LGA Operating Standards

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1 LGA Operating Standards PBL Operating Standards 1 March 2016

2 CONTENTS 1. Purpose of this Document Principles Risk Management Approach Chain of Responsibility Collection Site Operating Standards Workplace Health and Safety Workplace Health and Safety Plan Fire Protection Access Control Spill Kits Safety and First Aid Equipment Risk Management Quality Requirements Compliance Requirements Environment Management Systems Licences and Permits Legislation Environmental Management Plan Incident Reporting Collection Site Requirements Design and Layout Signage Staffing Acceptance, Storage and Collection Procedures Acceptance Storage Collection Audits Attachment A Architectural and Decorative Waste Paint Classifications Attachment B Collection Site Assessment Tool

3 1. Purpose of this Document Paintback Limited (PBL) has developed these Operating Standards to inform and document key decisions regarding the selection of suitable sites to collect waste architectural and decorative paints (as defined at Attachment A) and to establish collection contractor transport and waste treatment requirements and obligations. 2. Principles The principles on which these guidelines are based are: Protection of staff and employees site design and operation must meet the appropriate standards for workplace health and safety. Protection of public health and safety site design and operation must meet the appropriate standards for the handling and storage of hazardous substances and dangerous goods and measures must be put in place to protect the public. Protection of the environment site design and operation should minimise any potential impact on the surrounding environment. Safe disposal site design and operation should maximise the ability for eligible waste paint collected to be disposed of safely. Inherent safety through good design and planning buildings and associated structures must be designed to: comply with the relevant laws and codes promote safety through good design in location, construction and layout achieve good traffic management minimise the possibility of any adverse incident occurring reduce the impact of any incident that might occur. 3. Risk Management Approach This SOP has been developed following the risk management approach. Collection sites and contractors for the acceptance, storage, transport and treatment of hazardous waste should be designed and operated to achieve the following objectives: protection of staff and employees protection of public health protection of the environment facilitation of the safe treatment or recycling of waste architectural and decorative paints. Risk is a combination of the likelihood and consequence of any event that will impact the achievement of objectives. This means the likelihood and consequence of hazards such as: leakage from a container exposing staff, members of the public or the environment to its contents fire or explosion caused by flammable material or solvent coming into contact with an ignition source unintentional mixing of incompatible or reactive substances causing a chemical reaction, explosion or fire, and exposure to unknown substances thus generated. Risk management is a structured way of identifying threats and opportunities in achieving these objectives and responding to them with appropriate controls or management activities. This process has been summarised by Safe Work Australia in the following figure. 3

4 The Risk Management Process to Address Collection and Transport Risks The risk control process requires the consideration of the hierarchy of control The Hierarchy of Risk Control 4

5 4. Chain of Responsibility PBL s collection model involves 3 components: the waste paint receival site, transport from the site and treatment services. PBL will use third party providers for the supply of these services. All responsibility, risk and liability, environmental, emergency and quality management systems of the PBL program must reside with the third party whilst the waste paint is in their control. After delivery of the waste paint by an end-user to a collection site, the site operator has responsibility for and carries the risk and liability for the waste paint stored at the site awaiting collection by the collection contractor. The site operator must implement environmental, safety, emergency and quality management systems in relation to the public, employees and the wastes stored at the site. Once waste paint is received by the collection contractor at a collection site, responsibility for that waste must be passed to the collection contractor. Transport must be undertaken in accordance with relevant regulations in each state or territory. All treatment and treatment of the collected waste paint must be undertaken at premises that are licensed for this activity. 5. Collection Site Operating Standards 1.1. Workplace Health and Safety Established processes and documented procedures should be in place to protect the health and safety of customers and staff at the site and for managing the impact of the site on the environment. These processes and procedures should include procedures and equipment for safe handling of eligible waste paint, such as Personal Protective Equipment (PPE) and Safety Data Sheets. Due to the flammable nature of solvent-based paints a 'No Smoking' rule should be in place, and the use of mobile phones and other electronics and machinery, controlled Workplace Health and Safety Plan The site operator must comply with its Workplace Health and Safety Plan Fire Protection The site operator must ensure that appropriate fire protection and firefighting equipment is provided, installed, and maintained, as required by the Building Code of Australia: AS 1603: Automatic Fire Detection and Alarm Systems and AS 1670: Fire Detection, Warning, Control and Intercom Systems give the requirements for fire detection and alarm systems. AS 2444: Portable Fire Extinguishers and Fire Blankets: Selection and Location and the requirements of relevant dangerous goods codes Access Control Because of the hazards associated with chemicals and dangerous goods, access to collection site drop-off and storage areas must be controlled and restricted to those persons who have a legitimate reason to be there Spill Kits Spill kits should be located in high-risk areas. Spill kits need to be clearly labelled and readily accessible. A spill plan is required and staff are required to be trained in managing spills. Dry methods only should be used for spill clean-up. There should be no water clean-up, and discharge to stormwater must be prevented Safety and First Aid Equipment Showers and Eyewash Stations Emergency eyewash and shower equipment should be located within easy access of the site. Eyewash and shower equipment should comply with AS 4775: Emergency Eyewash and Shower and must be maintained and tested on a regular basis. 5

