Trade Waste Safety Manual

Trade

Waste

Safety

Manual

Introduction

INTRODUCTION2

To All Trade Waste Companies:

The mission of the City of New York Business Integrity Com-

mission (BIC) has expanded since its creation 22 years ago. While

our primary mission continues to be to remove and keep out any

form of corruption from the industries we regulate, our focus has

expanded to include safety in the trade waste industry.

It is my pleasure to release the “Trade Waste Safety Manual,”

a guide that every private carting company in the city, both large and

small, can use as a starting point to develop its own robust safety

program. To provide you with some context for the creation of the

manual, BIC is an integral member of the City’s Commercial Waste

Zone Advisory Board and the Mayor’s Vision Zero Task Force. In

September 2016, the New York City Department of Sanitation (DSNY)

and BIC brought together a diverse group of stakeholders to begin

the conversation about developing a commercial waste zone collec-

tion plan. During that meeting, one thing everyone agreed on was

that making the trade waste industry safer for all New Yorkers was an

effort that could and should begin immediately. To that end, BIC and

DSNY formed the Commercial Waste Zone Collection Safety Working

Group (Working Group), and invited everyone from that initial stake-

holder meeting to participate. In addition to members of City govern-

ment, the group includes members of the trade waste industry, union

leaders, and environmental and traffic safety advocates. I would like

to thank all the members of the Working Group for their assistance

and expertise during the development of the manual.

Safety is everyone’s issue. We appreciate all of your efforts

to make the trade waste industry safer. This manual is only the first

step. With your help, BIC will continue to develop training materials

and increase oversight. Together, we can help the City achieve its

Vision Zero goal of ending traffic-related deaths and injuries in New

York City.

Daniel D. Brownell

Commissioner and Chair

TRADE WASTE SAFETY MANUAL 3

Who, What, Where, and How

Welcome to the Trade Waste Safety Manual! Think of this manual as an

outline of important safety topics that you can use as a starting point to

develop your own safety program at your company. It covers important

laws and rules, as well as industry best practices. However, the man-

ual’s purpose is not to provide legal advice or to be a comprehensive

guide to all the laws and rules that are applicable to trade waste com-

panies operating in NYC. You should develop your own safety policies

and programming based on your company's operations.

Q: Who do I provide safety training to?

A: All of your workers – supervisors, drivers, mechanics, and

helpers alike. Drivers and helpers work as a team and, if qualied,

may on occasion need to step into the other's role on short notice.

Prepare your workers to operate safely in both roles.

Q: What topics do I cover in a safety training program?

A: Think about your operations step by step – from the moment

your workers arrive for their shifts until they go home. The Safety

Manual is great place to start. It covers essential safety topics like

personal protective equipment, proper lifting, collision avoidance,

and safe hopper operation.

Q: Where is the best setting to conduct safety trainings?

A: Provide a combination of “classroom” and hands-on training.

For example, you may want to talk through proper lifting proce-

dures with a hand-out, but then ask your workers to demonstrate

what they learned.

DEVELOPING YOUR SAFETY TRAINING PROGRAM

Introduction

INTRODUCTION4

Q: When should my company provide safety training to its workers?

A: Frequently! Create a culture of safety. Make safety part of “how

we do things here.” Have monthly or weekly safety meetings with

your team. Additionally, there are many other times you should

train your staff. For example:

• When your company hires a new worker.

• When a worker takes on a new role or responsibility.

• When a worker returns from a leave of absence.

• When your company buys new equipment, controls,

or other technology.

• After a worker is involved in a “near miss” collision.

• After a worker is involved in a collision or other serious

safety infraction.

Q: How do I create an effective training program?

A: This manual is a great place to start. Here are some things to

consider when building an eective safety training program:

• Commit to Safety

Owners’ and supervisors’ behavior should reect that

safety is a priority and an integral part of how the company

operates.

• Reward Safe Behavior

Acknowledge your workers knowledge and skill by giving

praise to workers who have a clean safety record.

• Keep Communication Respectful

Supervisors should coach workers how to improve by

providing constructive criticism, not put-downs. Clear

guidance and examples are helpful ways to do this.

• Make training engaging

Use visuals and have hands-on components to the trainings.

Make your training sessions fun – after you go over a section,

take a group quiz or have a discussion where your employees tell

stories of their experiences. If you have cameras on your trucks,

use footage to learn from real-life situations and start discussions.

TRADE WASTE SAFETY MANUAL 5

STEP 1 6

Safe Start to the Day

Safe Start

to the Day

TRADE WASTE SAFETY MANUAL 7

STEP 1 8

WORKER READINESS

Rest: Because most commercial refuse and recycling collection

happens late at night to early morning, during the body’s natural sleep

period, drivers have an increased risk of being drowsy. Drowsy driving

can slow reaction time and impair judgment not unlike using drugs

or alcohol.

• Help your drivers plan to get seven to eight hours of sleep

before driving their shift.

• Host a free or low-cost sleep apnea screening.

