CBOT sampling protocols

Best Practices in PET Recycling

Safety Issues at the PET

Intermediate Processing Facility

Issue: Maintaining a safe workplace environment is essential for reducing the incidence of worker injury, complying with safety regulations at the federal state and local levels, reducing liability costs associated with worker injury, and is corporate best practice in maintaining the health and well-being of its employees.

Many laws and regulations deal with worker safety at the federal, state and local levels of government. Every facility operator is responsible to ensure compliance with all laws and regulations. The most important law in workplace safety is the federal Occupational Safety and Health Act, administered by the Occupational Safety and Health Administration (OSHA), a division of the federal Department of Labor. Unlike other regulatory agencies that may have jurisdiction over the operations of recycling facilities, OSHA does not issue permits for construction or operation, which could help define worker safety requirements for specific types of operations. Given the number and complexity of safety regulations, many plastics recycling companies have a designated compliance officer who is responsible for identifying and complying with all regulations that might effect facility operations.

OSHA regulations and standards are contained in two volumes and are quite extensive (CFR 29, Parts 1900 to 1910.999, and CFR 29, Part 1910, Sections. 1910.1000 to end). OSHA regulations relate to almost every aspect of a facility’s operation and include such generic regulatory categories as processing, receiving, shipping and storage practices; the general condition of the building and grounds; exiting or egress; general in-plant housekeeping practices; electrical equipment; lighting; heating and ventilation; machinery, personnel, hand and power tools, chemicals, fire prevention, maintenance, personal protective equipment and transportation, that must be complied with in specific detail.

Hazards at plastics recycling facilities can be divided into three general categories: 1) health and hygiene hazards (noise, dust, climate, EMFs -- electromagnetic frequencies), 2) safety hazards (vehicle and machine hazards) and, 3) ergonomic hazards (fatigue and musculoskeletal). Compliance with worker safety regulations and proper system design and maintenance are the best practices to be followed to minimize the incidence of workplace hazards. In addition, reducing fatigue through proper ergonomic design can increase worker productivity and improve material quality at PET processing facilities.

While a discussion of regulatory compliance for all OSHA regulations is beyond the scope of this document, there are a number of major safety issues and safety best practices at PET recycling facilities that should be discussed. Once again, it is the responsibility of the facility operator to ensure that all safety regulations that apply to their specific operations are complied with at all levels of government. And, the Best Practices presented below are not intended as a comprehensive listing for regulatory compliance.

General Safety Best Practices:

· Provide all employees with adequate personal protection equipment, which may include such items as safety glasses, ear protection, gloves, hard hats, protective footwear, back-support belts, and dust masks/respirators.

· Make sure all conveyors, balers, grinders, and other processing equipment are equipped with emergency power-cut-off switches (often referred to as “kill” switches) and machine guards. This will allow plant personnel to react to safety hazard or emergency situations or to ensure worker safety during normal equipment operation and when performing equipment repair or maintenance.

· Make sure all grinders and regrind evacuation systems (blowers) are insulated to maintain noise levels below the OSHA regulated noise exposure level for workers (3).

· Make sure that all cyclone discharges from grinders are properly exhausted into baghouse or other dust collection systems, or are otherwise properly filtered in compliance with regulatory requirements, to maintain ambient dust levels within OSHA guidelines (4).

· Ensure that all equipment is properly maintained for safe and efficient operation through the implementation of a regular and preventative maintenance schedule for all equipment within the facility.

· Ensure that ergonomic considerations are factored into system design. For example, the width of sorting conveyors must not exceed to ability of the line inspector to comfortably reach the material on the belt, whether single-sided or double-sided sorting stations are used. In addition, proper belt speeds on manual sorting lines can greatly decrease worker fatigue and improve overall material quality.

· Provide adequate space for vehicle and worker activities.

· Ensure that adequate lighting is provided for general plant visibility and to prevent worker eye fatigue.

· Ensure that adequate fire protection equipment is in place based on the nature of the materials being processed and stored, the types of equipment being used, local fire codes and insurance requirements.

· Make sure that proper signage is maintained throughout the facility.

· If the facility is equipped with sorting systems that use electromagnetic frequencies (EMFs), like x-rays or ultraviolet light, as the detection signal, make sure that the equipment is properly shielded to eliminate worker exposure to EMFs.

· Ensure that only trained personnel operate specific equipment and that designated operators have any required operating certificates or licenses for that type of equipment.

· Provide adequate disposal containers that are in regulatory compliance for the disposal of oily, hazardous, or combustible wastes.

· Finally, hypodermic needles are an increasing safety concern at plastic recycling facilities. Many recycling programs request community members who require intravenous injections to store used needles in plastic containers that are then collected through special needle collection programs. Unfortunately, many of these containers make there way into plastic recycling facilities, increasing the safety concerns of worker exposure to blood borne pathogens. Every plastics recycling facility should have at least one employee who is trained in the proper handling and disposal of used hypodermic needles and has been inoculated for the hepatitis B virus. If a hypodermic needle is identified by an employee, they should hit the emergency cut-off switch for their conveyor or particular piece of equipment. Without handling the hypodermic needle or the plastic bottle containing it, they should notify their supervisor to summons properly trained and inoculated personnel to remove the hypodermic needle from the system. Removed hypodermic needles should then be placed in approved medical waste “sharps” containers for removal by trained medical or medical waste disposal professionals. In addition, if employees should be stuck with hypodermic needles encountered in the workplace, OSHA guidelines for proper medical attention should be followed for vaccination and post-exposure evaluation and follow-up (5).

References:

1. Occupational Safety and Health Administration, OSHA Handbook for Small Businesses, (OSHA 2209, US Department of Labor, Washington D.C.), 1996.

2. Pytlar, Theodore, S., Jr., “Protecting workers at processing facilities: Solutions and costs,” Resource Recycling, (March, 1996) pp. 32-39.

3. CFR 29, Sec. 1910.1030 for the OSHA regulations and procedures related to worker exposure to blood borne pathogens.

4. CFR 29, Sec. 1910.94(b) and Sec. 1910.94 (b)(4) for a discussion of OSHA regulations pertaining to dust exhaust and ventilation at grinding operations

5. CFR 29, Sec. 1910.1030 for the OSHA regulations and procedures related to worker exposure to blood borne pathogens