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Questions & Answers

  • ISBN: 978-1-4249-6190-0
  • Issued: May 2004
  • Content last reviewed: June 2009

This information has been prepared to assist employers, workers, constructors, supervisors, owners, suppliers, and others who have duties under the Occupational Health and Safety Act (OHSA) and its regulations. It should not be taken to be a statement of the law or what is necessary to comply with the law. A person with legal duties may or may not agree with these answers and there is no legal requirement to follow it. It is for each such person to decide what is necessary to comply with the Act and its regulations.

A person who needs assistance in determining what constitutes compliance should consult with his or her legal advisor. Ministry inspectors will assess workplace situations against the relevant provisions in the Act and its regulations but they do not enforce these answers, although they may refer to it in determining whether the law has been complied with.

  1. What is a 'pinch point'?

    A pinch point is a point at which it is possible for a part of the body to be caught between moving parts and/or moving and stationary parts of equipment.

    The ANSI definition of pinch point is as follows:

    "Points at which it is possible to be caught between moving parts, or between moving and stationary parts of a piece of equipment."

  2. What is the 'point-of-operation' in relation to mobile compacting equipment?

    The point-of-operation is the area of the equipment where the waste is actually loaded into the vehicle. This is the point where the waste is placed into the vehicle either manually or by mechanical means, as is the case with container-lifting devices.

  3. What is the difference between the 'crusher panel' and the 'compacting ram'?

    The compacting ram is used to push the waste to the back of the vehicle. Currently the guidelines permit the compacting ram to cycle (move back and forth) three times with a single activation by the operator.

    The crusher panel is a panel that is used to 'compress' waste so that it can be pushed by the compacting ram to the back of the vehicle. It is only used when the height of the waste is higher than the opening leading to the back of the vehicle. As a result it is normally only used intermittently and not with each cycle of the compacting ram.

  4. What is 'sustained pressure' relative to controls?

    A control, which is operated by sustained pressure, means that the control permits movement only as long as the control is held in a set position. When the control is released it then returns to the stop position. In the context of the guidelines it means controls that require continual pressure from one or both hands of a worker to operate. If hand(s) are removed from the control the equipment, operation stops.

  5. What does 'hopper opening' mean?

    The hopper opening is a term used in reference to side-loading compacting equipment. It represents the opening through which solid waste is thrown into the hopper, which contains the compacting ram. In some cases the hopper opening is reduced by side baffles or plates. For side-loading equipment the emergency stop bar is to extend across the usable horizontal width of the bottom of the hopper opening. For combination collection equipment the container lifting mechanism may prevent the emergency stop bar from extending across the full width of the opening. The emergency stop bar is to be within easy reach of the operator.

  6. How is 'clear view' defined?

    This term is used in reference to rear loading and other refuse compacting trucks where the controls are at the side of the truck and if not positioned correctly may prevent the operator from being able to have a clear view of the point-of operation. For this type of equipment it is critical that the operator have this clear view of the complete area of the point-of-operation to ensure that when the packer panel is moving downward it can be stopped if another worker is within easy reach of the pinch point.

  7. Does a loading step on a side-loader compromise the 42" criteria relative to guarding?

    The ANSI Standard Z245.1-1999 American National Standard for Equipment Technology and Operations for Wastes and Recyclable Materials - Mobile Wastes and Recyclable Materials Collection, Transportation, and Compacting Equipment - Safety Requirements in clause 7.3.3.2 states: "A Type B side-loader [Figure 8(b)] having a loading height of not less than 107 cm (42 in) measured from the ground to the loading sill, shall be considered as meeting the requirement of clause 7.2.8 (point-of-operation protection)".

    The use of loading platforms is not permitted in this standard unless equipped with a pressure sensitive protective device, or equivalent, which stops the ram movement when a worker steps onto the loading platform.

    This guideline sees a loading step that is not interlocked with the ram operation as compromising the 42-inch-criteria.

