Recycling & Waste Workers' Comp — Class Codes, Battery Fires and a Class Decoupling from the Market

Quick answer: why is recycling and waste hard to place?

Because it is moving in the opposite direction from the rest of the market. Private industry's injury rate hit 2.3 per 100 full-time workers in 2024, the lowest since 2003 — while materials recovery facility workers rose to 5.8 and solid waste collection to 5.0. Refuse and recyclable material collectors had a fatality rate of 37.4 per 100,000 full-time equivalent workers in 2024, the fifth-highest of any US occupation and roughly eleven times the all-worker rate of 3.3. Layer on lithium-ion battery fires and this stops being a standard-market class entirely.

Sources: BLS Census of Fatal Occupational Injuries and Survey of Occupational Injuries and Illnesses, 2024; EPA 530-R-21-002; NWRA/RRS lithium battery report; OSHA. Reviewed August 2026 by CPR Business Solutions.

Will we write it? Tell us the operation, the state, and roughly where the mod sits — we'll come back within one business day with a straight answer: yes, no, or what we'd need to see. No ACORD, no loss runs, no obligation. Agents and business owners both welcome. Run it past us here.

The scrap codes split four ways, and conflating them is the classic error

There is no single "recycling" class code. NCCI splits the dealer side four ways:

• 8263 — Junk Dealer & Drivers. Applies to risks collecting or handling a miscellaneous line of secondhand materials — bottles, rags, paper, bones, rubber, nonferrous scrap metals and ferrous scrap. Wrecking or salvaging is separately rated.

• 8264 — Container Recycling, Bottle or Can & Drivers. Dealers handling secondhand bottles, paper stock, rags and rubber.

• 8265 — Iron or Steel Scrap Dealer & Drivers. Dealers primarily collecting and handling ferrous scrap for resale.

• 8500 — Metal Scrap Dealer & Drivers. Collection and reduction of nonferrous scrap metals, with no collecting or handling of scrap iron or steel.

The ferrous versus nonferrous line between 8265 and 8500 is the most useful classification point in the class, and it is also where submissions get kicked back: a yard taking both ferrous and nonferrous fits neither cleanly, which is exactly the situation 8263 is written for.

On the collection side the code is 9403 — Garbage, Ashes or Refuse Collection & Drivers, covering public or private collection and transport to reduction or incinerator plants, rendering or fertilizer plants, or dumps. NCCI assigns it Hazard Group F — the top group. Adjacent: 9402 for street cleaning, and 9405 for exclusive mechanical operation, the automated side-loader code that matters because automation is the industry's main frequency-reduction lever.

Florida's NCCI-approved rates effective 1/1/2026 show the spread per $100 of payroll: 9403 at 5.331, 8263 at 4.674, 9402 at 4.144, 8500 at 3.923, 8264 at 3.822, 8265 at 3.218. Collection prices materially above every processing and dealer code — consistent with the fatality data below. It is a road-exposure class, not a factory class.

Two things to be careful about. State phraseology diverges materially even where the code number is the same — New Jersey's 8264 reads "Bottle Dealer, Used"; New York's reads "Bottle, Rubber, Paper Stock or Rag Dealer, Secondhand"; California's 8264 is "Paper Stock Dealers"; Michigan's is "Can Sorting, Recycle." And more significantly: there is no dedicated NCCI code for a materials recovery facility or a transfer station. In NCCI states, MRF and transfer-station operations get pulled into 9403 or one of the dealer codes depending on the governing operation. The fastest-growing part of the industry has no code of its own in most of the country.

California is the exception. The WCIRB maintains a classification titled Garbage or Refuse Landfill, Transfer Station and Material Recovery Facility Operations, plus separate classifications for recycled material dealers, metal scrap dealers, iron and steel merchants, garbage collection and document destruction. Pull the code numbers from the WCIRB Standard Classification System directly rather than assuming the NCCI numbers carry — California also runs a live classification dispute between garbage collection and trucking that the WCIRB has written about specifically, and which side of it an account lands on materially changes the rate.

The numbers that make it an outlier class

Refuse and recyclable material collectors recorded a fatality rate of 37.4 per 100,000 full-time equivalent workers in 2024 on 36 deaths — the fifth-highest of any US civilian occupation, behind logging, fishing and hunting, roofing, and structural iron and steel. That was an improvement from 41.4 and fourth place in 2023, but it is still up around 65% from 22.6 in 2022. Against an all-worker rate of 3.3, collectors die at roughly eleven times the national rate.

Transportation incidents accounted for 38.2% of all occupational fatalities in this group in 2024 — which is why 9403 prices the way it does. Within the sector, solid waste collection recorded 32 fatalities (23 of them transportation-related) and MRFs 8 (4 transportation-related).

On the nonfatal side, the divergence is the whole argument. In 2024:

• Private industry overall: 2.3 total recordable cases per 100 full-time workers — the lowest since 2003.