• For more information on drowsy driving visit:

www.cdc.gov/sleep/about_sleep

Important note: If your drivers operate trucks with a gross weight of

10,001 or more pounds, Federal and New York State regulations limit

when and how long your drivers may operate those trucks. Know the

rules. Visit the U.S. Dept. of Transportation’s Federal Motor Carrier

Safety Administration’s (FMCSA) website, www.fmcsa.dot.gov, and the

New York State Dept. of Transportation’s (NYS DOT) website at www.

dot.ny.gov.

Medication: Drivers taking medication must check with a doctor

to ensure the medication will not impair their ability to operate heavy

machinery.¹ If the medication has side eects, like drowsiness, it is

not safe to operate the truck as either a driver or a helper.

• Both drivers and helpers should report all medications, both

over- the-counter and prescriptions, to their supervisors.

Drugs and Alcohol: Illegal drugs and alcohol should be banned

from the workplace. Under no circumstances should drivers operate

trucks while under the inuence of drugs or alochol. Most importantly,

FMCSA and NYS DOT regulations prohibit commercial vehicle drivers

from consuming any alcohol within four hours of the beginning of

their shift.²

For alcohol and substance abuse prevention,

treatment, and recovery resources visit:

www.oasas.ny.gov.

Safe Start

to the Day

TRADE WASTE SAFETY MANUAL 9

Do not accessorize

Rings, necklaces, headphones, watches,

bracelets, and even loose clothing can increase

the risk of injury and should not be worn on the

collection route.

Uniforms and PPE should be clean, shirts should

be tucked in, and boots fully laced and tied. Your

employees will not only look good, but will reduce

the risk of injury. Consider providing the option

for your employees to participate in a uniform

washing service.

HAZARDS IN THE TRADE WASTE INDUSTRY

Train your sta to know the hazards they may face while working in

the trade waste industry and how to reduce the risk of injury.

Identify these potential hazards for workers:

• Lifting heavy or sharp objects.

• Exposure to blood borne pathogens, sewage, and hazardous

chemicals.

• Extreme temperatures.

• Working in low visibility conditions near heavy trac.

• Working with heavy equipment and hydraulics.

Discuss ways to prevent workplace accidents and injuries, and stress

the importance of the use of proper equipment.

Personal Protective Equipment (PPE) is essential safety equipment.

PPE includes apparel such as reective vests and other gear that is

worn to reduce exposure to workplace hazards, such as low visibility

at night.

PPE for drivers and helpers:

• ANSI Class II reective outerwear such as a reective vest, shirt,

or other outerwear.

• Pants or shorts secured with a belt.

• Puncture-liquid-resistant gloves such as nitrile coated cloth or

leather palm gloves.

• Steel toe or composite boots that cover the ankle rising to at

least 6 inches.

• Clear plastic goggles or a face shield.

PERSONAL PROTECTIVE EQUIPMENT

Make a good impression

STEP 1 10

Important Note: The Occupational Safety and Health Administration

(OSHA) requires employers to assess workplace hazards and to pro-

vide PPE at no cost to employees. Employers are also required to train

employees on the use and care of PPE.³ Drivers and helpers should not

be permitted to begin their collection route unless they are wearing the

appropriate PPE.

At the beginning of every shift, the vehicle’s driver is required to review

the previous day’s Driver Vehicle Inspection Report (DVIR) and then

perform a pre-trip inspection.

DVIR’S AND PRE-TRIP INSPECTIONS

If the DVIR does not

list any defects

The driver must sign the

DVIR certifying that he

has reviewed it.

The driver should make

sure the truck was re-

paired and that the DVIR

was signed by a me-

chanic certifying that the

repair was made or was

not necessary.

If DVIR lists defects

After signing the previous day's DVIR, the driver can now begin the

pre-trip inspection. This is required before every trip, even if the same

driver completed the DVIR for the same vehicle at the end of the previ-

ous shift.

FMCSA and NYS DOT regulations require that drivers of a commercial

motor vehicle with a gross weight of 10,001 pounds or more conduct a

What’s a DVIR? Also known as a post-trip inspec-

tion, the DVIR is the record of the inspection of a

vehicle at the end of a shift. The DVIR identies any

defects or deciencies in any of the truck's parts

or accessories. See page 32 for more information

on DVIR.

Safe Start

to the Day

TRADE WASTE SAFETY MANUAL 11

If the driver does not

nd any defects

The truck is

ready to be put

into service and the

driver can begin the

collection route.

A mechanic must inspect

the truck and complete

the necessary repairs or

certify the repairs are not

necessary. If the vehi-

cle cannot be repaired,

it must be taken out of

operation until the repair

can be completed.

If the driver notes defects

Some Tips for Truck Inspection:

• A sample DVIR is provided in the back which can also be used as

a template to develop a pre-trip inspection.

• Make a binder for each truck’s pre-trip inspection sheets and

DVIRs and keep it in the truck.

• Help your workers develop a routine.They should conduct the

pre-and post-trip inspections the same way each time.

pre-trip inspection to make sure the following parts and accessories

are in good working order before the vehicle is put into service:⁴

• Service brakes, including trailer brake connections.

