Pulp & Paper Mill Safety Manual

A Pulp & Paper Mill Safety Manual provides written occupational safety and health programs, procedures, and responsibilities for pulp mills, paper mills, paperboard mills, integrated pulp and paper facilities, and other employers involved in manufacturing or converting pulp, paper, and paperboard products.

Pulp and paper employees may work around pulpwood, conveyors, barkers, chippers, digesters, tanks, chemical systems, bleaching equipment, stock-preparation machinery, paper machines, dryers, reels, winders, rewinders, cutters, cranes, forklifts, clamp trucks, boilers, pressure systems, and other heavy industrial equipment.

These operations can expose employees to serious hazards including crushing, caught-in and caught-between hazards, hazardous energy, moving machinery, large rolls, chemicals, high temperatures, pressure, confined spaces, falls, noise, respiratory hazards, fires, explosions, and mobile equipment.

An effective Pulp & Paper Mill Safety Manual should therefore reflect the mill’s actual manufacturing processes, equipment, chemicals, material-handling systems, maintenance activities, and employee duties.

OSHA Pulp, Paper and Paperboard Mill Requirements

Federal OSHA maintains specific requirements for pulp, paper, and paperboard mills under 29 CFR 1910.261.

The standard applies to establishments where pulp, paper, and paperboard are manufactured and converted and contains requirements addressing numerous mill operations and hazards.

Depending on the facility, applicable requirements may address:

  • Pulpwood handling.
  • Material storage.
  • Conveyors.
  • Pulpwood preparation.
  • Barking equipment.
  • Chemical processes.
  • Bleaching.
  • Mechanical pulp processes.
  • Stock preparation.
  • Paper machine rooms.
  • Finishing rooms.
  • Materials handling.
  • Machine guarding.
  • Lockout and hazardous-energy control.
  • Personal Protective Equipment.

Other OSHA General Industry standards may also apply according to the mill’s operations and employee exposures.

What Should a Pulp & Paper Mill Safety Manual Include?

The contents of a Pulp & Paper Mill Safety Manual should reflect the work actually performed.

Depending on operations, the manual may address:

  • Pulp and paper safety responsibilities.
  • Hazard assessments.
  • Job Safety Analysis (JSA/JHA).
  • Pulpwood handling.
  • Conveyor safety.
  • Barking and chipping.
  • Pulp processing.
  • Chemical-process safety.
  • Bleaching operations.
  • Stock preparation.
  • Paper machine safety.
  • Machine guarding.
  • Lockout/Tagout.
  • Rolls and reels.
  • Winders and rewinders.
  • Slitters and cutters.
  • Preventive maintenance.
  • Confined spaces.
  • Chemical safety.
  • Hazard Communication.
  • Process Safety Management when applicable.
  • Respiratory protection.
  • Personal Protective Equipment.
  • Hearing Conservation.
  • Material handling.
  • Cranes and hoists.
  • Powered Industrial Trucks.
  • Fire prevention.
  • Emergency procedures.

Programs should be selected according to the mill’s processes, machinery, chemicals, raw materials, products, and employee exposures.

Pulp & Paper Mill Safety Program

An effective Pulp and Paper Safety Program establishes responsibilities and procedures for controlling machinery, hazardous energy, chemicals, pressure, heat, material handling, mobile equipment, and other mill hazards.

Management should provide employees with properly guarded equipment, safe work procedures, appropriate PPE, training, supervision, preventive maintenance, emergency procedures, and the resources necessary to perform work safely.

Managers, supervisors, and designated safety personnel should:

  • Identify and evaluate workplace hazards.
  • Maintain applicable written safety programs.
  • Establish safe operating procedures.
  • Maintain machine guards and safety devices.
  • Establish hazardous-energy procedures.
  • Evaluate chemical and process hazards.
  • Maintain ventilation and exposure controls.
  • Provide appropriate PPE.
  • Maintain material-handling equipment.
  • Coordinate contractors.
  • Correct unsafe conditions.
  • Investigate incidents.
  • Provide employee training.
  • Maintain applicable records.

Employees should follow established procedures, use guards and safety devices, wear required PPE, follow hazardous-energy controls, handle chemicals safely, and promptly report unsafe conditions, equipment defects, chemical releases, injuries, and other hazards.

Mill Hazard Assessments

Hazard assessments should consider each stage of mill operations.

Potential areas include:

  • Pulpwood receiving.
  • Raw-material storage.
  • Debarking.
  • Chipping.
  • Conveying.
  • Pulping.
  • Chemical recovery.
  • Bleaching.
  • Stock preparation.
  • Paper production.
  • Drying.
  • Winding.
  • Cutting.
  • Finishing.
  • Roll handling.
  • Warehousing.
  • Shipping.
  • Maintenance.

Potential hazards may include:

  • Crushing.
  • Entanglement.
  • Nip points.
  • Amputation.
  • Hazardous energy.
  • Chemical exposure.
  • High pressure.
  • Hot surfaces.
  • Steam.
  • Confined spaces.
  • Falls.
  • Noise.
  • Respiratory hazards.
  • Fire and explosion.
  • Mobile equipment.

Assessments should be reviewed when equipment, processes, chemicals, or facility conditions change.

Job Safety Analysis (JSA/JHA)

A JSA/JHA may be used to evaluate higher-risk mill activities.

Potential JSAs/JHAs may address:

  • Pulpwood unloading.
  • Conveyor maintenance.
  • Barker and chipper maintenance.
  • Digester work.
  • Tank and vessel entry.
  • Chemical handling.
  • Paper-machine maintenance.
  • Roll changes.
  • Winder and rewinder operation.
  • Slitter-knife changes.
  • Hot Work.
  • Crane and rigging operations.
  • Loading and unloading.

