Occupational Health and Safety in Ontario's 3Rs Sector:

Emerging Issues and An Overview of the Workplace Health and Safety Agency

Presentation to the 15th Annual Conference of the Recycling Council of Ontario.

Hamilton, Ontario, October 5-7, 1994

Marianne Levitsky
David McRobert
Catherine DeVos
Roxanne Lloyd

Workplace Health and Safety Agency
121 Bloor St. East, Suite 900
Toronto, Ontario  M4W 3M5
OPEIU343 October 1994

TABLE OF CONTENTS

ABSTRACT

INTRODUCTION  

LEGISLATIVE HISTORY AND POLICY BACKGROUND

a). Pressure for New Omnibus Occupational Health and Safety Laws

b). The Role of JHSCs

c).1990 Amendments to the Occupational Health and Safety Act

BACKGROUND ON THE WORKPLACE HEALTH AND SAFETY AGENCY

Certification Training

Other Programs Offered Through the Agency System

OCCUPATIONAL HEALTH AND SAFETY HAZARDS AND THE 3Rs

a)........... Safety Hazards

b)........... Chemical Hazards

c)........... Biological Hazards

d)........... Physical Hazards

e)........... Ergonomic Hazards

THE INCIDENCE OF OCCUPATIONAL INJURIES IN THE WASTE

MANAGEMENT AND 3Rs INDUSTRIES:  AVAILABLE EVIDENCE

RECOMMENDATIONS FROM RECENT ONTARIO STUDIES

Public Communications

Ergonomics

Heat Stress

Work Design

Workplace Education and Communications

Equipment Design

Municipal By-Laws

GUIDELINES AND STANDARDS

HOW CAN AGENCY SYSTEM PROGRAMS HELP TO REDUCE 3Rs

HAZARDS?

WHAT CAN WASTE REDUCTION ORGANIZATIONS DO TO HELP REDUCE

HAZARDS?

BIBLIOGRAPHY

BIOGRAPHICAL NOTES ON THE AUTHORS      

Occupational Health and Safety  in Ontario's 3Rs Sector:

Emerging Issues and An Overview of the

Workplace Health and Safety Agency

ABSTRACT

This paper provides an overview of occupational health and safety legislation and the mandate of the Workplace Health and Safety Agency.  As well, it reviews literature on hazards faced by workers in waste reduction and recycling operations, and provides some recommendations to reduce risk.

A primary responsibility of the Workplace Health and Safety Agency is to certify at least one worker and one management member of each Joint Health and Safety Committee (JHSC) in Ontario. The Agency, established in 1991, funds and oversees a network of health and safety delivery organizations, several of which deliver training programs for workers in the 3Rs industries.  In addition, the Musculoskeletal Injuries Prevention Program (MIPP), developed by the Agency in 1993, is designed to train the workplace parties to understand, identify and control job demands which lead to musculoskeletal injuries. 

3Rs workers are exposed to a variety of hazards and risks, including safety, physical, chemical, ergonomic and biological hazards.   Studies conducted in Canada, the United States, the Netherlands, and Denmark indicate that workers engaged in curbside collection or processing of secondary materials are at risk for injuries or illness such as musculoskeletal injuries (MSIs) from repetitive motions such as sorting and lifting, bronchitis and asthma from exposure to dusts in composting and processing, and injuries from broken glass and other sharp materials in collection and sorting. Some provincial and U.S. jurisdictions have developed or are currently developing standards and regulations to assist in hazard prevention and control. 

The paper summarizes recommendations to reduce risks to recycling workers, including: suggestions for a public awareness program; ergonomics guidelines for lifting and reaching; heat stress guidelines; job rotation; equipment design and municipal by-laws.

Recommendations and statements of opinion in this document do not represent the official policy or position of the Workplace Health and Safety Agency.  The authors gratefully acknowledge the assistance of Francine Pugliese, Richard Shave, Bill Stevenson and Ilene Stones in the preparation of this paper.

INTRODUCTION

In the past four years one of the spheres in which the Ontario government has been most active is in reforming laws, regulations and policies on the 3Rs of waste management (reduction, reuse and recycling).  While reaffirming a commitment to safe disposal of solid waste, the new approach is geared to shifting emphasis to avoiding disposal altogether.

This presentation provides a brief review of literature on occupational health and safety issues in the 3Rs field and offers some thoughts about how we can promote safer and healthier workplaces as we achieve our waste reduction goals.  In addition, the paper provides an overview of the activities of the Workplace Health and Safety Agency and the organizations in its system.

The Waste Management Act, 1992 (WMA) which is the main reform of provincial waste management laws undertaken in Ontario to date[1] and the 3Rs regulations both are silent on the issue of worker and workplace health and safety.  The WMA contains several amendments to the Environmental Protection Act[2] (EPA) which increase provincial regulatory powers related to 3Rs activities.  It was proclaimed on Monday, April 27, 1992 and came into force immediately.  The 3Rs Regulations under the WMA were proclaimed by the Ministry of Environment and Energy (MOEE) in March 1994 and are currently being implemented. 

Efforts to improve the environment, including waste reduction, have often been closely associated with workplace health and safety.  One reason is that workplace contaminants and physical agents often pose both occupational and environmental hazards.  Another is that joint labour-management processes to assess and resolve health and safety problems have proved to be a model for addressing environmental issues at the workplace level.

In the past five years, employers, unions and workers have begun to develop bipartite and multi-stakeholder processes, organizations and committees to address environmental issues arising in their workplaces and communities.  For example, as shown by a recent study prepared for the National Round Table on the Environment and the Economy and the Canadian Labour Congress,[3] joint labour-management environment committees have been established in many workplaces.  In other cases, responsibility for reviewing employer environmental policies is delegated to joint health and safety committees.

These workplace joint committees work to improve environmental performance in areas such as waste reduction, emission abatement, noise abatement, and resource conservation and renewal (e.g., reforestation).  In Ontario, these initiatives already have contributed significantly in the implementation of leading-edge waste reduction practices in numerous workplaces, as discussed at this year's RCO conference and documented in the proceedings of previous recent RCO conferences.

It is worth noting that health and safety issues in the waste management industry also are a topic of great interest in the United States. In a recent article in Safety + Health magazine the United States (U.S.) Secretary of Labour, Robert Reich, stated that waste management workers are one of six types of workers that have been targeted by the Occupational Safety and Health and Administration (OSHA) in the U.S. for reductions in illnesses and injuries.[4]

LEGISLATIVE HISTORY AND POLICY BACKGROUND

In order to provide a context for the analysis presented below, it is useful to summarize the historical development of occupational health and safety law and policy in Ontario and Canada from the mid 1970s to the early 1990s.

a) Pressure for New Omnibus Occupational Health and Safety Laws

Pressure for reform of OHS laws in Canadian jurisdictions began to grow in the late 1960s.  After the enactment of the Occupational Safety and Health Act in the U.S. in 1970, this pressure increased significantly. 