• Parking/hand brake.

• Steering mechanism.

• Lighting devices and reectors.

• Tires.

• Horn.

• Windshield wipers.

• Rear vision mirrors.

• Coupling devices.

• Wheels and rims.

• Emergency equipment.

Safety Matters

Pre-trip inspections keep your employees and

New Yorkers safe. It is designed to reduce

crashes, injuries, and fatalities by identifying

problems before the truck gets on the road.

STEP 1 12

FAQ

Q: I need to complete a collection route, but the only truck available

has been put out of service. If it is a small matter, can I put a downed

truck back into operation before the repair has been made?

A: No, never put completion of a route above driver and public

safety. After discovering any safety defect that can aect the safe

operation of a truck or result in a breakdown, you must down the

truck and not put it back into operation until the repair is made.

This is true even if the truck is needed to complete a collection

route.

If at all possible, consider having a spare truck that can be put into

operation if you need to down a truck. Also, encourage your drivers to

identify and report any defects immediately. Fixing a problem early on

can save you money, time, and lives.

Q: What are some examples of defects that aect the safe operation of

a vehicle?

A: Anything from a small problem like a broken seat belt to the

truck not starting will constitute the need to down the vehicle.

Encourage vigilant reporting to avoid an unexpected repair.

Q: What should supervisors do while drivers are completing the

pre-trip inspections?

A: Supervisors should make sure drivers properly complete their

pre-trip inspections by monitoring the reports regularly. Supervi-

sors should also perform spot checks before the trucks leave for

the night and after the trucks get on the road. If the supervisor

sees a driver skipping part of the pre-trip inspection, the supervi-

sor should have a one-on-one conversation with the driver about

how important a pre-trip inspection is to everyone’s safety, includ-

ing the driver’s.

Safe Start

to the Day

TRADE WASTE SAFETY MANUAL 13

NOTES:

STEP 1 14

On the Collection Route

Safe Start

to the Day

TRADE WASTE SAFETY MANUAL 15

16 STEP 2

NEW YORK STATE TRAFFIC LAWS

All drivers must obey all NYS and NYC trac laws. Here are some that

should be emphasized in training sessions:

Seat belt use: All drivers and front seat passengers must wear their

seat belts.⁵ There are no exceptions to this law! Please note: each

truck must have a seatbelt for every member of the crew.

Cell phone use: NYS law prohibits using a cell phone while driving.⁶

For supervisors: consider banning cell phones from the route or requir-

ing that they are kept in the glove box during the route. Studies show

that even hands free cell phone use is distracting.⁷

No rear step riding: Helpers are not allowed to ride on the rear

step of the truck on any public roadways.⁸

BE SMART OUT THERE!

Train your drivers and helpers to prioritize the following tips:

• Use the three point system: Use three points of contact - two

hands and one foot or one hand and two feet - when entering

and exiting the cab of the truck.

• Rock before you roll: Utilize the mirror’s full range of view by

moving in your seat. Check the mirrors every 3-5 seconds

while driving.

• Don’t get blocked: Maximize your eld of vision by keeping the

dash clear. Check that hoodies or hats don’t obstruct your vision.

Do not wear headphones or Bluetooth devices; they can prevent

you from hearing warning signals.

• Public interaction: Limit interactions with the public to respectful

greetings. As you know, drivers stopped behind your collection

truck get frustrated and may make angry or aggressive com-

ments. Your best bet is to de-escalate the situation by not

responding. If you are in danger, call your dispatch and 911.

• See Something – Say Something: As collection workers, you are

in the same neighborhoods every day and know what is nor-

mal and what isn’t. If you see something suspicious or discover

weapons or hazardous materials, call 911 immediately.

Did You Know? New York City employees are

not allowed to use cell phones, even hands free,

when driving.

Helpers' Role

The helper is the driver’s second set of

eyes. While in the cab, the helper should

be scanning the road and alerting the

driver of any obstacles.

On the

Collection Route

17TRADE WASTE SAFETY MANUAL

Provide robust collision avoidance training to your employees that

emphasizes urban driving. This training should cover defensive driving

techniques and include sharing the road with cyclists and pedestrians.

In addition, include these topics:

• 25 mph: The speed limit on most NYC streets is 25 mph. As a

larger, heavier truck, you must drive slowly to make it easier to

stop and avoid collisions.

• Use the six-second rule: Keep a distance between you and the

truck in front of you of SIX SECONDS when moving. Remember,

the heavier the truck – the longer it will take to stop.

• Consider the conditions: Leave extra room between yourself and

vehicles in front of you when the truck is full and when the roads

are wet or icy. Be aware of strong winds.

• Look on all sides: Be aware of your surroundings and leave room

for yourself to maneuver on the roadway.

Large trucks have been exploited by terrorists in ramming-style attacks.

Use these tips to safeguard your equipment:

• Lock all doors when exiting the cab.

• Never leave keys unattended.

• Never leave a truck running when the driver is not

in the driver’s seat.