The analysis should identify job steps, hazards, controls, PPE, and employee responsibilities.

Pulpwood Receiving

Pulpwood receiving areas can expose employees to large, heavy, and unstable materials.

Potential hazards include:

  • Falling logs.
  • Rolling logs.
  • Sliding material.
  • Trucks.
  • Railcars.
  • Cranes.
  • Mobile equipment.
  • Conveyors.

Employees should remain outside areas where uncontrolled pulpwood movement could strike or crush them.

Pulpwood Storage

Pulpwood should be stored to maintain stable piles and reduce the potential for uncontrolled movement.

Procedures should address:

  • Pile stability.
  • Employee access.
  • Mobile equipment.
  • Fire protection.
  • Traffic.
  • Loading and unloading.

Employees should not work in locations where unstable material could roll, slide, or fall onto them.

Log and Pulpwood Unloading

Unloading procedures should establish safe positions for employees before loads are released.

Employees should remain clear of:

  • Unstable logs.
  • Trailer loads.
  • Railcar loads.
  • Unloading equipment.
  • Suspended loads.

Load restraints should be released using procedures that protect employees from shifting material.

Pulpwood Conveyors

Pulpwood conveyors may expose employees to:

  • In-running nip points.
  • Chains.
  • Sprockets.
  • Drums.
  • Belts.
  • Falling material.

Required guarding should remain in place.

Emergency stopping provisions should be maintained and employees should understand how to use them.

Conveyor Safety

Conveyors throughout the mill may transport:

  • Pulpwood.
  • Chips.
  • Pulp.
  • Broke.
  • Finished material.
  • Waste.

Potential hazards include:

  • Nip points.
  • Entanglement.
  • Crushing.
  • Falling material.
  • Unexpected startup.

Employees should not climb, walk, sit, or ride on conveyors unless specifically designed and authorized for that purpose.

Conveyor Jam Clearing

Employees should not reach into hazardous conveyor areas to clear jams while unexpected movement is possible.

Applicable hazardous energy should be isolated before employees enter danger areas.

Emergency-stop devices should not be treated as substitutes for required Lockout/Tagout.

Barking Operations

Barkers can expose employees to:

  • Rotating equipment.
  • Moving logs.
  • Flying material.
  • Noise.
  • Mechanical hazards.

Feed and turnover systems should be used so employees do not need to manually hold logs or bolts during barking operations.

Required eye, head, and hearing protection should be used.

Barker Maintenance

Before employees change knives, perform repairs, or enter hazardous equipment areas, control devices should be appropriately locked out or otherwise controlled according to applicable procedures.

Employees should not rely solely on normal operating controls.

Chipping Operations

Chippers can cause severe or fatal injuries.

Potential hazards include:

  • Cutting equipment.
  • Feed systems.
  • Flying wood.
  • Mechanical energy.
  • Noise.
  • Dust.

Feed systems and guarding should prevent employee access to hazardous cutting components.

Chipper Jam Clearing

Chippers should be shut down and hazardous energy controlled before employees enter hazardous areas to remove blockages or perform maintenance.

Employees should recognize that large rotating components may continue moving after power is removed.

Working Over or Near Water

Some pulpwood handling operations may involve ponds, waterways, docks, or other locations where employees work over or near water.

Appropriate protection should be provided where drowning hazards exist.

Walking surfaces, handrails, access routes, rescue equipment, and personal flotation devices should be addressed where applicable.

Raw Material Handling

Mills may handle materials in forms including:

  • Pulp.
  • Paper rolls.
  • Bales.
  • Chemicals.
  • Wood chips.
  • Recycled fiber.
  • Additives.

Storage and handling procedures should prevent falling, shifting, or unstable materials.

Pulp and Paper Roll Storage

Large pulp and paper rolls can create severe crushing hazards if they move unexpectedly.

Roll-storage procedures should address:

  • Chocking.
  • Floor conditions.
  • Stack configuration.
  • Roll movement.
  • Equipment access.
  • Employee positioning.

Rolls should be secured against uncontrolled movement.

Chocking Rolls

Where required, rolls should be appropriately chocked to prevent shifting.

Employees should not place themselves in the anticipated path of a roll while installing or removing chocks.

Damaged or unsuitable chocks should not be used.

Pulping Operations

Pulping processes may involve:

  • Mechanical systems.
  • Chemical systems.
  • Digesters.
  • Tanks.
  • Pressure vessels.
  • Pumps.
  • Piping.
  • Steam.
  • High temperatures.

Safety procedures should reflect the particular pulping process used by the facility.

Chemical Pulping

Chemical pulping may involve hazardous:

  • Chemicals.
  • Gases.
  • Pressure.
  • Heat.
  • Liquors.
  • Process vessels.

The specific hazards depend on the mill’s process and chemical systems.

Employees should receive task-specific training for the chemicals and process equipment with which they work.

Digesters

Digesters and associated equipment may involve:

  • High temperature.
  • Pressure.
  • Steam.
  • Chemical exposure.
  • Hazardous gases.
  • Confined-space hazards.

Employees should not open, enter, inspect, or service digesters until applicable pressure, chemical, temperature, and hazardous-energy controls have been implemented.

Digester Piping

Piping, valves, and fittings associated with digesters and blow systems should be inspected and maintained.

Employees should promptly report:

  • Leakage.
  • Corrosion.
  • Damaged valves.
  • Abnormal pressure.
  • Other indications of deterioration.

Blow Lines and Blow Pits

Blow lines and related systems can contain high-temperature and high-pressure process material.