In the 1970s, Canadian jurisdictions began to respond to this pressure for reform by passing their own new "omnibus" OHS laws.[5]  Generally, these omnibus laws integrated a variety of statutory and regulatory provisions related to mining, forestry and industrial hazards into one law and regularized numerous provisions regarding standard setting for exposure levels, the imposition of penalties for regulatory violations, internal appeal procedures, and other administrative matters.  The most innovative features of these laws may be summarized as follows:

1) employers were required to establish joint health and safety committees (JHSCs);

2) workers were provided with a right to information about workplace hazards; and

3) workers were provided with a right to refuse unsafe work.

This constellation of provisions -- namely, the right to participate, the right to know, and the right to refuse -- have been characterized as the three major OHS rights in Canadian law and they are found in almost all of Canada's thirteen OHS laws.[6]

b) The Role of JHSCs

Joint labour-management processes and institutions are a key element of occupational health and safety (OHS) public policy and legislation in most Canadian jurisdictions.  One of the main instruments of such bipartite approaches is the joint health and safety committee (JHSC), through which workers and employers are provided with an opportunity to combine their knowledge and expertise to make workplaces safer and healthier.

JHSC members possess important rights in many Canadian jurisdictions.  In most provinces, JHSC members take part in accident investigations, communicate about OHS with workers and management and advise management about OHS policies and programs.  In addition, they gather essential information about workplace conditions, identify potential hazards, participate in workplace testing, follow up on action plans and work orders, develop training and influence specific changes and improvements in equipment, programs and policies.

c) 1990 Amendments to the Occupational Health and Safety Actc)            1990 Amendments to the Occupational Health and Safety Act

With the passage of amendments to the Occupational Health and Safety Act in 1990, the Ontario government took a further step to increase the importance of labour-management cooperation through the establishment of an arms-length, bipartite agency[7] called the Workplace Health and Safety Agency (WHSA) to coordinate delivery of OHS certification training programs for JHSC members[8] and other related services such as accreditation of employers with safe workplaces.  The legislation also provides that certified JHSC members representing workers and employers have certain rights and duties including: the right to conduct monthly inspections of the workplace; the right to have dangerous circumstances investigated; and the right to jointly order the employer to stop dangerous work.

BACKGROUND ON THE WORKPLACE HEALTH AND SAFETY AGENCY

The Workplace Health and Safety Agency was established by amendments to the Occupational Health and Safety Act (the "Act")in 1990 and became an official government agency on January 1, 1991.[9]  Its bipartite 20-member Board of Directors is comprised of an equal number of labour and management representatives and reports to the legislature through the Minister of Labour. Under the amended Act, the Agency is charged with the following responsibilities:

-- to develop standards for the certification of members of joint health and safety committees (JHSCs) and other workers, and establish and administer the certification process;

-- to provide funding for occupational health and safety research;

-- to develop an accreditation program for employers who operate successful health and safety programs and policies;

-- to oversee and coordinate the operations of the health and safety delivery organizations (HSDOs) in the province; and

-- to provide advice on matters related to occupational health and safety.

Certification TrainingCertification Training

The Agency has determined that certification of JHSC members will be based on fulfilment of three criteria:  completion of Core Certification Training; completion of a workplace hazard analysis and workplan; and completion of sector-specific training (Certification Specifics) when available.  As the Certification Specifics programs are currently under development, certification is provided on a provisional basis to designated JHSC members on completion of the first two criteria.

The Core Certification Training program is offered at three levels, corresponding to one, two or three weeks of training.  Joint health and safety committees in each workplace determine which level of training their certified members require, on the basis of criteria established by the Agency with respect to number of employees, hazards, and complexity of the workplace.

Like the Core Certification program, the Certification Specifics programs are being developed through a bipartite process, through teams made up of worker and management representatives.  The Specifics programs will be designed to provide candidates for certification with the knowledge and skills to identify and control hazards specific to their industry or sector.

At present, the primary goal of the Agency is to ensure that at least one representative of management and one representative of workers on each JHSC receives Core Certification Training on OHS laws, regulations and policies and specific workplace hazards.  To date, approximately 12,000 JHSC members have been trained.  A new Ministry of Labour regulation[10], promulgated in 1994, has set compliance deadlines for certification, based on size of workplaces.  This regulation requires certified members from most JHSCs to complete Core Certification Training by April, 1995.

In little more than one year since the launch of the Core Certification Training program, evidence of its success is mounting.  Preliminary reports of an independent evaluation of the Core Certification Training program suggest that both management and worker representatives report a high level of satisfaction with Core Certification Training and the belief that the training will have a strong positive impact on the performance of their JHSCs.

These reports are also confirming the value of what the Agency believes to be a key ingredient in certification training: the fact that, in most cases, worker and management representatives of the same JHSC are being trained together in the same classroom.  Prior to the establishment of the Agency, such opportunities for joint training were rare, with most of the existing delivery organizations geared to offering their services to either management or workers.  The opportunity for worker and management representatives from the same workplace to jointly explore co-operative approaches to assessing and resolving OHS problems is proving to be one of the most valuable aspects of the certification process.

Other Programs Offered Through the Agency System

One of the responsibilities of the Agency under the Act is to fund and oversee a network of health and safety delivery organizations (HSDOs), and the Occupational Health Clinics for Ontario Workers.  These provide a multitude of training programs, research, medical diagnosis, consulting and audit services, products and publications to employers and workers across the province.  Programs and services provided by the HSDOs include short training courses, diploma programs, telephone inquiry services, and resource libraries.

Two HSDOs that provide services to the waste management and recycling sectors are the Municipal Health and Safety Program (MHSP) and the Transportation Safety Association of Ontario (TSAO).

In November 1993, the Agency formally launched its Musculoskeletal Injuries Prevention Program (MIPP) which is intended to empower workplace parties to understand, identify and control or eliminate job demands that lead to musculoskeletal injuries (MSIs).  This program, which is delivered by the HSDOs, encourages employers and workers to modify work organization and work design in order to prevent some of the risk factors that contribute to MSIs.

OCCUPATIONAL HEALTH AND SAFETY HAZARDS AND THE 3Rs

There are numerous potential health and safety hazards associated with re-use or recycling activities.  These may be related to:

a)  source separation and collection activities; or

b)  post-collection processing activities.

