Metal recycling safety found lacking
In metal recycling, management is naturally focused on production and profits – sometimes at the sacrifice of safety.
Employee, customer and visitor safety should be the number one priority. Unfortunately often times it is not, compared to other dangerous industries.
“I am ashamed to report that the refuse and recycling collection industry (SIC Code 5093) is the fourth deadliest industry in America, behind commercial fishing, logging and private plane pilots,” reported John Gilstrap, director of safety at the Institute of Scrap Recycling Industries (ISRI). ISRI represents more than 1,700 companies nationwide that process, broker and industrially consume scrap commodities, including metals, paper, plastics, glass, rubber, electronics and textiles.
“We kill workers at the rate of 41.3 fatalities per 100,000 workers. To put that in perspective, miners get killed at a rate of 15.8 per 100,000 workers. In other words, we are 260 percent more deadly than an industry that sends people a mile underground to deal with cave-ins and natural gas leaks,” said Gilstrap.
According to the 2012 ISRI Scrap Yearbook, in 2011 the U.S. scrap recycling industry processed approximately 135 million metric tons of scrap commodities valued at $100 billion while directly and indirectly supporting nearly 460,000 jobs. That’s nearly a half million people exposed to high risk environments. Conduct an Internet search on “recycling accidents” to see the carnage that’s happening across the industry.
While all industrial processes involve risk, few operations are more potentially hazardous than metal recycling. It involves both sharp and heavy objects being loaded and unloaded and heavy equipment, shearing, torching, breaking, chopping, crushing, compacting, bailing and shredding.
On the other hand, Gilstrap thinks that while the industry poses a number of potential hazards, none of them are inherently dangerous. “There are potential hazards, but we need to embrace the notion that injuries are not necessary. Owners should recognize the fact that injuries are not a part of doing business and start managing their safety program with the same vigor they manage every other element of their business.”
Gilstrap wants the four basic elements of management applied to safety. Establish a goal, communicate the goal to others, put a plan in place and assess the plan periodically.
“You can certainly set goals that are attainable, but they shouldn’t start with ‘zero accidents.’ Goals need to be set as positive achievements, not as the absence of a negative outcome. If you set zero accidents as a goal and then someone gets hurt, what have we learned? Even if the goal is achieved, we won’t know what we did to achieve it. All too often, we set ‘zero accidents’ as a goal because it’s easy to say, even for those who believe that accidents are inevitable. That’s also why supervisors who tolerate unsafe actions on their watch are rarely penalized in a meaningful way. By setting a goal that no one believes in the first place, no one is surprised when the safety goal isn’t met. It’s an entirely different standard for goal setting than is used for any other element of the management model.”
“If we’re serious about establishing a culture of safety, however, we can set meaningful and measurable safety goals. For example, if you realize you are having a hard time getting workers to wear personal protective equipment, set a goal for 90 percent compliance with hard hats and safety glasses as measured by safety observations. If you don’t reach that goal then there should be consequences in the supervisory chain. Once one goal is achieved, you can always proclaim victory and then establish a new goal, a new safety target. This process forces a conversation about safety at the highest levels of an organization and gives it an equal place at the management table.”
Today more than ever, managers have to be concerned with Occupational Safety and Health Administration (OSHA) rules and regulations, but compliance should not drive the focus of the safety program. “OSHA is largely a performance based standard, to provide a safe and healthful workplace for employees,” said Gilstrap. “If you allow regulatory compliance to drive your goal setting you can end up with a lot of training records that do not necessarily reflect effective training and programs that don’t make the place safer. If, on the other hand, you start with a dedication to safety for safety’s sake, and you take the needs of the employees seriously and you train them effectively you have a much stronger safety program that will also comply with the regulations. Motivation is important.”
Gilstrap reported that he is seeing a much more aggressive interpretation of OSHA regulations under the current administration. Under past administrations, if an OSHA compliance officer found that a company did inadequate training for lead exposure, for example, the company would receive a single fine for the company-wide violation. Now, however, the company may be fined separately for each employee not receiving the proper training, thereby multiplying the number of fines.
An OSHA spokesperson said “Enforcement is just one of a range of tools OSHA uses to encourage employers to meet their responsibility to provide safe workplaces to their employees. For the majority of employers who want to meet or exceed these requirements, OSHA offers programs that help them abate their hazards and that recognize employers with the best injury and illness prevention programs. For some employers, it is only the threat of an inspection that motivates them to call for free compliance assistance. In the last several years, we have made strong, fair, and effective enforcement one of OSHA’s prime objectives. We have improved inspection targeting and hold the worst of the worst employers accountable for their actions through our Severe Violator Enforcement Program. We will continue to conduct rigorous, targeted inspections so no employer will think that it is acceptable to expose workers to serious health or safety hazards.”
OSHA’s Scrap Metal Recycling page provides information on how to prevent workplace injuries, illnesses and deaths. In addition, OSHA has a number of publications, fact sheets and web pages that can provide information and training. For example, fact sheets and websites on proper machine lock out/tag out procedures.
American Recycler News also spoke with Bill Rouse at PK Metals, headquartered in Coram, New York. Rouse is quality, environmental, health and safety manager at PK with 22 years experience in safety. With approximately 80 employees, PK Metals is a private, family operated company that has been handling recycling needs for large corporations, governmental agencies, utilities and the general public since 1979.
Rouse participated in creating the ISRI Safety Manual, a 142 page document that provides a comprehensive template for a company to create its own safety program and manual. Rouse is also a member of ISRI’s, Safety & Environmental Council, a group of about 140 industry pros working to build best management practices.
Ironically, Rouse reported that PK does not have a safety manual per se, rather a strong safety program. His veteran experience is well worth noting: “Obviously the goal of our safety program is to control accidents. As part of our management system, we evaluated all of the processes that we do and we have a footprint to put those processes on. Then we take that and figure out what are the all potential hazards that can happen within the yard. Off those potentials, we ask does it affect that process. If it does, we need to figure out how we are going to control that hazard. Obviously, the first choice is to try to engineer-out the hazard. Other than that you rely on training, personal protection equipment (PPE) and company policies. That would be the hierarchy for safety at any company.”
“A manual is nothing; it’s all about the program. It’s all about getting your employees to buy into it, make sure they wear their personal protective equipment, make sure they are following lock-out, tag-out procedures and wear respiratory protection when necessary. If you get buy-in from your employees, the enforcement part doesn’t really happen.”
PK holds departmental safety meetings at least weekly that run anywhere from half an hour to an hour. It’s an opportunity for each department to sit down and talk about problems that happened during the week. Meetings are led by supervisors and Rouse often sits-in to hear what’s going on and how the company can help. “I always tell them it does no good for me to walk around with an inspection card once a month and see the same thing a month later and find that they have been operating dangerously for 30 days. Our employees are the ones that report most of the hazards.”
Rouse believes it’s all about building a safety culture – a culture within a company where employees buy in to the safety program and fully understand the potential hazards and the possibility of death.
“Unfortunately, getting the whole company to buy into it requires somebody to be disciplined at some point. For instance, you just can’t walk around without safety glasses; otherwise you don’t have a job. I tell everyone when I hire them that I would rather fire you than hurt or kill you. So don’t put me in that position where I’m firing you and make me feel bad about it,” Rouse ended.