6 Safety Equipment The site operator must ensure that appropriate PPE for chemical and hazardous material (HAZMAT) protection, such as hard hats, safety glasses and other eye protection, overalls, gloves, chemical splash suits, masks and boots, is kept at the site and is easily accessible. Lockers for equipment such as protective clothing, gloves and self-contained breathing apparatus should be provided for staff operating within the site. PPE must be provided by the site operator and replaced when necessary. AS/NZS 1336:1997: Recommended Practices for Occupational Eye Protection gives the requirements for the selection of the correct type of eyewear. First Aid Kit A suitable, fully-stocked and easily accessible first aid kit should be located within the site or within easy access of it Risk Management The site operator shall manage the site and be responsible for the collection activities and ongoing risk assessment management of their site. A site risk management plan, based on or similar in nature to the process outlined in Section 3, should be prepared for each collection site. The risk management plan should identify hazards, risk level and controls to effectively manage risks to public, site staff and the environment Quality Requirements The site operator will provide a professional service that meets all relevant legislation and regulations Compliance Requirements In delivery of the required services, the site operator will be required to comply with relevant legislation and act in accordance with best practice safety systems. 6. Environment Management Systems 1.1. Licences and Permits The site operator must obtain, maintain and comply with all permits and licences required under the Environmental Protection, Workplace Health and Safety and Dangerous Goods legislation, associated regulations of those acts and any other relevant legislation which may be necessary to legally perform the services. In particular, the site operator must maintain a scheduled premises licence under the Environment Protection Act to store, treat or dispose of the waste paint Legislation The site operator must comply with all environmental legislation Environmental Management Plan The site operator must comply with its Environmental Management Plan Incident Reporting The site operator must maintain appropriate records of incidents and dangerous occurrences in accordance with the Workplace Health and Safety Act and the Workplace Health and Safety (Incident Notification) regulations connected with the PBL program or any licensing breaches, including environmental breaches. 7. Collection Site Requirements 1.1. Design and Layout Collection sites should be compliant with the relevant laws and codes and constructed in accordance with any development consents and applications. 6