Hazards related to collection of reusable and recyclable materials are often very similar to hazards associated with collection of waste intended for disposal.  However, because reuse and recycling often entails greater needs for handling and sorting of materials, collection hazards may be exacerbated. 

A number of studies on hazards faced by waste collection workers have identified hazards also encountered in waste reduction activities.  As well, some research has also been conducted on hazards associated with materials recovery facilities (MRF)  operations and processing of secondary materials.

Hazards associated with waste reduction activities fall into all the major types of occupational hazards, i.e. safety, chemical, biological, physical, and ergonomic hazards.  The following summary of hazards encountered in 3Rs operations draws primarily on the results of research described briefly below:

1.         A study conducted by the Institut de recherche en santé et en sécurité du travail du Québec (IRSST) of 55 workers (9 workplaces) ascertained many hazards faced by domestic waste collection workers.  The following distribution of injuries were noted among the sample studied:

. MSIs to back, shoulder and ankle - 55%,

. crushed limbs - 18%;

. lacerations - 12%;

. scrapes and bruises - 5%;

. eye or respiratory tract irritation - 5%. 

The study set out numerous recommendations in several areas including health and safety management, training and hiring, and work organization.[11]

2.         The City of Toronto Department of Public Works conducted a health and safety compliance audit and ergonomic review of its material management and sanitation sections.  The findings produced recommendations which included revisions of by-laws and by-law enforcement to better protect worker health and safety.[12]

3.         A City of Waterloo Physical Demands Analyses for Garbage and Recycling Collection workers produced recommendations primarily targeting ergonomic hazards.[13]

4.         The United States Environmental Protection Agency (EPA) published a report in 1993 concerning the public health, occupational safety and environmental concerns in municipal solid waste recycling operations.  This study sets out numerous hazards and prevention strategies.[14]

5.         Several ergonomic studies were recently conducted by academic institutions in Holland, one of which sets out recommended maximum acceptable work loads for male refuse collectors.[15]

6.         The Danish government, in conjunction with several academic institutions, has conducted a substantial amount of research regarding the health of workers in recycling and composting plants.  Their findings indicated that an estimated 60 percent of MRF workers had occupational health problems[16].

7.         A survey of Washington state waste workers found that 50 percent of respondents reported receiving cuts and scratches on the job and 33 percent reported contact with blood on their skin, eyes, face or clothing.  Only 26 percent of these workers were trained to deal with hazards posed by contact with medical wastes.[17]

8.         A study of New York sanitation workers found that lost-time injuries (19 per 100 workers in 1983), increased in average duration over a ten-year period, from 5.3 days in 1973 to 8.5 days in 1983.[18]  The study indicates that in 1983 the injury severity rate was among the highest (equal to mining) in the U.S.  Duration in this study was used as an indicator of injury severity.

Following is a brief summary of major hazards associated with reuse and recycling activities reported in these and other studies.

a) Safety Hazards

Injuries in MRFs may result from heavy or dangerous equipment such as balers, conveyors, compactors, shredders, overhead cranes, fork lifts, and extruders.  Injuries to workers have occurred through the catching of clothing, fingers or other body parts in conveyor belts, falling onto conveyor belts, or being pulled into shredding machines.  Forklift tip overs are also common.[19]

Flying or falling objects, and squirting liquids (such as oil and paint) may also pose a hazard to workers at the processing and collecting stages of recycling.  Recyclables may fall on workers at the collection stage from overhead, or be dropped onto feet and toes while materials are lifted, sorted or transported.  Containers with hazardous or messy liquids, such as motor oil or paints, are often squeezed at pinch points in the hopper, resulting in the splashing of workers.[20]

As documented in a video produced with the support of the Agency[21], young workers who are improperly trained and unsupervised are particularly vulnerable to accidents while using dangerous equipment.  Such was the case with two sixteen-year old boys who were crushed while dislodging material in their department store compactors used for compacting recycled cardboard and other recyclable and waste materials.  One was fatally injured; the other recovered from head, neck and chest injuries.

Processing of secondary materials may cause cuts from sharp edges of broken glass or metal.  The risk of injury to workers from broken glass in bottling recycling plants was reduced when bottlers switched to polyethylene terephthalate (PET) bottles.  Moreover, the bottlers realized tremendous productivity gains, initially in the range of 10 percent annually, because breakages no longer slowed the bottling lines.[22] 

Injuries involving trucks and traffic may occur during waste and recyclables collection, and when vehicles back up during pick up or drop-off.[23]  Accidents also involve other transfer equipment such as fork-lifts used in recycling facilities.  The IRSST study noted that the frequency of mounting and dismounting from collection vehicles increases the potential for slips and falls. 

Sharps such as broken glass, metals, plastics, hypodermic needles and razor blades are often found with recyclables[24].  Contact with these objects can lead to cuts, lacerations or punctures especially where recyclables are collected, lifted, sorted, and cleaned manually.  As one worker observed, hazards presented by collection of curbside materials are often more severe because they are disguised. "In garbage, unknowns are the hazard. If you know what you are handling, it's no problem...A lot of people hide this stuff: paint, oil, broken glass.  They put it in the bag and figure you'll never find it again.  We find it!  Same with overweight containers.  You feel that twinge when you grab a heavy can and next morning you can't get out of bed."[25]

b)  Chemical Hazards

Process chemicals and residues of hazardous chemicals in recyclable containers, and their gaseous emissions pose hazards to workers in the collection, sorting, and washing processes.[26]  Examples of common process chemicals include chlorine, fluorine; paper bleaching, de-inking and pulping agents; aluminum fluxing agents and compounds; plastics additives, and equipment cleaning solvents.  Recyclable container residues may include insecticides and herbicides; paints, stains and construction products; automotive oils and cleaners; gasoline, kerosene, and other fuels; and household cleaning products.  Some of these substances may contain carcinogens.  Contact with skin or inhalation or ingestion of these chemicals can cause dermatitis, disorders to the central nervous system, and possible liver and kidney damage.  Contact with harmful emissions from vehicles can occur wherever ventilation systems are inadequate.

