Editor's Note: This is the first in a series of articles about ANSI standards and solid waste equipment.
Late last year, WAL-MART Stores Inc. paid fines of $31,680 for violating child labor laws at stores in Pennsylvania and Wisconsin. The U.S. Department of Labor levied the maximum allowable penalty for the infraction: allowing minors — those under the age of 18 — to operate compactors.
The age restriction appears in the child labor provisions of the Fair Labor Standards Act, and the Wal-Mart Store managers should have known about it. Not knowing about it or not enforcing it could have added to the handful of compactor accidents — some fatal — that occur every year.
But isn't it difficult to discern the rules? Wouldn't you have to scrutinize the provisions of the Fair Labor Standards Act? Wouldn't someone at your company have to divine how Occupational Safety and Health Administration (OSHA) regulations apply to compactors? Isn't it true that OSHA regulations apply to so many pieces of equipment that they must discuss issues very generally? Isn't it also true that it might be unclear whether certain regulations have anything to do with compactors?
Actually, learning the rules about who may operate a compactor is easy. All anyone has to do is check the American National Standard Institute (ANSI) Standard Z245.2-2004. Section 7.1 of the standard lays out in clear language the responsibilities assigned to owners and employers that use compactors. Notable requirements state that an owner or employer is responsible for “ensuring that only authorized employees (18 years old or older) operate, inspect, or maintain stationary compactors.”
“OSHA regulations and other standards that may apply to stationary compactors have been out for years, and they are continually being updated,” says Denny Pool, CEO and president of Hopkins, Mich.-based SP Industries Inc. and chairman of the ANSI Z245 Accredited Standards Committee's subcommittee that develops the stationary compactor standards for manufacturers and for users. “ANSI standards interpret OSHA standards to industries like the waste industry that use this equipment.”
Pool's subcommittee actually develops two ANSI standards for stationary compactors. Z245.21-2004 sets out a manufacturer's responsibilities for designing compactors that minimize the risk of fire, electrical shock, and injury to individuals operating and maintaining the equipment. Meanwhile, Z245.2-2004 covers safety requirements for the installation, maintenance and operation of stationary compactors.
The scope of the ANSI Z245 Committee's work is much broader than just stationary compactors. It also encompasses requirements for the design, manufacture, installation, modification, maintenance and use of the whole range of equipment and technology systems used in the solid waste industry. While adherence to the standards is voluntary, complying with them both decreases a manufacturer's liability and a user's likelihood of injury.
The Z245 Committee's membership comes from the ranks of users, manufacturers, state and federal government safety agencies, workplace safety consultants and industry associations with a material interest in committee activities. The addition of new members requires a majority vote of the committee. The committee works to balance the interest groups among its membership with the goal of preventing individual categories of interests from dominating committee votes.
The Waste Equipment Technology Association (WASTEC), Washington, not only nominates many committee members, it is the secretariat for the committee, meaning it administers committee business and publishes the completed standards.
The committee, its relevant equipment subcommittees and WASTEC review the standards regularly. Periodic revisions aim to increase clarity and to deal with operational hazards that may arise from regular use or from the adoption of new technologies. In fact, one of the key values of the ANSI solid waste equipment standards is that they are constantly reviewed by the Z245 Committee to ensure that changes in technology are addressed and safety concerns have been considered.
For example, a number of years ago, most users assumed that the 42-inch height of the loading point in a compactor provided protection — because that was the height that most manufacturers used. Still, it was possible that when an individual loaded the machine, he or she would inadvertently allow a hand or piece of clothing to dangle down into the chamber, where the ram, if activated, could cause a severe injury.
“Over the years, the committee has steadily added ideas and finally gotten to the point that anything that is open must be guarded or protected,” Pool says. Today, the manufacturer's standard requires that a compactor protect users against contact with any moving parts when operating. Section 5.9.1 of Z245.21 provides three ways to protect people against reaching and touching moving parts while a machine operates:
Install a guard or loading hopper with a minimum loading height of 42 inches above the working surface. In addition, the sum of the height of the hopper from the floor and the width of the hopper opening must equal at least 84 inches.
Install a gate or door with an interlock switch that automatically prevents the machine from operating when the gate or door has been opened.
Install the on-switch so far away from any openings that the operator cannot reach into the compactor while pressing the button. Furthermore, use a switching device that requires the operator to press the switch and to maintain pressure until the compacting cycle has been completed. Should the operator release the button, the machine will switch off.
