Workplace Safety¶
Last Updated: February 2026 Target Audience: All Employees, Team Leaders, Operations Manager
This guide covers workplace safety requirements, PPE standards, emergency procedures, and incident reporting for Scott Recycling's facilities. Safety is everyone's responsibility -- every employee must understand and follow these procedures.
Overview¶
Scott Recycling's processing facility handles electronic waste that includes sharp metals, heavy equipment, hazardous materials (lead, mercury, lithium batteries), and industrial machinery (balers, shredders, forklifts). Our safety program is designed to comply with OSHA regulations and protect every employee from workplace injuries and illnesses.
OSHA Requirements for Recycling Facilities¶
The Occupational Safety and Health Administration (OSHA) sets and enforces workplace safety standards. The following OSHA standards are particularly relevant to Scott Recycling's operations:
| OSHA Standard | Topic | Applicability |
|---|---|---|
| 29 CFR 1910.132-138 | Personal Protective Equipment | All employees |
| 29 CFR 1910.147 | Lockout/Tagout (LOTO) | Baler, shredder, conveyor operators and maintenance |
| 29 CFR 1910.178 | Powered Industrial Trucks (Forklifts) | Forklift operators |
| 29 CFR 1910.1200 | Hazard Communication (HazCom) | All employees handling chemicals/hazardous materials |
| 29 CFR 1910.38 | Emergency Action Plans | All employees |
| 29 CFR 1910.39 | Fire Prevention Plans | All employees |
| 29 CFR 1910.157 | Portable Fire Extinguishers | All employees |
| 29 CFR 1910.22-30 | Walking-Working Surfaces | All employees |
| 29 CFR 1910.95 | Occupational Noise Exposure | Employees near balers, shredders, heavy equipment |
| 29 CFR 1910.134 | Respiratory Protection | CRT processing staff, anyone exposed to dust/fumes |
| 29 CFR 1910.151 | Medical and First Aid | All facilities |
| 29 CFR 1904 | Recordkeeping (OSHA 300 Log) | Company-wide |
PPE Requirements by Area and Task¶
PPE Matrix¶
| Area / Task | Steel-Toe Boots | Safety Glasses | Cut-Resistant Gloves | Hard Hat | Hearing Protection | Respirator | Face Shield | Reflective Vest | Other |
|---|---|---|---|---|---|---|---|---|---|
| Warehouse floor (general) | Required | Required | Required | -- | When near heavy equipment | -- | -- | -- | -- |
| CRT handling / processing | Required | -- | Heavy-duty required | -- | -- | N95 minimum (P100 if breaking glass) | Required | -- | Long sleeves required |
| Battery sorting | Required | Required | Required (chemical-resistant for lead-acid) | -- | -- | -- | -- | -- | -- |
| Baler operation | Required | Required | Required | Required | Required | -- | -- | -- | Lockout/tagout training |
| Shredder operation | Required | Required | Required | Required | Required | -- | -- | -- | Lockout/tagout training |
| Forklift operation | Required | Required | -- | Required (in designated areas) | -- | -- | -- | -- | Seatbelt required |
| Loading dock | Required | Required | Required | -- | -- | -- | -- | Required | -- |
| Drivers (on route) | Required | -- | Work gloves | -- | -- | -- | -- | Required | -- |
| Drivers (loading/unloading) | Required | Required | Required | -- | -- | -- | -- | Required | -- |
| Disassembly | Required | Required | Cut-resistant required | -- | -- | -- | -- | -- | -- |
| Toner handling | Required | Required | Nitrile gloves | -- | -- | N95 if cartridge is open/leaking | -- | -- | -- |
PPE Is Not Optional
Wearing the required PPE for your work area is mandatory at all times. Failure to wear proper PPE is a safety violation and will result in corrective action. If your PPE is damaged or does not fit properly, report it to your team leader immediately for replacement.
PPE Inspection and Replacement¶
- Inspect your PPE at the start of every shift
- Replace any PPE that is damaged, worn, or no longer fits properly
- Report PPE needs to your team leader -- do not work without proper protection
- The company provides all required PPE at no cost to employees
Lockout/Tagout (LOTO) Procedures¶
Lockout/Tagout procedures prevent unexpected startup of machines and equipment during maintenance or servicing. LOTO is required for balers, shredders, conveyor systems, and any other equipment with moving parts that could cause injury.