Exposure to other harmful airborne chemicals may occur in the remanufacturing or refining of recyclable materials.  Emissions from aluminum delacquering processes that burn paint and coatings can contain organic contaminants and heavy metals such as lead and cadmium.  Steel melting and demagging operations may release metallic oxides and chlorides, and acid and chlorine gases.  Plastics and polystyrene processing can produce emissions such as acids, volatile organic compounds, carbon monoxide, and styrene monomer.  Exposure to fumes from heated metals can produce metal fume fever (a flu-like condition); exposure to some of these other chemicals can cause irritation to the skin and respiratory tract, and potential damage to the liver and central nervous system.[27]

Particulate releases occur in the material receiving and sorting areas, where trommel screens, air classifiers, glass crushers, and shredder equipment are used to process recyclables.  Inhalation of metal, glass, paper or plastic dust from shredding, demagging and detinning can cause or aggravate chest discomfort, bronchitis or asthma.  Acute exposure to metal dusts may cause irritation of the upper respiratory system and eventually severe pulmonary irritation.  Chronic exposure to some heavy metals may cause cancer and adverse effects to the central nervous and gastrointestinal systems.[28]

c)  Biological Hazards

Workers may be infected by biological agents (e.g. bacteria or viruses) that contaminate waste and secondary materials.  Medical and pathological wastes are particularly hazardous, especially where there is a danger of cuts or puncture wounds from broken glass, metal edges, or needles.  Cuts or lacerations to the skin can become the site of infection following exposure to bacteria, viruses (including Hepatitis B virus), fungi or parasites.[29]   Cimino[30] documents 42 cases of hepatitis in sanitation workers in 1968, 3 of which were fatal. 

A Danish study of materials recovery facilities workers found that contact dermatitis, infections, diarrhoea and skin diseases were common health problems associated with exposure to certain bacteria, fungi and viruses, which often grow within recyclable containers or on paper products. Long‑term occupational exposure to contaminated air in composting operations can induce allergic responses, including asthma, bronchial asthma, chronic bronchitis, and hay fever.  Other symptoms common to MRF workers include fever; chills; diarrhoea; irritation of eyes, nose and upper respiratory tract; nausea; headache; chest tightness; and feeling of influenza.[31] [32]    

A similar Danish study determined that workers in paper sorting operations had the highest incidence of changes in lung function compared to all other MRF workers.  These adverse changes were caused by the high levels of organic dust and endotoxins (poisonous substances produced by bacteria) in the air.[33]

d) Physical Hazards

Noise, heat, cold, and vibration are among the physical hazards occurring in MRFs, and at the curbside.  Studies have indicated that noise levels in the primary and secondary shredder, and magnetic separator areas have measured as much as 100 decibels.[34]  Noise may cause permanent hearing loss and stress‑related conditions.[35] 

Concern about noise was one factor which encouraged bottlers to switch to PET plastic bottles.  Noise levels in glass refillable bottling plants were often deafening; bottling and handling operations for PET bottles were much quieter. 

Indoor temperature extremes are common due to the large size of buildings which have numerous delivery doors and openings, and are hence difficult to heat and cool adequately.  Workers can be exposed to extreme cold in the winter and heat in the summer months, due to inadequate temperature control.  Prolonged exposure to high temperatures in or around furnace or kiln areas may result in heat-related illnesses, such as heat exhaustion, cramps or stroke.[36]

Outdoor temperature extremes can also present hazards, leading to heat stress, hypothermia, or frostbite.[37]

e)  Ergonomic Hazards

Collection and sorting operations often require repeated lifting and twisting motions which are common sources of musculoskeletal injuries (MSIs), including repetitive strain injuries (RSIs).  Collection workers must lift and dump heavy bins and bags, and twist and reach during curbside sorting.  Audits conducted by the cities of Waterloo[38] and Toronto[39] found that lifting of waste and Blue Box materials exceeded guidelines recommended by the U.S. National Institute for Occupational Safety and Health (NIOSH).[40] 

Manual sorting tasks often require reaching, lifting and twisting.  These can cause workers pain, soreness, general fatigue, tendonitis, and MSIs of the feet, arms, shoulders, hands, wrists, and lower and upper back[41] [42].  

The Quebec IRSST study has also demonstrated that the repetitive motions conducted by curbside collection and MRF workers are cause for concern.[43]  The study shows that garbage workers have a high incidence of RSI because of repeated flexing and twisting motions, further noting that waste collection workers were usually inadequately trained and prepared for the fine motor activities required for curbside sorting.  In a Globe and Mail article describing the Quebec study,[44] Jenkins notes that "[a] recent two-year study by the Quebec Health and Safety Research Institute found that two-thirds of the province's garbage collectors spend time off work each year because of injuries.  It discovered that in an average hour, a worker makes 482 flexes, 203 throws, 159 twists and 53 jumps off a moving truck.  These calisthenics, often done on busy streets, are performed in all extremes of climate and with minimal protective equipment."

The Municipal Health and Safety Program, one of the HSDOs funded by the Agency, has observed that "finish and go home" pay schemes tend to encourage working at excessively fast rates, thereby increasing the potential for injuries from safety and ergonomic hazards.

THE INCIDENCE OF OCCUPATIONAL INJURIES IN THE WASTE MANAGEMENT AND 3Rs INDUSTRIES:  AVAILABLE EVIDENCE

The Agency is currently in the process of developing a major data base on health and safety experience in Ontario.  Most of the information in this data base is information on workers compensation experience transmitted to the Agency by the Ontario Workers Compensation Board (WCB).  The following discussion on compensation claims experience in the waste and recycling sectors is based on data contained in the Agency data base, and on information provided by the Transportation Safety Association of Ontario (TSAO) and the Municipal Health and Safety Program (MHSP). 

In the municipal sector, it was not possible to obtain specific information on recycling workers.  However, the general rate of injury reported by the MHSP for sanitation workers, which includes recycling workers, was 22 lost-time injuries per 100 workers in 1993.  This is reduced from a rate of 41 per 100 workers in 1985. 

In 1993, the Ontario Workers' Compensation Board introduced a new industry code (rate group 689) to identify firms in the "Waste Materials (Recycling)" industry.  These are private-sector firms that handle waste material and specialize in recycling.  As of June 1994, there were 329 lost-time injury (LTI) claims allowed in this industry for injuries sustained in 1993.  The rate of injury in these firms for 1993 was 8.5 per 100 workers. 

The difference between these rates and those for municipal waste workers does not necessarily mean that public sector waste and recycling workers are at greater risk than those in the private sector.  This is because of differences in the composition of these two groups:  rate group 689 includes a variety of occupations not directly comparable to the category of municipal sanitation workers.

The nature of injuries sustained by workers in the private sector recycling industry (rate group 689) follows a slightly different pattern from that of other claimants. 

