July/August 2013
By making a few strategic changes, scrapyards can reduce or even eliminate workplace hazards—before they hand out the PPE.
Is your equipment too loud? Issue earplugs. Do small pieces of scrap tend to fly off the end of the conveyor belt? Safety glasses are an easy fix. Do people walk in the vehicle pathway? Give them hard hats and reflective vests. A quick phone call or online order, and you’ve quickly, effectively, and cheaply created a safer workplace. Right? Wrong.
Personal protective equipment is essential, and it can reduce the risk of injury from a hazard, but it should never be the first line of defense. Federal safety regulations require workplaces to first make an effort to eliminate or reduce the hazard. In other words, make the environment as safe as you can make it, then issue PPE as a second line of defense if those measures can’t entirely eliminate the risk. Scrapyards have engineered greater safety through equipment modifications, changes to yard design, safer work practices, traffic and vehicle controls, and other efforts that keep everyone on site—employees and visitors alike—sound of life and limb.
Directing Traffic
The first major hazard-reduction opportunity is traffic and vehicle safety, and that starts at the front gate. Given the constant arrival, offloading, and departure of peddler and fleet trucks and other vehicles, it’s a never-ending, multilayered challenge to keep drivers and pedestrians safe. “The idea is to keep drivers from being distracted,” says Lee Twitchell, safety manager at Metro Group (Salt Lake City). “Giving visual cues about where to go is preferable to [providing] written materials,” he says. The company posts large signs with clear language like “unload here,” and it paints the signs a different color in each area. “Whenever possible, try to be sure that drivers at point A can clearly see point B, the next step in their journey,” he adds. Metro Group also offers laminated direction sheets in English and Spanish.
There’s a long list of conventional safety devices and strategies you can use to prevent accidents, such as motion-activated flashing lights, convex and concave mirrors, and clearly marked pedestrian paths. “We’ve painted the docks yellow to enhance visibility for someone backing up,” says Jerry Heitman, safety and environmental health manager at Sadoff Iron & Metal Co. (Fond du Lac, Wis.). Also, “we have plastic parking bunkers chained together five feet from the edge of the dock so that a peddler cannot back all the way against the dock, penning in another customer.” Many of these traffic-safety procedures might simply sound like common sense, but, as Heitman observes, “Common sense is not common.”
Controlling traffic movement is also a priority for Andy Knudsen, general manager and co-founder of Zero Accident Consulting (Libertyville, Ill.). “It’s important to minimize the amount of backing up that customers have to do,” he says. “Try to keep them moving forward and closely supervised.”
You can design traffic flow at a facility to encourage forward traffic movement and separate visitors from the machinery and activity of the yard. Traffic safety was at the top the agenda when City Scrap & Salvage Co. planned its new facility in Akron, Ohio, says Gregory Newsome, principal environment, health, safety and organizational advancement analyst. The company designed its new south yard to resemble a racetrack to keep traffic moving in one direction. It directs vehicles with nonferrous loads to drive through a building away from bigger truck traffic. The south yard has three separate scales: one for big trucks, one for pickups with trailers, and one for people in passenger cars bringing in aluminum cans. In addition, the company stores ferrous material in the center of the south yard. A truck coming in to drop off or pick up a ferrous load can only take the single road to the center and continue out on that road. Peddler traffic is restricted to one unloading location that’s far away from the north yard’s shredding operation.
Forewarned is Forearmed
A key way to reduce explosion or contamination risks is to identify the nature of the incoming material.
Learning what’s in the load—source identification—“is as important as any process, including guarding,” says Cap Grossman, president and CEO of Grossman Iron & Steel Co. (St. Louis). His is mainly a shredding operation, so employees have to spot and remove material that can’t be shredded safely, such as car batteries, mercury switches, and long wire cable that can wrap around the rotor and slingshot material hundreds of yards away. Radiation detection equipment is a standard part of most scrapyard entrance setups, but Grossman employees also conduct several visual inspections during the various steps leading to the shredder.
