MRFs, transfer stations and collection, UK wide
Waste and Recycling Health and Safety
Waste and recycling puts people next to heavy machinery, reversing vehicles and a material stream that nobody fully controls before it arrives. AL23 Safety helps materials recovery facilities, transfer stations, collection fleets and household waste recycling centres manage that exposure across the UK.
Why it matters in waste and recycling
The risks are real and so are the duties
Waste and recycling recorded the second highest fatal injury rate of any sector in 2025/26, at 5.47 deaths per 100,000 workers. The rate across all industries was 0.37. That is close to fifteen times the average, on sites that combine vehicle movements, unguarded access to running plant and a fire load measured in thousands of tonnes.
HSE splits the sector's risk profile into health risks such as bioaerosols, infection, musculoskeletal disorders, asbestos and noise alongside safety risks such as machinery, transport movements, lifting and slips. The operative standards sit with the Waste Industry Safety and Health Forum, whose guidance is HSE backed and is what an inspector will measure you against. WASTE 06 on skip and container safety was updated in May 2025. WASTE 09 on safe transport in the waste management and recycling industry was updated in August 2025.
The main risks
Where the harm comes from
Vehicle and pedestrian interface
Reversing refuse collection vehicles, shunting on the tipping floor, public cars at civic amenity sites and loading shovels working blind account for the sector's worst outcomes.
Machinery and stored energy
Balers, shredders, trommels, picking lines and conveyors kill when someone reaches in to clear a blockage without proving the machine is isolated and locked off.
Lithium-ion battery fires
Batteries hidden in mixed waste ignite in collection vehicle bodies, in tipping halls and inside baled stock, often hours or days after the load was made up.
Asbestos in the waste stream
Fly-tipped and mixed loads arrive with bonded and occasionally friable material in them, exposing tipping floor operatives and picking line staff who have no warning.
Bioaerosols and biological agents
Composting, anaerobic digestion feedstock handling and municipal waste sorting release respirable organisms that drive occupational asthma and respiratory disease.
Skips, containers and falls
Loading, sheeting, lifting and access to and from skips and roll-on roll-off containers put people at height and in the drop zone, which is the ground WASTE 06 covers.
The regulations that apply
Your legal framework, in plain terms
The Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999 set the base duties to employees and to members of the public on your sites. The Provision and Use of Work Equipment Regulations 1998 govern balers, shredders and conveyors, including guarding and isolation. The Lifting Operations and Lifting Equipment Regulations 1998 catch skip loaders, hook loaders, grabs and their accessories. The Control of Substances Hazardous to Health Regulations 2002 cover bioaerosols, dusts and contaminated loads. The Control of Asbestos Regulations 2012 apply the moment asbestos is suspected in the waste stream. The Regulatory Reform (Fire Safety) Order 2005 governs fire safety in your buildings and the Environmental Permitting (England and Wales) Regulations 2016 govern your permit, including fire prevention.
What changes for permit holders in 2026
Defra published the Waste Crime Action Plan on 20 March 2026, the largest regulatory shift the sector has seen in a decade. Carriers, brokers and dealers move from simple registration to environmental permitting, with imprisonment of up to five years for operating without one. The Environmental Permitting (Waste Controlling or Transporting) and Relevant Functions of Primary Authorities (Amendment) (England) Regulations 2026 create three new regulated facility classes covering waste controlling, waste transporting and both combined. Commencement and transitional provisions came into force 21 days after the regulations were made. The substantive permitting requirements bite 12 months after making, with a staggered transition for existing registrants. The date that applies to you depends on your current registration.
Three waste permit exemptions have been removed and seven tightened. Fit and proper person tests apply on permit transfers. Digital waste tracking became available in April 2026 and is mandatory from October 2026. If your duty of care paperwork is still a shared spreadsheet and a pile of transfer notes, that arrangement has a fixed expiry date.