Before inspection, repair, or other servicing, applicable valves and lines should be isolated, locked or tagged, disconnected, blanked, or otherwise protected as required.

Pressure Systems

Process pressure can remain after normal equipment shutdown.

Before employees loosen piping, open vessels, remove covers, or perform maintenance:

  • Pressure should be relieved.
  • Hazardous material should be isolated.
  • Stored energy should be controlled.
  • Equipment condition should be verified.

Employees should not assume a pressure gauge reading alone establishes that a system is safe to open.

Tanks and Vessels

Tanks, chests, vessels, and similar process equipment may contain:

  • Chemicals.
  • Process liquids.
  • Toxic gases.
  • Oxygen-deficient atmospheres.
  • Mechanical equipment.

Entry and maintenance procedures should address all applicable hazards.

Tank Isolation

Before employees enter or perform work where process materials could enter a tank or vessel, piping should be appropriately isolated.

Depending on the system, isolation may include:

  • Blanking.
  • Blinding.
  • Disconnecting.
  • Locking or tagging valves.
  • Other effective isolation.

Confined Spaces

Pulp and paper mills may contain numerous confined spaces.

Potential examples include:

  • Tanks.
  • Vessels.
  • Pits.
  • Chests.
  • Digesters.
  • Process equipment.
  • Vaults.

The employer should evaluate spaces and implement Permit-Required Confined Space procedures where applicable.

Permit-Required Confined Spaces

Where a space meets applicable permit-required criteria, procedures should address:

  • Entry authorization.
  • Hazard evaluation.
  • Atmospheric testing.
  • Isolation.
  • Ventilation.
  • Entrant duties.
  • Attendant duties.
  • Communication.
  • Rescue.
  • Entry termination.

Employees should not enter permit spaces without authorization.

Atmospheric Hazards

Potential confined-space atmospheres may involve:

  • Oxygen deficiency.
  • Toxic gases.
  • Flammable atmospheres.
  • Process chemicals.
  • Decomposition products.

Atmospheric testing should reflect the potential hazards of the particular space.

Confined Space Rescue

Rescue arrangements should be established before permit-space entry begins.

Rescue planning should consider:

  • Space configuration.
  • Access.
  • Atmospheric hazards.
  • Retrieval.
  • Chemical exposure.
  • Emergency medical response.

Employees should not make uncontrolled entries to rescue coworkers.

Chemical Recovery Operations — When Applicable

Chemical pulp mills may use recovery processes involving significant:

  • Heat.
  • Pressure.
  • Chemicals.
  • Combustion.
  • Process gases.

Safety procedures should reflect the mill’s specific recovery system and employee exposures.

Smelt Hazards — When Applicable

Certain recovery operations can involve molten smelt and extreme temperatures.

Employees should be protected from:

  • Burns.
  • Splash.
  • Explosive reactions.
  • Process upset.
  • Hot surfaces.

Applicable process controls, barriers, PPE, and emergency procedures should be maintained.

Smelt-Dissolving Tanks — When Applicable

Smelt-dissolving tanks and associated equipment should be operated and maintained according to applicable requirements and facility procedures.

Covers, vents, and explosion-relief provisions should be maintained where required.

Employees should remain clear of hazardous exposure areas.

Hydrogen Sulfide — When Applicable

Certain pulp and paper processes can generate or involve hydrogen sulfide.

Where potential exposure exists, the facility should evaluate:

  • Sources.
  • Employee exposure.
  • Ventilation.
  • Monitoring.
  • Alarm systems.
  • Respiratory protection.
  • Emergency procedures.

Hydrogen sulfide should not be treated as a universal exposure at every pulp or paper facility.

Turpentine and Combustible Vapors — When Applicable

Some pulp processes can produce or collect turpentine or other combustible vapors.

Systems should be operated and maintained to prevent:

  • Leaks.
  • Vapor accumulation.
  • Ignition.
  • Fire.
  • Explosion.

Hot Work involving vessels that may contain combustible vapors should not begin until required cleaning, purging, testing, and other controls have been completed.

Bleaching Operations — When Applicable

Pulp bleaching may involve hazardous oxidizing or corrosive chemicals.

Procedures should address the specific bleaching chemicals and equipment used by the mill.

Potential controls may include:

  • Ventilation.
  • Chemical isolation.
  • PPE.
  • Emergency eyewash and shower facilities.
  • Respiratory protection.
  • Emergency response.

Chlorine — When Applicable

Some facilities or processes may involve chlorine.

Where chlorine is present, procedures should address:

  • Storage.
  • Piping.
  • Ventilation.
  • Leak detection.
  • Employee training.
  • Respiratory protection.
  • Emergency response.

Chlorine should not be assumed to be present at every modern pulp and paper mill.

Chlorine Storage — When Applicable

Where liquid chlorine is stored, applicable storage areas should be appropriately ventilated and arranged so leakage does not expose employees.

Emergency access and egress should be maintained.

Piping should be clearly identified.

Chlorine Emergency Response — When Applicable

Employees assigned to emergency or rescue operations involving chlorine should be provided with respiratory protection appropriate to the hazard and assigned duties.

Emergency procedures should address:

  • Alarm.
  • Evacuation.
  • Isolation.
  • Emergency communication.
  • Trained response personnel.
  • Medical evaluation.

Employees without appropriate training and protection should evacuate rather than attempt emergency response.

Oxidizing Chemicals — When Applicable

Oxidizing chemicals used in bleaching or sanitizing may require special storage and handling.

Procedures should prevent contamination and incompatible storage.

Applicable oxidizers should be kept away from materials with which they can react dangerously.

