The recycling industry is vast, competitive and dynamic. With overseas consuming markets restricting imports of recyclables and an ever-shifting economy affecting the flow of materials, recycling companies have been inclined to get creative with their practices.
Dan Fay, environmental health and safety director of Lafayette, Indiana-based Oscar Winski Co., says while companies may strive to increase efficiency with new technology and processes, he argues that a streamlined safety program is just as crucial to a competitive business model.
One way to establish and implement such a safety program is through the Safety Health Achievement Recognition Program (SHARP) offered by the Occupational Safety and Health Administration (OSHA). SHARP allows businesses of a certain size to receive acknowledgement for safe practices, providing incentives for companies to develop and enhance their safety programs.
OSHA established SHARP in 1982 “to encourage and recognize employers that implement and continuously improve effective safety and health programs at their worksites,” says OSHA spokesperson Kimberly Darby.
Fay says Oscar Winski’s upper management initially was reluctant to participate in SHARP. “You have to convince your management team that this is a good thing” he says, “because people are so programmed to think that OSHA’s the enemy.”
Fay compares OSHA’s services to visiting the doctor’s office: “You don’t go to the doctor after you’re well; you go to the doctor when you’re sick.”
To receive SHARP status, businesses must participate in OSHA’s On-site Consultation Program. Businesses with fewer than 250 onsite employees and fewer than 500 corporatewide employees are eligible to participate in the program, which offers free and confidential services to improve safety programs.
“Consultants from local agencies or universities work with employers to identify workplace hazards, provide advice for compliance with OSHA standards and assist in establishing and improving safety and health programs,” Darby says.
The On-Site Consultation Program is separate from enforcement, she adds. Consultation staff will not issue penalties or citations to participating businesses.
“The consultant will work with [businesses] to evaluate their existing safety and health program, help them determine how to correct any hazards, if necessary, and assist in identifying and developing processes for continuous safety and health program improvement and will nominate them for SHARP recognition once they meet the program requirements,” Darby says.
To receive SHARP status, businesses must participate in OSHA’s On-site Consultation Program.
Achieving SHARP status
Oscar Winski has a variety of operations in different sectors of the recycling industry. Those that have received SHARP status include Lafayette Steel, Riverdale, Illinois; Oscar Winski eRecycling, Lafayette (profiled in the April 2018 issue of Recycling Today); Blue Arrow Trucking, Lafayette; and Lafayette Steel, Indianapolis. Fay says the company is working to achieve SHARP status at Oscar Winski Logistics and at its scrap processing facility, both of which are in Lafayette.
The time it took to be accepted into SHARP varied among each division, he says, explaining that the company’s first SHARP facility, Lafayette Steel in Riverdale, took about a year and half, while Blue Arrow Trucking took less than a year.
When introducing SHARP to the management team, Fay says he presented two options: keep enforcing safety the same way the company always had or implement a program that would streamline safety practices relatively quickly.
Before contacting the SHARP consultation team, Fay says he made sure he had the “fundamentals” down. This includes completing required trainings, getting forms and records in order and disseminating information to all the company’s employees.
“A lot of it is just education and communication and making sure that you’re not missing a boat somewhere,” he says.
Even when a company has mastered the fundamentals, Fay says the consultation team might offer critiques and changes.
He says consultants have critiqued many ideas of which he was proud. For instance, one safety requirement is to keep safety data sheets (SDS) for chemicals used at a facility. He had the idea to create an online SDS database, so the sheets could be pulled more easily.
OSHA said this system was legally sound, but the database held SDS for any chemical that could potentially be used on site. It did not specify which chemicals were actually on site and when they were used. “So it made a lot of sense that, even though I covered it, I could still do it better,” Fay says.
In addition to achieving SHARP status, businesses in the program receive several other benefits. Darby says they include protecting workers from safety and health hazards, increasing morale by involving workers in creating a safe workplace and attracting skilled workers interested in joining a company known for safety.
The SHARP website also notes lower workers’ compensation insurance premiums and improved worker retention as program benefits.
Darby says SHARP worksites are granted an exemption from OSHA programmed inspections for up to two years, with subsequent renewals for up to three years.
Not only are Oscar Winski’s injury rates below half of the industry average, Fay says, but he also has seen a change in employees after the company joined SHARP.
“It made an impact with the employees,” he says. “When they were able to see that the company was more involved, they got more involved.”
Fay says he can see a difference between his SHARP sites and his non-SHARP sites. With one Lafayette Steel site that is not yet a SHARP facility and two that are, “I can tell you that I have to spend so much more time at the not-SHARP site than I do the other two.”
He adds, “Our OSHA rate was good to begin with before the program, but it just gets better. And then, of course, that helps your workmen’s comp and insurance and everything else.”
While SHARP participation can result in lower insurance premiums, Fay says money isn’t always the most important thing when running a facility. Instead, as its website notes, “Oscar Winski has a special reverence for every individual with a stake in our commitment to safety.”