TOP TIPS TO AVOID COLLISIONS

Enroll your employees in a NYS DMV approved

collision prevention course.

Find providers at: www.dmv.ny.gov/pirp/classroom

Driver Reaction (yards)

Braking Distance (yards)

Stopping Distance At 25 mph

20.67

yards

9.33

yards

25 mph

18 STEP 2

• Pedestrians crossing mid-block.

• Cyclists riding parallel to trucks.

• Abrupt stops or turns by other vehicles.

• Sudden lane change by another driver, or drifting into your lane.

• Being tailgated.

• Getting boxed in.

INTERSECTIONS AND TURNS

• Continually scan mirrors and surroundings for pedestrians,

cyclists, and approaching vehicles.

• Stay alert and observe other drivers' behavior.

• Stay in the right-hand lane.

• Stay centered in lane.

• Maintain a safe speed and following distance.

• Slow down to increase distance between you and vehicles in

front or to avoid being boxed in.

In NYC, a majority of fatal pedestrian crashes involving trade waste

trucks have occurred in intersections. Your training program must

emphasize safety at intersections. Here are some tips to include in

your training:

• If you are stopped: When the signal turns green, pause! Check

your mirrors and scan the intersection for pedestrians, cyclists,

and other trucks. Helpers should do the same.

• If you are driving through: Cover your brake. Never accelerate

through an intersection. Both the driver and helper should check

corners for pedestrians, cyclist and other trucks.

Rock Before You Roll

Move forward, back, and side to side to utilize

your full range of vision in your mirrors.

In Heavy Trac?

The most important space is in front

of your truck. Give yourself at least

25 feet between you and the vehicle

in front.

Potential Hazards

Important Actions

On the

Collection Route

19TRADE WASTE SAFETY MANUAL

Left-hand turn tips

• Drive to center of

intersection before

starting the turn.

• If there are two turn

lanes, use the right-

most turn lane.

• Do not try to beat

oncoming trac.

• Turn wide as you

complete the turn,

not as you start

the turn.

Right-hand turn tips

BACKING UP

NYS trac law states that no one should back up unless it is safe to

do so and trac will not be blocked.⁹ You should train your drivers to

avoid backing up altogether. If they miss a collection stop, they should

go around the block. Pedestrians have been struck and killed by trade

waste trucks backing up.

If your drivers nd themselves in a position where they must back up,

train them to do the following:

• Never back up through an intersection for any reason.

• Never back up with someone on the rear step.

• If a helper is present, have the helper assist.

• If you are turning: Prepare for each turn carefully.

1. Use your turn signal to indicate to others your intention.

2. Slow down early.

3. Expect pedestrians in the crosswalk.

4. Check for cyclists as you approach the turn. Remember

that a bicyclist traveling straight has the right-of-way.

5. Turns must be made slowly – 5 mph is the recommended

speed for all turns.

20 STEP 2

Backing up with a helper

• Review your hand signals.

1. Stop = cross both arms above head.

2. Turn = point one arm to indicate the direction to turn,

bend other arm repeatedly towards head to indicate

continued turning.

3. Backward = raise arms with bent elbow so that ngers

face the sky, bend both arms towards head and chest and

then extend repeatedly.

• The helper should position himself at the rear of the truck and

inspect the intended path.

• Wait until the helper is ready to direct your movement.

• The helper should establish and maintain eye contact with the

driver, remain visible at all times, and immediately signal to the

driver to stop if someone enters the truck’s intended path.

• The driver should frequently check mirrors, and obey the helper’s

directions. Always back up slowly, and be ready to stop.

Backing up without a helper

• Exit your truck and conduct a visual inspection of the intended

path.

• Back up slowly and avoid backing up towards the passenger

side where there is increased obstructed vision.

• As you back up, frequently check all mirrors.

• If in doubt, stop and get out!

On the

Collection Route

21TRADE WASTE SAFETY MANUAL

Industry

Standard

Best

Practices

Aspirational

Industry standard items

are those that are either

required by law or industry

leaders consider essential

to safe operation.

Best Practices are items

that industry leaders strong-

ly recommend you incorpo-

rate in your operations.

Aspirational items are

technologies that are worth

exploring to nd out how

they can improve safety at

your company.

• Warning decals (e.g. Slow

Down to Get Around)

• Bottom of hopper painted

with reective paint

• High vision truck cabs

• On-board computer and

GPS

• Back-up camera

• Automated toters/tippers

• 360° cameras

• Collision avoidance

technology

• Pedestrian alert technology

• All safety equipment

required by the FMCSA

and NYS laws and

regulations¹⁰, including

seat belts, cross-over and

other mirrors, reectors,

headlights and other

lamps, service and

emergency brakes

• Sideguards¹¹

• Emergency stop button

• Audible back-up alert

• LED hopper lights

• Strobe lights

• Reective tape and logos

• Hydraulic safety latches

SAFETY EQUIPMENT FOR TRUCKS

Safety equipment technology and truck design can greatly improve

public and worker safety. In addition to what is required by state and

federal law, you may choose to incorporate additional equipment to

improve the safety of your operations.