    The guideline anticipates that side-loader operations involve one worker and provisions in the guideline and Q & A response are for one worker operation only. Additional precautions may be necessary for side-loaders operating with two or more workers.

    Recent critical and fatal accidents in Ontario caused by workers riding on the loading step make it necessary to consider the removal of the loading platform, and the vehicle or loading platform shall not be equipped with a grab handle to ensure that the loading platform is not used as a riding step.

    The guideline recognizes the need for workers to utilize the step when handling heavy loads on a repetitive basis and therefore permits the loading step to remain in place if equipped with a pressure sensitive protective device. The pressure sensitive device stops the compacting ram movement when a worker steps onto the loading platform. The compacting ram interrupt cycle shall be subject to a manual reset function.

  8. Is a clear plexi-glass window in the body of a rear-loader acceptable in providing the operator a clear view of the point-of-operation?

    The use of plexi-glass is not recommended but may be acceptable if the requirement to providing the operator a full view of the point-of-operation is met. Please note the requirement is for the complete point-of-operation to be in clear view of the operator, from one side to the other over the full width of the rear of the truck.

    Regular cleaning and maintenance to ensure that the plexi-glass is clear is necessary for the plexi-glass opening to provide 'clear view' as required in the guideline.

    The expanded metal section at the rear of the rear-loading truck shown in the guideline fulfills the clear view point-of-operation requirement; as well, it fulfills the requirement to prevent the worker to reach the point-of-operation with his/her lower limb (foot) when standing on the riding step while operating the controls. (Reference is made to the critical accident where the operator was able to reach the point-of-operation with a foot.)

    The expanded metal arrangement prevents the worker from reaching the point-of-operation and gives the operator a clear view of the point-of-operation. It fulfills the requirements under (B) 1 & 2 of the guideline.

  9. Will additional sustained pressure controls be required for 'trainers' when instructing or training workers?

    The requirement for additional sustained pressure controls for trainers is only required for rear loading refuse compacting and side-loading type II (Torpedo design) vehicles. This is due to the fact that this type of equipment is more hazardous than other equipment and the extra controls are deemed necessary.

  10. Are all aspects of the ANSI standard enforceable by the Ministry of Labour since it forms part of the guideline?

    Relevant aspects of the ANSI standard may be enforced, as reasonable precautions, under section 25(2)(h) of the OHSA by the Ministry of Labour other than those specifically covered by Ontario Regulations.

  11. Does this guideline apply to anyone other than workers?

    The legislation that the Ministry of Labour is responsible for enforcing (Occupational Health & Safety Act and Regulations) is generally intended to protect 'workers'.

    It may be prudent to identify health and safety risks to members of the public so that equipment operators will be aware of potential hazards and take necessary precautions.

  12. Does this guideline apply to both the private sector and municipalities & other public sector agencies and workers?

    These guidelines apply in every situation where workers are using the equipment mentioned to collect solid waste.

  13. Will the Ministry of Labour apply this guideline consistently and uniformly across the province?

    The Ministry of Labour is committed to full practical training of ministry inspectors to encourage application of the guideline consistently and uniformly across the province.

  14. Should this guideline be incorporated into municipal/company safety policies and employee training programs?

    Yes, the guidelines should be incorporated into municipal/company policies and employee training. In subsection 25(2)(j) of the Occupational Health and Safety Act the employer is required to prepare a written occupational health and safety policy and set up a program to implement it. The programs will vary, depending upon hazards encountered in a particular workplace. Certainly one of the elements would be guarding which is covered by the guidelines.

    In addition the Act also requires employers to:

    • instruct, inform and supervise workers to protect their health and safety [section 25(2)(a)]
    • inform a worker, or a person in authority over a worker, about any hazard in the work and train that worker [section 25(2)(e)]

    In order for employers to comply with the above-mentioned duties supervisors and workers would need to be trained on the correct application of the guidelines.

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