Runners' on waste collection vehicles - Position Paper
This position paper relates to ‘runners’ on waste collection (and recycling) vehicles and provides advice on how SafeWork interprets clause 215(3) of the Work Health and Safety Regulation 2017 (WHS Regulation). This paper also provides advice on the minimum control measures that should be followed when ‘runners’ ride on platforms (steps) at the rear of waste collection vehicles. ‘Runners’ must not ride on the front cabin steps of waste collection vehicles.
Clause 215(3) of the WHS Regulation requires a person conducting a business or undertaking (PCBU) to ensure, so far as is reasonably practicable, that no-one, other than the operator, rides on a vehicle (plant) unless they are provided with a level of protection that is equivalent to that provided to the operator.
Following consultation with the Local Government and Shires Associations of NSW, the Waste Contractors and Recyclers Association of NSW and other industry stakeholders it became apparent that confusion exists regarding the interpretation of clause 215(3). Some stakeholders interpret the clause to mean that a PCBU must provide the same level of protection for everyone who rides on the vehicle – ie the operator and the ‘runners’.
Current industry practice in the waste collection process indicates that up to three people – ie the operator and two ‘runners’ on the back of the vehicle – control the operation of the rear hopper and/or lifters that load waste into the vehicle.
Sub-rule 267 (2) of the Road Rules 2008 (made under the NSW Road Transport (Safety and Traffic Management) Act 1999 ) states that a person in or on a motor vehicle is exempt from wearing a seatbelt if both the following apply:
- the person is engaged in the door-to-door delivery or collection of goods, or in the collection of waste or garbage, and is required to get in or out of the vehicle, or on or off the vehicle, at frequent intervals
- the vehicle is not travelling over 25 kilometres per hour.
Having reviewed clause 215(3) and sub-rule 267 (2), together with industry guidelines, SafeWork has determined (in accordance with section 18 of the Work Health and Safety Act 2011 (WHS Act) that it is not reasonably practicable for PCBUs who operate waste collection vehicles with ‘runners’ to apply clause 215(3) to this type of work activity.
When it is necessary to use ‘runners’ on a waste collection vehicle the PCBU must ensure, so far as reasonably practicable, that no-one is placed at risk of injury or illness. The PCBU must eliminate or minimise the risks.
If a ‘runner’ stands on the rear of a waste collection vehicle, work should be carried out in accordance with safe work procedures. As a minimum, the following safeguards should be implemented:
- rear platforms should have non-slip surfaces and should be at least 400 mm x 300 mm, so that ‘runners’ can stand normally while holding suitable handles. Platforms should have at least 25 mm-high vertical kick plates and should be approximately 400-500 mm above the ground
- ‘runners’ must not alight from the vehicle while it is moving
- ‘runners’ should be able to prevent the bin lifter from operating in the case of emergencies – eg by using an emergency-stop system
- ’runners’ should have access to a buzzer (or two-way radio) that allows them to notify the driver when it is safe to move on to the next pick-up spot
- the driver should be able to alert ‘runners’ when the vehicle is to be reversed or when danger is pending – eg via two-way radio or a rear-sounding horn
- vehicles should be fitted with front and rear-mounted flashing lights to alert other road users and pedestrians
- ‘runners’ should work on the same side of the road, unless a risk assessment indicates it is safe to collect from both sides
- the driver and the ‘runners’ should be competent and trained in safe work practices
- when ‘runners’ are on the rear platforms, the driver should not exceed 25 kilometres per hour – road and traffic conditions should be taken into account
- the distance travelled between pick-up points should be restricted to a geographical collection zone – eg if the distance travelled extends beyond a geographical zone and the vehicle is required to exceed 25 kilometres per hour, ‘the ‘runners’ must travel in the cabin of the vehicle
- personal protective equipment (PPE), such as high-visibility vests, must be provided to the driver and ‘runners’.
To ensure you comply with your legal obligations, refer to the WHS Act, WHS Regulation and the Road Rules 2008. The Code of practice for the collection of domestic waste provides practical advice for those who work in waste collection.
This position paper was prepared by the Acting Manager – Engineering Team and was issued in August 2012. For more information, contact SafeWork on 13 10 50.