22 STEP 2

FAQ

Q: Does a helper riding in the cab need to wear a seatbelt between

each stop?

A: Yes. All front seat passengers must wear seat belts.

Q: Can helpers use the rear step if they follow ANSI guidelines?

A: No, NYS trac law prohibits riding on the rear step under any

conditions on public roadways.

Q: What do I do if my truck does not meet industry standards?

A: Some items listed under Industry Standard are strong recom-

mendations; however, some items are required by federal, state,

or local law. If your vehicle is not equipped with the items required

by law, talk to a mechanic about making the necessary repairs to

bring your vehicle into compliance with these requirements. If you

operate your truck and are not in compliance with safety laws, you

are not only breaking the law, but putting your workers and the

public at risk.

On the

Collection Route

23TRADE WASTE SAFETY MANUAL

NOTES:

STEP 1 24

Safe Collection Stops

Safe Start

to the Day

TRADE WASTE SAFETY MANUAL 25

26 STEP 3

SAFE STOPS

PROPER LIFTING

Training your operators to think about safety during stops is very im-

portant. Include the following practices in your safe collection stops

training:

When approaching a collection stop:

• As you slow down, indicate you are about to stop by using the

turn signal, strobe lights, or 4-way ashers. Pedestrians, cyclists,

and motorists need to know what to expect.

• Both the driver and helper should scan all mirrors to check for

bicyclists and other vehicles.

• Don’t back up! If you miss a collection stop on your route, go

around the block.

To reduce the risk of injury from lifting heavy objects, keep the following

in mind:

• Take a moment to examine the load and surrounding area. If

the bag is ripped or the load is too heavy, too large, or too

awkward, stop and get help.

• Keep a wide base of support. Straddle the load with feet

shoulder-width apart and facing the direction you want to go.

• Bend your knees and hips and keep your back straight by

looking up.

• Lift slowly by straightening hips and knees while maintaining a

rm, balanced grip on the load.

• Position load as close as possible without resting bags or

containers directly on your body.

• Use smooth, controlled movements and avoid twisting.

Do not rest bags on your legs to help you lift

the load into the hopper. Doing so increases

your risk of laceration or puncture wounds

from sharp debris inside the bag.

Safe Collection

Stops

27TRADE WASTE SAFETY MANUAL

CONTAINER MANAGEMENT

HOPPER CYCLING

Use these tips if the collection route includes servicing locations

with containers.

Emptying a container into a rear-loading waste collection truck:

• Cycle the hopper to make sure it is empty before lifting

the container.

• Inspect the container for damage – make sure the trunnion

bar or side bar “ears” are not damaged.

• Attach the trunnion bar to the pivot plate. Always use

safety latches.

• Never place hands on the “ears” of the container – doing

so may lead to hand or nger injuries.

Tips for safely cycling the hopper:

• Make sure you are distraction free. No headphone or

Bluetooth devices – even if they are o.

• No jewelry or loose clothing – the hopper could catch these

and pull you in.

• Use caution and keep hands clear.

• Always stand to the side of the truck when cycling the hopper.

If you stand directly behind the truck, you can be struck by the

debris that is being crushed.

• Use extreme caution when cycling large or bulky items, as they

may eject from the hopper.

Picking up a roll-on/roll-o container:

• Inspect container for damage.

• Properly align container guide rollers with container.

• Check that the hook or other lifting attachment device is

securely attached prior to lift.

• Attach container hold-down strap and cover container.

Remind employees to report damaged con-

tainers so they can be repaired or replaced.

Attempting to tip a damaged container may

result in serious injury.

If your company uses front-loading trucks

in the eet, consider developing a separate

protocol to safely tip these containers in

order to keep your employees safe.

Check surroundings before operating and be

mindful of members of the public in the area.

28 STEP 3

FAQ

Q: How do I know if I’m lifting correctly?

A: When you use proper lifting form, you will feel the lift in your leg

and hip muscles. You should not feel pain when lifting.

Q: When should I ask for help when lifting heavy objects?

A: Ask for help if you are not sure that you can safely lift or move

the object.

Q: If a container gets “stuck” in the hopper, what should I do?

A: Do not attempt to un-jam the container by yourself. Ask a

supervisor for help.

Q: When should I cycle the hopper?

A: In most cases, the best practice is to cycle the hopper before it

is halfway full. This reduces the risk of objects being propelled out

of the hopper.

Q: What should my employees do if a container is unsafe to tip?

A: Do not tip a container unless it can be done safely. If necessary

repair the container before servicing the stop.

Q: In addition to damage to the container “ears,” what type of damage

should I ask my employees to report?

A: Ask your employees to report any damage to the container,

including broken wheels, bent trunnion bars, and rust or rot.

It is important to keep containers well-maintained – doing so

will help avoid injuries. Your employees should never tip a

damaged container.

