ISRI has greatly expanded its safety efforts over the past three decades as ISRI members, leaders, and staff have worked to make the safety of scrapyard employees and visitors the keystone of recycling operations.
By Kent Kiser
Recycling can be hazardous work, which is why safety is so critical to the industry. Mobile equipment, processing machinery, vehicles, flying or falling scrap, fire, and chemicals are just some of the many potential hazards that place recycling employees and visitors at risk of injury or death. Occupational fatality data from the Bureau of Labor Statistics show that from 2000 to 2015, an average of 22 people have died each year while working in the wholesale scrap trade.
That statistic is one reason why safety is the core value for ISRI and its member companies. As ISRI President Robin Wiener wrote in Scrap in 2012, “Safety is the most important issue for our industry. Yes, other issues are essential to the success and long-term viability of our business, but none is as important as making sure every employee goes home uninjured every night.” In keeping with that philosophy, ISRI has expanded its safety staff, programs, services, and resources significantly in its 30-year history, pursuing an aggressive safety evolution that continues today.
Stepping Up on Safety
From the industry’s start, recyclers had to be safety-minded due to the industrial, equipment-intensive nature of the business. ISRI’s predecessor trade associations—the Institute of Scrap Iron and Steel and the National Association of Recycling Industries—offered some support, but the earliest association-related safety education efforts depended solely on member volunteers, who would occasionally organize and present safety training workshops or provide other support.
The industry stepped up its focus on safety following the passage of the Occupational Safety and Health Act in 1970 and the formation of the Occupational Safety and Health Administration in 1971. Although OSHA’s requirements imposed a host of new responsibilities on employers, “in the long run its provisions will be a benefit to all,” Scrap Age Editor and Publisher M.D. Oberman wrote in 1971. “Increased attention to safety will result in fewer serious, lost-time accidents and lower insurance rates. These, of course, can only result in increased profitability and we urge members of the scrap industry to fully participate in the new emphasis on increased occupational safety and health.”
In the OSHA era of the 1970s and 1980s, ISIS and NARI dedicated more time and resources to safety, in part by forming safety committees and hiring staff to address risk management issues. When ISIS and NARI merged in 1987 to form ISRI, the new association began life with a full-time director of risk management. ISRI quickly made its focus on safety clear through articles in its magazine, Scrap—with titles such as “Making Your Safety Program Work” in 1988 and “Dispelling the Myths: A Case Study in Developing Safety Programs” in 1989—and by offering safety forms and other resources to help members establish effective safety programs.
Although Superfund and other high-stakes legal and regulatory battles claimed the lion’s share of ISRI’s attention and funding throughout the 1990s, ISRI still worked to prevent injuries and fatalities in scrap operations. In 1993, for instance, the association launched its Safety & Loss Prevention newsletter and published its Safety Reference Manual, which offered guidance on equipment, procedures, materials, buildings and grounds, safety and human resource programs, and OSHA compliance.
When David “Cap” Grossman of Grossman Iron & Steel Co. (St. Louis) served as ISRI president from 1994 to 1996, he made safety a centerpiece of his term. He traces his dedication to safety to 1976, when a young mechanic in his company died in an equipment accident. Grossman was on site that day, and the episode left an indelible impression on him. “It’s imperative for us to do everything in our power to keep our people safe and healthy—it’s intolerable if we don’t,” he said in a 1994 interview. In his view, recyclers have “more direct control over the elements of effective plant safety programs than almost any other aspect of our businesses,” he said. “On a daily basis we have the opportunity to make safety our top priority and to protect our employees better than we ever have in the past.”
Throughout Grossman’s tenure and since then, ISRI has educated members about federal safety requirements and emerging safety threats—such as the growing presence of air bags in the scrap stream—while providing safety guidance from its professional safety staff and through newsletters and articles. Recognizing the need for bilingual safety education, in 1995 ISRI revamped its newsletters, launching the new Working Safe and Smart publication in English and Spanish.
Safety also figured prominently in the “Decision 2000” strategic planning meeting of about 60 ISRI members and staff in 1997. The meeting attendees brainstormed ways to help members improve their safety performance, and ISRI received from the meeting a clear mandate to expand its safety offerings. By 1999, it had done just that through new programs such as its “Train the Trainer” safety workshops, offered free to ISRI chapters. The goal, Wiener said at the time, was to make ISRI “your one-stop shop for the most up-to-date and practical industry-specific safety information.” The association also incorporated more safety content into some of its events, such as the annual shredder maintenance seminar—which included video reenactments of safety incidents—and the operations management roundtable.