Lockout/Tagout Saves Lives
Never attempt to clear a jam, perform maintenance, or reach into any machine without first completing the full lockout/tagout procedure. Equipment that starts unexpectedly can cause amputations, crush injuries, or death.
Equipment Requiring LOTO¶
| Equipment | Location | Authorized Personnel |
|---|---|---|
| Baler | Warehouse | Trained operators, Maintenance Tech |
| Shredder (hard drive) | Processing area | Hard Drive Team, Maintenance Tech |
| Conveyor system (if applicable) | Sort line | Trained operators, Maintenance Tech |
| Compactor | Loading dock area | Trained operators, Maintenance Tech |
LOTO Procedure (General)¶
- Notify -- Inform all affected employees that the equipment is being locked out
- Shut down -- Turn off the equipment using the normal operating controls
- Isolate -- Disconnect the equipment from all energy sources:
- Electrical: Turn off the breaker/disconnect switch
- Pneumatic: Close and bleed the air supply
- Hydraulic: Relieve hydraulic pressure
- Lock -- Apply your personal padlock to the energy isolation device (breaker, disconnect, valve)
- Tag -- Attach a "DANGER -- DO NOT OPERATE" tag with your name, date, and reason
- Verify -- Attempt to start the equipment to confirm it is de-energized; press the start button (it should not start)
- Perform the work -- Complete the maintenance, clearing, or servicing task
- Remove lock and tag -- Only the person who applied the lock may remove it
- Restart -- Verify all personnel are clear, remove tools, replace guards, then restart
LOTO Rules¶
- One person, one lock -- every employee working on the equipment applies their own lock
- Never remove another person's lock -- only the person who applied a lock may remove it
- If the person who applied the lock is unavailable, the Operations Manager may authorize removal following a documented verification procedure
- Locks and tags are available from the team leader or the lockout station
Fire Safety¶
Fire Prevention¶
- Keep work areas clean and free of clutter -- accumulated debris is fuel for fire
- Store flammable materials (solvents, aerosols) in approved flammable storage cabinets
- Do not block fire exits, fire extinguishers, or sprinkler heads
- Report any damaged wiring, overloaded outlets, or electrical hazards immediately
- No smoking inside the facility or within 25 feet of the building
Fire Extinguisher Types and Locations¶
| Type | Use For | Location |
|---|---|---|
| ABC (dry chemical) | General fires (paper, wood, electrical, flammable liquids) | Throughout the facility (every 75 feet or less) |
| Class D (metal fire) | Lithium battery fires, magnesium | Battery storage area, processing area |
| CO2 | Electrical fires, server room | Server room, electrical panel areas |
Lithium Battery Fires
Standard ABC fire extinguishers will not extinguish a lithium battery fire. Use the Class D extinguisher or sand bucket at the battery storage area. If the fire cannot be contained, evacuate immediately and call 911. Lithium fires produce toxic hydrogen fluoride gas -- do not breathe the fumes.
Fire Extinguisher Operation (PASS Method)¶
- Pull the pin
- Aim the nozzle at the base of the fire (not at the flames)
- Squeeze the handle
- Sweep side to side at the base of the fire
When to Fight a Fire vs. When to Evacuate¶
Fight the fire ONLY if ALL of the following are true:
- The fire is small (no larger than a trash can)
- You have the correct type of extinguisher
- You have a clear exit behind you
- You have been trained on fire extinguisher use
Evacuate IMMEDIATELY if ANY of the following are true:
- The fire is large or spreading rapidly
- You do not have the correct extinguisher
- The room is filling with smoke
- Your exit route may be blocked
- You are not sure you can control the fire
Ergonomics¶
Proper Lifting Technique¶
Lifting Injuries
Back injuries are among the most common workplace injuries in recycling facilities. Improper lifting technique is the leading cause. Follow these steps for every lift.