• MRF workers: 5.8, up from 4.4 in 2022 — about 2.5 times private industry.

• Solid waste collection: 5.0, up from 4.3 in 2023.

• Landfill: 2.8, down from 3.1 in 2023 — the one part of the sector improving.

General industry hit a twenty-year low while MRF and collection rates rose. A carrier looking at its book sees this class decoupling, and prices accordingly.

What actually injures these workers

OSHA's own case narratives for the sector describe the collection exposure exactly: a worker collecting recyclable materials exited the truck, walked to the rear, and was crushed when the truck rolled backwards. Another was in the bed of a container truck removing debris when a bulldozer dumped a load into the bed and asphyxiated him. Backing and struck-by on the route is the fatality mechanism.

Inside the facility the picture is different. Needlesticks on the sorting line are far more significant than most agents realise: a study of 35 MRFs across the US and Canada found an overall needlestick injury rate of 2.7 per 100 workers, rising to 3.9 per 100 for picking-line workers, and estimated 781 to 1,484 needlestick injuries per year at US MRFs at a cost of up to $2.25 million annually. Against a MRF injury rate of roughly 6 per 100 at the time, the study suggested around 45% of MRF injuries may be needlestick-related.

The rest of the facility exposure is machine-driven: baler and conveyor caught-in and amputation, sorting-line lacerations, heavy equipment struck-by, and silica and dust on construction-and-demolition debris and aggregate crushing lines. OSHA's own hazard list for the sector adds traffic safety, unexpected machine startup, lifting injuries, slips and falls, and exposure to scrap metal, electronics, batteries, used oil and chemicals.

The baler is the fatality machine, and OSHA has the citations to prove it

Two OSHA standards sit directly on top of a baler-and-conveyor operation, and both were in the national top ten most-cited standards in fiscal 2025: 29 CFR 1910.147 (control of hazardous energy — lockout/tagout) at fourth, and 29 CFR 1910.212 (machine guarding) at tenth.

NIOSH documented 34 compactor-related deaths between 1992 and 2000 and investigated 20 compactor fatalities through 2002. The causal pattern is remarkably consistent, and it is the claim narrative you will read on these accounts: workers entering compression chambers to clear jams without de-energizing the machine; malfunctioning or deliberately bypassed safety interlocks; automatic cycling while a worker is inside; a coworker activating the machine unaware someone is in it; workers falling into chambers while clearing jams.

The NIOSH publication is from 2003, but it remains the authoritative federal document on the mechanism, and nothing about the mechanism has changed. A submission that includes the written LOTO procedure, the interlock inspection log, and jam-clearing training is answering a question the underwriter was going to ask anyway.

There is no OSHA National Emphasis Program specific to waste and recycling — worth knowing, because it is often asserted. There is a Region VIII Local Emphasis Program for scrap and recycling industries covering used auto parts wholesalers, recyclable material merchant wholesalers, solid waste landfills and other nonhazardous waste treatment, targeting fires and explosions, falls, harmful substance exposure, caught-in and struck-by hazards, confined space, lockout/tagout deficiencies, electrical, noise and heavy metal exposure. Confirm its current status with OSHA Region VIII before relying on it; the published directive's own dates are inconsistent.

The better citation is cooperative rather than enforcement: OSHA's Alliance with the National Waste & Recycling Association and SWANA, signed in 2019 and most recently renewed in August 2025, names its focus hazards outright — transportation hazards including backovers and distracted driving, slips trips and falls, needlestick injuries, heat and cold stress, musculoskeletal injuries, and lithium battery hazards in waste collection and processing. That is the federal hazard list underwriters are working from.

Lithium-ion fires changed how the whole account is underwritten

This is the dominant issue in the class, and it is important to be precise about which line it has repriced.

The EPA's 2021 study found 245 fires at 64 waste management facilities between 2013 and 2020, across 28 states and all ten EPA regions, and reported that 78% of the MRFs it identified had called emergency responders at least once in the prior seven years. The EPA explicitly notes undercounting, since not all incidents are made public.

The industry tracking dataset covering publicly reported fires in the US and Canada recorded 448 fires in 2025 — an all-time record, against 430 in 2024 and 373 in 2023, with 2025 damage around $2.5 billion including roughly 100 catastrophic events. Early 2026 is running worse: 56 incidents in January and February, with February 2026 the worst February on record since tracking began in 2016. Note the methodology when you cite it — it tracks publicly reported incidents, generally two-alarm or greater, so the true count is far higher.

A 2024 NWRA and RRS report put the operational reality in terms that explain the underwriting response: more than 5,000 fires occur annually at recycling facilities, averaging more than 18 per MRF per year across roughly 300 US facilities; more than 1% of MRFs experience a catastrophic loss every year, and the rate of catastrophic losses rose 41% over five years. Small fires cost around $2,600; catastrophic fires average $22 million. Property insurance rates went from $0.15–$0.18 per $100 of insured value to $1.80–$10.00 — a ten to fiftyfold increase. Each MRF receives dozens of misplaced lithium batteries every day.

