Prompting from the federal government is causing the solid waste industry to take a closer look at safety and working conditions. While OSHA puts its proposed ergonomics standard into final form and decides who it will ultimately cover, some solid waste managers share their thoughts on safety in the industry.

By Janice Kaspersen

Are We Different Enough for Exemption?
The First Step: Taking It Seriously, All the Time
Automated Collection Equipment
Where It Stands Now
What OSHA Wants, in Brief

Long regarded as a dangerous field, solid waste collection is getting closer scrutiny these days to see how some of its more ubiquitous problems can be improved. Although hazards include everything from traffic accidents to being struck by moving equipment, the Occupational Safety and Health Administration (OSHA) proposed standard has cast a spotlight on musculoskeletal disorders (MSDs) and ergonomic solutions to prevent them (see sidebar). Repetitive stress injuries, such as carpal tunnel syndrome, receive lots of attention, but lower-back pain is still the most common - and most costly - category of MSD in the United States. It’s also one of the most common among refuse collectors.

How will OSHA’s ruling affect the industry? And perhaps more importantly, what can we do to make solid waste operations safer - with or without a new standard? There seem to be two key elements: one that managers can take steps to improve and another, in some cases, that they can’t. The first is awareness: turning safety into part of employees’ routines rather than something they dismiss out of hand or think about only at quarterly meetings. The second is automated collection equipment.

Are We Different Enough for Exemption?

Three industries - agriculture, construction, and maritime - are exempt from the OSHA standard. In March, SWANA requested that OSHA postpone applying the standard to the solid waste industry and allow time (nine months to a year) to gather data and develop a separate ergonomics standard tailored to solid waste operations. SWANA also suggested that at least some of the standard development be done by its own members. (The complete comments are available on SWANA’s Web site at www.swana.org/WhyPolicy(10).htm).

Why not let OSHA simply design the safety standards for the industry, including the ergonomics standard? In support of its request, SWANA has pointed out several differences between solid waste and general industry that make the general standard difficult or inappropriate to apply here. For example, waste collection and landfill disposal occur under a variety of conditions - outdoors, at extreme temperatures, and in confined or high places. Collection workers have no fixed work sites or work stations, and the employer has no control over the sites they visit or the nature or volume of waste collected. And the industry employs many temporary or seasonal workers to handle increased holiday volume and clean up after natural disasters.

Susan Young, head of the Minneapolis Division of Solid Waste and Recycling and head of SWANA’s Collection and Transfer Station Division, expresses the difference in more basic terms. "The beginning of the garbage industry happened to protect public health and safety. We have to deal with the stuff people don’t want. And they don’t want it for a reason. Our ability to pick and choose what we lift and what we don’t is limited."

To illustrate why realistic standards must come from within the industry rather than outside it, she points to a suggestion OSHA representatives made to her during an inspection three years ago. "They said that we should do nothing other than perfect lifts. Well, it’s very tough to do a perfect lift on a mattress that’s full of water. But I can’t leave that kind of garbage in the alley, because it constitutes a public safety problem. There are ways that I can minimize risks, and we teach our employees to do that, but I cannot eliminate risks." OSHA also suggested daily job rotation for employees. "My union employees will not agree to that," says Young. "It’s not an option."

David Cochran, the man who wrote the OSHA standard on ergonomics, has seen many industries over the last several months request similar exemptions. A professor of industrial and management systems engineering at the University of Nebraska-Lincoln, Cochran spent two and a half years at OSHA’s Office of Safety Standard Programs in Washington, DC, working on the standard. He closely followed the hearings around the country in which members of various industries responded to it. "OSHA will consider every point that’s put forth in those hearings and in the comments before and after the hearings," he states. But a particular industry’s claim for exemption or delay might not be easy to come by. "Construction, maritime, and agriculture were left out of OSHA’s decision. That was not based on a petition by any of those industries," notes Cochran, adding that all three industries are already covered by separate OSHA regulations.

Cochran spoke to SWANA’s dual symposia in Tampa last February, and he feels that the comments he heard there are in line with those from many other industries. He says solid waste professionals especially expressed concern about the one-incident trigger, the grandfather clause, and work-restriction protection. (The standard would require an employer to provide temporary work restrictions to an employee with a covered MSD for six months, until the employee can return to the job, or until the employer implements measures to eliminate MSD hazards or reduce them so they pose no risk to the recovering employee.)

"Quite honestly I think a lot of [industries] are already doing what this standard requires, and in a lot of cases it’s not going to cost them much, if anything," says Cochran. "If they have a program that’s working, we would hope that fits under our definition of what should be grandfathered. A lot of the criticism we’ve gotten has been on the costs, but in my experience those costs pay back dividends that are greater than the costs were."

