Managing risk at your waste facilities

Risk Matters - Summer 2022

Waste and recycling facilities are considered high-risk locations due to their high hazard operations.

WA local governments control over 140 landfill facilities and approximately 84 waste transfer stations. 

Waste and recycling facilities are considered high risk due to the increased levels of combustibles, the potential for environmental damage, and health and safety concerns.

The most obvious risk posed is environmental contamination. Clean up expenses, fines and damages, increased costs, and fines are all further potential outcomes. 

Examples of waste facilities include (but are not limited to): 

  •   recycling centres 
  •   resource recovery 
  •   materials recovery facility 
  •   re-processors (e.g. paper, cardboard, plastic, e-waste) 
  •   energy recovery centre 
  •   transfer stations
  •   landfills

Waste management locations in WA have generated some of the largest claims ever managed by LGIS since the Scheme’s inception.

The consequences of a major loss can be disastrous on many fronts. Reputational costs can be substantial, and they may affect how your community views your operation.

Other sections in this season's Risk Matters

Liability risks

Waste facilities have evolved from past models of landfill-only operations to sophisticated waste transfer stations including refuse recovery, recycling, and waste composting functions. 

A waste facility is not a risk-free environment and it is not possible to remove all risk to the public, however as the operator of these facilities, your local government is subject to legislative and common law duty of care obligations to ensure the facility is as safe as you can reasonably make it. In general terms, this duty of care is determined in reference to the foreseeability of risk, the likelihood and severity of risk, and whether reasonable action could have been taken to eliminate or mitigate the risk.  

While it is less common for the public to have access to the landfill tip face these days, there are still challenges with managing public safety at waste facilities.

The risk of harm to the public who access these facilities is real – when disposing of items at transfer stations, people are often faced with unfamiliar hazards such as falls from height, slips and trips and heavy vehicle movement/interactions.

Depending on the layout of the facility, people may also encounter risks associated with excavated areas (e.g. asbestos and animal disposal pits, and sewage/liquid waste ponds) and have free access to other waste areas. Where there is free access there is often the temptation to interact with and scavenge for disposed items, some of which contain multiple hazards.

What can you do?

With your duty of care in mind, it may be possible to manage risks by making improvements at the facility. This is achievable partly through good design of the facility and implementing other controls focusing on the operational aspects.

Supervision of public access and movement around the site is one of the most important and effective operational risk controls. However, adequate supervision often requires a balance between providing a facility for the community to dispose of waste, and limited resources to manage safety at this facility. 

Some additional control considerations are:

  • Perimeter fencing of the facility to reduce unauthorised access and dumping of waste, waste migration (i.e. being blown off the site), and vandalism (to plant and other assets). Internal fencing to prevent access to dangerous areas such as excavations and sewage disposal ponds.
  • Falls prevention through methods such as adequate edge protection, edge highlighting or alternative methods of waste transfer (e.g. eliminating dumping from height).
  • Providing a waste disposal location on solid ground that is not susceptible to giving way underweight (such as the tip face).’
  • Segregation of people from operating plant and machinery.
  • Appropriate signage from the point of entry, to navigation around the site and nomination of correct areas of disposal for specific items.
  • Additional controls on vehicle movements during fire and movement bans.
  • Delineation – in combination with signage, barriers or buffer areas to segregate different types of waste (e.g. recyclable items, household hazardous goods).
  • Suitable space for reversing and turning around vehicles
    (many people accessing these facilities may not be experienced in operating trailers in confined spaces).
  • Storage – fit for purpose receptacles. To store items such as: 

Used oil and chemicals in appropriate containers on bunding to capture spills. A bund is an embankment or wall of brick, stone, concrete or other impervious material, which forms the perimeter and floor of a compound and provides a barrier to retain liquid – the main part of a spill containment system.

Lead acid and other batteries separated where required and place in purpose made battery storage containers. 

LPG and other pressurised gas containers stacked and stored per requisite standards.

Combustible items such as tyres, cardboard/paper, green waste and mulch with appropriate fire controls including separation/fire breaks, monitoring of compost/mulch piles to reduce likelihood of spontaneous combustion, and ensuring availability of fire suppression equipment. 