Safe Collection

Stops

29TRADE WASTE SAFETY MANUAL

NOTES:

STEP 1 30

End of the Shift

Safe Start

to the Day

TRADE WASTE SAFETY MANUAL 31

32 STEP 4

DRIVER VEHICLE INSPECTION REPORT

Train your employees that a safety routine at the end of a shift and in

the garage or yard is just as important as when they are out in the eld.

At the end of each shift, FMCSA and NYS DOT regulations require

drivers to complete a written Driver Vehicle Inspection Report (DVIR).¹²

This report must identify the truck and list any defects that would aect

the safety of operation or result in a breakdown. At a minimum, the

report must cover the same parts and accessories covered under the

pre-trip inspection. Managers may also want to include a comment

section on this form. It allows the driver to make notes and summarize

items that do not pass the inspection. Flip to the back to see a sample

DVIR.

What happens if the driver nds a defect?

If the driver identies a defect that is likely to aect the safety of the

truck's operation, it must be repaired before the truck can be put back

on the road. The mechanic who repairs the defect must certify that he

either made the repair or that the repair is not necessary by signing the

inspection report. After any necessary repairs have been made, the

truck can be put back on the road.

Who has to sign the DVIR?

Both the driver at the end of the shift and the driver who will operate

the truck during the next shift must sign the DVIR. Your mechanic is

required to sign the DVIR when a defect is listed to either certify the

necessary repairs have been made or that the defect does not aect

the safe operation of the truck.

End of shift tips for your drivers:

• By the end of a shift, the hopper may have been cycled up to 100

times. Perform a thorough inspection of the hopper and hydrau-

lics as part of your DVIR.

• Cleaning out the cab and vacuuming the oor at the end of the

shift keeps the dash clear and prevents debris from building up

under the brake pedal.

Safety Meetings are Key: Get everyone

together at the start of a shift to go over the

pre-trip inspection and DVIR. This will remind

everyone why these steps are so important.

End of

the Shift

33TRADE WASTE SAFETY MANUAL

GARAGE AND YARD SAFETY

PREVENTATIVE MAINTENANCE

As you train your sta, don’t forget about the time spent at the garage

or yard.

Make a Plan:

Develop methods to safely move trucks in and around the garage or

yard. This may include having regular trac patterns and trac direc-

tors, developing uniform hand signals to guide trucks through tight

spaces or blind corners, and requiring employees to wear high-visibility

clothing when in the garage or yard.

Hazardous Materials:

Garages or yards can have anti-freeze, diesel or gasoline, grease,

hydraulic uid, solvents, and other chemicals. Train your employees

on how to safely handle these hazardous materials and make the safety

data sheets (SDS) easily accessible at your garage or yard location.¹³

Safety Training:

Provide basic safety trainings such as re safety, including how to use

re extinguishers and emergency exits. Other topics, such as ladder

safety and truck lifts, as they apply, are important. If your garage or

yard is a fueling station, sta should be trained in safe fuel and storage

practices and spill prevention.

Garage Safety Equipment

Keep a debrillator, rst aid kit, re extinguisher,

and safety data sheets accessible and with clear

signs marking their location. It is a good idea to

have an eye wash station.

Reminder: Always follow FMCSA regulations on

when to take an unsafe truck out of service.

To keep your trucks running smoothly and safely, develop a preventa-

tive maintenance schedule in addition to your daily pre-and post-trip

inspections. These regular checks should identify any needed main-

tenance. Either follow the manufacturer’s recommended maintenance

schedule or perform a “major” pre-trip inspection every 40 days.¹⁴

Use experienced mechanics who are familiar with the make and model

of your trucks. If you have your own mechanics on sta, provide fre-

quent training on new diagnostic technology and equipment.

34 STEP 4

FAQ

Q: Where do I get safety data sheets (SDS) for hazardous materials?

A: OSHA rules require that the chemical manufacturer, distributor,

or importer provide an SDS for each hazardous chemical. The SDS

includes information about the hazards, protective measures, and

precautions for each chemical. Under OSHA rules, employers must

make sure SDS for all hazardous chemicals used in the workplace

are easily accessible to all employees. For more information visit

www.osha.gov.

Q: I’m a very small company. Do I still need to complete DVIRs?

A: Depending on the number of trucks your company uses, you

may not be required to complete a DVIR. However, even if you are

not required by law, completing the DVIR will help keep all New

Yorkers safer on the roads. For more information about DOT and

FMCSA regulations, please visit www.dot.ny.gov/divisions/operat-

ing/osss/truck and www.fmcsa.dot.gov.

Q: My driver identies a safety defect on the DVIR. My mechanic says

nothing is wrong. What do I do?

A: If your mechanic inspects the truck and nds that nothing is

wrong or that the defect does not aect the safe operation of the

vehicle, the mechanic must sign the DVIR certifying that no repair

was needed. After your mechanic does this, the truck can be put

back into operation.

