September/October 2013
Keeping customers and other visitors away from scrapyard hazards requires thinking through a reporter’s five W’s—who, what, where, when, and why—as well as the H: How will you ensure their safety?
By Diana Mota
For practical, ethical, and legal reasons, you train your staff in safety and hazard awareness. What about your visitors? The customers, vendors, delivery people, service technicians, and others who come to your facility could be at greater risk for injury because they are exposed to the same hazards without that training or expertise, says Jeff Wilke, director of safety for Alter Trading Corp. (St. Louis). Even those who frequent your facility might not fully understand the risks, says Andy Knudsen, general manager of Zero Accident Consulting (Libertyville, Ill.).
RecycleGuard® receives about a dozen claims a year involving injuries to scrapyard visitors, estimates Anthony Doman, claims quality assurance director for Willis Programs (Portsmouth, N.H.), which manages the RecycleGuard insurance program for ISRI. The associated medical and legal costs can add up to hundreds of thousands of dollars, he says. And the Occupational Safety and Health Administration (Washington, D.C.) has the regulatory authority to investigate serious injuries or accidents involving a visitor such as a commercial driver or vendor, which could trigger a fine, he says. To design a visitor safety plan for your facility, it helps to think like a reporter trained to find what are called the five W’s and the H. Consider the who, what, where, when, and why of visitors coming to your facility to best answer the how: How will you keep them safe?
Who
Who will be coming to your facility? From a legal perspective, you must take all reasonable precautions to protect individuals you allow onto your property for any reason, says Ed Sterrett, an independent safety trainer and consultant based in Orlando, Fla. Those precautions will vary, he says, but a visitor protection program should spell out the types of visitors allowed on the premises as well as who decides whether someone is allowed if there’s a question. Scrapyards can receive an array of callers on any given day. Proper risk management means scrutinizing where every visitor—regardless of type—goes on the property for risks and addressing them, Doman says. Examples of likely visitors and factors that might affect their safety include the following:
--Commercial vehicle drivers delivering or picking up scrap. These visitors almost certainly are familiar with scrapyards and similar industrial environments, but that doesn’t mean you can count on them to act safely. Drivers might work for companies with inadequate safety training or standards, or their desire to get back on the road quickly might make them careless. When in your yard, they must follow your safety rules, such as chocking their wheels before unloading, not climbing on loads of scrap, and not jumping out of the vehicle’s cab. If drivers are careless in the yard, don’t follow the rules, or seem to be under the influence of drugs or alcohol, escort them off the premises immediately, Knudsen says. Jerry Sjogren, safety director for E.L. Harvey & Sons (Westborough, Mass.) and chairman of the ReMA Safety and Environmental Council, suggests calling the police and, until they arrive, detaining anyone who appears to be under the influence of drugs or alcohol. “I couldn’t in good conscience allow them to leave our facility and risk them killing someone,” he says. If a driver operates a vehicle negligently in your yard and strikes another person or vehicle, you could be found at fault for improper yard safety, Doman says. Facilities should provide drivers with explicit signage and instructions about what areas they are and are not allowed to access, he says.
--Peddlers selling scrap. These visitors might be coming to your facility for the first time, or they might be familiar faces. Either way, they might not be wearing appropriate attire or personal protective equipment for being in a yard or handling scrap. Sometimes they arrive with passengers in the vehicle, including children and pets. They might speak a language that no one in your facility speaks. Some peddlers—and other visitors—arrive under the influence of drugs or alcohol. Some might want to use your tools to clean their scrap for a better price—a practice that E.L. Harvey & Sons does not allow, Sjogren says. The yard also prohibits children or pets from coming on site, he adds. “It’s way too dangerous.” Knudsen recommends developing rules and policies that address these concerns and then posting them at all visitor entrances. For example, he suggests requiring proper (sturdy, closed-toe) footwear, forbidding children and pets, and stating visitors must stay out of unauthorized areas, among other policies. As they do for commercial drivers, facilities should post signage for peddlers with clear instructions regarding where they may and may not enter, Doman says.
--Vendors and service technicians. Vendors who deliver supplies might have a better understanding of scrapyard surroundings and know what to watch out for, Doman says. Safety concerns for them might be different from concerns for those who come to work on the security system or fill the vending machines. For the latter, consider where they have to travel in the yard—and what hazards they will encounter—to get to their work. Concerns for vendors are similar to concerns for other visitors, Doman says.
--Community members. Whether you have a community appreciation day or host regular tours for adults or children, groups of visitors create different safety concerns than individual visitors. Zero Accident Consulting discourages third-party tours of scrapyards, Knudsen says. Most operators don’t want the liability concerns or work disruption that come with them, he adds. Even though visitors will have varying levels of scrapyard safety awareness, “your [visitor safety] program should be simple enough so anyone can understand it and can comply,” Sterrett says, “and as much as possible, it should be uniform to eliminate confusion.”
