Over the past 18 months, we at Blue Ridge Services, Inc. have conducted several national surveys. The surprising results indicate that more than 90% (sometimes up to 97%) of waste facilities do not have the documents required to comply with federal, state, and industry standard expectations. What that means is that more than nine out of 10 workers within the waste industry are working every day—without all of the training, safety, operational, and procedural documentation that they need in order to do their job safely and efficiently.
On a separate, but perhaps eerily related note, data from Occupational Safety and Health Administration (OSHA) and the National Institute of Occupational Safety and Health (NIOSH) indicate that the waste industry is the 5th most dangerous industry in the United States. Every year, approximately 40 solid waste workers are killed on the job—most on collection routes. An average of one per month occurs at a landfill. A number of non-employees are killed in accidents each year, too.
Is there a direct correlation? Common sense would indicate, “yes.” Our team has developed an acronym for all of these mission-critical documents that essentially carry the administrative load of your facility. We call them “SHERPADocs,” with SHERPA being an acronym for:
Let’s clarify what we are talking about in regard to these critical documents. Essentially, we are referring to standard operating procedures, administrative policies, training documents, safety plans, and all the other standards that are considered to be normal to solid waste facilities and operations. This includes landfills, transfer stations, material recovery facilities (MRFs), collection operations, and organics processing facilities.
There are two common formats for these documents. The first is a narrative-type format—where the layout resembles a book or report. For example, when standard operating procedures (SOPs) are written in a narrative-type format, the document generally flows well and integrates all procedures in a logical progression—like reading a story.
The narrative-type documents—sometimes referred to as manuals or guides—set forth the narrative in a format that reads like a mini book from start to finish. This document format provides perhaps a more comprehensive document, but making modifications as things change can be more difficult, because you are essentially rewriting portions of the entire the manual.
The second is a module-type format. This layout is less formal and breaks individual procedures into logical chunks of 1–2 pages per topic. The module-type format may be explained in a very condensed format, with key items shown in numbered or bulleted lists. For example, there will be individual sections for every OSHA-required safety topic such as: blood-borne pathogens, hearing conservation, and confined space. Similarly, there may be individual SOP sections for: wheel loader operation, fueling machines, walk-around inspections, pushing waste, unloading at the landfill, handling bulky materials, directing traffic, etc.
Making changes in a module-type format is easy, because you can simply change the appropriate sheet…and insert it into the binder. Regardless of which format you choose for your facility, the most important thing is to do something.
As a manager, how many times have you had to settle conflicts within your crew as to the right way to do a specific task? “Joe” complains because “Bill” lets trash build up too much on the tipping pad before pushing; “Sue” complains that the pick-line backs up because “Mike” doesn’t properly floor sort at the MRF; and “Sam” complains that “Pete” doesn’t clean out the Front loader on the Saturday commercial route. And, the payload and cycle times for the transfer trailers show way too much variation from one driver to another.
These simple tasks—along with hundreds more—can be traced back to a root cause: Not having clear, comprehensive training documents in place. There are many ways to do a specific task, but unless you standardize how to do those tasks at your facility—everyone will run their play…their own way.
It doesn’t work for football, and it won’t work at your facility. Having had the opportunity first hand to work as an expert witness on nearly 50 cases within the solid waste industry, I’m still surprised when I see how common it is for waste operations—all types of them—to operate without standardized procedures. One of the most common cracks in the foundation of an otherwise well-run operation is related to training.
In a typical injury or fatality case, there is always a question about what training the crew received…and who conducted the training? Too often we find that there was none. Or the training that was provided was inadequate. We sometimes find that nobody really knows who did what training. The director assumes the manager did the training; the manager assumes the supervisor did the training; and the supervisor assumes that HR did it. Too often, nobody did.
Another serious industry trend has become apparent to our team. We are constantly working on a safety audit or operational review of some waste operation—often several at a time. And unfortunately, we find that an increasingly alarming percentage of managers do not follow even the few procedures that they have because they are not aware of what those procedures are. In other words, they do not follow the SOPs because they don’t know the SOPs.
Ignorance is no defense. If you are a manager, you’re supposed to know the rules and the procedures. And if you don’t know what they are, it’s impossible to ensure that everyone else follows them.
Unfortunately, creating and implementing good SHERPADocs is one of those proactive things—like changing the oil in your car or brushing your teeth. You can let it slide…and slide. But, eventually the consequences of not doing what you know you should be doing catch up with you.
And in the meantime, at least in regard to your waste operation, your team will be confused, frustrated, inefficient, and at risk.
So, what does it take to get your SHERPADocs in place? You need to know what’s required, by regulation, policy, and industry standard. Then, you must determine what you have. For example: What does OSHA require? What does your permit require? What does the machine manufacturer require for operation and maintenance?
Chances are you have some of these documents in place. But if you are like 90% of your peers, many will be outdated, incorrect—or non-existent.
Here’s a brief excerpt of some key SHERPADocs:
Safety & Health
- Injury and Illness Prevention Plan
- Heat Stress Plan
- Hearing Conservation
- Safety Meeting Topics/Schedule
- Confined Space Entry Plan
- Walk-Around (Pre-trip) Inspection Form
- Equipment Maintenance & Repair Program
- Fuel Log
- Equipment Controls
- Machine Safety Devices
- Warranty Tracking System
- Emergency Response Plan
- Spill Response Plan
- Fire Prevention/Control Plan
- Accident Response Plan
- Natural Disaster Response Plan
- Odor Control Plan
- Weekly Manager’s Report
- Fill Sequence Plan
- Haz-Mat Load Check Form
- Standard Operating Procedures (for all tasks)
- Employee Handbook
- Regulatory Inspection Records
- Self-Inspection Records
- Landfill Gas Monitoring Plan
- Groundwater Monitoring Plan
- Succession Plan
- Employee Training Plan
- New Hire Orientation Program
- Employee Job Descriptions
These tools are every bit as important as shovels and hammers, or as bulldozers and route trucks. One compliments the other. But after working as an operations consultant in the waste business for nearly 30 years, I can report that most facilities will get serious about their SHERPADocs only after a tragedy forces the issue. Don’t be part of the 90% who wait until someone gets hurt or killed or sued. Be responsive, and get your policies and procedures in place.
For a more comprehensive list of documents utilized for various types of waste facilities/operations, please email me at firstname.lastname@example.org.