Those are property figures, not workers' comp figures, and it is worth not blurring them. What flows into comp is the sorting-line consequence — burns and smoke inhalation to workers standing at the picking line when a cell goes into thermal runaway, plus the evacuation and egress exposure — and the fact that the same underwriting scrutiny now applies across the whole account. Carriers now evaluate system design, containment and firewalls, third-party monitoring analytics, early-detection systems and operational practice. The underwriting question has shifted from whether an event will occur to whether it will stay contained.

One thing we will not publish is a percentage of fires attributable to lithium-ion batteries. No credible source produces one — the industry itself concedes that quantifying battery-related fires is an imperfect science and that underreporting is a significant barrier. Use the counts and the EPA framing instead. The root-cause point that does hold up: mechanical damage during ordinary waste handling triggers ignition regardless of battery quality, which is why disposable vapes and nitrous canisters entering the stream matter more than battery chemistry.

What 2026 does to the premium base

Seven states have enacted packaging extended producer responsibility laws, and the compliance calendar is now live. Oregon's program began July 1, 2025 — the first operational EPR program in the US — and Colorado required producers to join a producer responsibility organisation by the same date. Maine, Maryland and Washington all have 2026 registration and onboarding milestones; Minnesota runs 2025–2026 limited registration ahead of 2027 operations; California producers must join a PRO by January 1, 2027.

EPR shifts funding toward MRFs, which drives throughput, capital investment, retrofits and headcount at exactly the facilities already generating the worst loss experience. Rising payroll in 9403, 8263 and 8264 with unchanged hazards means premium growth without loss-ratio improvement — which is not the same thing as a market softening.

The labor side compounds it. Recycling economists have flagged that changes in immigration policy have reduced the labor pool in a significant way in certain sectors, against a backdrop of tariffs reshaping commodity markets and low recycling commodity prices into 2026. A tighter labor pool in a high-turnover, high-hazard manual class means more green employees on sorting lines and in cabs — and new-hire tenure is the classic frequency driver.

What a recycling submission needs

• Payroll split by operation — collection route, sorting line, baler and equipment operation, yard, admin — with the governing operation identified.

• Ferrous versus nonferrous mix for a scrap yard, since it decides between 8265, 8500 and 8263.

• Written lockout/tagout procedure, interlock inspection records, and jam-clearing training documentation.

• The fire story: battery removal protocol, thermal detection and suppression systems, monitoring service, containment and separation, and the fire loss history whether or not it produced a comp claim.

• Sharps protocol for the picking line — cut-resistant and puncture-resistant gloves, sharps containers, post-exposure procedure and hepatitis B vaccination policy.

• For collection: backing policy, camera and telematics deployment, route safety program, and the automation mix between manual and mechanical loading.

Recycling and waste workers' comp FAQ

What class code applies to a materials recovery facility?

In most of the country, none specifically — there is no dedicated NCCI code for a MRF or a transfer station. Operations get pulled into 9403 (garbage, ashes or refuse collection) or one of the dealer codes depending on the governing operation. California is the exception, with a WCIRB classification covering landfill, transfer station and material recovery facility operations.

What is the difference between class 8265 and 8500?

Ferrous versus nonferrous. 8265 is for dealers primarily collecting and handling iron and steel scrap; 8500 is nonferrous metal scrap with no scrap iron or steel handling. A yard taking both fits neither cleanly and usually belongs in 8263, Junk Dealer, which is written for a miscellaneous line of secondhand materials including both.

How dangerous is waste collection compared to other jobs?

Refuse and recyclable material collectors had a fatality rate of 37.4 per 100,000 full-time equivalent workers in 2024 — the fifth-highest of any US occupation, roughly eleven times the all-worker rate of 3.3. Transportation incidents accounted for 38.2% of fatalities in the group, which is why the collection code prices well above the processing codes.

Are needlesticks really a problem at recycling facilities?

Yes, and they are badly underappreciated. A study of 35 MRFs found an overall needlestick rate of 2.7 per 100 workers, rising to 3.9 per 100 on the picking line, with an estimated 781 to 1,484 injuries per year at US MRFs. The study suggested roughly 45% of MRF injuries may be needlestick-related.

How do lithium-ion battery fires affect workers' comp specifically?

Directly, through burns and smoke inhalation to sorting-line workers and evacuation exposure; indirectly, and more importantly, because the fire problem has repriced property so sharply — rates went from roughly $0.15 per $100 of insured value to as much as $10.00 — that the same underwriting scrutiny now applies across the whole account. Carriers evaluate containment, detection and monitoring before they price anything.

Send us a recycling or waste account

Send the payroll split by operation, currently valued loss runs, the fire and safety documentation, and the mod worksheet. Email proposals@cprbrokers.com or call 714-928-3858. CPR Business Solutions is a wholesale workers' comp MGA placing hard-to-write accounts since 2021.

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