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.
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:
Other OSHA General Industry standards may also apply according to the mill’s operations and employee exposures.
The contents of a Pulp & Paper Mill Safety Manual should reflect the work actually performed.
Depending on operations, the manual may address:
Programs should be selected according to the mill’s processes, machinery, chemicals, raw materials, products, and employee exposures.
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:
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.
Hazard assessments should consider each stage of mill operations.
Potential areas include:
Potential hazards may include:
Assessments should be reviewed when equipment, processes, chemicals, or facility conditions change.
A JSA/JHA may be used to evaluate higher-risk mill activities.
Potential JSAs/JHAs may address:
The analysis should identify job steps, hazards, controls, PPE, and employee responsibilities.
Pulpwood receiving areas can expose employees to large, heavy, and unstable materials.
Potential hazards include:
Employees should remain outside areas where uncontrolled pulpwood movement could strike or crush them.
Pulpwood should be stored to maintain stable piles and reduce the potential for uncontrolled movement.
Procedures should address:
Employees should not work in locations where unstable material could roll, slide, or fall onto them.
Unloading procedures should establish safe positions for employees before loads are released.
Employees should remain clear of:
Load restraints should be released using procedures that protect employees from shifting material.
Pulpwood conveyors may expose employees to:
Required guarding should remain in place.
Emergency stopping provisions should be maintained and employees should understand how to use them.
Conveyors throughout the mill may transport:
Potential hazards include:
Employees should not climb, walk, sit, or ride on conveyors unless specifically designed and authorized for that purpose.
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.
Barkers can expose employees to:
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.
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.
Chippers can cause severe or fatal injuries.
Potential hazards include:
Feed systems and guarding should prevent employee access to hazardous cutting components.
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.
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.
Mills may handle materials in forms including:
Storage and handling procedures should prevent falling, shifting, or unstable materials.
Large pulp and paper rolls can create severe crushing hazards if they move unexpectedly.
Roll-storage procedures should address:
Rolls should be secured against uncontrolled movement.
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 processes may involve:
Safety procedures should reflect the particular pulping process used by the facility.
Chemical pulping may involve hazardous:
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 and associated equipment may involve:
Employees should not open, enter, inspect, or service digesters until applicable pressure, chemical, temperature, and hazardous-energy controls have been implemented.
Piping, valves, and fittings associated with digesters and blow systems should be inspected and maintained.
Employees should promptly report:
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.
Process pressure can remain after normal equipment shutdown.
Before employees loosen piping, open vessels, remove covers, or perform maintenance:
Employees should not assume a pressure gauge reading alone establishes that a system is safe to open.
Tanks, chests, vessels, and similar process equipment may contain:
Entry and maintenance procedures should address all applicable hazards.
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:
Pulp and paper mills may contain numerous confined spaces.
Potential examples include:
The employer should evaluate spaces and implement Permit-Required Confined Space procedures where applicable.
Where a space meets applicable permit-required criteria, procedures should address:
Employees should not enter permit spaces without authorization.
Potential confined-space atmospheres may involve:
Atmospheric testing should reflect the potential hazards of the particular space.
Rescue arrangements should be established before permit-space entry begins.
Rescue planning should consider:
Employees should not make uncontrolled entries to rescue coworkers.
Chemical pulp mills may use recovery processes involving significant:
Safety procedures should reflect the mill’s specific recovery system and employee exposures.
Certain recovery operations can involve molten smelt and extreme temperatures.
Employees should be protected from:
Applicable process controls, barriers, PPE, and emergency procedures should be maintained.
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.
Certain pulp and paper processes can generate or involve hydrogen sulfide.
Where potential exposure exists, the facility should evaluate:
Hydrogen sulfide should not be treated as a universal exposure at every pulp or paper facility.
Some pulp processes can produce or collect turpentine or other combustible vapors.
Systems should be operated and maintained to prevent:
Hot Work involving vessels that may contain combustible vapors should not begin until required cleaning, purging, testing, and other controls have been completed.
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:
Some facilities or processes may involve chlorine.