Twitchell agrees that one of the industry’s greatest fears involves “the limitless possibilities of what customers can bring to our yards.” Although video cameras are helpful, he says, “they cannot replace educated employees trained to do the main material screening, and … empowered and willing to just say no to hazardous material—as well as to environmentally unfriendly items and obviously stolen material.” The company also has a handout that specifies what it will and won’t accept.
Metro Group tries to avoid making such hazards someone else’s problem by directing customers to where they could or should take a rejected item. For example, propane cylinders could go to a local company that recertifies the tanks or drains and scraps them free of charge; chemical waste could go to a local landfill with a chemical disposal facility and reasonable fees. “If a customer knows why we are rejecting the item and what to do with that item, we are less likely to see it dumped on the side of the road or hidden underneath their next load.” Twitchell says.
Hazard Avoidance by Design
Inside the facility, yard design elements and company policies can reduce hazards. “It’s important to realize that there are people on foot in the facility and to direct them away from where bales and bundles are stacked,” says Tony Smith, one of ISRI’s safety outreach managers. “Paint lines on the floor to give people designated safe walkways, and post signs to instruct people to stay at least 75 feet away from mobile equipment.” For greater safety, Sadoff aims for no more than three bales per stack, Heitman says.
Also, the quantity of material the yard accepts should not exceed what it can safely store. Knudsen says hazards often occur where the facility has a small footprint and there is a limited amount of space for outdoor scrap storage and for negotiating around piles of material.
In designing its new facility, E.L. Harvey & Sons (Westborough, Mass.) had a hazard analysis done to see what hazards it could engineer out. “Struck-by hazards are the greatest [issue] for the industry,” says Safety Director Jerry Sjogren. “We designed the layout to ensure that workers could get to the bathroom easily without crossing the tipping floor. It’s important to locate restrooms and exits so that people do not need to go where hazards are.”
One of the many safety features Metro Group designed into its new facility is a safer torching area. “The working surface is packed recycled asphalt,” Twitchell says. “Bulk oxygen and bulk propane are piped under the road and under the property to the torch stations. Hoses do not have to be long—thus avoiding serious fire and other hazards—and torchers work in a circle at each station. The torchcutter is never close to the crane that drops the material; [he or she] is always on the other side of the area from the pickup and dropping activity. When one lot is done, the two activities reverse places, and the torcher moves to the other side. They stay out of each other’s way.”
Yards designed to keep people away from machinery also can ensure against accidents. City Scrap & Salvage has made its aluminum baler a permit-required confined space; OmniSource Corp. (Fort Wayne, Ind.) uses guarding to keep people away from this equipment at one of its nonferrous locations. “The scrap feeding area is restricted while baling is in progress by installed fixed guarding near the baler. This prevents the Bobcat operator and ground employees from entering this dangerous area,” says Greg Kadziolka, corporate safety manager at OmniSource.
Falling Hazards
When the height difference between the walking surface and the working surface exceeds 4 feet, the Occupational Safety and Health Administration (Washington, D.C.) requires installed handrails on an adjacent working platform or an overhead fall-protection system with a harness and self-retracting lanyard. OSHA’s rule here, as elsewhere, is to first use engineering controls to eliminate the fall hazard, then to use an overhead fall-protection system if needed. Although platforms and open-sided floors are the obvious candidates for railings, material handlers and other mobile equipment also qualify, Kadziolka says. For example, on a loader, “does anyone need to climb on the back to maintain it?” he asks. If so, “handrails need to be installed because the equipment does not come with them.”
One way to eliminate a falling hazard is to remove the need to climb—or to climb very high. For example, Metro Group’s 900-ton guillotine shear needs frequent greasing, but the company was able to eliminate the need for a catwalk by installing extension hoses that give workers access to all the fittings from the ground. “Our operator is a little squeamish about heights, and he’s much happier not having to climb ladders or use man baskets,” Twitchell says. “I think he actually believes me now when I tell him we are concerned about his safety.”
Ladders present their own hazards. At City Scrap & Salvage, after a video camera initially inspects a load at its truck scale, an employee climbs up to view the load via a staircase rather than a ladder.
