PCR Credit 11: Post-Collection Recovery Facility Safety Protocols and Training (1-3 points)
Reciprocal
Intent:
To reduce accidents and injuries and ensure worker safety and health outcomes during daily material recovery and organics processing facility operations through attention to hazards and making worker protection a part of company culture.
Local Government and Industry Requirements:
Implement a Safety Incentive Program that is not directly connected with accident-free periods. The program must include ‘whistleblower’ protection where employees are never to be disciplined for identifying and reporting hazards or reporting accidents.
The Employer and the employees shall comply with all state and federal health and safety laws and regulations.
Establish an employee-led Safety Committee consistent with OSHA Recommended practices [1]:
● Establish regular meetings to be conducted during paid hours
● Ensure that Safety committee members receive the necessary safety training to enable them to effectively perform their required functions as committee members.
● Ensure that employees have the opportunity to communicate opinions on the effectiveness of worker safety regulations and suggestions for improvement.
● The Safety Committee should automatically receive all copies of the employer’s OSHA 300 illness and Injury logs as well as the facilities’ personnel-hours
● Ensure that safety committee members have proper, secured storage for OSHA 300 logs as these logs can often contain sensitive employee data.
● No worker shall be punished or discriminated against in any way for refusing work that he or she believes in good faith to be immediately dangerous or for bringing health and safety violations to the attention of any person.
And
Tier 1: (1 point)
● Verify that weekly safety and equipment usage demonstrations and training are being conducted for all employees
● Operates in a documented safety-training system that complies with ANSI Z245 safety guidelines as applicable.[2]
● Monitor, record, and report worker illnesses, fatalities and injuries
● Provide workers with a health insurance plan that has the characteristics of an Affordable Care Act qualified plan for pre-existing conditions, young adult coverage, cancellation and appeals, benefit limits, and preventative care. The health insurance plan should also have at a minimum, an actuarial value of 90% that covers all employees and family members, with no employee/family payroll premium deductions or waiting periods regardless of company size.
● Ensure all workers are paid not less than a Living Wage, including hourly wage, benefits, and paid overtime OR an Alternative Living Wage set at 150% of the Minimum Wage.[3]
o To determine the Living Wage for your region, utilize MIT’s Living Wage Calculator or EPI’s Family Budget Calculator. If you are using a living wage calculator, the calculated Living Wage should not exceed the Median Household Income[4].
● Provide “Accessible” Training that is available in the predominant/fluent language of the workers being trained:
o Mandatory weekly for new hires for at least the first quarter
o Ongoing monthly training for existing employees)
o Features graphic-based or video training;
o American National Standard (ANSI Z245) symbols are used throughout
● Provide weekly “Accessible” Training (Mandatory for new hires; and ongoing for existing employees) that is available in the predominant/fluent language of the workers being trained:
o Graphic-based or video training;
o American National Standard (ANSIZ245) symbols used
Tier 2: (2 points)
● All the requirements of Tier 1,
● Workers receive additional worker training program(s) recognized by their collective bargaining representative.
Or
● Provide “Advanced operational training” covering fixed and onsite mobile equipment
o Training should include both “classroom” and “field” components
o For training on existing equipment or improved existing equipment, Trainers should have a minimum of 2 years of full time operating experience on the equipment that is the subject of the training and demonstrated training experience of 100 hours, or equivalent certification.
o For newly introduced equipment (e.g. robotics), Trainers should have a minimum of 6 months of field or laboratory operating experience on the equipment that is the subject of the training and demonstrated training experience of 100 hours, or equivalent certification.
Potential Strategies:
Accomplish increased operational regulation, safety resources, and safety awareness campaigns by implementing the following recommendations:
● Complete all employee safety and health training programs and track participation and if employees passed tests.
● Incorporate safety training into all onboarding training.
● Complete and record Risk Assessments for all work tasks; remediate identified hazards.
● Implement a system to report near-misses and discuss for practical lessons.
● Implement and follow a Safe Driving Policy & training for facility mobile equipment (option: using SWANA’s template)
● Conduct regular safety training at least weekly for all employees, track attendance.
● Create and maintain standard operating procedures based on industry best practices.
● Regularly hold focus group meetings between employees and employers. Ensure both parties have the opportunity to communicate opinions on the effectiveness of worker safety regulation, and suggestions for improvement.
● Worker participation means that workers are involved in establishing, operating, evaluating, and improving the safety and health program. All workers at a worksite should participate, including those employed by contractors, subcontractors, and temporary staffing agencies.
[1] https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf
[2] https://swana.org/Safety/ANSIStandardsforWasteandRecycling.aspx
[3] As will be further described in the Certification Manual, the Living Wage is calculated as follows–Either use the referenced living wage calculators or use the Alternative Living wage. The Alternative Living Wage is defined as 150% of the Minimum Wage. The Minimum is defined as the average of 1) the existing Federal Minimum Wage of $7.25/hr., indexed to current dollars using the CPI deflator (https://www.bls.gov/data/inflation_calculator.htm) and 2) Fifteen dollars ($15). For the Pilot Program, the Applicable Minimum Wage is calculated as $11.75. The Alternative Living Wage for SWEEP is calculated to be $17.63.
[4] SWEEP uses a Median Household Income of $60,293 defined by the Census of the United States. https://www.census.gov/search-results.html?q=median+income&page=1&stateGeo=none&searchtype=web&cssp=SERP&_charset_=UTF-8
Accessible training that workers understand (conducted in their primary language) is basic requirement- not a “Tier 2″/above and beyond requirement. OSHA has already spelled out an employer’s obligation to provide training in a method and language that workers understand. SWEEP is meant to be a leadership standard, and this misses the mark.