Public deposition of self-hauled waste to a landfill is the oldest form of coordinated waste deposition. For more than a century, the risks associated with having the public on landfills has been regarded as an OH&S operational issue to be avoided.
With heavy machinery, hazardous waste materials and expansive dynamic work fronts that are difficult to contain, these industrial zones are not a place for the general public. In comparable high-risk environments such as mining and construction, the general public, without competency verification and inductions, are restricted from site access due to the associated high risk with severe consequences.
In waste, the safety bar appears lower than other industry sectors, particularly with reference to visitors. While many landfill sites have implemented Public Waste Transfer Stations (PWTS), there are still hundreds of sites across Australia that invite the public to dispose of their waste directly to the landfill; this is an invitation for disaster. Why does this still happen?
Operational priorities
For most sites, it’s simply about operational priorities. Waste volumes that present themselves daily at a landfill from commercial collection services draw the most attention and resources. In contrast, public deposition represents a relatively small part of the volumes; it is instead a service that is required to be provided for public convenience, political expediency, and to avoid illegal dumping.
The primary regulatory driver and source of funding support for councils operational demands are the Environmental Protection Agencies (EPAs). EPA’s naturally focuses on environmental protection, which for landfills means focusing on activities such as cell construction, mass tracking and leachate management. Waste operators are constantly engaging with their EPA’s, with routine inspections, reporting, approvals and levy reconciliations.
The EPA’s ability and willingness to levy substantial fines and notices for noncompliance also contributes to EPA priorities dominating operator priorities. In contrast, safety regulators tend to engage in response to reported incidents. If safety incidents are underreported, the safety regulator has no trigger for routine engagement. Safety agencies don’t typically provide capital support for improvements in safety and are more likely to issue improvement notices than fines. This often leads to issues of visitor safety falling down the operational priority list.
Capital scarcity
Volumetric collection, deposition and compaction rates are the focus of most capital planning for landfills. Building new cells, installing Weighbridges and procuring waste handling machinery are examples of large capital spendings tied to servicing EPA Licence obligations.
Establishing a traditional civil constructed PWTS can demand millions of dollars in funding and years of planning. For many waste managers, choosing to put scarce capital into a PWTS is something they should do, but investing in a new cell is something they must do. This at its core, is a decision to prioritise the environment over human safety. What are the risks?
Legal
Operators have a legal “Duty of Care” to all visitors and staff who enter and or work on their site. For harm to occur to a person where the risks are well known, and mitigation measures have not been taken, creates criminal & civil liabilities. These liabilities can be applied to owners and their staff, potentially resulting in convictions with significant financial penalties and jail time.
Safety: machine vs pedestrian
Machines on pedestrians are a major cause of fatalities and serious injury in waste, with recent fatalities on several Australian sites. Safety authorities across the country provide detailed requirements as to how pedestrians should be protected from machines, trucks and vehicles. These requirements include barriers, designated walk/roadways, competency verifications, inductions and high vis PPE as baseline standards for all industries.
When it comes to landfills with uninducted public on site, these minimum standards tend to fall away. These sites rely heavily on operational procedures and operator awareness, the least effective mitigation measures, as those most at risk, the public, are not trained in the required procedures. To apply procedural controls, intensive, focused supervision of the public is needed.
Few waste sites have the staff to fully supervise the public across the broad deposition areas.
Fires, hazardous and toxic waste
Landfills by their nature, receive the waste that we can’t safely or effectively reprocess. The public are exposed to this potentially deadly cocktail of hazards, including sharps, toxic materials, chemicals, gases, combustibles, and ignition sources like batteries. Visitors can initiate fires with their depositions or by simply smoking while on site. Uniformed public on foot, often with insufficient PPE, who are often tempted to fossick or end up in incorrect locations on a site, are at much higher risk than aware staff.
Compliance
EPA Licences prescribe a long list of materials that can not be received in a landfill. These restricted items are defined in Site Licences and Acts of governments. The obligation to comply with these conditions is on the Landfill operator. When an operator invites the public onto a landfill to deposit waste, they are permitting the uninformed visitors to determine what they receive.
Any problem waste items deposited by the public at a landfill becomes an operator’s breach of their licence. The consequence for the operator can be serious and costly, fires can be triggered, deposited Asbestos or other chemicals can create exposure risks with costly remediation response, and licence non-conformances can lead to fines or facility closures.
Avoiding disaster
To avoid the inevitable disaster, facilities must act to ensure the public’s safety and mitigate the non-compliance risks. This means getting the public off the landfills and implementing PWTS. The major barrier to acting quickly for most councils is often the costs and time to establish traditional PWTS.
Several sites are addressing the issue by rolling out new modular PWTS technologies that are safer, quicker and vastly more cost-effective. Gunnadah Shire Council in NSW recently won the Waste Innovation Award- Regional for its new PWTS established to get the public off its landfill. Using the LBin System was less than 20 per cent of the cost of the alternative traditional Sawtooth.
The savings avoid the need to compromise on other capital investments in cell construction, plant and equipment. Similarly, other sites like Hawkesbury in NSW and Harvey in Western Australia have established similar systems for the same reasons. Uralla, Lithgow, Orange, and Forbes councils in NSW have all secured EPA Landfill Consolidation and Environmental Improvements Grants to build LBin PWTS for less than the cost to design traditional civil constructed PWTS.
By implementing these new systems, the public is now away from the landfill, contained in one controlled area, physically separated from machines/trucks, on well-defined and sealed routes. Containing the public in a common area has made it both easier to do detailed load inspections and monitor those on-site. His overall approach reduces the amount of staff needed, further amplified by the introduction of CCTV within this common area.
PayBack
The low capital cost and time to deploy have made it much easier to fit these facilities into tight capital budgets, and best of all, the improved reuse and recycling recovery has meant that most installations have an ROI of less than 3 years. With low-cost and effective solutions now available to address this century-old problem, continuing to invite the public into landfills should be a disaster for the past.