Even during the height of the industry’s Superfund battle in 1999, ISRI’s president at the time—Shelley Padnos of Louis Padnos Iron & Metal Co. (Holland, Mich.)—wouldn’t let recyclers overlook safety. “Among all the pressures that currently overwhelm our industry—from quality to financing to Superfund liability to the state of the markets—it’s up to each of us to ensure that safety doesn’t get lost in the shuffle,” she wrote. “Professional scrap processors adopt safety as a core value in their company culture. From the top level of management, they make a commitment to dedicate the time, energy, and resources necessary to implement safety programs that educate and influence the behavior of their employees.”
New Day, New Choices
The new millennium brought new challenges in the form of stricter OSHA oversight. For instance, in 2003 a new OSHA program targeted high-hazard work sites for unannounced safety and health inspections. The industry also experienced several years of poor safety results, with 21 fatalities in 2003 and 29 in 2004. “I was terribly afraid our industry would be put on some sort of OSHA watch list because of our terrible performance,” says Joel Denbo of Tennessee Valley Recycling (Decatur, Ala.), who served as ISRI chair from 2004 to 2006. “I was firmly convinced our members could not withstand the scrutiny that would be foisted upon them. It would have been a catastrophe.”
In response, ISRI embarked on an aggressive new safety program in February 2005. “My idea,” Denbo recalls, “was to ramp up the association’s safety efforts to where we could take the lowest common denominator among our members and give them the assistance to truly be proficient in safety.” ISRI launched its new safety push under the ISRI Safety brand, with a new logo bearing the tagline “New Day. New Choices.” Leading the effort was John Gilstrap, who joined ISRI as the new director of safety in 2004. The program’s centerpiece was ISRI Safety Consulting Services, a fixed-cost program that allowed ISRI members to bring an experienced safety consultant into their facilities at a fraction of what it would cost to hire consultants on their own.
To further spread the safety message, ISRI produced a series of posters that used dramatic images and messaging to remind workers about the importance of safety gear and safe behavior. It also released DVDs on the safety concerns of common scrapyard activities such as torchcutting, crane operation, fire prevention and response, and managing visitors and customers. A new publication—Monthly Safety Meeting—aimed to help recycling supervisors run informative, effective monthly safety meetings. ISRI stepped up its safety training options, offering a course that provided two-day, 10-hour OSHA safety training specific to the recycling industry, and it expanded the safety content in other events, such as its 2005 Operations Forum and 2005 annual convention. The latter offered a series of four safety workshops; individuals who attended all four could earn an ISRI Safety certificate.
2005 also saw the formation of the ISRI National Safety Committee (later renamed the ISRI Safety and Environmental Council), which held its inaugural meeting in October 2005 in Rosemont, Ill. The event attracted 80 safety professionals, who selected Joe Bateman of Mervis Industries (Danville, Ill.) as the group’s first chair. “If there was common agreement on any single point,” Gilstrap wrote in Scrap after the meeting, “it was on the belief that our business need not be inherently dangerous.” In Grossman’s view, the creation of ISEC “is one of the best things we’ve done as an industry—offering a forum for our safety professionals to get together and make their companies better.” Two-time ISEC Chair Jerry Sjogren of E.L. Harvey & Sons (Westborough, Mass.) agrees. “Getting safety people together from across the country has been a powerful thing,” he says. “We’ve educated, mentored, and networked with hundreds of people. I can tell you that numerous companies have cut their teeth in safety programs from those efforts.”
A key component of ISRI’s revamped safety efforts was a safety pledge that asked members to operate “Safely, or Not at All.” That pledge was “a statement of basic values—a commitment to treat employees and customers as human beings and not merely as revenue streams,” Gilstrap explained. ISRI would provide certain safety services, such as the 10-hour training course, only to member companies that signed the pledge. In the first six months after ISRI introduced the pledge, about one-third of its 1,400 member companies had signed it.
To act on the desire for ISRI to provide on-site safety training directly to members—to get ISRI “boots on the ground and get staff out there in the field with our members,” as Grossman puts it—ISRI hired its first director of safety outreach, Barney Boynton, in late 2005. By 2007, Boynton was spending much of his time visiting members to conduct ISRI’s Scrap Safety Blueprint program, which used a scorecard with 20 key safety elements to evaluate the state of a recycler’s safety program. ISRI continued to expand its safety staff—and broaden its safety-training scope—in 2007 with the addition of a transportation safety and training manager. “It’s really nice to have an outside set of eyes watch what you do because sometimes you can’t see the forest for the trees,” Sjogren says. “You don’t see things because you’re looking at them every day.”