The largest single type of injury in the waste materials industry was "sprains and strains", which accounted for 37 percent of all claims in this rate group.  This is less than the proportion of sprains and strains among all workers compensation claims.  Across the system as a whole, sprains and strains account for approximately 50 percent of all claims. The following table compares the distribution of injuries in the private waste materials/recycling sector and the overall distribution of injuries for all claims in 1993.  Unfortunately, we do not at this time have comparable data for public sector 3Rs workers.

Percent of Claims

Nature of Injury - All Claims Compared to

Rate Group 689

Nature of Injury

Percent of Claims Rate Group 689

Percent of All Claims

Sprains and strains (MSI)

37%

50%

Contusions/bruises with intact skin

16%

13%     

Fractures

11%

5.7%

Occupational injuries unspecified

10.5%

9.3%

Cuts/lacerations

10%

9%

Scratches/abrasions

4.2%

2.5%

Agency data also indicates that in this rate group, the most injured part of the body was the back or lumbar spine, which accounted for 25 percent of the claims.  The second most frequently injured part of the body was the fingers, which accounted for 12 percent of the claims.

RECOMMENDATIONS FROM RECENT ONTARIO STUDIES

There are practical options that can be pursued by managers and workers to improve OHS performance in Ontario's 3Rs sector.  Following are some suggestions for reducing hazards, drawn largely from the recommendations from the Cities of Toronto and Waterloo audit reports and the IRSST study, discussed earlier in this paper.

Public CommunicationsPublic Communications

Measures to protect the health and safety of collection workers should be relayed to the public through an awareness campaign.  This should include information about:

-            the risks of excessive load weights and recommended lifting weights;

-            the dangers to waste and 3Rs workers of depositing prohibited, hazardous or hidden              waste materials;

-            the importance of labelling waste material that may be deceptively heavy or contain sharp              objects.

ErgonomicsErgonomics

-            Follow basic ergonomic principles for materials lifting such as:

-            mechanize lifting and carrying tasks, e.g. place objects on a pallet and use a forklift when              possible to avoid manual lifting;

-            ensure materials to be lifted manually are as light as possible;

-            utilize "team-lifting" techniques to improve lifting of awkward or heavy items;

-            provide instruction to workers and supervisors regarding proper lifting techniques;

-           design jobs to reduce the frequency of lifting; and

-           reduce bending and overreaching during sorting with the use of equipment such as tilt              boxes and scizzor tables, or platforms at a conveyor for shorter workers to stand on.

Heat StressHeat Stress

-            Workers handling heavy materials in temperatures above 25 oC should be required to               take 15 minute rest breaks for every hour worked;

-            Ensure the availability of drinking water for workers;

-            Implementation of an acclimatization process whereby workers expecting to be subject              to extremely high temperatures should acclimatize by either:

            1--  limiting time in the hot environment to 50 percent of the shift on the first day and 80             percent on the second day; or

            2--  reducing the physical demands of the job for the first week or two.

Work DesignWork Design

-            Job rotation patterns should be implemented to reduce repetition of the same motions.  For example, workers can alternate between driving and collecting, or between collecting waste and Blue Box materials;

-            Materials should not be lowered to the floor if they will be transported elsewhere later.

-            "Finish and go home" pay schemes should be avoided.

-            Night collection should be avoided;

Workplace Education and CommunicationsWorkplace Education and Communications

-            Programs should be adopted to raise awareness about health and safety among all levels             of management and workers;

-            Training should be provided at the onset of hiring, and on an ongoing basis to educate all             workers and managers about hazards, injuries, and their reduction and prevention;

-            "Buddy systems" should be implemented to encourage beginner/veteran information and             experience sharing;

-            Internal communications should be improved through regular cooperative labour and             management meetings, where work conditions, application of regulations, public                         education, and complaint systems are discussed; and

-            All levels of management should be educated on their responsibilities to ensure worker              health and safety.

Equipment DesignEquipment Design

-            Specifications for collection and MRF equipment should incorporate features to protect             health and safety such as:

            - truck step heights that are neither too steep or too shallow

            - sorting platforms and automatic lift and tilt mechanisms on trucks

            - enclosure and ventilation of MRF processing and sorting equipment

            - mechanical washing equipment to prevent the necessity of direct contact with cleaning             chemicals

            - design for noise abatement such as enclosures, baffles and dampeners

Municipal By-LawsMunicipal By-Laws

-            implementation of by-laws imposing requirements for size and type of containers and             restrictions on inappropriate materials; and

-            improved by-law enforcement through a sticker system which notifies the resident of the             by-law infraction and provides information on penalties.

GUIDELINES AND STANDARDS

Guidelines and standards relevant to controlling hazards to waste and 3Rs workers have been developed or are being considered by governments in a number of jurisdictions, as well as by several non-governmental standard setting organizations.  Even where compliance with standards is not required by law, they can serve as useful guides to help employers and workers assess and reduce ergonomic hazards.  Relevant standards include the following:

-           In January 1992, the American National Standards Institute (ANSI) approved a new standard, Z245.1-1992 -- Mobile Refuse Collection and Compaction Equipment -- Safety Requirements which revise and replace former standards dating from 1984.  This standard is one of a series of standards covering mobile waste collection, stationary compactors, refuse bins, baling equipment and rear loader lifting systems.  The standard applies to all parties, including designers, manufacturers, installers, modifiers and maintenance shops.  It includes criteria for equipment safety features, training, recordkeeping, and work practices. 

-           The U.S. National Solid Waste Management Association (NSWMA) has produced a Manual of Recommended Safety Practices (1989) which provides guidelines to assist the Association's member companies in implementing the relevant ANSI and OSHA standards.

-          In August 1992, the U.S. Occupational Safety and Health Administration (OSHA) issued an Advanced Notice of Proposed Rulemaking (ANPR) on the need for a specific rule on ergonomics.  It is expected that the standard will be performance based, establishing criteria for ergonomics assessments and control measures.

-           In July 1994, the Workers' Compensation Board of British Columbia published draft Ergonomics Regulations and an associated Code of Practice.  These are currently being reviewed through public hearings, for anticipated approval by early 1995.  The Regulations were developed to "eliminate or minimize the risk of adverse health effects to workers through the application of ergonomic principles and methods in the workplace."[45]  The Regulations comprise eleven components including employers' responsibility to identify ergonomic hazards; assess and control risks; plan a compliance strategy; educate and train workers; monitor and evaluate the effectiveness of control measures; and adhere to a Code of Practice. 

-           The Canadian Standards Association (CSA) and National Research Council (NRC) both have established committees to develop national ergonomic standards. 

HOW CAN AGENCY SYSTEM PROGRAMS HELP TO REDUCE 3R HAZARDS?