End of

the Shift

35TRADE WASTE SAFETY MANUAL

NOTES:

STEP 1 36

When Things Go Wrong

Safe Start

to the Day

TRADE WASTE SAFETY MANUAL 37

38 STEP 5

BREAKDOWNS

COLLISIONS

The goal of a comprehensive safety training is to prevent collisions

and work-related injuries. However, in the event that there is an incident

that results in dangerous conditions, an injury or a fatality, your sta

should be prepared to respond quickly.

Train your employees to follow these steps to keep themselves and the

public safe in the event of a truck breakdown:

• Pull over out of the ow of trac when possible.

• Maximize visibility: turn on your four-way ashers and put

out an emergency triangle.

• Call dispatch for assistance as soon as your vehicle is stopped

and safely secured.

• Turn o hydraulic valves if you are able to do so safely.

However, do not put yourself in danger.

• Keep members of the public away from the vehicle.

Collision scene best practices:

Be prepared!

Train drivers and helpers how to respond to collisions. Keep the follow-

ing equipment in the truck:

Emergency Triangle Emergency Kit

Fire Extinguisher

Spill Kit

Emergency Cell Phone Collision Packet Truck Tools

When Things

Go Wrong

39TRADE WASTE SAFETY MANUAL

PREPARE A COLLISION PACKET

This should include a step-by-step guide for the driver and helper to

follow in the event of a crash, helpful phone numbers like company

supervisors and utility providers, a company contact card to provide

to the other parties involved in the crash, vehicle regristration and

insurance card, and a camera to document the collision.

If you are involved in a serious collision:

• Stay calm and immediately call 911.

• Stay at the scene and set up your emergency triangle.

• Position yourself in a safe location.

• Contact dispatch.

• Provide company contact information to other parties.

• Wait for NYPD to arrive.

If there is only property damage:

Exchange information such as driver’s

license, insurance, registration and if

damage is over $1,000 le an NYS

Accident Report (Form MV-104) within

10 days.

Important note: Under certain circumstances after a collision,

drivers are required by FMCSA and NYS DOT regulations to undergo

drug and alcohol testing. Here are the circumstances in which you

must test your driver under these rules:¹⁵

Type of Injury

or Damage as

Result of Crash

Citation Issued

to the CMV

Driver

Test Must Be

Performed by

Employer

Human Fatality No

No No

Yes

Yes Yes

Yes

Bodily Injury With

Immediate Medical

Treatment Away From

the Scene

Bodily Injury With

Immediate Medical

Treatment Away From

the Scene

Disabling Damage to Any

Motor Vehicle Requiring

Tow Away

Disabling Damage to Any

Motor Vehicle Requiring

Tow Away

40 STEP 5

If the driver tests positive or refuses the test, the driver is subject

to additional drug and alcohol testing. For more information about

FMCSA and NYS DOT required drug and alcohol testing, visit

www.fmcsa.dot.gov and www.dot.ny.gov.

Train your sta to take the following measures:

Engine:

If you suspect there is an engine re, pull over immediately, turn o

the engine, and engage the work brake. Keep the area around the truck

clear and assess the situation. Use a re extinguisher to smother the

re if you can do so safely.

If you are not able to smother the re, move away from the vehicle and

call 911.

Hopper:

A re in the hopper is a potentially volatile situation. If you suspect

there is a re, do not cycle the hopper, as it could cause the truck

to explode.

It may become necessary to dump the load to control the re, but

never dump the load if it contains hazardous material.

Safety is Number One: Go above and beyond the FMCSA require-

ments. Administer a drug and alcohol test to your drivers following

every collision that results in an injury or if you believe your driver

may have been at fault.

Important Note: No one wants to deal with a collision, but when one

happens, try to learn from it. Create a collision review team to analyze

collisions and how you can improve safety equipment and driver train-

ing to prevent future collisions.

FIRES

Not sure what to do? Call 911 and wait

for instructions from FDNY and NYPD.

When Things

Go Wrong

41TRADE WASTE SAFETY MANUAL

Demonstrate to your employees that safety – their's and the commu-

nity’s – is your number one priority by rewarding safe behaviors and

coaching workers to improve unsafe ones.

Reward Safe Practices:

Show your appreciation by recognizing workers for a job well done.

Drivers who have safe driving records (one, ve, ten, or fteen years)

can be recognized or given a token of appreciation. When a worker

makes a suggestion that improves safety at your company, they should

be acknowledged and others should be trained in the practice.

Written Expectations:

It is important to provide clear directives for your workers and to devel-

op company-specic policies, in addition to following all federal, state,

and local laws. You should have a protocol that allows for a graduated

range of responses if your workers do not follow your rules. Here is a

good place to start:

1. Place safety infractions on a scale from preventable

to severe.

• Preventable may include clipping a mirror on a parked

car, but reporting it when returning from the shift.

• Events on the serious end of the scale are those that

include risk of loss of life or serious injury or serious

property damage.

• The most severe safety infractions include failure to

report a collision, a positive drug test, or behavior that

is grossly negligent or results in the loss of the

driver’s CDL.

2. Keep track of all safety infractions for each worker over a

rolling 12-month period, so you can detect patterns.