7 The site layout, signage, storage control measures and staff interaction should work together to ensure that customers are welcomed, clearly understand what architectural and decorative paints they can drop off at the site and where they should do so, and clearly understand where they can take non-eligible waste paint that is not accepted at the site. The site layout should support the safe and smooth flow of traffic through the site, minimise customer waiting times, reduce the likelihood of congestion and provide the minimum possible distances that customers need to carry eligible waste paint they are dropping off at the site. It should also minimise interactions between pedestrian and vehicle traffic. The site should provide sufficient space for truck and forklift movements, including allowance for turning circles. The site should have enough room to safely and easily move full receptacles into a storage area and empty replacement receptacles into a dropoff area. It should also allow sufficient area for the loading of full storage receptacles for transport. The site should demarcate and create a minimum distance, or 'no-go' zone, between forklifts and pedestrians. If a collection site is to be established at a works depot or other similar site where it is not desirable to allow customer access, consideration could be given to providing a drop-off area. In such a situation the site layout must ensure that storage areas can be secured out of hours. Collection sites should ensure that waste streams are segregated and the potential for cross contamination is minimised. Clear signage is required to indicate which waste paints can be accepted in each storage receptacle. All waste paint should be collected at a single point. It is also highly preferable to have separate water and solvent-based receptacles if sufficient space is available at the collection site. The site design must include measures to prevent discharge of any waste products to stormwater. Discharges to sewer must be within the limits stipulated by the local sewer regulator or utility Signage Signage including opening times and the Paintback logo should be placed on the exterior of the site, or as agreed with PBL. Large format signage that clearly indicates with pictures and text whether a receptacle is for water or solvent-based paint should be installed above each drop-off area Staffing While dedicated full-time supervision of the waste paint collection area may not be necessary or available, it is expected that it would be located within a site where adequate overall supervision is available by appropriately qualified and trained staff. Only trained staff should be permitted to manage the acceptance procedure and have access to non-public storage areas where waste paint may be kept. 8. Acceptance, Storage and Collection Procedures 1.1. Acceptance The site operator must prepare a risk management plan for the drop-off and storage area covering design and operations, and comply with the placarding signage requirements. Sites are to be operated so that the weight of eligible waste paint held on-site remains under manifest quantities in accordance with applicable regulations and standards. The collection site should also be designed and operated not to exceed any thresholds for waste storage. The maximum permitted volume of waste paint per customer per visit shall be 100 litres of liquid in total, stowed in containers of no more than 20 litres in volume. There should not be any on-site decanting of waste paint. 7

8 8.5. Storage All core eligible waste paint delivered to the site should be contained by placement in storage receptacles that are to be provided by the collection contractor. Storage receptacles are to be appropriate to the class of material being stored and transported. Eligible waste paint accepted should be stored in its original packaging as brought in by the customer and neatly stacked into the storage receptacles. This will enable the receptacles to be collected for recycling without the need for repacking. Customers must wrap any leaking containers in a plastic bag before removing them from their vehicles. Leaking containers should be left in the plastic bags and then placed in the appropriate receptacle. The number of storage receptacles must be controlled to limit the total volume of eligible waste paint held on-site. This will minimise risks and may remove any need for licence amendments. The customer will be required to separate water and solvent-based paints by placing them in separate storage receptacles where available. If the customer is unsure of paint type, the waste paint should be placed in the solvent-based waste paint receptacle. Safety cabinets for the storage of unsolicited by-catch, such as toxics, reactives and inflammables, should be available. The safety cabinets must meet applicable Australian standards and regulations, and incompatible materials must be separated. It is recommended that these safety cabinets be kept in a separate area out of sight from the main drop-off area to discourage the delivery of non-target eligible waste paint. If a collection site does not have appropriate by-catch safety cabinets, it should not be accepted at the site. The customer should retain possession of the by-catch and properly dispose of it through an alternative appropriately licensed site Collection Placard and manifest quantities for eligible waste paint to be stored at collection sites are shown in the table below. The classifications of eligible waste paints under the Australian Dangerous Goods Code (ADG) and the UN Globally Harmonised System of Classification and Labelling of Chemicals (GHS) are also shown. Placard and Manifest Quantities for Eligible Waste Paint Stored at Collection Sites Material ADG Class GHS Placard Quantity Manifest Quantity Paint Water-Based None None No limit No limit 3 Flammable Liquid: Flammable Liquid: Paint Solvent-Based Packing Group II Category L 2,500 L Packing Group III Category 3 1,000 L 10,000 L 9. Audits PBL may, at its own discretion and at its own cost, audit a collection site, to verify any aspect of the operation, design, record keeping and storage procedures at the site. The audit will consider areas identified in the Collection Site Assessment Tool (refer to Attachment B). If an audit has made findings requiring rectification, which are accepted by the site operator, the site operator must undertake remedial action within the required time stated in the audit report. Rectification shall be at the respective party's own cost. 8

