Early the week of January 13, NWRA submitted comments on OSHA鈥檚 proposed Heat Injury and Illness Prevention Standard, stressing the need for flexibility to address heat risks across diverse work environments. The waste and recycling industry operates year-round in a wide variety of conditions, making adaptable safety measures essential.
鈥淪afety is a core value of the waste and recycling industry,鈥� said NWRA President and CEO Michael E. Hoffman. 鈥淥ur members are committed to protecting their employees from heat-related illnesses and injuries through proactive measures, including comprehensive training, access to hydration, and adherence to safety protocols tailored to the unique demands of our industry.鈥�
NWRA urged OSHA to allow employers to customize Heat Injury and Illness Prevention Plans (HIIPP) based on local conditions and existing safety tools. Recommendations include using region-specific weather data and tailored monitoring methods. This flexibility ensures plans reflect the nature of work and environmental conditions, improving their effectiveness. Managing daily waste and recycling collection and disposal is very local and therefore rulemaking needs to account for specific local conditions.
鈥淲ith a proposed rulemaking intended to apply to employers across a range of industries and environments under OSHA jurisdiction, ensuring the rule guarantees the flexibility of employers to develop plans appropriate to their operations is critical,鈥� said Kirk Sander, NWRA senior vice president of safety and standards. 鈥淣WRA and its members are committed to employee health and safety. We are determined to reduce the risks involved in our industry, which extends to setting appropriate plans for temperature and weather response. Overly prescriptive rules would make it more difficult to provide safe working conditions in all the many locations and environments in which we work.鈥�
NWRA鈥檚 comments also highlighted potential unintended consequences of rigid rules, such as requiring electrolyte beverages unsuitable for all workers or PPE that may increase safety risks. Flexibility in these areas is vital to addressing varied workplace conditions safely.
鈥淥ur comments emphasize the commitment of NWRA members to plan and respond in ways that protect employees in high heat situations,鈥� Sander said. 鈥淭he comments also try to provide examples to demonstrate our belief that this cannot be a one-size-fits-all rule.鈥