01 April 2020
CIWM welcomes WISH advice and highlights key areas for further work
CIWM welcomes the valuable and timely work that WISH is undertaking to assess the risks of COVID-19 to waste management sector key workers and provide clear advice on the steps that should be taken to mitigate those risks to ensure that essential waste and recycling services continue.
CIWM’s expert networks have responded to the consultation and provided feedback which has been communicated back to WISH.
Drawing on this feedback, CIWM has highlighted three key areas where there is a need for greater clarity and consensus to ensure that the sector is taking a consistent approach to managing the risks associated with COVID-19 and ensure that essential waste and recycling collections continue.
Social distancing and collection crews
A hierarchy of preferred options should be developed to reduce the risks to collections crews and individual drivers operating vehicles. While acknowledging that local circumstances such as rurality and the configuration of collection rounds will have a bearing on the approach taken, feedback from CIWM members suggests that the preferred option should be to move to a Driver + 1 system in the cab, with established crews staying together and effectively working as ‘members of the same household’. An additional crew member travelling in a separate vehicle can work where necessary along with appropriate round/frequency adaptation (it should be noted that this applies primarily to local authority collections rather than C&I collections where driver-only rounds are more common). Where the Driver + 1 option is not practicable, other measures such as crews travelling independently to meet RCVs on site, additional shifts and service frequency changes, should be considered. Where individual drivers are engaged in the emptying and /or exchange of waste containers, advice should be given on maintaining safe distancing while at collection or disposal sites, including the arrangement of paperless waste transfer notes.
Household Waste Recycling Centres (HWRCs)
CIWM supports the WISH statement that “As CA/HWRC sites are places where members of the public may meet in numbers local authorities can be encouraged to consider closing the sites until social distancing is relaxed. If there is necessity and it is essential for CA/HWRC sites remain open…” and would reinforce that the rationale for keeping HWRCs open to the public while strict social distancing measures are in place, except in exceptional circumstances, is weak for a number of reasons:
1. It effectively contravenes the Government’s instruction that citizens should only leave the house for essential tasks, these being:
· shopping for basic necessities
· one form of exercise a day
· any medical need or to provide care / help a vulnerable person
· travelling for essential work purposes
2. Most HWRCs are not laid out in such a way that social distancing can be effectively maintained, putting both operatives and members of the public at risk. Approaches such as restricting the flow of traffic to the site to enable effective social distancing may have impacts beyond the site, including unacceptable and potentially unsafe levels of congestion on access roads
3. Evidence from CIWM members prior to the widespread closure of HWRCs highlighted examples of unacceptable public behaviour at HWRCs which put site operatives at additional risk.
HWRCs do provide valuable services, however, and their closure increases pressure on kerbside collections and recycling and disposal routes for some businesses. CIWM is, therefore, prepared to work with WISH, industry stakeholders and UK governments as appropriate to develop a protocol to determine if and when strategic HWRC sites could be opened and to establish guidelines to ensure they can be operated safely according to social distancing requirements.
Current and future advice may also need to note that different waste streams may appear in the residual waste stream as a result of HWRC closures or restrictions, some of which may also pose additional risks e.g. broken mirrors/glass.
Personal Protective Equipment (PPE) and hygiene
Greater clarity is needed in a number of areas related to PPE and hygiene.
Respiratory Protective Equipment (RPE) and PPE: The guidance may need to be more explicit on the issue of face masks. While current advice is that they offer little or no protection against COVID-19, and indeed may increase the risk of exposure, further consideration of specific circumstances in the waste sector may be required. CIWM agrees with the WISH statement that “where an employee in the waste and recycling sector would usually be expected to wear respiratory protection as part of their normal job then they should continue to do so” and would recommend that further thought be given to areas where there is a higher risk of exposure to waste materials and bioaerosols that could potentially be contaminated with COVID-19, such as in MRFs. This is important because instructions given to householders to store waste for 72 hours if infection is suspected or confirmed may not always be followed.
Additionally, more detailed guidance on the safe use and removal of PPE is needed to avoid workers inadvertently contaminating themselves - a risk that has already been identified in the health service. For example, hands should be cleaned first before removing face masks and again after, and only the straps should be touched rather than the fabric of the mask.
Mustering and breaks: The guidance needs to be more explicit with regard to observing social distancing during start-of-day and end-of-day mustering, breaks, shift changes, etc. across all relevant sections of the guidance (i.e. the sections on collections or transfer stations) as many operational teams may muster pre-start and at the end of the working day. Advice could also include consideration being given to staggered break times for employees.
Deep cleaning and 72 hour park up: Further detail is needed on effective ‘deep clean’ procedures where a case of COVID-19 is suspected or confirmed. Feedback suggests that waiting for 72 hours before a deep clean may not be practicable if vital services are not to be impacted, particularly in the case of vehicles, but also for shared areas, office areas, etc.
Aligned to these key issues, CIWM believes that further work is needed to communicate to the public that people should avoid major DIY, spring cleans and garden overhauls, whilst their waste collections services and other local council services are under pressure.
CIWM will continue to contribute to and support collaborative industry efforts to ensure that workers in the resources and waste sector are well informed, trained and equipped to work safely.
1. WISH is a UK forum and any advice or information may not be directly relevant or applicable in the Republic of Ireland, where guidance in the workplace is primarily provided by the Health and Safety Authority.
2. CIWM: CIWM is the leading professional body for the resource and waste management sector representing around 5,700 individuals in the UK, Ireland and overseas. Established in 1898, CIWM is a non-profit making organisation, dedicated to the promotion of professional competence amongst waste managers. CIWM seeks to raise standards for those working in and with the sector by producing best practice guidance, developing educational and training initiatives, and providing information on key waste-related issues. More information can be found at www.ciwm.co.uk
Head of Policy, Knowledge & External Affairs
Tel: 01604 620426
Mob: 07912 228260