Where chlorine is present, procedures should address:
Chlorine should not be assumed to be present at every modern pulp and paper mill.
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.
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:
Employees without appropriate training and protection should evacuate rather than attempt emergency response.
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 should reflect:
Containers and process piping should be properly identified.
A Hazard Communication Program should address hazardous chemicals used throughout mill operations.
Applicable elements may include:
Employees should understand how to obtain chemical hazard information before beginning work.
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:
PSM applicability should be determined from the chemicals, quantities, processes, and applicable regulatory criteria at the individual facility.
Facilities subject to PSM should evaluate covered changes involving:
Safety information and employee training should be updated as required before affected changes are implemented.
Mechanical pulping operations may expose employees to:
Required guarding and PPE should be maintained.
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 operations may involve:
Machinery should be guarded and employees protected from hazardous moving components.
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, 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 machines contain numerous moving rolls, dryers, drives, shafts, nips, and other components capable of causing severe or fatal injuries.
Potential hazards include:
Employees should receive machine-specific training before performing assigned paper-machine duties.
Paper machines should have emergency stopping devices as required.
Employees should know:
Emergency stopping devices should be periodically tested according to applicable requirements and facility procedures.
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 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.
Paper machines contain numerous locations where rotating rolls create in-running nip hazards.
Employees should keep:
away from operating nips.
Required guards and safe threading or feeding devices should be used.
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.
Machine access areas should provide safe walking and working surfaces.
Walkways should be maintained:
Employees should not use machine components as improvised access platforms.
Paper-machine dryers may expose employees to:
Required guards should remain in place.
Lubrication and maintenance should be performed using methods that protect employees from heat and moving equipment.
Before employees enter hazardous dryer areas or perform covered maintenance, applicable hazardous-energy procedures should be followed.
Employees should account for:
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.
Equipment used for lifting reels may include:
Lifting devices should be appropriate for the load and maintained in safe condition.
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.
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.
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 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 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.
Before changing knives:
Employees should not leave exposed knives where they can contact other employees.
Finishing rooms may contain:
Each machine should be evaluated for point-of-operation, nip, cutting, crushing, and hazardous-energy hazards.
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-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 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.
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 may expose employees to cutting and nip hazards.
Appropriate guarding should prevent access to the cutter knife and hazardous nip points during operation.
Machinery throughout pulp and paper operations should be evaluated for:
Required guards should remain installed and functional.
Hazardous energy is one of the most significant hazards in pulp and paper mills.
Applicable energy-control procedures should be followed during covered:
Potential energy sources may include:
Employees should identify all hazardous energy sources before work begins.
Complex mill equipment may require isolation of multiple:
Normal control switches should not be relied upon for hazardous-energy isolation.
Stored energy should be relieved, restrained, blocked, dissipated, or otherwise controlled.
Potential sources include:
Employees should verify isolation before beginning work.
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.
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 should address safety-critical equipment and systems.
Inspections may include:
Identified defects should be corrected promptly.
Facilities subject to Process Safety Management should maintain applicable process equipment according to PSM mechanical-integrity requirements.
Equipment may include:
Inspection and testing should follow applicable procedures and recognized practices.
Pulp and paper mills may use cranes and hoists for:
Only appropriately trained and authorized employees should perform assigned lifting operations.
Rigging equipment should be:
Employees should remain clear of suspended loads.
Damaged rigging should be removed from service.
Crane operators should consider:
Employees should not stand or work beneath suspended loads.
Mills may use:
Only trained and authorized employees should operate applicable equipment.
Clamp trucks used for large paper rolls require careful control of:
Operators should follow equipment and attachment limitations.
Facilities should reduce interaction between pedestrians and mobile equipment.
Potential controls may include:
Employees should not assume equipment operators can see them.
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.
Shipping and receiving operations may involve:
Procedures should address vehicle movement, load stability, employee positioning, and communication.
Mills using railcars should establish procedures to protect employees during:
Appropriate warning and protective systems should be used.
Pulp and paper operations may use a wide variety of process and maintenance chemicals.
Potential chemical categories may include:
The specific hazards depend on the mill’s processes.