Clothing bins considering design and the risk of entrapment.

It is also worth considering the risks involved in providing certain disposed items for either resale or re-use to the public. Certain items come with safety obligations that apply in circumstances of re-supply. Some of these items, particularly if defective, could pose a risk of harm to the end user exposing you to liability risk, or at least reputational risk as the supplier.

Electrical items certainly fall into this category. There are electrical safety standards that apply to electrical goods and this includes requirements under the Electricity Act 1945 (WA) and the Electricity Act Regulations 1947 (WA), along with guidelines and standards adopted by this legislation. Standards Australia publish specific standards in relation to ensuring the safety of second hand electrical equipment. For example AS/NZS 5761:2011 ‘In-service inspection and testing – Second-hand equipment prior to sale’ specifies, “Prior to sale, the vendor shall confirm that the electrical equipment is operationally safe to use by determining that the equipment is free of obvious defects which may cause harm to the person or property when properly installed, maintained and used in applications for which it was made.” Compliance with additional standards requires testing and inspection by competent persons to ensure electrical safety. Further information relating to the importing selling and hiring of electrical appliances can also be found on the Department of Mines, Industry, Regulation and Safety website.

There are other items that could present a high risk in a resale
or re-use situation including products that may attract scrutiny from the Australian Competition and Consumer Commission (ACCC) regarding safety (refer Product Safety Australia:

Many local governments have adopted an approach in relation to restricting items accepted for resale at waste facility recycling shops. If you are uncertain about the type of items to accept and offer at recycling shops, seek advice from the Department of Mines, Industry Regulation and Safety – Consumer Protection.

If you have any questions regarding your liability risks at your facilities, please contact the LGIS risk management team or your regional risk coordinator.

WHS at waste facilities

Site safety is paramount at all local government facilities, particularly those with higher risks like waste facilities. You can maintain site safety through careful planning, the provision and utilisation of appropriate equipment, and worker training. Accidents can be minimised by effective site management, implementation of safety processes and training programs.

These programs should include the following:

  • Identification of potential sources of risk
  • Assessment of the degree of risk from these sources
  • Determination of procedures for addressing the risks
  • Development of procedures to minimise accident/risks when they occur
  • On-going monitoring to ensure effective implementation of safe working procedures
  • Site plant and all structures should be equipped with fire extinguishers.
  • A well-stocked first aid kit should be available on-site and first aid training should be considered essential for one or more of the operating personnel who spends the majority of the working day on the site.

Common hazards

The most common hazards associated with waste facility operations include:

  • Slips, trips, or falls
  • Manual handling
  • Tip face collapse
  • Asbestos
  • Airborne fibres and materials – respiratory diseases
  • People being hit or run over by vehicles
  • Falls from vehicles
  • Vehicle overturns

Training for workers

Workers should be adequately trained in all safety aspects and processes in the operational area. Examples may include:

  • Do not permit those under the influence of alcohol or controlled substances to work on or use the site.
  • Do not allow horseplay or idle time in the tipping area.
  • Do not permit trucks to discharge waste within three meters
    of others.
  • Complete separation of mechanical discharging trucks from those which must be hand unloaded increases safety and decreases the area of tipping face required
  • Only allow drivers to enter the disposal area.
    Ensure the spotter is not distracted by external activity.
  • Smoking should be prohibited on site
  • All site personnel should be required to sign in and out each time they arrive or depart from the site.

Personal protective equipment (PPE)

All workers should have the appropriate PPE. High visibility clothing should be provided and worn. Safety boots and/or wellingtons should be issued to all workers. Gloves should be issued as required and should be puncture resistant and suitable for the relevant task.

Safety helmets and eye protection should be available as necessary. Hearing protection should be available for those working in high noise areas. Workers work in all weather conditions and should be provided with suitable windproof wet weather clothing. It is essential for management to take the lead in personal safety and establishes the standard expected for all workers.