- Plan the lift -- know where you are going and clear the path
- Stand close to the object with feet shoulder-width apart
- Bend at the knees, not at the waist
- Get a firm grip on the object
- Lift with your legs -- straighten your knees while keeping your back straight
- Keep the load close to your body
- Do not twist -- move your feet to turn
- Set down carefully -- bend at the knees, not the waist
Weight limits:
| Situation | Maximum Weight |
|---|---|
| One person lift | 50 lbs |
| Two person lift | 100 lbs |
| Over 100 lbs | Use mechanical assistance (forklift, hand truck, dolly) |
Workstation Ergonomics¶
For employees at processing stations or desks:
- Position your work at waist height when possible (adjust table height or use a platform)
- Alternate between standing and sitting if your station allows
- Take stretch breaks every hour
- Use anti-fatigue mats at standing workstations
- Keep frequently used tools and materials within arm's reach
Incident Reporting¶
Every workplace incident, injury, illness, or near-miss must be reported immediately. Prompt reporting protects the employee (ensures they get medical attention) and the company (ensures we meet OSHA requirements and can prevent future incidents).
What to Report¶
| Type | Examples | Report To |
|---|---|---|
| Injury | Cut, burn, strain, broken bone, eye injury | Team Leader + Operations Manager |
| Illness | Exposure symptoms, breathing difficulty, skin reaction | Team Leader + Operations Manager |
| Near-miss | Almost got hit by forklift, tripped but didn't fall, equipment malfunction | Team Leader |
| Property damage | Damaged equipment, spill, vehicle accident | Team Leader + Operations Manager |
| Fire or hazmat event | Any fire, chemical spill, battery thermal event | Operations Manager + 911 if needed |
Incident Reporting Procedure¶
- Get medical attention first -- if someone is injured, address the injury before paperwork
- Notify your team leader immediately (or the Operations Manager if the team leader is unavailable)
- Secure the area if the hazard is ongoing (e.g., spill, equipment malfunction)
- Complete an incident report within 24 hours:
- Date, time, and location of the incident
- Names of the injured/involved employees
- Names of witnesses
- Description of what happened (be specific and factual)
- Description of any injuries
- What corrective action was taken or is needed
- Submit the report to the Operations Manager
- Follow up -- the Operations Manager will investigate and implement corrective actions
OSHA Recordkeeping¶
- The Office Manager maintains the OSHA 300 Log (Log of Work-Related Injuries and Illnesses)
- Reportable injuries and illnesses are recorded within 7 calendar days
- The OSHA 300A Summary must be posted February 1 through April 30 each year
- Severe injuries (hospitalization, amputation, loss of an eye) must be reported to OSHA within 24 hours
- Fatalities must be reported to OSHA within 8 hours
Emergency Evacuation Plan¶
Evacuation Triggers¶
Evacuate the building when:
- Fire alarm sounds
- Announcement to evacuate is made
- You see fire or heavy smoke
- Chemical spill that cannot be safely contained
- Structural damage to the building
- Any other event that makes the building unsafe
Evacuation Procedure¶
- Stop work immediately -- shut down equipment if it can be done safely in seconds (do not delay evacuation)
- Leave personal belongings -- do not go back for anything
- Walk (do not run) to the nearest exit
- Close doors behind you (do not lock them)
- Go to the designated assembly point (parking lot area -- location designated by management)
- Report to your team leader for headcount
- Do not re-enter the building until the Operations Manager or emergency services give the all-clear
Assembly Point¶
- The designated assembly point is in the parking lot away from the building
- Team leaders are responsible for taking headcount of their teams
- If someone is missing, report immediately to the Operations Manager or emergency services -- do not re-enter the building to search
Evacuation Drills¶
- Evacuation drills are conducted at least twice per year
- All employees must participate
- Drill results are documented (time to evacuate, headcount accuracy, issues identified)
First Aid¶
First Aid Station¶
- A fully stocked first aid kit is maintained at the main warehouse area
- Additional first aid kits are located at the loading dock and processing area
- First aid kit contents are inspected monthly and restocked as needed
- An AED (Automated External Defibrillator) is located at the main first aid station (if equipped)
First Aid Supplies (Minimum)¶
| Item | Quantity |
|---|---|
| Adhesive bandages (assorted) | 20+ |
| Sterile gauze pads (3x3 and 4x4) | 10+ |
| Adhesive tape | 2 rolls |
| Elastic bandage | 2 |
| Triangular bandage | 2 |
| Antiseptic wipes | 20+ |
| Burn cream | 5 packets |
| Cold packs (instant) | 4 |
| Disposable gloves (nitrile) | 10 pairs |
| Eye wash solution | 1 bottle |
| Scissors | 1 pair |
| Tweezers | 1 pair |
| CPR breathing barrier | 1 |
| First aid guide | 1 |
When to Call 911¶
Call 911 immediately for:
- Unconsciousness
- Difficulty breathing
- Severe bleeding that cannot be controlled
- Suspected broken bones (especially spine, neck, or pelvis)
- Chest pain
- Seizures
- Severe allergic reaction
- Chemical exposure to eyes or skin that does not respond to flushing
- Any situation where you believe the person's life is in danger
Forklift Safety¶
Certification Requirements¶
OSHA Certification Required
Only OSHA-certified forklift operators may operate forklifts at Scott Recycling. Operating a forklift without certification is a serious safety violation and will result in immediate corrective action.