Programs offered through the Agency system can help to reduce the potential for injury and illness among workers in the waste and secondary materials occupations.  The training and certification of JHSC members, for example, prepares them to fulfil their responsibilities under the Occupational Health and Safety Act, so that they will be better able to co-operatively identify and address hazards.  For example, certification training can help prepare JHSCs to undertake the following activities:

-            workplace inspections to identify and correct hazards.  Inspection duties should include             observations of work conducted on collection routes as well as in fixed workplaces.

-            recommending and observing testing of hazards

-            review of reports of injuries and recommendations on ways of preventing them.  Many             JHSCs go beyond this legislated requirement and also investigate "near misses", which can             be highly instructive in preventing actual injuries.

-            recommending training programs

-            recommending safe work practices and procedures.

-            recommending equipment design for health and safety.

The HSDOs funded by the Agency offer many training programs in addition to Certification training which can help the workplace parties to reduce waste-related hazards.  In particular, the MIPP program mentioned earlier is designed to help workers and employers identify and reduce the risks of MSI.  Other relevant training programs cover back care, safe work procedures/task analysis, and material handling.  As well, most HSDOs offer consulting services to help the workplace parties address hazards in their own workplaces. 

The Municipal Health and Safety Program (MHSP) has developed a training video for sanitation and MRF workers on hazards and protective equipment.  In addition, MHSP conducts courses and seminars in traffic control, heat stress, and driver improvement programs.  The Transportation Safety Association of Ontario offers employers assistance with safety audits and the establishment of joint health and safety committees; a safe driver award program; and several truck and vehicle driver programs, including a classified driver improvement program.

WHAT CAN WASTE REDUCTION ORGANIZATIONS DO TO HELP REDUCE HAZARDS?

Organizations such as the Recycling Council of Ontario (RCO) and the Association of Municipal Recycling Coordinators (AMRC) are in a position to make major contributions to improving occupational health and safety among waste reduction workers.  By sponsoring discussion of the issue, such as this presentation, the RCO is helping to promote awareness of the need for hazard reduction.  Such organizations can serve as major resources to public and private sector enterprises by disseminating information and encouraging workers and employers to co-operatively assess and reduce workplace hazards.  One area in which the waste reduction movement has excelled is in changing public behaviour through education and communication initiatives.  Those involved in waste reduction have a great opportunity to serve another important social goal by employing this skill and expertise in the cause of occupational health and safety.

October 4, 1994

BIBLIOGRAPHY

American National Standards Institute, American National Standard for Refuse Collection, Processing and Disposal Equipment -- Mobile Refuse Collection and Compaction Equipment -- Safety Requirements, ANSI Z245.1--1992, Jan. 1992.

Ballard, J.  "Waste Management", Safety and Health Practitioner (U.K), Vol. 9, No. 3, Mar 1991, pp. 36-41

Bourdouxhe, M., Guertin, S., and Cloutier, E.  Etude des risques d'accident dans la collecte des ordures ménagères, Institut de recherche en santé et en sécurité du travail du Québec (IRSST), December 1992.  Montreal: IRSST.

British Columbia, Workers' Compensation Board, Secretariat for Regulation Review, Board of Governors.  Draft Ergonomics Regulations and Statement of Context, Draft Code of Practice and Proposed Implementation Strategy, July 1994.

Bryson, C.  "Be Prepared", Occupational Health and Safety Canada, Mar./Apr. 1994, pp. 78-85.

Cimino, J.A. and Mamtani, R.  "Occupational Hazards for New York City Sanitation Workers", Journal of Environmental Health, Vol. 50, No. 1, 1987, pp. 8-12.

Cimino, J.A.  "Health and Safety in the Solid Waste Industry", American Journal of Public Health, Vol. 65, No. 1, 1975, pp. 38-46.

City of Toronto, Occupational Health, Safety and Rehabilitation Division, Management Services Department.  Occupational Health and Safety Audit Report for the Material Management and Sanitation Section, Jan. 1993.

Combs, S.  "Building Safety Into MRF Design",  Waste Age, Aug. 1991, pp. 95-96.

de Looze, M., Stassen, A., Markslag, A., and Toussaint, H.  "Low Back Stress in Different Methods of Refuse Collecting".  Proceedings of the International Ergonomics Conference, Vol. 2, Aug. 1994, pp. 417-419.

Dessoff, A.  "Planning Safe MRFs", Waste Age, May 1991. pp. 79-80.

Edwards, C.  "Health and Safety in the Recycling and Waste Disposal Industries",  Occupational Health and Safety Magazine (Alberta), Sept. 1992, pp. 7-14.

Edwards, C.  "Edmonton Recycling Society Cultivates Safety", Occupational Health and Safety Magazine (Alberta), Sept. 1992, pp. 15-16.

Fredrickson, L.  "Recyclers Learn Safety Rules", BioCycle, April 1993, pp. 64-66.

Frings-Dresen, M., Stassen, A., Markslag, M., Kemper, H., de Looze, M., and Toussaint, H.  "Maximum Acceptable Work Load for Refuse Collectors in Relation to Age".  Proceedings of the International Ergonomics Conference, Vol. 2, Aug. 1994, pp. 234-236.

General Code Publishers Corporation.  City of Etobicoke Municipal Code, Section 149 on Garbage Collection, Sept. 1992.

Hendry, F.  "Handle With Care: Responsible Hazardous Waste Reduction and Disposal",  Accident Prevention, July/Aug. 1990, pp. 8-11.

Human Factor Inc.  Report on Physical Demands Analyses for Garbage Collection and Recycling Collection.  For the City of Waterloo, June 1992.

Jenkins, A.  "The Yeoman of Garbage", The Globe and Mail, Oct. 20, 1993, p. D5.

Kemper, H., Frings-Dresen, M., de Looze, M. and Toussaint, H.  "Ergonomics of Refuse Collection in the Netherlands".  Proceedings of the International Ergonomics Conference, Vol. 3, Aug. 1994, pp. 256-258.

Legler, J.A.  "New Standards Enhance Worker Safety", Waste Age, Apr. 1992, pp. 195-198.

Legler, J.A.  "Safety Training for Workers in Materials Recovery Facilities",  Waste Age, Jan. 1994, pp. 77-80.

Liss, G.  "Office Disposal of Needles and Other Biomedical Waste",  Ontario Medical Review,  Mar. 1991, pp. 20-23.

Malik, O.  "Occupational Health and Safety for Composting Operations".  A lecture presented at the Conference "Composting: An Answer to Controlling Pollution", Toronto, Sept. 1991.

