A Continuous Challenge

A Continuous Challenge

Waste operations and new regulations will make compiling a good safety record a tough task in 2011.

The start of a new year gives safety managers and others a fresh start in the constant effort to reduce fatalities, accidents and injuries involving solid waste employees and vehicles. Many new corporate and municipal safety programs are implemented in January, with the idea being that employees will improve their safety performance in the year ahead.

The area of focus varies, but the overarching objective is to prevent fatal and/or costly accidents. Regardless of whether you are a national company with operations in most states or a small hauler with a few trucks, the goal is the same: collect and dispose of waste and recyclables safely.

The solid waste industry’s safety performance has improved dramatically in recent years. According to the Department of Labor’s Bureau of Labor Statistics (BLS), the overall injury and illness rate for solid waste employers has declined by about 37 percent since 2003. In 2009, the rate was 5.2 per 100 full-time employees. The number of employees killed in workplace accidents has decreased substantially as well, with BLS reporting 21 waste collection employee fatalities in 2009 compared to 34 in 2008.

However, substantial challenges remain. First, even with the lower fatality rate, according to the Department of Labor, waste collection employees still work in one of the 10 most hazardous occupations in the United States, and they have an injury rate that is well above the overall national average. Second, a disproportionate number of these fatalities are occurring at smaller hauling firms and municipal sanitation departments. For example, six collection worker fatalities during the last two months of 2010 involved employees at such entities.

Third, the number of fatal third-party accidents — those in which other motorists and pedestrians are killed — has not declined. The frequency of accidents in which a motorist crosses into the path of an oncoming garbage truck or drives into the back of a stopped or slowing truck suggests an increase in distracted driving. Also, there have been several high-profile accidents involving pedestrians wearing headphones over the past year.

Finally, both the federal Department of Transportation (DOT) and the Occupational Safety and Health Administration (OSHA) have finalized new programs, have proposed new rules or intend to propose new regulations that would affect the industry’s operations.

Common Challenges

Solid waste safety directors and others identify a variety of safety challenges and goals for 2011. However, “struck by” accidents is consistently identified as a significant problem. According to data collected by the National Solid Wastes Management Association (NSWMA), there have been at least 12 fatal accidents over the past two years in which a collection worker was killed after being struck by another car. NSWMA continues to work with haulers and others to expand its Slow Down to Get Around program, which includes free truck stickers and other materials. In addition, NSWMA is working with the National Institutes for Occupational Safety and Health (NIOSH) to develop a written document for haulers and local governments to distribute to customers and the general public about the program.

Larry Stone, director of safety for Cincinnati-based Rumpke, urges haulers and local sanitation departments to participate in the Slow Down to Get Around program. “With struck-by accidents increasing every year, it is essential for everyone to push this message,” he says. Stone started the program in 2004 after several Rumpke collection employees were struck by motorists.

Creating a culture of safety in acquired companies also can be an issue for waste firms, safety supervisors say. “Maintaining the integrity of the [our] loss prevention program as the company grows” is an ongoing challenge, says Marti Dickman, vice president of risk management at Jacksonville, Fla.-based Advanced Disposal Services. According to Dickman, safety and compliance are not high priorities at many of the firms Advanced Disposal acquires, and getting employees at these companies to embrace Advanced’s emphasis on safety can be difficult.

Don Williamson, president of Wilmar, Minn.-based West Central Sanitation and chairman of NSWMA, notes that creating a positive safety culture is a never-ending process. Part of that process, he says, is encouraging supervisors to perform more frequent and higher quality route observations of drivers and helpers. Many companies have made route observations a core focus of their safety programs. Williamson also emphasizes the importance of identifying high-risk behaviors and recognizing that different incentives and disciplinary approaches may be needed for different workers.


Solid waste haulers face new truck safety programs in 2011. The Federal Motor Carrier Safety Administration (FMCSA) launched its Compliance, Safety, Accountability (CSA) program nationwide in December 2010. According to Chaz Miller, NSWMA’s director of state programs, “CSA creates a new safety management system that will be used to analyze violations from out-of-service inspections and crash data.” This system could make haulers vulnerable to increased enforcement, including warning letters from FMCSA. Subsequent failure to improve performance could result in targeted roadside inspections or other investigations.

The good news is that size and weight violations are not part of the new system. The bad news is that all crashes, even when a car runs into the back of a stopped garbage truck, are part of the new system. Several safety managers identified CSA as a top-level concern for 2011.