Another important “who” question is, who is in your yard at any given moment? “Establish a procedure to account for all visitors,” Sterrett says, such as by having them sign in when they arrive and out when they leave. The sign-in sheet should identify the reason for their visit and where they’re going. If an emergency arises, that information could be essential, says Tony Smith, ReMA safety outreach manager. “You need an accurate count. Someone can grab the log book and know who is on the premises.” Knowing where visitors are and why they’re at your facility protects everyone, Sterrett says. It also helps if you can quickly distinguish visitors from employees, Smith says. Some companies have vendors, suppliers, and contractors wear color-coded badges to distinguish them from other workers. At Jarvis Metals Recycling (Lubbock, Texas), visitors wear high-visibility yellow hard hats to distinguish them from yard workers, who wear high-visibility green hats and shirts, and shredder employees, who wear high-visibility orange hats and shirts. The firm started using the system after a customer claimed he had been injured unloading scrap from his vehicle, and the investigators had to review the surveillance tape to determine what happened. “When you’re looking at [black and white] video footage, everyone blends together,” says Deborah Vasquez, Jarvis’ human resources and safety director. “It’s hard to tell who’s who when they’re all wearing white hard hats.”
Surveillance cameras where people load or unload material can be a beneficial investment for both liability protection and safety, Doman says. “We’ve had instances where people injure themselves and, as months turn into years, the story [of what happened] changes.” For that reason, the sign-out process should provide an opportunity for visitors to report any accident or injury, he says. “That would go a long way to establishing whether the company has any liability” and help protect against claimants who report an injury after they leave. If the person didn’t report the incident prior to leaving, it raises credibility issues, and it’s up to them to prove the injury happened at your facility, he says. Scrapyards that have both cameras and a sign-in/sign-out process can protect themselves further, he adds.
What
What hazards are visitors likely to encounter? Consider the purpose of the visit for each category of visitor, including what the person will be doing and where he or she will be going, Sterrett says. Then conduct a hazard assessment from a visitor’s perspective, Smith says. Often visitor injuries and accidents relate to slips, trips, and falls (addressed in “Watch Your Step,” page 107); shifting scrap; or running equipment, says John Henshaw, senior vice president and managing principal of Cardno ChemRisk (San Francisco) and former assistant secretary of labor for OSHA. Indeed, most incidents RecycleGuard encounters involve customers delivering scrap who are struck by material, Doman says. For example, customers who are unloading scrap can be injured by nearby scrap that yard personnel are handling, he says.
Pay attention to the traffic and machinery in areas visitors access. “Is there the potential for flying objects? Is there heavy-duty equipment nearby?” Smith asks. Regardless of the grapple or magnet a facility uses, “material could always come loose or fall,” Vasquez says.
Also review past incidents involving visitors, Knudsen says. “Ask yourself, ‘Where do we know accidents have occurred?’” Once you’ve identified the hazards, it’s important to address them, Henshaw adds. “Consider each hazard and then consider the steps to mitigate [it].” (For more information on mitigating hazards, read “Safety Series: Engineering Better Safety” in the July/August issue of Scrap.)
Where
Where are visitors allowed—or not allowed—in your facility? To shorten the list of hazards visitors might encounter, consider restricting access to the yard. “You don’t want people straying around your facility,” Sterrett says. They “could pose threats to themselves or others by distracting employees from their work or exposing themselves to dangers that [they] aren’t aware of,” he explains. “Control the [site] as best as you can.” Visitors should enter in a controlled fashion through designated entry points, he says. Station someone at the entry who can screen and direct them so they don’t get lost or find themselves in restricted or hazardous areas.
Safety professionals strongly recommend scrapyard traffic-flow designs that keep visitors—especially scrap peddlers—far away from heavy equipment and scrap processing activity. As Sjogren puts it, when heavy equipment and people cross paths, the equipment is always going to win. Smith suggests segregating peddler traffic from commercial pickup and delivery vehicles and keeping equipment such as loaders, material handlers, or forklifts out of the peddler area. Equipment should only enter that area to remove the scrap after customers leave, he says. “A lot of yards are going that way.”
If it’s not possible to entirely keep visitors away from moving equipment—such as when you need a loader or crane to unload a vehicle—keep them away from the equipment while it’s in use. Drivers and passengers should exit the vehicle and stand in a designated area, Sjogren says—and cordon off the area, he adds, to ensure they don’t wander off. “You have to corral them, keep them together, and keep them where you can watch them at all times.” In the past, it was considered safer to keep customers in the vehicle, Smith says. Although some yards still do that, “we’ve gotten away from that as an industry.”
E.L. Harvey & Sons uses a different process for unloading commercial tractor-trailers, Sjogren says. Drivers must chock their own wheels and then get back in the vehicle. “That way the driver [of the unloading equipment] understands that the truck is going to be unloaded.” Likewise, when unloading baled or palletized material, “forklift drivers are not to unload a vehicle until they see the wheels chocked.” On its loading dock, the firm has posted signs that say “Drivers, chock your wheels,” which can be read directly or when viewed in a driver’s mirror.
