layout, material streams, and work organization.

Root Cause Analysis

Root Cause Analysis may identify underlying issues involving:

• Equipment design.
• Preventive maintenance.
• Lockout/Tagout.
• Machine guarding.
• Employee training.
• Traffic management.
• Staffing.
• Work procedures.
• Material screening.
• Hazard communication.
• Corrective-action systems.

Corrective actions should address the identified causes.

Recycling Employee Safety Training

Employee training should reflect assigned duties and workplace hazards.

Depending on responsibilities, training may address:

• Recycling facility orientation.
• Traffic safety.
• Mobile equipment.
• Forklifts.
• Machine guarding.
• Lockout/Tagout.
• Balers.
• Conveyors.
• Sharp objects.
• Needlesticks.
• Batteries.
• Chemicals.
• PPE.
• Fire prevention.
• Emergency procedures.

Task-specific training should be provided before employees independently operate hazardous machinery or perform specialized work.

New Employee Orientation

New employees should receive safety orientation before independently performing assigned duties.

Orientation may address:

• Traffic.
• Equipment hazards.
• Restricted areas.
• Lockout/Tagout.
• PPE.
• Material hazards.
• Incident reporting.
• Emergency procedures.

Employees should be instructed not to operate equipment until properly trained and authorized.

Safety Meetings

Periodic safety meetings may address:

• Traffic and backovers.
• Lockout/Tagout.
• Machine guarding.
• Battery fires.
• Needlestick prevention.
• Slips and falls.
• Material handling.
• PPE.
• Recent incidents and near misses.

Recordkeeping

Recycling employers should maintain occupational safety and health records required for their operations.

Records may include:

• Employee training.
• Injury and illness records.
• Safety inspections.
• Equipment inspections.
• Lockout/Tagout records.
• Exposure monitoring.
• Respiratory Protection records.
• Hearing Conservation records.
• Incident investigations.
• Medical and exposure records.

Records should be retained according to applicable requirements.

Additional Safety Programs

Depending on recycling operations and employee exposures, additional programs may be necessary for:

• Job Safety Analysis (JSA/JHA).
• Mobile Equipment.
• Heavy Equipment.
• Forklift / Powered Industrial Truck Safety.
• Traffic Control.
• Loading & Unloading.
• Machine Guarding.
• Lockout/Tagout.
• Conveyor Safety.
• Baler & Compactor Safety.
• Hand & Power Tools.
• Electrical Safety.
• Welding, Cutting & Hot Work.
• Hazard Communication.
• Chemical Safety.
• Lead Exposure.
• Cadmium Exposure.
• Respiratory Protection.
• Personal Protective Equipment.
• Eye & Face Protection.
• Hand Protection.
• Hearing Conservation.
• Manual Lifting & Material Handling.
• Ergonomics.
• Slips, Trips & Falls.
• Walking-Working Surfaces.
• Housekeeping.
• Compressed Gas Cylinders.
• Confined Space.
• Fall Protection.
• Ladder & Stairway Safety.
• Heat Stress Prevention.
• Cold Stress.
• Severe Weather.
• Working Alone.
• Workplace Violence Prevention.
• Workplace Security.
• Emergency Action Plan.
• Fire Prevention.
• First Aid.
• Spill Prevention & Response.
• Hazardous Waste Management.
• Incident Reporting & Investigation.
• Root Cause Analysis.

Programs should be included when the facility’s equipment, processes, material streams, chemicals, vehicles, and employee exposures make them applicable.

Building a Recycling Safety Manual

A useful Recycling Safety Manual should reflect the actual materials and processes at the facility.

A material recovery facility processing mixed municipal recyclables may require extensive procedures for sorting lines, conveyors, mobile equipment, batteries, needles, traffic, balers, dust, and material handling.

A scrap-metal recycler may require greater emphasis on heavy equipment, metal cutting, toxic-metal exposure, compressed cylinders, hot work, machine guarding, and large scrap handling.

An electronics recycler may require additional controls for batteries, lead, cadmium, mercury, broken components, dust, and dismantling activities.

A cardboard or paper recycling operation may focus more heavily on conveyors, balers, forklifts, combustible materials, manual handling, and fire prevention.

A company performing collection as well as processing may need substantial additional procedures for truck operations, backing, traffic exposure, lifting, route safety, and severe weather.

The safety manual should therefore be based on the facility’s actual material stream and operations rather than automatically assigning every recycling-related program to every company.

Customized Recycling Safety Manuals

A Recycling Safety Manual can be developed around the facility’s recyclable materials, processing equipment, sorting operations, conveyors, balers, compactors, mobile equipment, batteries, chemicals, employees, collection operations, and other workplace hazards.

The finished manual may incorporate applicable programs for Lockout/Tagout, Machine Guarding, Conveyor Safety, Forklift Safety, Mobile Equipment, Traffic Safety, Battery Hazards, Hazard Communication, Lead Exposure, Respiratory Protection, Hearing Conservation, PPE, Fire Prevention, Emergency Action Planning, and other hazards associated with the operation.

This provides recycling centers, material recovery facilities, scrap processors, collection companies, and other recycling employers with a practical safety manual organized around the work their employees actually perform.