Chemical Storage

Chemical storage should reflect:

  • Chemical compatibility.
  • Container requirements.
  • Ventilation.
  • Secondary containment where appropriate.
  • Ignition control.
  • Employee access.
  • Emergency response.

Containers and process piping should be properly identified.

Hazard Communication

A Hazard Communication Program should address hazardous chemicals used throughout mill operations.

Applicable elements may include:

  • Chemical inventory.
  • Labels.
  • Safety Data Sheets.
  • Employee training.
  • Non-routine tasks.
  • Process chemicals.
  • Maintenance chemicals.

Employees should understand how to obtain chemical hazard information before beginning work.

Process Safety Management — When Applicable

Certain pulp and paper facilities may possess highly hazardous chemicals in quantities that trigger OSHA’s Process Safety Management requirements.

Where applicable, a Process Safety Management program may address:

  • Process safety information.
  • Process hazard analysis.
  • Operating procedures.
  • Employee training.
  • Contractor safety.
  • Pre-startup safety review.
  • Mechanical integrity.
  • Hot Work.
  • Management of Change.
  • Incident investigation.
  • Emergency planning.
  • Compliance audits.

PSM applicability should be determined from the chemicals, quantities, processes, and applicable regulatory criteria at the individual facility.

Management of Change — When Applicable

Facilities subject to PSM should evaluate covered changes involving:

  • Chemicals.
  • Process technology.
  • Equipment.
  • Procedures.
  • Facilities.

Safety information and employee training should be updated as required before affected changes are implemented.

Mechanical Pulping

Mechanical pulping operations may expose employees to:

  • Grinders.
  • Rotating machinery.
  • Saw hazards.
  • Falling material.
  • Noise.
  • Wet surfaces.

Required guarding and PPE should be maintained.

Pulp Grinders

Pulp grinders should be operated within applicable equipment limitations.

Employees should remain clear of hazardous rotating components.

Doors, guards, and protective devices should be maintained.

Stock Preparation

Stock-preparation operations may involve:

  • Pulp shredders.
  • Conveyors.
  • Beaters.
  • Agitators.
  • Pumps.
  • Refiners.
  • Other processing equipment.

Machinery should be guarded and employees protected from hazardous moving components.

Pulp Shredders

Pulp-shredder cutting heads should be appropriately enclosed.

Employees should not reach into feed or cutting areas.

Cleaning blockages and repairs should be performed only after the shredder is shut down and hazardous controls are appropriately locked.

Refiners and Beaters

Refiners, beaters, and similar equipment may contain powerful rotating components.

Covers and guards should remain in place.

Employees should not access hazardous internal components while unexpected movement is possible.

Paper Machine Safety

Paper machines contain numerous moving rolls, dryers, drives, shafts, nips, and other components capable of causing severe or fatal injuries.

Potential hazards include:

  • Crushing.
  • Entanglement.
  • In-running nips.
  • Rotating shafts.
  • Hot surfaces.
  • Steam.
  • Falls.
  • Unexpected startup.

Employees should receive machine-specific training before performing assigned paper-machine duties.

Paper Machine Emergency Stops

Paper machines should have emergency stopping devices as required.

Employees should know:

  • Device locations.
  • How to activate them.
  • Their purpose.
  • Their limitations.

Emergency stopping devices should be periodically tested according to applicable requirements and facility procedures.

Emergency Stop vs. Lockout/Tagout

An emergency-stop button or pull cord can stop equipment quickly but does not necessarily isolate hazardous energy.

Employees performing covered servicing or maintenance should use required hazardous-energy procedures even when the machine has already been stopped.

Paper Machine Drives

Paper-machine drives and exposed rotating shafts should be appropriately guarded.

Lockout devices should be available at applicable power switches.

Employees should not reach across exposed drive systems.

In-Running Nip Points

Paper machines contain numerous locations where rotating rolls create in-running nip hazards.

Employees should keep:

  • Hands.
  • Clothing.
  • Tools.
  • Cleaning materials.

away from operating nips.

Required guards and safe threading or feeding devices should be used.

Feeding Paper

Employees should use appropriate belts, carrier ropes, air systems, or other effective methods for starting paper into hazardous nips or drum-type reels.

Employees should not manually feed material into hazardous nip points.

Paper Machine Walkways

Machine access areas should provide safe walking and working surfaces.

Walkways should be maintained:

  • Clear.
  • Nonslip.
  • Appropriately guarded.
  • Adequately illuminated.

Employees should not use machine components as improvised access platforms.

Dryer Sections

Paper-machine dryers may expose employees to:

  • Hot surfaces.
  • Steam.
  • Rotating shafts.
  • Gears.
  • Nip points.
  • Elevated work.

Required guards should remain in place.

Lubrication and maintenance should be performed using methods that protect employees from heat and moving equipment.

Dryer Maintenance

Before employees enter hazardous dryer areas or perform covered maintenance, applicable hazardous-energy procedures should be followed.

Employees should account for:

  • Electrical energy.
  • Mechanical movement.
  • Steam.
  • Pressure.
  • Heat.
  • Gravity.

Reels

Reels can be extremely heavy and contain substantial stored rotational energy.

Reels should stop rotating before they are lifted from their bearings.

Lifting equipment should be inspected and maintained.

Employees should remain clear of suspended reels.

Reel Lifting

Equipment used for lifting reels may include:

  • Clamps.
  • Cables.
  • Slings.
  • Hoists.
  • Cranes.

Lifting devices should be appropriate for the load and maintained in safe condition.

Winders and Rewinders

Winders and rewinders can expose employees to severe in-running nip and roll-handling hazards.

Applicable nip points should be guarded.

Where required, barrier guards should be interlocked with machine drives.

