DOSH Statewide Evaluation of the Activity of Walking on Waste

December 30, 1999

John Howard, Chief
DIR/DOSH
455 Golden Gate Ave, 10^th floor
San Francisco, CA 94102

Dear Chief Howard:

Subject: DOSH Statewide Evaluation of the Activity of Walking on Waste

The California Integrated Waste Management Board (CIWMB) and your agency entered into Memorandum of Understanding (MOU), effective March 5, 1999. This MOU addresses worker health and safety at transfer/processing operations and facilities. During the past few months, Local Enforcement Agencies (LEAs) have referred worker health and safety issues to the respective DIR/DOSH (Department of Occupational Safety and Health) regions. LEAs have made observations, during their monthly inspections, and have requested guidance in referring these types of activities. CIWMB requests your agency’s evaluation on worker safety and health issues for those practices identified below.

Please consider this as a referral made in accordance with the MOU.

The CIWMB needs help from DOSH in evaluating the following activities where waste is walked on:

• A refuse hauler walks on mixed solid waste within a transfer trailer truck, and
• A transfer/processing facility worker walks on mixed solid waste on the tipping floor.

We request a statewide evaluation of the subject activities for two reasons:

1. DOSH compliance staff may not see the activities occur during a facility inspection, or, other DOSH District Office staff may see the same activities and arrive at different findings. This matter may be further complicated by the fact that many refuse haulers are independent and not employed by the transfer/processing facility.
2. The CIWMB can apprise all LEAs of the results of your evaluation thereby reducing the need for additional individual LEA referrals on the same topic.

Briefly, these activities are described as follows: refuse haulers transport mixed solid waste in transfer trailers from transfer/processing facilities to landfills for disposal. Sometimes, in order to pull a litter control tarp over the waste, or to remove protruding or hazardous materials, refuse haulers walk on the waste inside the transfer trailer (Photo #1).

At transfer/processing facilities, some workers step onto waste to retrieve salvageable recyclable materials on the tipping floor (Photo #2).

Workers can come in contact with the following commonly found hazards in municipal solid waste; these hazards present a strong potential for worker injury and transmission of disease:

• household hazardous wastes;
• torn treated medical waste bags and associated sharps;
• airborne particles, dusts, vapors, fumes and fibers;
• waste water containing toxic, reactive, corrosive and pathogenic agents;
• vectors: flies, roaches, fleas, ticks, insect larvae, rats, mice and snakes;
• pathogens, such as bacteria, spores, virus, protozoa, and helminthes;
• sharp objects;
• dead animals; and
• human and animal waste, etc.

We also request an evaluation pursuant to AB 1127 of a similar practice at landfills. This practice involves workers stepping in compacted waste to apply a cover tarp, rather than soil, at the end of the operating day (Photo #3). This activity presents an additional risk of stepping into a waste fire.

Through your evaluation of these activities we hope that your agency will:

• inform the CIWMB of DOSH policy in writing,
• provide guidance for LEAs and operators in the appropriate way to re-position or retrieve materials protruding from transfer trailers, or from the compacted waste at the active face of the landfill,
• specify the appropriate Title 8 codes for use in future LEA referrals, and
• identify appropriate personal protective equipment that should be used.

Here are examples of preventive or alternative measures identified by LEAs and CIWMB Health and Safety staff through our inspection process:

• the use of pike poles or rakes (when feasible) to remove or reposition waste (photo #4),
• the use of mechanically operated tarps, and
• the use of personal protective equipment as follows:
  • foot protection, Title 8, section 3382;
  • body protection, Title 8, section 3383(a);
  • hand protection, Title 8, section 3384(a);
  • respiratory protection, Title 8, sections 5141, 5144(c);
  • eye protection, Title 8, section 3382(a);
  • readily available first aid kit, Title 8, section 3400(c); and
  • safety harness when needed, Title 8, section 3380.

We would like to have your evaluation and response by the end of January so that we can offer LEAs the guidance they have requested within a reasonable time. Your assistance with this issue is greatly appreciated. If I can be of further assistance, please contact me at (916) 341-6360, or Sue Happersberger at (916) 341-6383.

Sincerely,

Original signed by:

Julie Nauman, Deputy Director
Permitting & Enforcement Division

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