Some additional safety items which may be considered, are:

  • Hard hats
  • Steel mid-soled and steel-toe capped footwear
  • Hearing protection
  • Dust masks
  • Goggles or face masks
  • Communication devices -air horns, whistles, intercoms, or radios

Ways to prevent injuries and improve overall facility safety include:

  • Have a Safety Management Plan
  • Integrate safety as a part of the job
  • Create accountability at all levels
  • Take safety into account during planning processes
  • Make sure contractors are pre-qualified for safety
  • Make sure workers are adequately trained in appropriate areas
  • Have a fall protection system
  • Prevent and address substance abuse to workers
  • Make safety a part of everyday conversations
  • Review accidents and near misses, as well as conduct regular inspections

For more information on managing WHS risks at your facilities, contact our knowledgeable WHS team on 9483 8868 or your regional risk coordinator.

Emergency management

Over recent times, there have been a number of major fires associated with the operation of waste facilities, including landfill and waste treatment sites. Major waste facility fires or hazardous materials incidents can take an extended period of time to control and in the past have resulted in evacuations of local communities and injuries requiring first aid and hospital treatments. 

They can also cause short and long-term environmental harm. Fires can generate a hazard to the environment from toxic smoke plume, firefighting water runoff (likely containing waste contaminants) and direct thermal and smoke damage to buildings and structures. From research, the potential fire size can be closely correlated with the nature of combustible waste materials being stored or processed, stockpiling arrangements, on-site fire safety systems and emergency response planning of the respective site.

In addition, a loss of or reduction in waste acceptance and processing capacity can have significant issues for waste stream management in WA. 

Effective risk management frameworks and practices ensure the frequency and severity of fires at waste facilities is reduced.

Waste fires have demanded significant fire service resources over multiple days to extinguish. The largest and longest-lasting fires often involve large stockpiles of unsorted waste with inadequate separation, where physical removal, separation and extinguishment is required. These fires also result in major pollution impact on the community, especially from smoke, which is unable to be contained.

Guidance on fire safety for waste facilities requires case-by-case consideration of the special hazards unique to each facility. DFES Fire Prevention and Management in a Recycling Facility guidance note provides broad principles to plan, manage, assess or determine the risks and measures applicable to any given facility in the absence of any other requirements.

It is imperative every facility has an emergency management plan that is updated annually. When developing your emergency management plan, ensure that it: 

  • Includes site map/s, including key features and location of flammable material by material type 
  • Up to date map of roadways and vehicle access around site, including secondary access or egress roads 
  • Identifies all likely emissions and their impacts in the event of a fire (e.g. products of combustion and contaminants of firefighting run off) 
  • Identifies actions to be taken to minimise emissions and off-site impacts 
  • Determines emergency waste actions to be taken and resources required (e.g. drain blocking, waste water tankers) 
  • Specifies how assistance will be provided to firefighters and volunteers using equipment (such as to break apart waste stockpiles)
  • Determines all credible off-site impacts such as smoke and firefighting run off water 
  • Lists contact information for key staff out of hours 
  • Contains current, concise information about the site’s operation, infrastructure, hazards and emergency resources
  • Contains credible emergency scenarios and clear procedures to manage them, including notification and escalation procedures
  • Identifies specific personnel roles and/or a warden structure so notification and escalation procedures are clear during an emergency
  • Contains a clear emergency management communication plan to internal staff and external emergency responders
  • Contains a schedule and process for reviewing, updating and testing (exercising) the emergency management plan

For assistance in managing these procedures, please contact the LGIS risk management team or your regional risk coordinator.


Our claims experience at local government waste facilities demonstrates the risk of harm waste facilities can pose. The LGIS Liability Scheme has paid just under $1M managing personal injury claims on behalf of members. Falls is one of the most common causes of injury claimed at waste facilities, making up around one quarter of claims received. More broadly, the LGIS Scheme has covered over $35M in losses arising from waste facilities across all protection classes, including two of the largest losses being the fires at the South Metropolitan Regional Council and Shire of Brookton tip.   

Cleanaway fire

On 25 November 2019, a fire destroyed Cleanaway’s main recycling processing facility in South Guilford. This affected the majority of metropolitan local governments’ recycling operations but the contracts with Cleanaway provided that Cleanaway was responsible for arranging alternative recycling services – so for many this was not an issue. 