So what is the industry doing right already?

The First Step: Taking It Seriously, All the Time

High turnover rates and a large number of temporary or seasonal workers make management’s job harder. Although everyone needs safety training and constant reminders of how to prevent injury, employees in some areas cycle in and out so fast that there are fewer opportunities to drive the message home.

The Mesa, AZ, Solid Waste Division, with about 120 employees, is doing a number of standard things right. Recognizing that those standards aren’t always enough, however, Solid Waste Management Director Kari Kent is also trying some innovative ideas to get extra mileage out of the program.

The division has had a safety committee in place for about six years and is in the process of hiring a person to coordinate safety throughout the division. Besides implementing federal and state safety requirements, the coordinator will ensure that safety-program elements are carried across the division so that workers in, say, residential collection are aware of and can benefit from a solution that someone in recycling has already thought of. The coordinator will also track more closely injuries and workers’ comp claims and compare them from year to year.

Kent’s concern, however, is how to keep safety uppermost in employees’ minds. Having the coordinator ride along with operators when there are concerns about safety and including safety in employees’ performance plans provide incentive to learn and follow procedures. "Carrots" are also used: Accident-free employees receive rewards such as movie passes, gasoline cards, jackets bearing the city logo, and dinners for two.

Another incentive is letting employees help determine what gets scrutinized and changed, rather than making them feel they’re always on the receiving end of rules and guidelines. Forms are readily available for employees to point out dangers that may have been overlooked. "Anybody can fill out one of these forms, and it brings attention to a potential safety hazard out in the field," Kent points out. "If an operator does have a concern, we provide a quick response to it." If filling out a form seems too formal or time-consuming, an employee can simply report the problem verbally to a supervisor. A prompt answer from the safety committee - a signal that the problem has been taken seriously and investigated - is often more important than finding a perfect solution, which in some cases doesn’t exist. "Sometimes we have impossible situations out there that, because of how things were designed a long, long time ago, we’re sort of stuck with. Sometimes the only thing that can be done is sticking a sign up on the bin for an operator to look for low wires, or to make sure that they dump the bin so they have clearance from overhead obstructions," says Kent.

Public relations and education are also part of Mesa’s program. "People are weaving in and out of traffic to try to get around our vehicles. Everyone’s in such a hurry that they really try to dodge our vehicles as much as possible, and some of these are backing onto major streets. Our operators face a lot when they’re out there," Kent observes. Public-awareness campaigns range from presentations at neighborhood block parties and at preschools - allowing kids to sit in the trucks and teaching them the importance of staying out of the way when bins are being lifted - to information on the city’s Web site and signs on the vehicles themselves.

Minneapolis is also looking at ways to keep safety in the forefront under extreme conditions. "I have a very aggressive safety program in place," states Young. "However, there’s nothing that I can do that will protect my workers from Mother Nature. This is Minnesota. In the wintertime, we can have an 80-below wind chill. In the summertime, we can have a 110 heat index."

She can, however, determine exactly when and how problems occur, from traffic accidents to MSDs. Minneapolis recently completed a joint union-management project to analyze work-related accidents and injuries over a three-year period, with regression analyses to determine common factors. "Basically it came down to paying attention," says Young. "Most of our injuries and almost all of our accidents occurred in the 10:00-11:30 time frame. You get to a point where you’ve got low blood sugar, you’re almost to the end of your route, and your attention starts to slip. Stuff happens on straight, clear days. Days when it’s slippery and icy, everybody’s paying attention and being really careful about what they do. On a nice day, your mind sort of wanders. So basically what we’re working on is paying attention."

Automated Collection Equipment

The safety issue revolves, on a couple of levels, around automation. First there’s the question of how the OSHA standard will apply to automated or semiautomated collection operations. Then there’s the fact that automated collection has radically altered working conditions in the industry - including in some ways no one expected. Automated collection equipment is the biggest single factor in reducing MSDs, and it’s also causing some new and different types of MSDs.

The City of Plano, TX, has had fully automated trash collection since 1994 and sometime this year will have collection of recyclables fully automated as well. "It has had a huge impact on our workers’ comp costs," reports Nancy Nevil, Plano’s solid waste manager. "When we were manual, we had a lot of back injuries in particular. Two years in a row, we were close to the half-million-dollar price tag for workers’ comp. Now we probably are under $50,000."

Kent sees a similar trend in Mesa. "It’s a different type of industry. The numbers have dramatically changed since we went to automated collection in 1988, so the numbers are relatively low based on the national standard that deals with a lot of manual collection programs that are still out there."

"What we were finding with manual lifting - and I think we’re going to begin to see this with manual lifting of recycling as well because of the heaviness of the newspaper - is that it’s going to be difficult for people to retire doing that kind of work," Nevil notes.