Mamtani, R. and Cimino, J.A.  "Work Related Diseases Among Sanitation Workers of New York City", Journal of Environmental Health, Vol. 55, No. 1., July/Aug. 1992, pp. 27-29.

Ontario Ministry of the Environment.  "New Waste Management Legislation Introduced by Environment Minister Ruth Grier", MOE News Release, Oct. 24, 1994.

Ontario Ministry of Labour, Occupational Health and Safety Division.  Health and Safety Guidelines: Heat Stress, July 1993.

O'Brien, C. and McIlwain, L.  "Tackling Trash",  Occupational Health and Safety, Jan./Feb. 1994, pp. 37-42.

Ontario Natural Resources Safety Association.  "Hepatitis B -- The Risk Increases", Health and Safety Resource, May/June 1994, p. 6.

Powell, J.  "Safety of Workers in Recycling and Mixed Waste Processing Plants".  Resource Recycling, Sept. 1992, pp. 49-50.

Queen's Printer for Ontario.  The Occupational Health and Safety Act, R.S.O. 1990.

Queen's Printer for Ontario.  Regulation Respecting Control of Exposure to Biological or Chemical Agents -- made under the Occupational Health and Safety Act.  R.S.O., 1980 Chapter 321. -- Ontario Regulation 654/86.

Queen's Printer for Ontario.  Ontario Regulation 362/94.  Regulation Made Under the Occupational Health and Safety Act -- Joint Health and Safety Committees - Exemption from Requirements.

Reich, R.  "Reich Reviews OHSA Reform", Safety and Health, July 1994, p. 30.

Shecker, T.  Sustainable Development:  Getting There From Here -- A Handbook for Union Environment Committees and Joint Labour-Management Environment Committees (1993).  Ottawa: National Round Table on the Environment and the Economy and the Canadian Labour Congress.

Society of Plastics Industry of Canada.  "Plastic Soft Drink Bottles: The Right Choice for Ontario", Submission to the Ontario Ministry of the Environment, June 9, 1993; p. 9.

Turnberg, W. and Frost, F.  "Survey of Occupational Exposure of Waste Industry Workers to Infectious Waste in Washington State", American Journal of Public Health, Vol. 80, No. 10, Oct. 1990, pp. 1262-1264.

United States Environmental Protection Agency.  Public Health, Occupational Safety, and Environmental Concerns in Municipal Solid Waste Recycling Operations, Dec. 1993, pp. 5/33-5/35.

Walsh, P., Pferdehirt, W., and O'Leary, P.  "Safety Considerations in Solid Waste Collection", Waste Age, Jan. 1994, pp. 81-91.

Waste Age, "How a Missouri Hauler Reduced Risk", Jan. 1991, pp. 74-78.

Workplace Health and Safety Agency. Core Certification Training Program -- Participant's Manual. Rev. ed. Toronto, 1992.

Workplace Health and Safety Agency.  Working Together for Health and Safety: The Impact of Joint Health and Safety Committees on Health and Safety Trends in Ontario.  A Paper presented to the 1994 Conference "International Evidence: Worker-Management Institutions and Economic Performance, sponsored by the Commission on the Future of Worker-Management Relations and the Work & Technology Institute, Mar. 1994, Washington, D.C.

WorkWeek Television Productions.  Children for Hire.  A full-length documentary aired June 17, 1994.

BIOGRAPHICAL NOTES ON THE AUTHORS

Marianne Levitsky is Director of Policy and Research for the Workplace Health and Safety Agency.  She is a Certified Industrial Hygienist and has previously worked for the Waste Reduction Office of the Ontario Ministry of Environment and Energy.

David McRobert is a Senior Policy Analyst in the Agency's Policy and Research Department.  He holds a B.Sc. in Biology from Trent University, a Masters in Environmental Studies (M.E.S.) from York University, and a LL.B. from Osgoode Hall Law School.  Between July 1991 and May 1993, David was Senior Policy Advisor working on several policy and regulatory projects related to 3Rs activities for the Waste Reduction Office in the Ontario Ministry of the Environment. 

Roxanne Lloyd is a Senior Research and Policy Analyst in the Agency's Policy and Research Department.  She holds a M.Sc. degree in Health Services Planning and Administration from the University of British Columbia.

Catherine De Vos is the Grants Administrator in the Agency's Policy and Research Department and is currently assisting with various research projects in the department.  She has previously worked for the Ontario Ministry of Labour's Grants Administration Section.


[1]For an overview, see Ontario Ministry of the Environment, "New Waste Management Legislation Introduced by Environment Minister Ruth Grier", MOE News Release, October 24, 1991.

[2]R.S.O. 1990, c.E.19.

[3]Ted Shrecker (ed.), Sustainable Development: Getting There From Here -- A Handbook for Union Environment Committees and Joint Labour-Management Environment Committees (1993).  Ottawa: National Round Table on the Environment and the Economy and the Canadian Labour Congress.  

[4]Robert Reich, "Reich Reviews OSHA Reform," Safety + Health, July 1994, p. 30.

[5]In Canada, OHS law and policy is developed and applied by thirteen different jurisdictions.  Conditions for most workplaces are governed by provincial labour laws because the ten provincial governments in Canada have constitutional authority for regulating between 80-90 percent of employers within their provinces.  Similarly, the majority of workplaces in the two territories -- the Yukon and the Northwest Territories -- are regulated by the two territorial governments.  Other workers who are employed in workplaces under federal jurisdictions, such as shipping and rail transportation, are governed by provisions in the Canada Labour Code.

[6]For further discussion, see Workplace Health and Safety Agency, Working Together for Health and Safety: The Impact of Joint Health and Safety Committees on Health and Safety Trends in Ontario. A Paper Presented to the 1994 Conference, International Evidence: Worker-Management Institutions and Economic Performance sponsored by the Commission on the Future of Worker-Management Relations and the Work & Technology Institute, March 1994, Washington, D.C.

[7]The Workplace Health and Safety Agency is considered to be bipartite because it is governed by a Board of Directors composed of equal numbers of representatives of labour and management.

[8]Under the amendments to Ontario's Occupational Health and Safety Act passed in Bill 208, at least one committee member representing management and one representing labour of joint health and safety committees in almost all workplaces are required to be certified in accordance with standards set by the Agency.  In 1992/1993, the Agency used bipartite processes to develop its Core Certification Training program to train designated members of JHSCs about safety issues and legislation.

[9]Occupational Health and Safety Act, R.S.O. 1990, c.O.1 (as amended).

[10]Ont. Regulation 362/94.