The federal government also has two regulatory proposals regarding hours-of-service rules out for comment. One proposal would require two nights of rest during the 34-hour restart period, which allows commercial vehicle drivers to restart the clock on their weekly service hours limit by taking at least 34 straight hours off. The other would require a rest period after seven hours of on-duty driving. The agency also invited comment on whether the maximum number of driving hours in a work day should be 11 or 10. A reduction to 10 hours could impact some long-haul operations.

The other proposal is the latest attempt to eliminate driver distractions and would ban hand-held cell phone use by commercial truck drivers. Two-way radios and fleet management equipment are not covered by the proposal. The proposal would not cover Bluetooth and other hands-free devices.


Many solid waste companies are concerned about increased enforcement activity by OSHA and higher fines for violations. Over the past three years, the average fine issued to a solid waste company for an OSHA violation has nearly doubled, to more than $1,500. Recent changes to OSHA’s penalty matrix are expected to result in even higher fines this year. However, with the House of Representatives now in Republican hands, last year’s proposal to expand OSHA’s regulatory authority and authorize even higher fines will not move forward.

OSHA is very active on the regulatory front, and has identified its Injury and Illness Prevention Program (I2P2) as its top regulatory priority. OSHA is expected to propose a I2P2 standard later this year that would require employers to have such programs. It is unclear at this stage whether there will be lesser I2P2 requirements for small companies. OSHA continues to move forward on combustible dust and hopes to propose a rule in late 2011. OSHA previously identified transfer stations and recycling facilities as locations vulnerable to explosions or conflagrations due to combustible dust. OSHA’s proposed revisions to the Hazard Communication and Walking-Working Surfaces standards are expected to be finalized later this year.

Susan Eppes, president of Houston-based EST Solutions Inc. and a safety consultant with decades of waste industry experience, identifies regulatory compliance as one of the solid waste industry’s most difficult challenges. She says that OSHA regulations were not designed for solid waste workplaces or employees, which makes understanding how to comply with the rules particularly challenging.

Looking Ahead

Operational safety is a high priority at many solid waste companies, and this is reflected in the reduced fatalities and injuries over the past few years. However, many challenges remain, and responding to distracted drivers and pedestrians and changing regulatory requirements are top priorities. Smaller haulers and local governments have a disproportionate share of fatal accidents, and these employers usually do not have a full-time safety manager. Getting these employers and their employees to reduce accidents and injuries in 2011 would enable the industry to shore up its safety record.

David Biderman is general counsel for the National Solid Waste Management Association. He oversees the organization’s safety programs.

Sidebar: Safety Tools

The National Solid Wastes Management Association (NSWMA) has a number of services to help haulers improve safety at their operations. Below is an overview of these initiatives:

  • "Be Safe, Be Proud" videos. Using grants from the Occupational Safety and Health Administration (OSHA), NSWMA produced the "Be Safe, Be Proud" video series. The four-part series addresses safety on collection routes, at landfills and at transfer stations, and also includes an installment that instructs safety supervisors and risk managers on how to train employees.

    Each video is approximately 20 minutes long. The videos are available in English or Spanish and in VHS or DVD formats. To order one of the videos, visit www.environmentalistseveryday.org.

  • "Slow Down to Get Around" campaign. The association's "Slow Down to Get Around" public-service program encourages motorists to drive carefully around waste trucks. For more information about the campaign and to order promotional truck decals, visit www.environmentalistseveryday.org.

  • Safety Monday. This weekly newsletter is available to all NSWMA, Environmental Industry Associations and Waste Equipment Technology Association (WASTEC) members. To receive Safety Monday, contact [email protected]

  • ANSI standards. These voluntary standards cover waste equipment and operations. NSWMA and WASTEC members can participate in the development of the standards. For information on participation, contact [email protected]

WasteExpo Safety Sessions

The 2011 WasteExpo conference program includes a Safety track. The track has two sessions. "Visual Communication Strategies for Improved Workplace Safety" will take place on Monday, May 9, from 1:45 p.m. to 3 p.m. "Government Views on Safety in the Waste Industry: Recent Data and Improvements" will be held on Monday, May 9, from 3:15 to 4:30 p.m.

"The Aging Workforce: Occupational Safety, Health, and Wellness for the Waste Industry," part of the Workplace Health track, will take place from 10:30 a.m. to 11:45 a.m. on Monday, May 9.

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