9 10. Attachment A Architectural and Decorative Waste Paint Classifications Product Covered by Program Product not Covered by Program Interior and exterior architectural paint Deck coatings and floor paints Primers, undercoats and sealers Stains and shellacs Varnishes and urethanes (single component) Wood coatings Packaging Industrial maintenance coatings Original equipment manufacturer (e.g. car manufacturing) and industrial surface coating (shop application) paints and finishes Aerosol paints Automotive paints Anti-fouling coatings Melamine, metal and rust preventative Caulking compounds, epoxies, glues or adhesives Colourants and tints Resins Paint thinners, mineral spirits or solvents Paint additives Roof patch or repair Tar-based or bitumen-based products Two-component coatings Traffic paints Texture coatings Bagged renders Isocyanates Metal coatings Paint washings 9

10 11. Attachment B Collection Site Assessment Tool Site Address Shire/Council Site Contact Date of Assessment Assessed By Element Criteria Question Management System Is a site-specific Risk Management Plan available? Management System Are the names and positions of staff with specific environment, health and safety responsibilities clearly documented? Risk Control Are adequate warning signs displayed (e.g. speed limit, no smoking)? Manual Handling Are manual handling risks identified and controls defined for activities undertaken (e.g. container size limits)? Are the risk controls adequately implemented? Risk Control Are staff wearing adequate PPE (e.g. safety vests)? Public Access & Security Is the site secured from unauthorised access? Information, Instruction & Training Information, Instruction & Training Traffic Management Traffic Management Are staff, including any new staff, inducted and trained? Have they been made aware of site-specific HSE plans? Is there a defined process to inform staff subsequent to any review and changes to risk controls? Is a Traffic Management Plan prepared and implemented (evidence of risk controls such as Reversing camera, line marking, bollards, speed humps and speed restriction signs)? Is there a designated safe driver zone identified for loading and unloading operations? Are public excluded from areas where powered mobile plant operates? Supervision Is there adequate supervision of contractor and public activities (e.g. waste transporter)? Common Areas & Public Liability Are loading and storage areas kept clear at all times? Are there any other damaged items in common areas that could pose a public liability risk? ENV Waste Storage Are there clear signs to promote waste disposal in correct bins? Assessment Findings Action Required 10

11 ENV Spill Control Are spill kits and drain blockers provided on-site at strategic locations? ENV Stormwater Are waste storage areas located undercover and away from stormwater drains? ENV Stormwater Is there appropriate bunding and management of wind-blown litter? ENV Land Contamination Is there any evidence of staining or spills on-site? ENV Land Contamination Is there a procedure for dealing with contamination received? DG&HS DG&HS DG&HS CON Risk Management Interaction with other substances Placards Site Condition Have adequate controls been implemented for handling and storage of dangerous goods and hazardous substances? Is there a process for segregating incompatible dangerous goods (e.g. gas cylinders in cages, suitable secondary containment for liquid wastes such as paint)? Are appropriate placards displayed, where placarding quantities are exceeded (e.g. outer warning placard, class labels)? Is a manned gatehouse provided with trained staff to promote the household waste collection service and filter known target eligible waste paint? CON Signage Is adequate signage, including safety signs and product signage, displayed in strategic locations? CON Training Has refresher training been provided to staff relating to the program? Were staff interviewed able to provide information relating to the program? EMP Emergency Contacts Is there an emergency manual available with names and phone numbers of emergency contacts? EMP Evacuation Drawing Are evacuation diagrams showing the emergency assembly locations displayed? EMP Emergency Plan Does the emergency plan consider events such as spills, fire and flooding? EMP First Aid Is there a trained first aider on-site? Is their training current? EMP First Aid Are appropriate kits provided for managing emergencies (e.g. first aid)? Are these kits maintained? EMP Firefighting Is there manual firefighting equipment provided? Has the equipment been appropriately maintained? Key: EMP Emergency Preparedness Workplace Health and Safety DG&HS ENV Environment CON Contractual Dangerous Goods and Hazardous Substances 11