Fire safety in waste and recycling
A permit condition and a life safety duty are not the same thing
The Environment Agency guidance on fire prevention plans for environmental permits sets three objectives. Minimise the likelihood of a fire, extinguish any fire within four hours and prevent fire spreading within the site and beyond the boundary. It backs those objectives with dimensions. Piles are capped at 4 metres in height and 20 metres in length and width, with 6 metres of separation between piles and from buildings and site boundaries. You need a quarantine area sized to at least half of the largest pile with 6 metres of clearance around it. Combustible waste should not be stored for more than six months unless you can justify it. A plan is required for new bespoke permits involving combustible waste and may be required on variation.
Here is the caveat that costs operators money. A fire prevention plan is an environmental permitting document. It does not discharge your duty under article 9 of the Fire Safety Order to record a fire risk assessment protecting relevant persons. The two documents answer different questions and we write both so they agree in front of a regulator. Lithium-ion batteries sit across both. The Environment Agency has published appropriate measures guidance for waste batteries at permitted facilities in direct response to the fire risk. Our fire team applies it alongside detection selection in tipping halls, thermal imaging on baled stock and quarantine discipline after a suspected ignition.
How we help
Built around your operation
We work the site as it runs, not as the traffic plan describes it. That means the tipping floor at a delivery peak and the picking line at shift change.
- Transport risk reviews against WASTE 09 and HSG136, covering segregation, reversing, rollaway prevention and public interface at civic amenity sites, feeding into a full workplace transport review where the layout is the problem.
- Machinery safety and isolation audits against WASTE 29 and WASTE 33, testing whether lock off is a written procedure or an actual padlock in a hasp, alongside your PUWER and LOLER regime.
- Skip and container safety assessments against WASTE 06, covering loading, sheeting, access and the drop zone.
- COSHH assessments for bioaerosols, dusts and contaminated loads, with health surveillance triggers set for the exposures you actually have.
- Asbestos arrangements for the waste stream, covering identification at the tipping face, stop work triggers, quarantine and notification, supported by our asbestos survey work.
- Fire risk assessments for site buildings and welfare, plus fire prevention plan review and lithium-ion battery controls.
- Incident investigation and enforcement support when a notice, an intervention letter or a serious injury lands.
Why AL23 Safety
Sector-aware support that gets used
Accountable
If your isolation procedure is being defeated because the blockage clears faster with the guard open, we write that down and say who allowed it.
Practical, not just compliant
We separate the change you can make on Monday from the capital project that needs a shutdown. Waste sites cannot stop taking material while somebody rewrites a manual.
One team, three disciplines
Health and safety, fire safety and fire engineering in-house. The people assessing your baler guarding sit with the people assessing your compartmentation and your permit fire plan.
Nationwide
We support waste and recycling operators across the UK, from single transfer stations to multi-site collection contracts.
Get in touch
Tell us what the site handles and we will tell you what it needs
Send us the permit, the site layout and the material types. We will tell you honestly whether the priority is transport, machinery isolation or fire.
Common questions
Answers, up front
Cannot see your question? Get in touch and we will answer it directly.
Contact usNo. WISH guidance is not law and carries no direct penalty of its own. It is developed with HSE involvement and is recognised as the sector standard. An inspector will use it to judge whether your arrangements are suitable and sufficient under the general duties. Departing from it without a written justification is what gets enforced.
You cannot eliminate them at the tipping face so the controls have to be layered. That means customer communication, load inspection where practical, early detection in tipping halls and on baled stock, defined quarantine space and a procedure that assumes a smouldering load will reignite hours later.
No. The plan is an environmental permitting requirement aimed at protecting the environment and preventing spread. The Fire Safety Order requires a recorded fire risk assessment protecting people in and around your buildings, including welfare units, workshops and offices. Most sites need both.
A single transfer station usually needs a day on site plus reporting. A multi-site collection contract with a MRF and a fleet is programme work, usually best held on a retainer. Our Core retainer starts at £250 per month and rises with scope. Tell us the sites and the material streams and we will price it properly.
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