Employees handling corrosive materials should be protected against:
Appropriate PPE, containment, handling equipment, eyewash facilities, and emergency showers should be provided as required.
Potential respiratory hazards may include:
Employee exposure should be evaluated according to the actual processes and materials present.
Where respirators are required, the employer should maintain an appropriate Respiratory Protection Program.
Applicable elements may include:
Emergency-response respirators should be selected for the anticipated atmosphere and assigned duties.
PPE should be selected based on workplace hazard assessments.
Depending on work performed, PPE may include:
Employees should understand PPE use and limitations.
Eye and face protection may be necessary during:
Face shields should be used with appropriate primary eye protection where both are required.
Pulp and paper mills can contain substantial noise from:
Employee noise exposure should be evaluated.
Where applicable thresholds are reached, a Hearing Conservation Program should be implemented.
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 should address:
Energized work should be limited and controlled according to applicable requirements.
Welding, cutting, brazing, and grinding may be performed throughout mill operations.
Hot Work procedures should address:
Hot Work should not begin until applicable precautions have been implemented.
Hot Work on tanks or vessels that may contain combustible vapors requires particularly careful preparation.
Applicable controls may include:
Employees should not begin welding or cutting until the vessel has been placed in a safe condition.
Pulp and paper mills may contain significant quantities of combustible:
Fire-prevention procedures should address both combustible material and ignition sources.
Certain mill processes may generate combustible dust.
Where applicable, facilities should evaluate:
Combustible-dust hazards should be evaluated based on the actual material and process rather than assumed to exist in every mill area.
Good housekeeping should address:
Aisles, emergency exits, and equipment-access areas should remain clear.
Pulp and paper operations can create wet walking surfaces.
Employees should promptly address:
Walking surfaces should provide appropriate slip resistance.
Employees should report:
Hazards should be corrected promptly.
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.
Employees may be exposed to falls while working around:
Fall hazards should be evaluated and protected according to applicable requirements.
Employees may work around:
Heat-illness prevention procedures should consider:
Mills may contain boilers and extensive steam systems.
Employees should be protected from:
Only appropriately trained and authorized personnel should perform specialized boiler or steam-system work.
Pulp and paper mills may use contractors for:
Contractors should be informed of hazards relevant to their work.
Facility and contractor responsibilities should be coordinated before work begins.
Major shutdowns may involve large numbers of employees and contractors performing simultaneous maintenance activities.
Shutdown planning should address:
Coordination is essential where multiple work groups can affect one another.
The mill should maintain emergency procedures appropriate to its operations.
Potential emergencies may include:
Employees should understand applicable alarms, evacuation routes, assembly areas, and reporting procedures.
Emergency procedures should reflect the chemicals present.
Depending on the facility, procedures may address:
Employees should not perform emergency response beyond their training and assigned responsibilities.
Appropriate first-aid resources should be available.
Potential mill injuries may include:
Employees should promptly report injuries and obtain appropriate medical evaluation.
Employees should promptly report:
Prompt reporting helps identify hazards before similar incidents occur.
Significant incidents should be investigated to identify:
Investigations may consider:
Root Cause Analysis may identify underlying factors involving:
Corrective actions should address identified causes rather than simply assigning blame.
Periodic safety inspections should evaluate:
Identified deficiencies should be corrected in a timely manner.
Employee training should reflect assigned duties and hazards.
Depending on responsibilities, training may address:
Employees should not independently perform specialized work until they have received appropriate instruction.
Employees should receive instruction for the equipment they are authorized to operate.
Training should address:
Training on one machine should not automatically be considered adequate for substantially different equipment.
New employees should receive safety orientation before independently performing assigned work.
Orientation may address:
Refresher or remedial training may be appropriate following:
Periodic safety meetings may reinforce safe work practices.
Potential topics include:
Pulp and paper employers should maintain occupational safety and health records required for their operations.
Records may include:
Records should be retained according to applicable requirements.
Depending on mill operations and employee exposures, additional programs may be necessary for:
Programs should be included when the mill’s processes, machinery, chemicals, material-handling operations, and employee exposures make them applicable.
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.
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.