Harvey & Sons used technology to eliminate a similar hazard. “Previously, drivers had to climb on top of roll-off containers, cover them manually, and secure [the cover] with bungee cords. Now the company has autotarpers so that the driver can stand on the ground and hydraulically play out the canvas cover,” Sjogren explains.
Machine Guarding
In Guidance for the Identification and Control of Safety and Health Hazards in Metal Scrap Recycling, OSHA specifies that “material handling equipment must be equipped with proper machine guards to prevent employees from coming in contact with moving parts.” OSHA’s hierarchy of safeguards ranges from primary (guards or physical barriers that enclose the dangerous parts of the machine) to secondary (devices that either stop hazardous motion or prevent it from starting) to complementary (various awareness devices and other approaches). The guards also must stop high-velocity flying fragments.
“The problem with machine guards is that they get torn up,” ISRI’s Smith says. “Repair is a constant battle.” The danger is that someone might remove the guard for maintenance but not replace it before the machine resumes operation. “The best practice is, if the guard is off, the machine is locked out,” he adds.
Sjogren points out that when an operator buys components from a manufacturer, that manufacturer doesn’t always know where those components will go—for example, linking up conveyors. The operator is responsible for providing the necessary guards, he says, adding that most manufacturers are good about offering guard options.
Knudsen notes that sometimes scrapyard owners build their own machines or modify existing equipment. “They may fail to install or reinstall safeguards,” he says. “Removing devices intended to protect workers can be an OSHA violation.”
Conversely, “many yard owners engineer their own controls to get us safer,” Grossman says. “For example, the manufacturer may think it has a guard that’s easy to get on and off for maintenance. Sometimes employees find it’s not. We prefer to find a particular way to guard that’s more effective. It’s a question of added guarding to give protection beyond what’s required by law. But nevertheless, we audit all day long to ensure the guarding is in place,” he says.
Another effective approach to equipment hazard reduction, Twitchell says, is to “replace equipment built before safety was of much concern. Newer equipment comes with guarding,” he says. “For example, our new baler comes with workable guards, emergency stop switches, and fully interconnected lock-out systems. Our new cranes come with railing all around the sides of the engine compartment deck. A lot of old equipment does not come with guarding, and there’s a liability risk in engineering retrofits for old equipment.”
OmniSource has completely enclosed some of its shredders. The result is minimal noise and effective guarding against potential spillage and projectiles as well as smoke, dust, and other airborne particulates. “Due to the destructive nature of the shredder mill, effective guarding is an ongoing challenge to maintain, and enclosures have provided very good results,” Kadziolka says.
Conveyors present multiple hazards. OSHA requires protective guarding up to 7 feet high so that no one can reach up into the machine. “Harvey & Sons has a lot of conveyors,” Sjogren explains, “so rather than guard each conveyor separately, [the company] blocked off the entire area, erecting a perimeter guard with padlock and gates, designating it a restricted area. No one can enter while the conveyor is operating. Some places use caution tapes or curtains, but that’s not enough,” he says.
In some cases, companies have reduced hazards—and guarding difficulties—by simply giving up some activities or equipment. OmniSource used to use alligator shears more often, Kadziolka says, but it found that providing effective fixed guards for small-item downsizing and trimming was so difficult that it eliminated most of that work. Now the company sells material as-is instead of separating valves and doing similar upgrading—and placing operators’ hands in harm’s way, even with the guard on.
Over the past three years, Metro Group has scrapped nearly all of its old alligator shears as well. “Although they were well made, they were difficult to guard effectively,” Twitchell says. “The problem is that many owners are not willing to give up equipment that still runs.”
Reducing Exposure to Airborne Hazards
OSHA rules regarding exposure to hazardous airborne material are specific and extensive. They require employers to provide engineered controls to the extent feasible when employee exposure exceeds permissible exposure limits for any metal or other hazardous substance. The rule, again, is not to depend solely on PPE.