- All forklift operators must complete OSHA-compliant forklift training and pass a practical evaluation
- Certification is specific to the type of forklift being operated
- Re-certification is required every 3 years or sooner if:
- The operator is involved in an accident or near-miss
- The operator is observed operating unsafely
- A different type of forklift is introduced
- Workplace conditions change significantly
Daily Pre-Use Inspection¶
Before operating a forklift at the start of each shift:
- Walk around the forklift -- check for visible damage, leaks, tire condition
- Check fluid levels -- hydraulic fluid, engine oil, coolant, fuel/charge level
- Test controls -- steering, brakes, horn, lights, backup alarm
- Test the mast and forks -- raise, lower, tilt forward and back
- Check the seatbelt -- must be functional and used at all times
- Document the inspection on the daily forklift inspection form
- Report any issues to the team leader -- do not operate a forklift that fails inspection
Forklift Operating Rules¶
- Wear seatbelt at all times while operating the forklift
- Speed limit: walking speed in the warehouse; never exceed 5 mph
- Sound horn at intersections, blind corners, and when approaching pedestrians
- Keep forks low (4-6 inches off the ground) when traveling
- Do not carry passengers -- forklifts are designed for one operator only
- Do not raise or lower loads while moving
- Keep clear of edges -- dock edges, ramps, and elevated surfaces
- Yield to pedestrians at all times
- Never leave a running forklift unattended -- turn off, lower forks, set parking brake
- Do not exceed the rated load capacity -- check the data plate
Pedestrian Safety Around Forklifts¶
For all employees working near forklifts:
- Stay alert -- watch and listen for forklifts
- Make eye contact with the operator before crossing their path
- Never walk under raised forks or loads
- Stay clear of the forklift's turning radius
- Use designated pedestrian walkways where marked
Safety Training Schedule¶
| Training Topic | Frequency | Audience | Duration |
|---|---|---|---|
| New employee safety orientation | At hire | All new employees | 2 hours |
| PPE requirements and use | At hire + annually | All employees | 30 minutes |
| Lockout/tagout | At hire + annually | Equipment operators, maintenance | 1 hour |
| Fire safety and extinguisher use | At hire + annually | All employees | 30 minutes |
| Forklift certification | At hire + every 3 years | Forklift operators | 4-8 hours |
| Hazard communication (HazCom) | At hire + annually | All employees | 30 minutes |
| Emergency evacuation | At hire + drill 2x/year | All employees | 15 minutes |
| Ergonomics and lifting | At hire + annually | Warehouse and processing staff | 30 minutes |
| CRT handling | At hire + annually | CRT processing staff | 30 minutes |
| Battery safety | At hire + annually | All warehouse staff | 30 minutes |
| Incident reporting | At hire + annually | All employees | 15 minutes |
| First aid / CPR / AED (optional) | Voluntary + every 2 years | Designated first aid responders | 4 hours |
All training must be documented with: date, topic, trainer name, attendee names, and attendee signatures.
Questions? Contact your supervisor or refer to the Getting Started guide.