[11]Madelaine Bourdouxhe, Serge Guertin and Esther Cloutier, Étude des risques d'accident dans la collecte des ordures ménagères, Institut de recherche en santé et en sécurité du travail du Québec (IRSST), December 1992.  Montreal: IRSST. (A 30-page English summary titled "A Study of the Risk of Accidents in Garbage Collection" is available from the IRSST.)

[12]Occupational Health, Safety and Rehabilitation Division, Management Services Department, City of Toronto, Occupational Health and Safety Audit Report for the Material Management and Sanitation Section, January 1993.

[13]The Human Factor, Inc., Report on Physical Demands Analyses for Garbage Collection and Recycling Collection.  For the City of Waterloo, June 1992.

[14]U.S. Environmental Protection Agency.  Public Health, Occupational Safety, and Environmental Concerns in Municipal Solid Waste Recycling Operations, December 1993, pp. 5/33-5/35.

[15]Michiel de Looze, Arthur Stassen, Aanemiek Markslag, and Huub Toussaint.  "Low Back Stress in Different Methods of Refuse Collecting".  Proceedings of the 12th Triennial Congress of the International Ergonomics Association, Toronto, August 1994, Vol. 2, pp. 417-419.

Han Kemper, Monique Frings-Dresen, Michiel de Looze, and Huub Toussaint.  "Ergonomics of Refuse Collection in the Netherlands".  Proceedings of the 12th Triennial Congress of the International Ergonomics Association, Toronto, August 1994, Vol. 3, pp. 256-258.

Monique Frings-Dresen, Arthur Stassen, Annemiek Markslag, Han Kemper, Michiel de Looze, and Huub Toussaint.  "Maximum Acceptable Work Load for Refuse Collectors in Relation to Age".  Proceedings of the 12th Triennial Congress of the International Ergonomics Association, Toronto, August 1994, Vol. 2, pp. 234-236.

[16] Jerry Powell.  "Safety of Workers in Recycling and Mixed Waste Processing Plants".  Resource Recycling, September 1992, pp. 49-50.

[17]Wayne L. Turnberg, and Floyd Frost.  "Survey of Occupational Exposure of Waste Industry Workers to Infectious Waste in Washington State", American Journal of Public Health, October 1990, Vol. 80, No. 10, pp. 1262-1264.

[18] Joseph A. Cimino and Ravinder Mamtani.  "Occupational Hazards for New York City Sanitation Workers", Journal of Environmental Health, 1987, Vol. 50, No. 1, pp. 8-12.

[19]Alan Dessoff, "Planning Safe MRFs", Waste Age, May 1991, pp. 79-80.

[20]Mr. Wes Vinter, Manager of Waste Management, City of Etobicoke, Phone conversation with C. De Vos, September 26, 1994.

[21]WorkWeek Television Productions, Children for Hire.  This full-length documentary was aired on CBC Newsworld "Rough Cuts", June 17, 1994.

[22]Society of Plastics Industry of Canada, "Plastic Soft Drink Bottles: The Right Choice for Ontario," Submission to the Ontario MOE, June 9 1983, p. 9.

[23]Patrick Walsh, Wayne Pferdehirt, and Phil O'Leary.  "Safety Considerations in Solid Waste Collection", Waste Age, January 1994, pp. 81-91.

[24] Gary M. Liss. "Office Disposal of Needles and Other Biomedical Waste", Ontario Medical Review, March 1991, pp. 20-23.

[25]Anthony Jenkins.  "The Yeoman of Garbage", The Globe and Mail, October 20, 1993, p. D5.

[26]U.S. Environmental Protection Agency.  Public Health, Occupational Safety, and Environmental Concerns in Municipal Solid Waste Recycling Operations, December 1993, pp. 5/33-5/35.

[27]Ibidem, p. 5/33-5/40.

[28]Ibidem, p. 5/40-5/44.

[29]Ibidem, p. 5/8.

[30] Joseph A. Cimino.  "Health and Safety in the Solid Waste Industry", American Journal of Public Health, Vol. 65, No. 1, 1975, pp. 38-46.

[31]Jerry Powell. "Safety of Workers in Recycling and Mixed Waste Processing Plants.", Resource Recycling, September 1992, pp. 49-50.

[32] Om Malik, Ontario Ministry of Labour.  "Occupational Health and Safety for Composting Operations".  A paper presented at the conference, Composting: An Answer to Controlling Pollution, Toronto, September 25, 1991.

[33]Ibidem, p. 50.

[34]                     U.S. EPA, Public Health, Occupational Safety, and Environmental Concerns in Municipal Solid Waste Recycling Operations, December 1992, p. 5/27.

[35]Workplace Health and Safety Agency.  Core Certification Training Program -- Participant's Manual. Toronto: Workplace Health and Safety Agency, (Rev. 1993), p. 174.

[36]U.S. EPA. Public Health, Occupational Health and Safety, and Environmental Concerns in Municipal Solid Waste Recycling Operations, December 1992, pp. 5/17-5/20.

[37]Ibidem, p. 5/19-5/20.

[38]The Human Factor, Inc., Report on Physical Demands Analyses for Garbage Collection and Recycling Collection.  For the City of Waterloo, June 1992.

[39]Occupational Health, Safety and Rehabilitation Division, Management Services Department, City of Toronto, Occupational Health and Safety Audit Report for the Material Management and Sanitation Section, January 1993.

[40]Ibidem.  Both the Waterloo and Toronto reports.  Waterloo report: pp. 2-10, Toronto report: p. 9.

[41] Michiel de Looze, Arthur Stassen, Annemiek Markslag, and Huub Toussaint.  "Low Back Stress in Different Methods of Refuse Collecting".  Proceedings of the 12th Triennial Congress of the International Ergonomics Association, Toronto, August 1994, Vol. 2, pp. 417-419.  This study found a high incidence of low back injury among Dutch refuse collectors.

[42] The Human Factor Inc.  Report on Physical Demands Analyses: Garbage Collection and Recycling Collection.  A report prepared for the City of Waterloo, June 1992.

[43]Madelaine Bourdouxhe, Serge Guertin and Esther Cloutier, Étude des risques d'accident dans la collecte des ordures ménagères, Institut de recherche en santé et en sécurité du travail du Québec (IRSST), December 1992.  Montreal: IRSST.

[44]Anthony Jenkins. "The Yeoman of Garbage", The Globe and Mail, October 20, 1993, p. D5.

[45]The Secretariat for Regulation Review, Board of Governors, Workers' Compensation Board of British Columbia.  Draft Ergonomics Regulations and Statement of Context, Draft Code of Practice and Proposed Implementation Strategy, July 1994, p. 1.