One example of engineered controls replacing PPE is the OmniSource copper-sorting operation, which is done indoors. The skid-steer used in the facility to move and separate the copper is unlike the usual ones that are open on the sides and have no glass in front. Instead, Kadziolka says, “In some areas we are using skid-steers that have a pressurized, enclosed cab. The cab replaces the need for a respirator to control potential dust exposure from this operation.”
Lead exposure is a major airborne hazard concern at scrapyards that do torchcutting. Heitman says the torchers at Sadoff know that whenever they see a coating or paint, they must test for lead. If the result is positive, they don’t torch it. Instead, they use a shear attachment, a mechanical size-reduction option that does not cause the same type of exposure hazard. In fact, Sadoff is torching less overall, using shears instead when possible. But the company also tries to bale radiators as-is, without using shears, torches, or cutting wheels to clean the ends. “That was creating exposure,” Heitman says. “There was not much difference in revenue, but baling as-is is safer for employees.”
It’s also important to work with an independent industrial hygienist to monitor for hazardous exposures. The way to avoid hazardous situations is to “keep data current; you must be proactive. If you think it’s just dust, you might be wrong,” Heitman says.
To keep employees from ingesting or inhaling hazardous dust or taking it home with them, Metro Group designed its new building with space for each employee to have a locker for clean clothes and a locker for dirty clothes, to avoid contamination. Also, the company’s laundry service provides clean uniforms so that employees do not need to take contaminated clothing home.
Proper ventilation also can help abate airborne hazards. OSHA rules cover both general exhaust ventilation for an entire room or area and local exhaust ventilation for a specific work area or process. At Metro Group’s new maintenance facility, “the ventilation system includes four overhead exhaust fans, four wall-mounted fresh-air intake vents, and four gas monitors installed in the work areas,” Twitchell says. “When the gas monitors sound an alarm, a computer-controlled system kicks on the exhaust fans and opens the fresh-air intake vents. The contaminated air is quickly replaced with fresh outside air.” The automatic system ensures the facility is well-ventilated, whether or not the mechanic—busy repairing engines or cleaning parts—remembers to activate it, Twitchell adds.
City Scrap & Salvage looked at ventilation issues throughout its new facility. Newsome says there was a concern about carbon monoxide buildup, especially in winter, in the new drive-through building for nonferrous peddlers and associates. So the company installed a carbon monoxide monitoring system, which independently activates four exhaust fans.
Noise—the Pervasive Hazard
The downdraft HVAC system on Sadoff’s shredder sorting house protects workers from airborne hazards and also from noise, a pervasive hazard the company has been tackling with impressive results. A sound engineer suggested the company also use fiberglass insulation behind perforated steel panels in that building to thicken the walls and absorb noise.
“If we can cover 50 to 60 percent of the area in the sorting house, we’ll have a positive effect,” Heitman says. “If there’s an area of the wall that is being struck often, we can just weld a steel plate over it. We’re also adding additional noise-absorbent panels to the ceiling. We’re taking a look at our operations—any place you can put panels on walls, you can put noise-absorbing materials. We’re also looking at [doing so in] the shop, with its pneumatic tools.”
One more noise-abatement solution Sadoff implemented required modifying the sorting house chutes. The company installed rubber belting against the metal chute and then put a ½-inch hard plastic lining over it and the “ears,” or sides, of the chute. “We have been very pleased with how long the plastic lasts and also happy to have found a use for the old belting. The sound now is less metallic and more like a thud,” Heitman says.
“Overall, there’s been a decrease of more than 10 decibels and sometimes more than 13 decibels. There’s been a very positive response from the employees. Hearing loss is one of those preventable illnesses,” Heitman says. “We can engineer out much of the hazard. Of the company’s 250 employees, four or five were developing hearing loss illnesses every year—a figure that had to be reported to OSHA. But with noise being engineered out, in 2012, there were zero recorded hearing losses.”
And zero injuries is the goal, regardless of OSHA rules and requirements. As Grossman puts it, “We are trying to engineer an overall workplace that is safer.”
Anita Blumenthal, a freelance writer based in Potomac, Md., contributed to this story.