However, three local governments were in the final stages of renegotiating agreements with Cleanaway when the fire happened and as such, Cleanaway denied it had any contractual responsibility to arrange alternative recycling services to these three local governments – this meant that these local governments may have had to bear the costs of these alternative recycling services (although they maintained Cleanaway was contractually obligated to provide these alternative services).

The Property Policy has an extension to its Business Interruption cover (which indemnifies local government members for any additional costs as a result of damage to its property which causes an interruption to its business) that will also cover any additional costs as a result of business interruption caused by damage at a supplier’s premises – which was the case in this instance. Consequently, the Policy responded to all three local governments’ additional costs (being the additional recycling costs) as a result of the fire at Cleanaway’s facility.

However, Cleanaway eventually covered the additional costs for two of the local governments (meaning we only incurred some legal costs). That said, the Property Policy paid out approximately $1m to the last local government for their additional recycling costs.

The LGIS claims team is here to assist you and provide advice, guidance and strategic management of claims to reduce potential liability exposures and claims’ costs by prompt identification and processing. 

Your protection

LGIS has a robust protection regime covering some of the key exposures you face. The table below outlines incidents relating to the hazardous nature of waste management facilities, and which policy provides coverage.

LGIS PropertyWaste/recycling facilities account for approximately 20% of all claims paid for by LGIS Property. More broadly, in 2016/17 alone there has been over $50M in property-related claims in the recycling industry in Australia.
LGIS WorkCareThere have been three fatalities (including contractors) and 78 workers compensation claims in the past five years relating to waste incidents.
LGIS LiabilityIn the early 90’s the Shire of Brookton was involved in a tip fire, which resulted in a devastating bushfire and one of the largest claims in LGIS’ history. The most common liability claim arising from this class of activity is person and plant interaction which, given the operations, is not surprising.
Pollution Legal Liability CoverIncidents involving accidental environmental contamination arising from migration of pollution conditions affecting land owned has resulted in individual claims in excess of $20M. Following a review of local government, LGIS fully funded a pollution legal liability policy in 2016 to benefit the sector.
Management Liability – Statutory Fines/ Penalties CoverSuccessful prosecution by the Department of Environment Regulation and WorkSafe in relation to site management and safe work practices. Fines, penalties and defence costs in relation to these breaches can be significant and are normally associated with damaging media coverage. Please note, from 2022 fines and penalties will not be covered as per changes to the Work Health and Safety Act.

There is an ongoing reluctance in the market to accommodate this occupancy class (waste). Inside Waste magazine states that realistically, businesses should be prepared for premium increases of at least 10-15 per cent. This is due to a number of factors. Claims for natural disasters have eaten into the pool of funds reserved for paying claims, with the result that insurers’ profits have more than halved. The recent fires, cyclones and storms have inflated claims for damaged buildings and plant, while liability in all areas have also contributed to the cost of claims.

This highlights the increased need for better, and more proactive, risk management in these facilities. 

In 2021, LGIS risk consulting undertook 10 site risk reviews of member waste facilities to determine the property and liability risks associated with the management and operation of these facilities.

The reviews were completed against the principles of the Australian Standard for Risk Management (AS/NZ 31000:2018), and guidelines issued by various state government bodies across Australia, to identify the risks to council-owned property, the environment and members of the public and where applicable provide recommendations for improving the management of risks and ensuring that all member waste facilities strive to meet a set of ‘Minimum Standards’ which define the required safe operating practices for all facilities.

Six of the 10 site received less than 70%, which is considered a poor result with significant room for improvement or a greater level of inherent risks. 

Common themes: 

  •   Stockpiling protocol 
  •   Fixed fire systems – water supply 
  •   Mobile equipment protection 
  •   Natural exposures (neighbouring bush) 

These reviews will be continued into 2022.

To discuss your local government’s protection, please contact your LGIS member services account manager directly.

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WA local governments control over 140 landfill facilities and approximately 84 waste transfer stations.
Waste and recycling facilities are considered high risk due to the increased levels of combustibles, the potential for environmental damage, and health and safety concerns.

Read more »