Throughout ISRI’s safety evolution, its national leaders have used their high-profile positions to promote safety as the industry’s core value and urge members to continually strive for higher safety performance. As Denbo asserted at the end of his term as ISRI chair in early 2006, “Safety—successful safety—is a culture, not a procedure. The responsibility lies with everyone in your organization. In short, safety must be your new top priority. You must spend whatever it takes in both time and money to ensure success.” When Frank Cozzi of Cozzi Enterprises (Burr Ridge, Ill.) took the reins as ISRI chair in 2006, he named safety a key focus of his administration and pledged to include a safety message in each of his 12 columns in Scrap during his tenure.
Despite ISRI’s significant efforts to improve the industry’s safety record, scrap recyclers continued to struggle with injuries and fatalities. The regulatory scrutiny also continued to increase, with OSHA naming recycling an at-risk industry in its National Emphasis Program on Combustible Dust Explosions in 2008 and stepping up enforcement of its lead standards. Against those headwinds, ISRI created additional safety resources, releasing in 2008 a new poster on the identification and handling of radioactive materials in the scrap stream and offering a multifaceted transportation safety program. That program included ISRI’s Transportation Safety Manual, a driver’s handbook, a weekly For Your Driving e-newsletter, driver ride-along assessments performed by ISRI’s transportation safety director, and a series of “Two-Minute Drill” online videos, in which a fictional driver named “Dave” relays a transportation safety message. This period also saw ISRI start developing best management safety practices—later renamed recommended industry safety practices—on topics such as employee training, pulleys/shafts/flywheels/belts, opening roll-off container doors, and conveyors.
Throughout this time, however, the industry continued to experience a high rate of injuries and fatalities—and steep insurance losses. By 2011, ISRI leaders were frustrated that not enough member companies were taking advantage of the association’s safety benefits. “Part of the problem is we have more than 1,000 members with processing operations, but less than 30 percent of them have taken advantage of ISRI’s safety services,” Wiener said in Scrap in 2011. As she explained later that year, it was imperative for the industry to improve its safety performance. “Unless and until we chart a new course,” she said, “OSHA will only intensify its focus on our industry, insurance rates will skyrocket when the insurance market hardens, and our loss history will eclipse much of the good our industry does for the environment and the economy.”
Faced with such challenges, ISRI did some soul-searching. “The truth is that we—ISRI’s staff and volunteer leaders—don’t know what more we can do to move the needle on [safety] in our industry,” Wiener said in 2013. Then-ISRI Chair Jerry Simms of Atlas Metal & Iron Corp. (Denver) was even blunter, stating that “the lack of commitment to safety by many CEOs, officers, and other senior managers in our industry is nothing short of deplorable. This must be exposed for what it often is—abject apathy. The harsh truth is that our industry is becoming deadlier, not safer.” In his view, it was the industry’s ethical and moral responsibility to reverse its unsafe course. While he excoriated the industry for its “unconscionable” safety record, he offered the optimistic note that “it also can be changed.”
As a step toward that end, ISRI added a second safety outreach director to its staff in early 2013. Also, Grossman and longtime ISRI member Peter Kramer of The Greenfield Recycling Co. (Greenfield, Mass.) heard Simms’ call for change and took action. They organized a professionally facilitated safety summit in May 2013 to consider ways to change the industry’s safety culture. Attendees addressed topics such as elements of an effective and sustainable safety program; aligning the interests of top management, middle management, and hourly workers; how ISRI could transform safety outliers into enterprises that are committed to safety; and the challenges recyclers face regarding OSHA. To sustain the momentum from the summit, Simms assembled a Safety Working Group with the charge of submitting a report on its recommendations to the ISRI board in 2014.
When Doug Kramer of Kramer Metals (Los Angeles) became ISRI chair in April 2014, he affirmed his resolve to take the industry to the next safety level, calling safety the industry’s “most important core value.” Echoing President John F. Kennedy’s speech about America’s moon-landing dream in the 1960s, Kramer said recyclers “must choose to be safe and operate responsibly, not because it’s easy, but because it’s right, because that challenge is one we are willing to accept, unwilling to postpone, and determined to meet. To do so, we must be bold.”