Employees should not bypass winder guarding.

Winder Area

Walking surfaces around winders should provide secure footing.

Paper, broke, water, oil, and other material should not be allowed to create slip hazards in employee work areas.

Winder Roll Handling

Mechanical lifting devices should be used where required or appropriate for placing and removing heavy rolls.

Employees should remain clear of potential roll movement.

Core Shafts

Core shafts can be heavy and awkward.

Mechanical handling devices should be used when shaft weight or configuration makes manual handling unsafe.

Employees should avoid unnecessary lifting and awkward posture.

Slitter Knives

Slitter knives can cause severe lacerations.

Applicable knives should be guarded against accidental contact.

Appropriate carriers should be used for transporting slitter knives.

Employees should use appropriate hand protection when handling exposed blades.

Knife Changes

Before changing knives:

  • Stop equipment.
  • Control hazardous energy.
  • Secure moving components.
  • Use appropriate blade carriers.
  • Wear task-appropriate PPE.

Employees should not leave exposed knives where they can contact other employees.

Finishing Operations

Finishing rooms may contain:

  • Winders.
  • Rewinders.
  • Cutters.
  • Embossers.
  • Roll splitters.
  • Packaging equipment.
  • Conveyors.

Each machine should be evaluated for point-of-operation, nip, cutting, crushing, and hazardous-energy hazards.

Cleaning Rolls

Roll-cleaning procedures should protect employees from in-running nip points.

Where permitted by applicable procedures, cleaning should be performed from the safer outrunning side of rolls.

Employees should never wrap cleaning material around hands or fingers near rotating machinery.

Guillotine Cutters

Guillotine-type cutters can cause severe amputations.

Applicable machines should have required controls and nonrepeat protection.

Knife handling should be performed using appropriate carriers and safe procedures.

Rotary Cutters

Rotary cutters should be guarded to prevent accidental contact with knives and nip points.

Safe access should be provided where employees must reach cutter components for maintenance.

Embossers

Embossing rolls can create severe nip hazards.

Operator-side nipping points should be guarded as required.

Employees should not bypass interlocked protective devices.

Roll Splitters

Roll splitters may expose employees to cutting and nip hazards.

Appropriate guarding should prevent access to the cutter knife and hazardous nip points during operation.

Machine Guarding

Machinery throughout pulp and paper operations should be evaluated for:

  • Rotating shafts.
  • Gears.
  • Chains.
  • Sprockets.
  • Belts.
  • Nip points.
  • Cutting equipment.
  • Reciprocating equipment.

Required guards should remain installed and functional.

Lockout/Tagout

Hazardous energy is one of the most significant hazards in pulp and paper mills.

Applicable energy-control procedures should be followed during covered:

  • Maintenance.
  • Inspection.
  • Cleaning.
  • Adjustment.
  • Repair.
  • Jam clearing.
  • Blade changes.
  • Equipment entry.

Potential energy sources may include:

  • Electrical.
  • Mechanical.
  • Hydraulic.
  • Pneumatic.
  • Steam.
  • Pressure.
  • Gravity.
  • Thermal energy.
  • Process materials.

Equipment Isolation

Employees should identify all hazardous energy sources before work begins.

Complex mill equipment may require isolation of multiple:

  • Electrical disconnects.
  • Valves.
  • Hydraulic systems.
  • Pneumatic systems.
  • Process lines.
  • Mechanical drives.

Normal control switches should not be relied upon for hazardous-energy isolation.

Stored Energy

Stored energy should be relieved, restrained, blocked, dissipated, or otherwise controlled.

Potential sources include:

  • Pressure.
  • Steam.
  • Hydraulic accumulators.
  • Raised equipment.
  • Rotating equipment.
  • Tensioned rolls.
  • Process materials.

Employees should verify isolation before beginning work.

Group Lockout/Tagout

Large mill maintenance activities may involve multiple employees, departments, crafts, or contractors.

Group energy-control procedures should provide each authorized employee with protection equivalent to personal lockout.

Responsibilities should be clearly coordinated.

Shift Changes

Where servicing continues across shifts, procedures should maintain continuous hazardous-energy protection during employee transitions.

Locks should not be removed without following established procedures.

Preventive Maintenance

Preventive maintenance should address safety-critical equipment and systems.

Inspections may include:

  • Machine guards.
  • Interlocks.
  • Emergency stops.
  • Conveyors.
  • Piping.
  • Valves.
  • Pressure systems.
  • Lifting equipment.
  • Ventilation.
  • Chemical systems.
  • Mobile equipment.

Identified defects should be corrected promptly.

Mechanical Integrity — When Applicable

Facilities subject to Process Safety Management should maintain applicable process equipment according to PSM mechanical-integrity requirements.

Equipment may include:

  • Pressure vessels.
  • Storage tanks.
  • Piping systems.
  • Relief systems.
  • Emergency shutdown systems.
  • Controls.
  • Pumps.

Inspection and testing should follow applicable procedures and recognized practices.

Cranes and Hoists

Pulp and paper mills may use cranes and hoists for:

  • Reels.
  • Rolls.
  • Machine components.
  • Motors.
  • Pumps.
  • Maintenance materials.

Only appropriately trained and authorized employees should perform assigned lifting operations.

Rigging

Rigging equipment should be:

  • Appropriate for the load.
  • Inspected.
  • Properly attached.
  • Protected from damage.

Employees should remain clear of suspended loads.

Damaged rigging should be removed from service.

Overhead Crane Operations

Crane operators should consider:

  • Load weight.
  • Travel path.
  • Employee location.
  • Equipment clearance.
  • Load control.
  • Communication.

Employees should not stand or work beneath suspended loads.

