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COVID-19: General Safety Checklist for Recycling Operations

The COVID-19 pandemic requires an assortment of modified procedures and ways of doing business to keep employees, customers and visitors safe. This also provides an opportunity to reinforce existing safety practices, in addition to adapting to new concepts, such as social distancing.  

If you already have an Infectious Disease Response Plan, utilize that document to guide you through what needs to be done in your operations to keep everyone safe, updated with the considerations contained within this guidance document.  If you do not have such a Plan, document the steps you are taking in accordance with the information contained within this guidance document to provide the basics of such a Plan.  As all operations are different and decisions are site specific, ISRI is providing the following checklist of items to consider in your specific operation:

 

  1. Tell all Employees who are sick to stay home.  If someone in their immediate household is sick, or they have otherwise been exposed to someone who is sick, also ask them to stay home. Designate someone within your operation for your employees to call if they are sick or experiencing symptoms of COVID-19 been developed.

  2. Consider developing procedures for immediately isolating people who have signs and/or symptoms of COVID-19. Priority should be to retail areas and other points of contact with the public. Move potentially infectious people to a location away from workers, customers, and other visitors. Although most worksites do not have specific isolation rooms, designated areas with closable doors may serve as isolation rooms until potentially sick people can be removed from the worksite.

  3. Consider whether any employees can work remotely.  Consider allowing any employee whose job function can be done remotely to do so, so as to minimize the number of people who are physically present at your operation.

  4. Keeping Safe Distances.  Current recommendation is that a minimum of 6 feet is maintained between people. Consider what points of contact exist between people in your operation and whether changes can be made to avoid contact.
    • Look for any opportunities to separate employees within your operation by a minimum of 6 feet
    • Consider staggering breaks for employees
    • Consider closing retail operations if exposure cannot be avoided.
    • Discourage workers from using other workers’ phones, desks, offices, or other work tools and equipment, when possible.
  5. Clean and disinfect frequently touched surfaces daily.  This includes tables, doorknobs, light switches, countertops, handles, desks, phones, keyboards, toilets, faucets, and sinks.
    1. Consider what parts of your equipment (e.g., controls) and tools (e.g., handles) are exposed and need to be disinfected regularly.  
    2. If surfaces are dirty, clean them: Use detergent or soap and water prior to disinfection. 
    3. The CDC recommends the following options for disinfecting surfaces:
      1. Diluting your household bleach. To make a bleach solution, mix: 5 tablespoons (1/3rd cup) bleach per gallon of water
        OR
      2. 4 teaspoons bleach per quart of water
        Follow manufacturer’s instructions for application and proper ventilation. Check to ensure the product is not past its expiration date. Never mix household bleach with ammonia or any other cleanser. Unexpired household bleach will be effective against coronaviruses when properly diluted.
    4. Alcohol solutions. Ensure solution has at least 70% alcohol.
    5. Other common EPA-registered household disinfectants. Products with EPA-approved emerging viral pathogens pdf iconexternal icon claims are expected to be effective against COVID-19 based on data for harder to kill viruses. Follow the manufacturer’s instructions for all cleaning and disinfection products (e.g., concentration, application method and contact time, etc.).
    6. Consider how scale tickets, shipping documents and other paperwork are handled in your operations.    When paperwork, “handle with care,” and immediately wash your hands following handling. If your employees use an electronic device, it should be disinfected after a customer has handled it, and the employee should immediately wash his or her hands
      .
    7. Ensure continued use of all Personal Protective Equipment (PPE) and make sure that Face shields and protective eyewear are cleaned frequently due to the close proximity of an infection pathway (the eyes).
      a. Provide gloves to all employees
      b. Have all employees wearing a respirator, met all the OSHA requirements for a respiratory protection program to include initial fit testing?  Following is the NIOSH approved list of respirators: https://www.cdc.gov/niosh/npptl/topics/respirators/factsheets/respsars.html
      c. On March 14th, OSHA issued temporary enforcement guidelines on respirator fit testing for healthcare workers, which are to remain in effect until further notice.  One of the reasons for the temporary enforcement guidelines stems from the fact that there was a national shortage of N95 masks for healthcare workers prompting many to use surgical masks. Surgical masks do little to protect the employee and are designed to protect the patient from the medical worker.  N95 masks, due to their ability to seal around the face, provide protection in both directions.
      d. The following is a very good YouTube video which covers the requirements for voluntary respirator use in the workplace per the OSHA standard: https://www.youtube.com/watch?v=QW3bjPkdRzM. The voluntary use alternative, while it sounds good on the surface, is really not that dissimilar from the full respiratory protection regulation. Additionally, the temporary guidance removes the requirement for annual fit testing but not for the initial fit testing.
      e. If an employer does choose to have a voluntary use program, each employee must receive a copy of appendix D of the standard which can be found at:  https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.134AppD 
      f. The N95 facemask typically has a metal strip at the nose bridge noted above in red. This metal strip needs to be fitted around the nose bridge during the fitting process.

    8. Consider a review of engineering controls for possible ways to minimize potential exposures. Considerations include:
      a. Installing high-efficiency air filters
      b. Increasing ventilation rates in the work environment
      c. Installing physical barriers, such as clear plastic sneeze guards
      d. Installing a drive-through window for customer service

    9. Document all the steps you are taking within your operations to keep everyone safe.If you there are changes you are making to standard processes and practices within your operations to address COVID-19, document those changes and the reason for doing so.

    10.  Handling UBCs.
      a. Unfortunately, a lot is still not known about how long COVID-19 can live on metal and plastic surfaces.  While some have determined that 3 days is the limit, this has not been confirmed and there have been others suggesting it may be as long as a week. (1)
      b. There are a number of options that recyclers can consider:
      • Not accepting UBCs at this time;
      • Put in administrative controls where you accept and hold the material for 3 days or more. Again, the specific duration of time is not known at this time.In addition, employees should keep a safe distance from the customer while UBCs are being weighed; once they are properly weighed or checked in to the company system, the retail scale operator could direct the customer to a designated area where the material will be quarantined for a safe period of time; or
      • Suit up the retail worker in nitrile gloves, leather gloves, long sleeves, mask, etc. However, these items (gloves & masks) are quickly becoming scarce, which will limit this option.
    11. Constantly remind employees to stay focused. This is especially important for line workers and drivers on the road.With all that is going on now, distraction and fatigue from stress and worry is challenge for everyone.

    12. Conserve safety supplies. We will likely be challenged to find additional safety supplies in the weeks ahead, so consider talking to employees about the importance of treating all safety supplies with extra care.

[1] As for the life of the virus on surfaces, this study from NEJM - https://www.nejm.org/doi/full/10.1056/NEJMc2004973 and this one from the NIH - https://www.nih.gov/news-events/news-releases/new-coronavirus-stable-hours-surfaces show that it can be stable for hours and/or days depending on the surface (copper, plastic, stainless, cardboard, etc.).

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