Manufacturing & Engineering UK-wide

Paper manufacturer: compliance checklist

Use this checklist to confirm your paper business (SIC division 17) meets its obligations. Work through the universal workplace items every mill shares, then the sections for environmental permits and water, and for placing products on the market. If you answer no to any item, follow the linked guide before you proceed.

Guide summary

Work through this checklist to meet your legal duties as a paper manufacturer. You must write risk assessments, control process chemicals, safeguard machinery, and hold employers’ liability insurance of at least £5 million. You also need environmental permits, trade effluent consent, and water abstraction licences where they apply. For products you sell, meet the general product safety duty and check Northern Ireland rules separately if you supply there.

  • Write risk assessments and safe systems for your mill
  • Assess and control process chemicals under COSHH
  • Safeguard machinery under PUWER
  • Assess manual handling and fire risks
  • Hold employers’ liability insurance of at least £5m
  • Get an environmental permit if above the threshold
  • Get trade effluent consent for sewer discharges
  • Get a water abstraction licence if you take water
  • Ensure consumer goods meet the general product safety duty
  • Check Northern Ireland rules separately if you supply there
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Related guides in Health & Safety

Use this checklist to confirm your paper business meets its obligations. Work through each item and answer yes or no. If you answer no, follow the linked guide before you proceed.

Workplace health and safety is enforced by the Health and Safety Executive in Great Britain and by HSENI in Northern Ireland. Environmental permits and abstraction licences are issued by the regulator for your nation (Environment Agency, NRW, SEPA, NIEA/DAERA). Trade effluent consent comes from your sewerage undertaker. The product-safety regime is a Great Britain regime — if you supply Northern Ireland, check the position separately. Each section names the body that applies.

Section 1 — Every paper manufacturer

These workplace and employment duties apply to every mill, whatever you make. Confirm each one.

  1. 1

    Have you written your risk assessments and put safe systems of work in place?

    Your general duty under the Health and Safety at Work etc. Act 1974 is to ensure, so far as is reasonably practicable, the health, safety and welfare of your people. Risk-assess the paper machine, rewinders and converting plant, steam and confined spaces, noise and handling. Put safe systems of work, training and supervision in place. If not, follow "Set up and run a safe paper mill".

  2. 2

    Have you assessed and controlled your process chemicals under COSHH?

    COSHH requires control of bleaching chemicals, biocides, sizing agents, dyes and cleaning chemicals, with ventilation and health surveillance where required.

  3. 3

    Is your machinery safeguarded, maintained and inspected under PUWER?

    Pulpers, the paper machine, calenders, rewinders, slitters and corrugators must be guarded, maintained and safely isolated for cleaning and maintenance under PUWER.

  4. 4

    Have you assessed manual handling and carried out your fire risk assessment?

    Reduce hazardous handling of reels, bales and pallets. Assess fire risk from paper, board and dust under the fire-safety regime for your nation.

  5. 5

    Do you hold employers' liability insurance and meet your equality and data duties?

    Hold at least £5 million of cover once you employ anyone. Do not discriminate under the Equality Act 2010 (or separate NI equality law enforced by the Equality Commission for Northern Ireland). Comply with the UK GDPR and Data Protection Act 2018, registering with the ICO unless exempt.

Section 2 — Environmental permits and water

Paper-making is water-intensive, so most mills carry these duties. Confirm each one that applies to your mill.

  1. 1

    Does your installation hold the environmental permit it needs?

    Pulp and paper installations above the permit threshold need an environmental permit from the Environment Agency, NRW, SEPA or NIEA, with emission, discharge and monitoring conditions. If not, follow "Manage environmental permits and water at your paper mill".

  2. 2

    Do you hold a trade effluent consent for discharges to the sewer?

    Discharging process effluent to the public sewer needs the prior consent of your sewerage undertaker, within its volume, strength and content limits. Discharging without consent is an offence.

  3. 3

    Do you hold a water abstraction licence if you take water?

    Taking water from a river, canal or borehole above the threshold needs an abstraction licence from the regulator for your nation, within its quantities and conditions.

Section 3 — Placing products on the market

Confirm the regime for each product you make. The product-safety regime is a Great Britain regime. Check Northern Ireland separately if you supply there.

  1. 1

    Do your consumer goods meet the general product safety duty?

    Paper and board consumer goods outside a specific regime must be safe under the General Product Safety Regulations 2005, enforced by OPSS and Trading Standards. If not, follow "Place paper products on the market".

  2. 2

    Does your food-contact paper and board meet the food-contact materials rules?

    Cartons, wrap, cups and food packaging board must meet the food-contact materials rules — good manufacturing practice, migration and composition limits, and a declaration of compliance — enforced by local authorities and Trading Standards.

  3. 3

    Have you met your packaging producer responsibility duties?

    If you are an obligated producer under packaging EPR, collect and report your packaging data, register, and pay the producer fees.

If you answered no to anything

Work through the guide linked in that item. The three task guides — the safe-mill spine, environmental permits and water, and placing products on the market — set out what to do. Start from the router if you are not sure which apply to you.

Official sources

Authoritative health and safety, environmental and product guidance.