Manufacturing & Engineering UK-wide

Set up and run a safe paper mill

Making pulp, paper and paper products — from stock preparation and the paper machine through to converting, corrugating and finishing — is heavy-machinery, steam and chemical work. Whatever you make, this is the universal spine. It takes you through your core workplace health and safety duties, control of process chemicals, work equipment safety, manual handling, fire safety, employers' liability insurance, equality and data protection.

Guide summary

You must ensure the health and safety of your employees and anyone affected by your paper mill. Risk assess all machinery, steam systems, and confined spaces. Control hazardous chemicals under COSHH and provide training and supervision. HSE or HSENI enforces these duties; you could face unlimited fines or up to 2 years in prison for serious breaches.

  • Risk assess paper machine, rewinder, nip points, steam, and confined spaces
  • Provide safe systems of work and supervise employees
  • Assess and control hazardous chemicals under COSHH regulations
  • Use local exhaust ventilation where needed to reduce exposure
  • Carry out health surveillance if your risk assessment shows it is needed
  • Review COSHH assessments when processes change or every few years
  • Balance risk against cost – safety comes first unless costs are grossly disproportionate
  • Follow the same duties in Northern Ireland under HSENI
  • Keep records of risk assessments and training
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Making pulp, paper, board and paper products — stock preparation, the paper or board machine, corrugating, converting and finishing — is heavy-machinery, steam and chemical work, often around large rotating plant, hot surfaces and confined spaces. The duties in this guide apply to running the mill and employing people, whatever you make. Get this spine in place first, then layer your environmental, water and product duties on top.

Health and safety law here is largely devolved. The Health and Safety Executive (HSE) is the regulator in Great Britain and the Health and Safety Executive for Northern Ireland (HSENI) in Northern Ireland. The underlying duties are equivalent across the UK. Work through the sections below in order.

A. Meet your general health and safety duty

The Health and Safety at Work etc. Act 1974 is the foundation. You must ensure, so far as is reasonably practicable, the health, safety and welfare of your employees and of anyone else affected by your work. In a paper mill that means risk-assessing the paper machine and rewinders, nip points, steam and hot surfaces, confined-space entry for chests and tanks, noise and material handling. It also means providing safe systems of work, and training and supervising your people.

B. Control process chemicals (COSHH)

Paper-making uses a range of hazardous substances — bleaching chemicals, biocides and slimicides, sizing agents, dyes, retention aids and cleaning chemicals, plus dust from dry-end and converting operations. The Control of Substances Hazardous to Health Regulations 2002 (COSHH) require you to assess, then prevent or adequately control, exposure. This includes local exhaust ventilation and health surveillance where the regulations require it. In Northern Ireland the equivalent COSHH (Northern Ireland) Regulations 2003 apply.

C. Keep your work equipment safe (PUWER)

Your machinery includes pulpers, the paper or board machine, calenders, rewinders, slitters, corrugators and balers. It must be suitable, properly maintained, inspected and adequately safeguarded under the Provision and Use of Work Equipment Regulations 1998. Nip-point guarding, safe access for cleaning and reel changes, and safe isolation for maintenance are recurring enforcement themes in the sector.

D. Manage manual handling

Moving reels, bales, pallets and finished product is routine and often very heavy, so the Manual Handling Operations Regulations 1992 apply. Avoid hazardous manual handling so far as is reasonably practicable. Where you cannot, assess the risk and reduce it — through lifting and handling equipment, better layout and safe systems of work.

E. Manage fire safety

Paper, board, dust and packaging give a mill a high fire load. The responsible person must carry out a fire risk assessment and maintain fire-safety arrangements, including housekeeping, dust control and control of ignition sources. The duty is devolved. In England and Wales it is the Regulatory Reform (Fire Safety) Order 2005. In Scotland it is the Fire (Scotland) Act 2005 and Fire Safety (Scotland) Regulations 2006. In Northern Ireland it is the Fire and Rescue Services (Northern Ireland) Order 2006.

F. Hold employers' liability insurance

As soon as you employ anyone, you must hold employers' liability compulsory insurance — normally at least £5 million of cover. You must also display or make available the certificate. This is a legal requirement across Great Britain, with an equivalent duty in Northern Ireland.

G. Meet your equality duties

As an employer you must not discriminate against, harass or victimise people because of a protected characteristic. In Great Britain this is governed by the Equality Act 2010. In Northern Ireland separate equality legislation applies, enforced by the Equality Commission for Northern Ireland.

H. Handle personal data lawfully

If you process personal data — about staff, customers or suppliers — you must comply with the UK GDPR and the Data Protection Act 2018. In most cases you must also pay the data protection fee to the Information Commissioner's Office (ICO). This applies UK-wide.

  1. 1

    1. Write your health and safety risk assessments

    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 under HASAWA 1974.

  2. 2

    2. Put COSHH controls in for your process chemicals

    Assess bleaching chemicals, biocides, sizing agents, dyes and cleaning chemicals. Control exposure with ventilation and health surveillance where COSHH requires it.

  3. 3

    3. Bring work equipment into a PUWER regime

    Make sure pulpers, the machine, calenders, rewinders, slitters and corrugators are guarded, maintained, inspected and safely isolated for cleaning and maintenance.

  4. 4

    4. Control manual handling and carry out your fire risk assessment

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

  5. 5

    5. Take out employers' liability insurance and register with the ICO

    Arrange at least £5 million of cover before anyone starts work, and pay the data protection fee unless you are exempt.

What to do next

This spine covers the duties of running the mill and employing people. On top of it sit your environmental, water and product duties:

Official sources

Authoritative health and safety and data-protection guidance.