Powered Industrial Trucks

Mills may use:

  • Forklifts.
  • Clamp trucks.
  • Tow tractors.
  • Other powered industrial trucks.

Only trained and authorized employees should operate applicable equipment.

Clamp Trucks

Clamp trucks used for large paper rolls require careful control of:

  • Roll weight.
  • Clamp pressure.
  • Visibility.
  • Travel speed.
  • Pedestrians.
  • Roll placement.

Operators should follow equipment and attachment limitations.

Forklift and Pedestrian Safety

Facilities should reduce interaction between pedestrians and mobile equipment.

Potential controls may include:

  • Designated walkways.
  • Barriers.
  • Mirrors.
  • Traffic rules.
  • Restricted areas.
  • Warning devices.

Employees should not assume equipment operators can see them.

Roll Movement

Employees should never attempt to stop an uncontrolled heavy paper roll with their hands, feet, or body.

Employees should remain outside the roll’s potential travel path.

Appropriate mechanical equipment should be used.

Loading and Unloading

Shipping and receiving operations may involve:

  • Trucks.
  • Trailers.
  • Railcars.
  • Forklifts.
  • Clamp trucks.
  • Cranes.

Procedures should address vehicle movement, load stability, employee positioning, and communication.

Rail Operations

Mills using railcars should establish procedures to protect employees during:

  • Switching.
  • Loading.
  • Unloading.
  • Coupling.
  • Material handling.

Appropriate warning and protective systems should be used.

Chemical Safety

Pulp and paper operations may use a wide variety of process and maintenance chemicals.

Potential chemical categories may include:

  • Acids.
  • Caustics.
  • Oxidizers.
  • Bleaching chemicals.
  • Water-treatment chemicals.
  • Process additives.
  • Cleaning chemicals.
  • Fuels.
  • Lubricants.

The specific hazards depend on the mill’s processes.

Corrosive Chemicals

Employees handling corrosive materials should be protected against:

  • Skin contact.
  • Eye contact.
  • Splash.
  • Inhalation where applicable.

Appropriate PPE, containment, handling equipment, eyewash facilities, and emergency showers should be provided as required.

Respiratory Hazards

Potential respiratory hazards may include:

  • Process gases.
  • Chemical vapors.
  • Dust.
  • Fibers.
  • Fumes.
  • Maintenance exposures.

Employee exposure should be evaluated according to the actual processes and materials present.

Respiratory Protection

Where respirators are required, the employer should maintain an appropriate Respiratory Protection Program.

Applicable elements may include:

  • Exposure evaluation.
  • Respirator selection.
  • Medical evaluation.
  • Fit testing.
  • Training.
  • Inspection.
  • Maintenance.
  • Program evaluation.

Emergency-response respirators should be selected for the anticipated atmosphere and assigned duties.

Personal Protective Equipment

PPE should be selected based on workplace hazard assessments.

Depending on work performed, PPE may include:

  • Safety glasses.
  • Goggles.
  • Face shields.
  • Hard hats.
  • Protective footwear.
  • Chemical-resistant gloves.
  • Heat-resistant gloves.
  • Hearing protection.
  • Respiratory protection.
  • Fall protection.
  • Chemical protective clothing.

Employees should understand PPE use and limitations.

Eye and Face Protection

Eye and face protection may be necessary during:

  • Chemical handling.
  • Pulpwood operations.
  • Maintenance.
  • Grinding.
  • Cutting.
  • Pressurized-system work.
  • Process sampling.

Face shields should be used with appropriate primary eye protection where both are required.

Hearing Conservation

Pulp and paper mills can contain substantial noise from:

  • Paper machines.
  • Chippers.
  • Barkers.
  • Pumps.
  • Fans.
  • Compressors.
  • Conveyors.
  • Material-handling equipment.

Employee noise exposure should be evaluated.

Where applicable thresholds are reached, a Hearing Conservation Program should be implemented.

Electrical Safety

Mill electrical systems may power large motors, drives, pumps, conveyors, process equipment, and paper machines.

Electrical equipment should be maintained in safe condition.

Electrical work should be performed by appropriately qualified employees.

Electrical Maintenance

Electrical maintenance should address:

  • De-energization.
  • Lockout/Tagout.
  • Verification.
  • Appropriate PPE.
  • Safe work practices.

Energized work should be limited and controlled according to applicable requirements.

Hot Work

Welding, cutting, brazing, and grinding may be performed throughout mill operations.

Hot Work procedures should address:

  • Combustible materials.
  • Process chemicals.
  • Combustible vapors.
  • Dust.
  • Confined spaces.
  • Fire protection.

Hot Work should not begin until applicable precautions have been implemented.

Vessel Hot Work

Hot Work on tanks or vessels that may contain combustible vapors requires particularly careful preparation.

Applicable controls may include:

  • Isolation.
  • Cleaning.
  • Purging.
  • Atmospheric testing.
  • Ventilation.
  • Permit procedures.

Employees should not begin welding or cutting until the vessel has been placed in a safe condition.

Fire Prevention

Pulp and paper mills may contain significant quantities of combustible:

  • Wood.
  • Chips.
  • Paper.
  • Dust.
  • Process chemicals.
  • Fuels.
  • Packaging.

Fire-prevention procedures should address both combustible material and ignition sources.

Combustible Dust — When Applicable

Certain mill processes may generate combustible dust.

Where applicable, facilities should evaluate:

  • Dust generation.
  • Dust accumulation.
  • Dust collection.
  • Ignition sources.
  • Electrical equipment.
  • Housekeeping.

Combustible-dust hazards should be evaluated based on the actual material and process rather than assumed to exist in every mill area.

