Expanding environmental requirements and limited full-time resources have meant growth in hiring external contractors and consultants at landfills. While external hires can be a big benefit in providing extra assistance or expertise, it also is possible for them to contribute to the safety of landfill operations.
In the parking lots of many landfill operations, there is a growing fleet of cars and pickup trucks bearing contractor names and logos. Some are from environmental consulting firms monitoring groundwater, surface water, landfill gas or leachate. Others may be from construction companies involved in landfill projects including cell construction, landfill gas collection systems and final cover placement. Contractors from engineering firms could be onsite to provide surveying or construction quality assurance services. Suppliers may be using the site to train staff for a new product, such as GPS equipment used for waste grade control.
In short, many landfill operations are putting greater reliance on outside expertise to complete non-core functions, such as environmental monitoring and reporting. And there’s a good chance that the number of third-party workers on landfill sites will increase, according to David Biderman, general counsel and safety director for the National Solid Wastes Management Association. Biderman says that as waste comes to be viewed more as a resource, and as landfill gas and biomass become more valuable fuel sources, there will be a greater need for outside specialized expertise.
External hires can provide a helping hand. But health and safety (H&S) considerations need to be made. Landfills are large, complex operations with many moving parts. Some of those “parts” may be large, yellow vehicles — and anyone who has not been trained to stay out of their blind spots can be at risk.
Yet contractors can also strengthen a landfill’s H&S performance by being knowledgeable about potential risks, and by assessing and mitigating hazards. What follows are some points to ensure that external contractors and consultants are safety savvy, rather than sources of danger to themselves or others.
Many landfill operators already take steps to ensure that contractors who come onto their sites are aware of hazards and safety procedures. This might include a requirement that all contractor personnel watch a safety orientation video before signing a document indicating that they understood the training materials. Some sites issue contractors a card indicating that they have completed the necessary safety training.
This site-specific orientation is valuable because landfills contain unique physical and chemical hazards that may be foreign to workers unfamiliar with such complex sites. There may also be site-specific risks that contractors should be apprised of, such as which areas of the landfill will be active at a particular time. Ongoing special activities, such as cell lining or gas well drilling, should also be communicated.
Know Who Is Onsite and Where
Given the physical size of many landfills, it is possible for a contractor to be on the property without landfill management’s knowledge. That means these contractors may not receive a location-specific warning in the event of a fire, tornado, thunderstorm or other emergency. In addition, landfill employees, including those operating heavy equipment, may be focused on the task at hand and thus unaware of a contractor who decides to take a “short cut,” putting himself in harm’s way.
It is therefore a good practice to require that all contractors check in with the landfill office upon arrival, indicate the nature of their work and where it will be done, and check out when the work is complete. This gives the landfill staff an accurate list of the extended staff onsite and where they can be located at the facility.
Keep in Compliance with Current Regulations
Landfill operators, government regulators, such as Occupational Safety and Health Administration (OSHA) inspectors, and contractors themselves each have their own expectations regarding H&S requirements. For instance, while OSHA may require the wearing of personal protective equipment (PPE), a landfill may have a specific color or design of PPE they expect workers to wear. Meanwhile, a contractor unaccustomed to working on a landfill may fail to don PPE of any sort.
Landfill operators need to take the initiative to make sure site workers are aware of factors like the color of safety vests or a requirement to carry a calibrated four-gas meter when working around landfill gas systems. Meanwhile, contractors should take the initiative to ask what H&S requirements exist before they enter the site.
Select Safe-Minded Contractors
Landfill operators consider several factors in selecting which contractors to retain, including the contractor’s experience, specialized skills, availability and cost. One factor that demands closer attention is the contractor’s H&S record. Factors to consider in contractor selection may include past safety performance, types of training, the safety culture of the firm and corrective measures taken for employees who violate H&S rules (either the contractor’s or the client’s).
Unsurprisingly, the lowest priced contractor may not have the most qualified staff or the best safety record. And in the long run, it could cost the landfill operator more if someone gets hurt on the job.
One option is to build training into the contractor selection requirements. For instance, a landfill may require a contractor’s employees to have taken OSHA’s 40-hour course on hazardous waste operations and emergency response (HAZWOPER), with annual refresher training. While this training is not generally required to work on municipal solid waste landfills, it gives contractors the flexibility to work on a wider range of project sites. This training also is valuable when unpleasant surprises occur. For example, a HAZWOPER trained contractor overseeing the drilling of a LFG well in an older part of a landfill would be prepared for the surfacing of hazardous materials such as asbestos or chemical wastes.
Landfill contractors may benefit from additional training, such as in defensive driving and communications. This knowledge is particularly valuable when contractors are trained alongside personnel from the landfill, so that the landfill operations staff is able to give its perspective on how contractors can contribute to safe operations.
In evaluating contractors, ask for a site-specific H&S plan. One sign of a safety-conscious contractor is whether it has developed a specific H&S plan for each landfill site it services. This plan may include a survey of site-specific hazards, including modes of transportation, terrain, tasks to be completed, mechanical and electrical processes, potential biological and chemical exposures, and necessary PPE and monitoring equipment.
The site-specific H&S plan also shouldinclude directions to the nearest medical facility, as well as an onsite muster point or evacuation plan, in the event of an emergency. It is common for landfill owners to require the same H&S requirements of any third-party sub-trades the contractor brings onto the site, such as welders and drillers.
Benefitting From Good H&S Practices
A contractor with an exemplary H&S record, policies and practices can be a strong asset to the overall health and safety of landfill operations. In many cases, a safety-conscious contractor can point out to the landfill operations staff a dangerous situation or “near hit” that the landfill staff may not have noticed, such as a missing cover on a landfill gas well.
Moreover, having additional safety-conscious staff working on a site can lead to more effective daily tailgate briefings, a higher level of hazard recognition, and more accurate monitoring and documentation. Contractors can assist owners and operators in identifying and rectifying items that may be contributing factors to unsafe conditions and operations.
The benefit is that all employees — landfill staff and contractors alike — get to go home safely at the end of the day.
Paul Sgriccia is principal and U.S. Waste Market Sector Leader with Golder Associates. He can be contacted at [email protected] John Wise ([email protected]) is a senior scientist and office safety coordinator with Golder. Both are based in the company’s Wixom, Mich., office. Angela Cook ([email protected]) is the Great Lakes regional safety manager for Golder, located in Lansing, Mich.