She also sees automation as necessary not only for workers’ safety but as a way to recruit and retain workers in a tight labor market. "I think it’s a trend. I think you’ll find that you have to, just to attract the work force that you need. We’ve seen a difference in the type of employee we had when we used to have manual and now that we’ve gone to a fully automated system. They’re more educated."

But in some places, complete automation isn’t possible. "I have begged every one of the major packer companies to develop a fully automated lifter that I can use in my alleys. None of them has been able to show me something that will work," says Young. "This is an older city. My alleys are 10 feet wide. In areas that don’t have alleys, we have on-street parking. So while it would be nice to have a fully automated system, physically that’s just not possible in my city." Minneapolis does use semiautomated rearloaders and has seen improvements in safety since adopting them, "but anything that’s outside the cart is manual," adds Young, including recyclables, yardwaste, and "sofas, chairs, and end tables." Tommy lifts on the backs of some trucks aid in lifting appliances and other problem materials.

Many in the industry fear that OSHA doesn’t fully understand the differences in manual versus automated collection. Although OSHA’s proposed standard gives examples of "manual handling" and "manufacturing" types of jobs, employers in many industries are still unclear about which jobs fit those categories. This confusion is especially understandable in the solid waste industry. In an attempt to clarify the standard from the working-draft version published in February 1999, OSHA added a table listing "Examples of jobs that are typically manual handling jobs" and included "garbage collecting" as one of 10 examples. The concern among solid waste agencies that have moved to automated or semiautomated collection is that all collection activity will be included under the standard, requiring costly implementation of an ergonomics program even in cases where no manual collection is taking place.

"There’s definitely a concern about lumping it all together," says Kent. "Semiautomated and automated need to be removed from this general legislation. The definition that they used really pertained to manual collection, a variety of stops that are performed with a repetitive motion. The systems are just so different."

Cochran thinks they’re worrying needlessly. It is not the case, he says, that all parts of the industry, regardless of the type of collection system used, are automatically covered by the standard. "If they have automated garbage collection where people really aren’t lifting things, they don’t come under this standard until they have a covered musculoskeletal disorder. When the employer looks at the job, if there’s no manual handling in that job and there’s no manufacturing, they’re not in the early part of the standard. They’re not in for the basic program prior to a musculoskeletal disorder that meets the criteria we put in the standard."

Ironically, some municipalities that have reduced injuries resulting from manual labor by moving to automated or semiautomated collection are now seeing an increase in operator MSDs from using the keypads inside the collection vehicle cabs - and these MSDs, too, can be the single trigger for implementing the standard.

"Occasionally we’ll see an industrial for carpal tunnel syndrome from using the keypads. That’s becoming more popular," observes Kent. She says Mesa now includes ergonomically correct cabs in its vehicle specifications, including movable seats and armrests and wrist pads for the control panel.

Although Nevil has yet to see MSDs of this sort, she’s keeping track of vehicle manufacturers’ ongoing design changes. She notes that at least one manufacturer is experimenting with push-button rather than joystick in-cab controls.

Where It Stands Now

"There are always things we can do better," says Young. "But in the industry we need to find those things to do better. SWANA has made a proposal that it would like to design the standard. We can take into account the diversity in the industry. It’s to our benefit to do a good job of reducing accidents and injuries. On the public side, we have to be competitive. The word privatization is one that we all take seriously, and with workers’ comp, quite frankly I’m not as competitive with my private-sector competitors as I’d like to be. So we have a vested interest in getting safe."

Nevil also agrees with SWANA’s request for a delay. "I think that SWANA’s doing the right thing in trying to see what the problem is first and how prevalent it is before we automatically implement restrictions or more regulations along those lines. Let’s see what we’re dealing with and how big it is." She acknowledges, though, that mandatory programs can achieve more than goodwill can. "I think that we as managers owe it to our employees to make sure that we can provide an environment where they can work and not get injured. I know we’ve done a lot to make sure we have a better work environment for our employees, but I know that’s not true with all cities. And sometimes a change in the requirements or the standards forces cities to look at things differently."

Although he can’t predict the final form the standard will take, Cochran believes many industries’ objections will be settled as more information becomes available. "As OSHA works toward a final rule, it’s also going to be simultaneously working on the compliance document, which I think will give more information as to how OSHA’s going to go about enforcing this. And I think that will help."

"If your sole focus is to eliminate risk, you’re going to come up with different strategies than if you are trying to manage risk. It’s a difference in philosophy," says Young. "OSHA’s goal is to eliminate risk. But in my world, I cannot eliminate risk. That is a worthy goal, but I have to recognize that I will make progress toward that goal; I will not achieve it."

Janice Kaspersen is the features editor for MSW Management.

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