One bold move—an offshoot of the Safety Working Group’s discussions—was the creation of the Circle of Safety Excellence™ program in July 2014. “It’s the group of companies that commits to implementing solid safety programs and sharing injury and illness data that will allow members to compare themselves with their peers without the statistical weight of those who are less committed,” Gilstrap explained. The COSE program was the result of the industry’s desire to create a “safety movement” in the recycling industry, Kramer said, calling the program “simple, stringent, and functional” while expressing confidence it would “move us forward, both within the industry and outside the industry with OSHA, DOT, and insurance carriers.” ISRI and its members spent the second half of 2014 working out the program’s details. The COSE program officially debuted in 2015 with nearly 60 charter member companies.
Before 2014 ended, ISRI made another bold move by establishing a Safety Stand-Down Day for the industry, holding the first one that October. The industry had experienced a spike in deaths in the first three quarters that year, and ISRI viewed the stand-down day as a way to reaffirm safety awareness. ISRI asked member companies to halt operations for at least one hour per shift that day to conduct additional safety training and to reinforce that safety is their No. 1 core value and that employees are their most valuable asset. ISRI sent member companies information on 11 recent scrap industry fatalities as well as five safety guides related to the leading causes of those fatalities. (ISRI has continued to hold an annual Safety Stand-Down Day, moving the observation date to June. See how companies observed it this year beginning on page 34.)
Yet another bold move came in October 2015, when ISRI signed a formal two-year alliance with OSHA. “To many recyclers, ISRI and OSHA might appear to be an odd couple,” Kramer said at the time, “but with ISRI’s renewed focus on safety, our new partnership with OSHA makes perfect sense.” Under the agreement, ISRI agreed to work with OSHA to provide members with information, guidance, training, and other resources to protect the health and safety of recycling industry workers. “With OSHA’s support, ISRI will be able to provide even greater resources for our member companies to ensure our workers return home safely to their families every night,” Kramer said.
ISRI started seeing some positive trends when comparing the losses of ISRI member companies in the RecycleGuard® insurance program with the losses of nonmember recyclers in the program. According to RecycleGuard data in 2015, ISRI member operations were “significantly safer than nonmember operations, as measured by their losses as a percentage of their premiums,” Wiener said. Those results were a marked change from the past, when the same reports showed ISRI members’ loss rates to be the same, or worse in some years, than nonmembers’ rates. “But for the last three years [from 2012 to 2014], ISRI members’ rates have been significantly better, and the overall loss rate has declined year after year,” Wiener said. “This tells us ISRI’s safety message and [members’] safety efforts are making a difference.”
Buoyed by that positive trend, ISRI made several additions to its safety efforts, including a training program on material handler safety in 2014. It subsequently received a $140,000 grant from OSHA in 2016 to develop and deliver a new training program on hazard recognition and mitigation in recycling operations. Recyclers—both members and nonmembers—can receive this training free at their facilities if they ensure at least 20 attendees. (To schedule training, contact Elly Torabian at 202/662-8511 or firstname.lastname@example.org. To review ISRI’s numerous other safety programs, services, and resources, visit isrisafety.org.)
Despite such progress, Wiener conceded “there’s more work to be done, a reality that even the safest operators in our industry recognize.” Looking back on ISRI’s safety work, Grossman says, “I’m sad our efforts haven’t succeeded better, but I know lives have been saved because people joined ISEC or heard one safety idea at a meeting.” Sjogren has a similar realistic-but-optimistic view. “I’ve seen enormous change over the years in the safety mentality and attitude in the industry, and I continue to see that change and grow,” he says. “That’s exciting, and I think that has to make a difference at some point.” Although Denbo adds that “the progress has been painfully slow, it hasn’t been for lack of trying. I wish we were further along, but we are where we are, and we’re in a lot better shape than we used to be.”
In the end, ISRI’s safety program—like the pursuit of safety itself—is ongoing, a journey rather than a destination. “Like most things in life, building a successful safety program begins and ends with commitment,” wrote ISRI Chair George Adams of SA Recycling (Orange, Calif.) in 2009. “Safety cannot be No. 1 on the agenda just one day a month or one day a week. It cannot just be left up to the ‘safety guy.’ A safe recycling operation requires commitment to safety 24 hours a day, seven days a week, from the CEO to the bottom of the pyramid. The process isn’t easy, but the journey is a valuable one.”
Kent Kiser is publisher of Scrap and assistant vice president of industry communications for ISRI.