ACCOUNTABILITY

42 STEP 5

3. Determine the appropriate response for each safety infraction

and communicate this system in advance. Some examples

of a progressive disciplinary system are:

• First step: Provide a verbal or written warning to

the worker and discuss how the unsafe behavior

can be corrected. You may choose to provide

multiple warnings.

• Second step: If the behavior persists or is serious, then

suspension or other monetary penalties like reduced pay

may be necessary.

• Third step: If behavior continues to persist or is severe,

termination may be necessary.

FAQ

Q: What utility company contact information should I include in my

collision packet?

A: Utility providers that service NYC are:

• Con Edison: 1-800-752-6633 (gas and electric);

1-800-914-9112 (steam)

• National Grid: 1-800-867-5222 (electric);

1-718-643-4050 (gas)

• PSEG Long Island (Rockaways): 1-800-490-0075

(electrical)

Q: What if my driver is involved in a collision with a parked vehicle or

other property is damaged?

A: If they are not able to locate the owner, they must contact

NYPD. Notify dispatch of the collision and leave a company con-

tact card so the owner can get in contact with your company.

When Things

Go Wrong

43TRADE WASTE SAFETY MANUAL

NOTES:

Personal Protective

Equipment

Workers must wear proper PPE to reduce

exposure to workplace hazards such as

low visibility at night.

Recommended:

Reective Shirt

Puncture Resistant

Gloves

Steel Toe

Boots

Clear Plastic

Goggles

Don't Cut Corners!

Turn With Caution

For safe turns:

1. Use your turn signal.

2. Expect pedestrians in the crosswalk.

3. Don't turn faster than 5 mph.

4. Look for cyclists before you turn.

Backing Up Can Kill!

Go Around the Block

If you are in a position where you absolutely

must back up:

With a Helper:

1. Review hand signals.

2. The helper should be at the

rear of the truck.

3. Check your mirrors and stay

in constant contact with

the helper.

By Yourself:

1. Exit the truck and check

surroundings.

2. Back up slowly and avoid

the passenger side which

has lower visibility.

Driver's Vehicle Inspection Report

Check Any Defective Item and Give Detail Under "Remarks."

Date:

Truck/Tractor No.

Trailer(s) No.(s)

Remarks:

Air Compressor

Air Lines

Battery

Brake Accessories

Brakes

Carburetor

Clutch

Defroster

Drive Line

Engine

Fifth Wheel

Front Axle

Fuel Tanks

Heater

Brake Connections

Brakes

Coupling Chains

Coupling (King) Pin

Doors

Condition of the above vehicle is satisfactory

Above defects corrected

Above defects need not be corrected for safe operation of vehicle

Hitch

Landing

Lights - All

Roof

Springs

Tarpaulin

Tires

Wheels

Other

Horn

Lights

Head - Stop

Tail - Dash

Turn Indicators

Mirrors

Muer

Oil Pressure

On-Board Recorder

Radiator

Rear End

Reectors

Safety Equipment

Fire Extinguisher

Flags-Flares-Fuses

Spare Bulbs & Fuses

Spare Seal Beam

Springs

Starter

Steering

Tachograph

Tires

Transmission

Wheels

Windows

Windshield Wipers

Other

Driver's Signature

Mechanic's Signature

Driver's Signature

Date

1. 49 C.F.R. § § 382, 391 and N.Y. Comp. Codes R. & Regs. tit. 17, § § 820.2, 820.3.

2. 49 C.F.R. § 382.207 and N.Y. Comp. Codes R. & Regs. tit. 17, § 820.2.

3. 29 C.F.R. § 1910.132.

4. 49 C.F.R. § 392.7 and N.Y. Comp. Codes R. & Regs. tit. 17, § 820.4.

5. N.Y.S. Veh. & Traf. Law § 1229-c.

6. N.Y.S. Veh. & Traf. Law § 1225-c.

7. See National Safety Council, Understanding the Distracted Brain, White Paper (Apr., 2012), http://www.nsc.org/

DistractedDrivingDocuments/Cognitive-Distraction-White-Paper.pdf. See also, Centre for Accident Research & Road

Safety - Queensland, Mobile Phone Use and Distraction, (Sept., 2015), https://research.qut.edu.au/carrsq/wp-content/

uploads/sites/45/2017/12/Mobile-phone-distraction-email.pdf.

8. N.Y.S. Veh. & Traf. Law § 1233 (2).

9. N.Y.S. Veh. & Traf. Law § 1211 (a).

10. 49 C.F.R. § 393 and N.Y. Comp. Codes R. & Regs. tit. 17, § 820.5.

11. New York City Administrative Code § 16-526.

12. 49 C.F.R. § 396.11 and N.Y. Comp. Codes R. & Regs. tit. 17, § 820.7.

13. 29 C.F.R. 1910.1200 (g).

14. 49 C.F.R. § 396.3 and N.Y. Comp. Codes R. & Regs. tit. 17, § 820.7.

15. 49 CFR § 382.303 and N.Y. Comp. Codes R. & Regs. tit. 17, § 820.2.

ENDNOTES