This section of the standard also allows that other means may be used to guard the equipment as long as the means are as effective as the three suggested guards, thus allowing for technological advancement or innovation.
What Users Need to Know
“There are a lot of compactors out there that are not in compliance with user safety standards,” says Stephen Detrick, national compaction manager for Beachwood, Ohio-based Wastequip Inc. “If we see one of these, our policy is to inform the user immediately. Of course, we can't tell a hauler what to do, but we do recommend that any time they see a compactor out of compliance that they send a registered letter to the person of authority at the facility, noting the ANSI and OSHA rules that apply.”
James Cunningham, an engineer with Marathon Equipment Co., a compactor manufacturer based in Vernon, Ala., notes that it can be difficult for haulers to get their customers to keep up with safety modifications for compactors. “The standards give credence to the need to upgrade and improve equipment as it ages,” he says. “The standards also can be used as a training tool.”
A number of haulers have adopted insistent policies for dealing with compactors needing upgrades or not being used in accordance with the standards. Not long ago, for example, a salesperson from Milwaukee-based Veolia Environmental Services Solid Waste visited a customer in Georgia, says William Weeks, Veolia's area sales and marketing manager for Georgia and North Florida. “He took a look at the compactor they were using — one that we were servicing,” Weeks continues. “Another company had installed it years ago. At some point, the manufacturer's maintenance crew had removed the key switch and replaced it with a pushbutton.”
Modifying a compactor's controls to enable anyone to activate the machine at any time violates ANSI Z245.2-2004, section 5.6.1, which says, “A key-lock on-off switch, or similarly functioning security switch, shall be maintained by the user/operator as a means to disconnect power to the operating controls and lock these controls in the ‘off’ position.”
The salesperson informed the plant manager that Veolia would stop servicing the machine unless the key switch was replaced. “There's no requirement that we adopt such a policy,” Weeks says. “But we believe that it is a safe practice.”
Manufacturers, haulers and maintenance providers that remain informed about the standards can protect customers that lease or buy compactors. Quite often the lessee or buyer that uses a compactor will seek to improve efficiency by removing or bypassing safety controls. ANSI Z245.2-2004 applies to all compactor users, no matter what their financial relationship to the machine. This includes the waste management companies that use, sell or lease compactors. It also applies to the companies that buy or lease the equipment from a waste management firm.
According to Michael Lambert, director of corporate safety for Fort Lauderdale, Fla.-based Republic Services Inc., a company that sells or leases compactors to end users should train virtually everyone that interacts with the end users in aspects of the ANSI Z245.2 standard. “When a new standard comes out, as it did in 2004, I look at it to make sure I'm doing what I should be doing,” he says.
If necessary, Lambert will edit new material into his corporate safety program. Likewise, he adds, Republic's attorneys check new ANSI standards to make sure that they are incorporated into the contractual agreements that the compactor end users sign with the company.
Salespeople and drivers review new standards too and are expected to observe how the compactor is being used when they visit the customer. Is it being used in compliance with ANSI? Crews and managers responsible for maintaining compactors must be familiar with the standards as well. Like others that come into contact with customers, Lambert says, they should take a few minutes to inspect for compliant operations.
“Compactors are dangerous machines,” Lambert says. “If you are going to use them, sell them or install them, you should consider all of the safety requirements outlined in these ANSI standards and in other standards that apply.”
Compactors designed and manufactured to comply with ANSI Z245.21 cost more than compactors that do not meet the standards. “I would estimate that the ANSI premium runs between 5 percent and 10 percent,” says Chris Weiser, president of J.V. Manufacturing, which makes Cram-A-Lot compactors. He notes that his estimate applies to small compactors that generally carry price tags under $20,000.
While ANSI standards and their accompanying costs are voluntary and sometimes ignored, there are at least three compelling reasons for manufacturers and users to comply. First, a compactor complying with ANSI standards and used in accordance with the installation, maintenance and operating procedures will decrease the likelihood of accidents. Fewer accidents mean fewer lawsuits.
Second, because ANSI stationary compactor standards take OSHA regulations into consideration, ANSI-complying compactors and user procedures will help to ensure compliance with OSHA regulations and result in fewer fines and penalties from regulators. Finally, and perhaps most importantly, as a user or a manufacturer, it's a responsible thing to do.
Phillip Headley is the manager of technical programs for the Waste Equipment Technology Association (WASTEC). Michael Fickes is a contributing writer based in Cockeysville, Md.