Housekeeping

Good housekeeping should address:

  • Pulp.
  • Paper.
  • Broke.
  • Wood chips.
  • Dust.
  • Oil.
  • Water.
  • Chemicals.
  • Packaging.
  • Maintenance materials.

Aisles, emergency exits, and equipment-access areas should remain clear.

Wet Floors

Pulp and paper operations can create wet walking surfaces.

Employees should promptly address:

  • Water.
  • Process liquids.
  • Pulp.
  • Chemical leaks.
  • Oil.

Walking surfaces should provide appropriate slip resistance.

Slips, Trips and Falls

Employees should report:

  • Damaged flooring.
  • Missing grating.
  • Broken stairs.
  • Unsafe ladders.
  • Poor lighting.
  • Blocked walkways.
  • Unprotected openings.

Hazards should be corrected promptly.

Walking-Working Surfaces

Platforms, walkways, stairs, ladders, elevated machine areas, and catwalks should be maintained in safe condition.

Applicable guardrails, toeboards, covers, and fall-protection systems should be provided.

Fall Protection

Employees may be exposed to falls while working around:

  • Elevated machinery.
  • Tanks.
  • Roofs.
  • Platforms.
  • Process equipment.
  • Maintenance areas.

Fall hazards should be evaluated and protected according to applicable requirements.

Heat Stress

Employees may work around:

  • Dryers.
  • Boilers.
  • Steam systems.
  • Recovery operations.
  • Hot process equipment.

Heat-illness prevention procedures should consider:

  • Workload.
  • Environmental heat.
  • Protective clothing.
  • Acclimatization.
  • Drinking water.
  • Rest and cooling.

Boilers and Steam Systems

Mills may contain boilers and extensive steam systems.

Employees should be protected from:

  • Pressure.
  • Hot surfaces.
  • Steam release.
  • Burns.
  • Mechanical hazards.

Only appropriately trained and authorized personnel should perform specialized boiler or steam-system work.

Contractor Safety

Pulp and paper mills may use contractors for:

  • Shutdowns.
  • Maintenance.
  • Construction.
  • Electrical work.
  • Welding.
  • Tank cleaning.
  • Specialized process work.

Contractors should be informed of hazards relevant to their work.

Facility and contractor responsibilities should be coordinated before work begins.

Mill Shutdowns and Outages

Major shutdowns may involve large numbers of employees and contractors performing simultaneous maintenance activities.

Shutdown planning should address:

  • Hazardous energy.
  • Confined spaces.
  • Hot Work.
  • Cranes and rigging.
  • Chemical isolation.
  • Electrical work.
  • Work at heights.
  • Contractor coordination.

Coordination is essential where multiple work groups can affect one another.

Emergency Action Plan

The mill should maintain emergency procedures appropriate to its operations.

Potential emergencies may include:

  • Fire.
  • Explosion.
  • Chemical release.
  • Toxic gas release.
  • Process upset.
  • Machine injury.
  • Confined-space emergency.
  • Severe weather.
  • Medical emergency.

Employees should understand applicable alarms, evacuation routes, assembly areas, and reporting procedures.

Chemical Release Emergency

Emergency procedures should reflect the chemicals present.

Depending on the facility, procedures may address:

  • Alarm systems.
  • Evacuation.
  • Shelter-in-place.
  • Wind direction.
  • Isolation.
  • Emergency shutdown.
  • Respiratory protection.
  • Trained response personnel.

Employees should not perform emergency response beyond their training and assigned responsibilities.

First Aid

Appropriate first-aid resources should be available.

Potential mill injuries may include:

  • Crushing.
  • Amputation.
  • Burns.
  • Chemical exposure.
  • Eye injury.
  • Falls.
  • Lacerations.
  • Strains.

Employees should promptly report injuries and obtain appropriate medical evaluation.

Incident Reporting

Employees should promptly report:

  • Injuries.
  • Near misses.
  • Machine contacts.
  • Guard failures.
  • Chemical releases.
  • Unexpected equipment startup.
  • Fires.
  • Process upsets.
  • Mobile-equipment incidents.
  • Unsafe conditions.

Prompt reporting helps identify hazards before similar incidents occur.

Incident Investigation

Significant incidents should be investigated to identify:

  • Immediate causes.
  • Contributing factors.
  • Root causes.
  • Corrective actions.

Investigations may consider:

  • Machine guarding.
  • Lockout/Tagout.
  • Process conditions.
  • Chemical isolation.
  • Maintenance.
  • Training.
  • Supervision.
  • Contractor coordination.
  • Procedures.

Root Cause Analysis

Root Cause Analysis may identify underlying factors involving:

  • Equipment design.
  • Preventive maintenance.
  • Mechanical integrity.
  • Procedures.
  • Training.
  • Staffing.
  • Production pressure.
  • Contractor coordination.
  • Hazard assessments.
  • Management of Change.
  • Corrective-action systems.

Corrective actions should address identified causes rather than simply assigning blame.

Pulp & Paper Mill Safety Inspections

Periodic safety inspections should evaluate:

  • Machine guards.
  • Paper machines.
  • Conveyors.
  • Winders and rewinders.
  • Roll storage.
  • Chemical systems.
  • Confined spaces.
  • Emergency equipment.
  • Cranes and hoists.
  • Forklifts.
  • PPE.
  • Walking-working surfaces.

Identified deficiencies should be corrected in a timely manner.

Pulp & Paper Mill Safety Training

Employee training should reflect assigned duties and hazards.