To ensure other types of visitors don’t stray from where they need to be in the yard, have designated staff people escort them while they’re on the property, Knudsen says. Vasquez agrees. “We don’t allow visitors on the yard without an escort, and only four employees who are members of management can escort visitors,” she says. “Visitors are only allowed in areas that we take them. They are not allowed to go into the yard alone, and they can’t go where the equipment is being used.”
These safety experts suggest special procedures for public tours of the facility. When Jarvis hosts a tour, “we will shut down equipment,” Vasquez says. The group is typically sandwiched between two escorts, she says—“If it’s a large group, we have someone in the middle as well.” Some plants do driving tours only, putting visitors in a vehicle they’ve designated for that purpose, Smith says. “It keeps people contained.” If you have a processing floor that you like to show regularly, consider building a platform that lets visitors see the operation but keeps them at a safe distance, Wilke says.
When and How
When and how do you communicate safety information to visitors? After they sign in and before they leave the office, they should know what you expect of them. Start with conduct rules, such as no smoking, climbing on scrap piles, or touching equipment, Sterrett says. Also explain the facility’s hazards and emergency procedures, and provide visitors with the personal protective equipment they must wear, Henshaw says. Scrapyards should communicate policies and procedures in writing by giving a copy to visitors when they arrive, Sterrett says—otherwise, “they’re not enforceable.” Keep the text to a minimum so it’s easy to understand and doesn’t leave room for misinterpretation, he adds. The document should stipulate that visitors must comply with security, safety, and health guidelines as well as outline the risks and hazards.
Sterrett suggests combining such content with a liability waiver visitors sign to signify they have read and understood the material and acknowledge their responsibility to follow the rules. “You want to make sure they understand the hazards involved” before they enter the scrapyard, he says. By having them read about the risks and expectations as well as sign the document, “you can point to what they were told” if something were to happen. That signature does not absolve you from responsibility, however. A company still must protect visitors from workplace hazards, Doman says. About 10 months ago, Alter Trading began using a pamphlet at all 44 of its processing facilities, printed in English and Spanish, that outlines visitor expectations and contains a diagram of “no zones”—the areas they should avoid around equipment and vehicles, Wilke says. It’s available at the office counter where customers are paid. Alongside the pamphlets is a 14-by-20-inch enlargement of the no-zones diagram. The firm also plans to develop a looping video of safety information that will run continuously for customers to watch while they wait in line, he says.
Even if you hand out a written visitor-safety policy, “before a visitor goes out on the premises, there should be some discussion of what to look out for and what to do or what not to do,” Henshaw says. Visitors who must enter hazardous areas should receive a brief orientation on safety and evacuation procedures, he adds. (If visitors are always escorted, you can provide less education up front, he notes.)
At a minimum, Smith says, tailor the discussion to what hazards a specific visitor could encounter. For example, delivery people who must enter the yard should know what equipment could cross their path or what processes they could encounter. “Most of the time it’s the same driver [each day] because they’re on a route,” he points out, so you might not have to present the information to everyone every day. (Ideally, delivery personnel such as FedEx or UPS drivers can go directly to the main office and not encounter any scrapyard hazards on the way there, Sjogren says.) No matter how you communicate visitor safety policies upon a visitor’s arrival, reinforce the policies with signs throughout the facility, and enforce these rules, Knudsen says.
Also make sure employees understand their role in ensuring the safety, health, and welfare of visitors, Henshaw says. Train them to be alert for unescorted visitors or those in places they don’t belong as well as how to instruct visitors on the proper safety rules. “It should be standard procedure [for employees] to stop people every time they see an unsafe situation—whether it’s another employee or a visitor,” Sterrett says. Sjogren agrees. “We train our people to approach people they notice walking around” and direct them to a safe area.
Why
Why worry about visitor safety? In addition to your legal obligation to do so, visitors who aren’t aware of hazards can put your employees at risk as well as themselves, Sjogren says. For example, they might light a cigarette in an area that contains highly flammable materials. That’s one reason E.L. Harvey posted large “no smoking” signs around the facility, which is tobacco-free. Not effectively managing who’s on your premises also could put your company at risk of theft, violence, or sabotage, Sterrett points out.
Despite those reasons, some companies worry that customers will see any safety requirements as a nuisance, Sjogren says. “I’ve heard people argue over and over, ‘If we don’t kowtow to people, we’re going to lose them as a customer.’” That’s the wrong mindset, he says. “We need to step up and say, ‘In our yard, this is the way we do it.’” With safety procedures in place, customers should appreciate your concern for them, Doman says. “They should say to themselves, ‘This is a facility that cares for my safety.’”
Diana Mota is associate editor of Scrap.