Depending on responsibilities, training may address:

  • Machine hazards.
  • Lockout/Tagout.
  • Paper-machine safety.
  • Roll handling.
  • Chemical hazards.
  • Confined spaces.
  • PPE.
  • Respiratory hazards.
  • Forklifts.
  • Cranes and rigging.
  • Emergency procedures.

Employees should not independently perform specialized work until they have received appropriate instruction.

Machine-Specific Training

Employees should receive instruction for the equipment they are authorized to operate.

Training should address:

  • Machine controls.
  • Guarding.
  • Emergency stops.
  • Nip points.
  • Safe setup.
  • Hazardous-energy procedures.
  • Prohibited practices.

Training on one machine should not automatically be considered adequate for substantially different equipment.

New Employee Orientation

New employees should receive safety orientation before independently performing assigned work.

Orientation may address:

  • Mill traffic.
  • Machine hazards.
  • Chemicals.
  • PPE.
  • Emergency procedures.
  • Housekeeping.
  • Incident reporting.
  • Restricted areas.

Refresher Training

Refresher or remedial training may be appropriate following:

  • Unsafe equipment operation.
  • Lockout/Tagout violations.
  • Chemical-handling incidents.
  • Process changes.
  • Equipment changes.
  • Incidents or near misses.
  • Identified knowledge gaps.

Safety Meetings

Periodic safety meetings may reinforce safe work practices.

Potential topics include:

  • Lockout/Tagout.
  • Machine guarding.
  • Paper-machine nips.
  • Roll handling.
  • Chemical safety.
  • Confined spaces.
  • Hot Work.
  • Mobile equipment.
  • Contractor safety.
  • Recent incidents.

Recordkeeping

Pulp and paper employers should maintain occupational safety and health records required for their operations.

Records may include:

  • Employee training.
  • Injury and illness records.
  • Equipment inspections.
  • Preventive maintenance.
  • Lockout/Tagout inspections.
  • Confined-space records.
  • Exposure monitoring.
  • Respiratory Protection records.
  • Hearing Conservation records.
  • Forklift training.
  • Incident investigations.
  • Chemical records.

Records should be retained according to applicable requirements.

Additional Safety Programs

Depending on mill operations and employee exposures, additional programs may be necessary for:

  • Pulp & Paper Mill Safety.
  • Paper Machine Safety.
  • Pulpwood Handling.
  • Conveyor Safety.
  • Machine Guarding.
  • Lockout/Tagout.
  • Preventive Maintenance.
  • Roll Handling.
  • Winder & Rewinder Safety.
  • Slitter & Cutter Safety.
  • Chemical Safety.
  • Hazard Communication.
  • Process Safety Management.
  • Management of Change.
  • Chlorine Safety.
  • Hydrogen Sulfide Safety.
  • Confined Space.
  • Respiratory Protection.
  • Personal Protective Equipment.
  • Hearing Conservation.
  • Electrical Safety.
  • Hot Work.
  • Welding & Cutting.
  • Fire Prevention.
  • Combustible Dust.
  • Overhead Cranes & Hoists.
  • Rigging & Material Handling.
  • Powered Industrial Trucks.
  • Loading & Unloading.
  • Rail Safety.
  • Fall Protection.
  • Ladders & Stairways.
  • Walking-Working Surfaces.
  • Working Over or Near Water.
  • Heat Stress Prevention.
  • Housekeeping.
  • Emergency Action Plan.
  • First Aid.
  • Contractor Safety.
  • Incident Reporting & Investigation.
  • Root Cause Analysis.

Programs should be included when the mill’s processes, machinery, chemicals, material-handling operations, and employee exposures make them applicable.

Building a Pulp & Paper Mill Safety Manual

A useful Pulp & Paper Mill Safety Manual should reflect the facility’s actual manufacturing processes.

An integrated pulp and paper mill may require extensive procedures for pulpwood handling, barkers and chippers, pulping, chemical systems, bleaching, stock preparation, paper machines, roll handling, winders, Lockout/Tagout, confined spaces, cranes, forklifts, and process emergencies.

A pulp mill may require greater emphasis on digesters, chemical processes, pressure systems, recovery operations, tanks, hazardous gases, chemical isolation, confined spaces, respiratory protection, and Process Safety Management where applicable.

A paper mill receiving manufactured pulp may have little or no pulpwood or chemical-pulping exposure but require extensive programs for stock preparation, paper machines, dryers, reels, winders, cutters, roll handling, forklifts, Lockout/Tagout, and machine guarding.

A paperboard mill may require additional procedures based on its stock preparation, forming, pressing, drying, finishing, cutting, converting, and material-handling processes.

A converting facility may require significantly less pulp-processing content while requiring extensive machine guarding, Lockout/Tagout, cutting, winding, roll handling, printing, coating, packaging, and material-handling procedures.

The safety manual should therefore be based on the operations actually performed rather than automatically assigning every pulp-and-paper-related program to every facility.

Customized Pulp & Paper Mill Safety Manuals

A Pulp & Paper Mill Safety Manual can be developed around the facility’s pulpwood handling, pulping systems, chemical processes, paper machines, dryers, reels, winders, cutters, rolls, cranes, forklifts, process chemicals, maintenance activities, employees, and other occupational hazards.

The finished manual may incorporate applicable programs for Machine Guarding, Lockout/Tagout, Paper Machine Safety, Chemical Safety, Process Safety Management, Confined Space, Respiratory Protection, PPE, Hearing Conservation, Roll Handling, Crane and Rigging Safety, Powered Industrial Trucks, Fire Prevention, Emergency Action Planning, Incident Investigation, and other hazards associated with pulp and paper operations.

This provides pulp mills, paper mills, paperboard mills, integrated mills, and converting operations with a practical safety manual organized around the work their employees actually perform.