Open Government Status

Fully open

Author Unit/Section

Manufacturing sector

Review Date

26.06.2013

Target Audience

Inspectors who inspect the papermaking and finishing industries, specialist inspectors

Summary

This SIM revises and replaces SIM 03/2002/68.  It provides technical details on the implementation of PABIAC guidance Making Paper Safely (MPS); highlights specific priority areas arising from its implementation; and clarifies the enforcement support offered by the Sector.

Introduction

1. The Paper and Board Industry Advisory Committee (PABIAC) guidance Making Paper Safely (MPS) was published in February 2001. Early lessons arose from the introduction of the new guidance, in particular the need for mills to improve process efficiency and reduce operator intervention at papermaking and finishing machines.

Key issues

2.A number of key issues arose consistently:

Tail feeding

3. Tail feeding is one of the times when operators are at highest risk. These include entanglement (arising from whole or part-body access), falls from height, manual handling, stress, heat and noise. Making Paper Safely (page 20, para 56) effectively prohibits hand feeding of paper tails directly into roll nips and sets out a hierarchy of preferred options. Mills have realized that effective guarding makes manual intervention during tail feeding increasingly difficult. Most mills have made considerable efforts to improve performance in this important area.

4. At a tail feeding seminar organised by the Confederation of Paper Industries (CPI) presentations were given by tail feeding system suppliers. An outline of the types of systems is set out at Appendix 1. The message that emerged was that a combination of measures is almost always required to achieve successful feeding. It was clear that great benefits could be derived from careful analysis of tail feeding and the application of the right combination of measures. It was also apparent that the different equipment suited certain grades of paper (and had limitations) and that setting and maintenance regimes had to be explicit and operators well trained in these in order to maintain the efficiency of such systems and avoid reversion to hand feeding.

5. Appendix 2 contains the text of a Sector bulletin, first issued in June 2001, that is set out as FAQs covering various aspects of Making Paper Safely.

Runability - Paper breaks and maintenance

6. Another time when operators are at risk is when a break occurs and they are called to clear 'broke' from the machine and 'get it away' i.e. get the machine back to normal production. Mills expressed concern that guarding would increase the time taken to reach into the machine, remove broke and restart the process.

7. Mills should be encouraged to identify why breaks occur and take action to eliminate them using break detection technology. The Sector has information suggesting that mills who took this approach reduced the frequency of breaks by more than 50% and downtime by 75% or more. These sorts of savings can significantly improve the productivity of a paper machine. Effective break detection can reduce the amount of broke that builds up and the time required to clear the machine.

8. Guards should be designed to enable the safe removal of broke from key areas where breaks and build up cannot be completely eliminated. This tends to be more of an issue where 'wads' of broke occur rather than wraps. In some cases machines can be operated so that a 'wrap' is dropped out of the machine into the under-machine pit at a suitable point, e.g. where there is a 'slalom' (single tier drier section), without the need for any manual intervention.  Wads can be more problematic and tend to involve manual removal under a safe system of work.

9. Mills should be encouraged to employ condition/vibration monitoring technology (on-line as well as portable) to detect problems early enough to repair them during a scheduled shut. Guarding should be designed to enable such portable monitoring to take place safely. Recent articles about maintenance in trade publications highlight the cost benefits that can be gained from early identification of problems that could halt production, in some cases causing significant damage after problem components are run to catastrophic failure. Such detection reduces the potential for the removal of guards during unplanned downtime.

MPS and the Provision and Use of Work Equipment Regulations 1998 (PUWER)

10. There was a perception in some mills that compliance with BS EN 294: 1992 Safety of machinery - Safety distances to prevent danger zones being reached by the upper limbs (since replaced by BS EN ISO 13857:2008 Safety of machinery – Safety distances to prevent hazard zones being reached by upper and lower limbs) alone is sufficient to achieve compliance with the law. In some mills this resulted in the installation of interlocked distance guards with no regard for the PUWER hierarchy and the particular risk of entry between the guard and the machine. In mills visited by Sector staff where this was found, managers were challenged to justify the guarding arrangement in accordance with the PUWER hierarchy and to demonstrate how they would prevent operators standing in the area between the guard and the machine to work. Many mills have installed fixed or interlocked guards close to or on the machine frame which prevent access to dangerous parts, allow necessary operations to be carried out safely (such as vibration monitoring) and prevent full-body access between the guard and the machine. The Sector would encourage inspectors to challenge any mill which approaches the PUWER hierarchy 'from the bottom up' and press for close fixed or interlocked guards wherever practicable.

Safety-related control systems for papermaking and finishing machines

11. A number of paper mills raised concerns in relation to the advice in MPS about standards for safety-related control systems which they felt to be unclear. As a result HM Specialist Inspectors (Electrical and Control Systems) gave presentations to mill engineers at a seminar organised by the CPI to explain the design principles to be applied and the application of the relevant BS EN Standards covering safety-related control systems to papermaking machines.

12. Following this a clearer explanation of the issues was put out to the industry by way of a PABIAC Bulletin the contents of which were subsequently added to MPS in the form of Annex 1 Updated information on the design and implementation of safety-related control systems and this is included in the 2005 reprint of MPS.

13. HM Specialist Inspectors later undertook visits to a sample of paper mills to inspect the safety-related control systems on papermaking machines. They encountered significant shortcomings with the design and implementation particularly where programmable logic technology was involved.

14. CPI subsequently ran a series of training workshops for mill engineering staff on this topic at which HM Specialist Inspectors again explained the principles behind the design and implementation of safety-related control systems including application to Programmable Logic Control (PLC).

15. A significant finding from the sample inspections made by HM Specialist Inspectors was that not all of the mill engineering staff responsible for the safety-related control systems on their machines had the background knowledge and familiarity with PLC to be able to understand how to apply the requirements of the relevant BS EN Standards to the control systems on their machines. The Sector has made it clear to CPI that it is not part of HSE’s role to provide mill engineering staff with basic competence in relation to Programmable Logic Control (PLC) systems. This is the responsibility of the duty holders who operate the paper mills.

16. Given this experience Inspectors who have any doubts about the integrity of the safety-related control systems (especially if they are PLC systems) on papermaking and finishing machines are advised to seek assistance from HM Specialist Inspectors (Electrical and Control Systems). The Sector will support enforcement action in relation to this topic.

Target for action

17. The agreed deadline for full compliance with MPS was 31 August 2001. The Sector is aware that some mills failed to meet the deadline but have secured compliance with MPS since. However, the Sector believes there may still be some mills that have still not achieved full compliance with MPS.

18. The Sector will support appropriate enforcement action, in particular, a Notice (IN or PN) in circumstances where mills have failed to demonstrate sufficient action in response to MPS.

Strategic factors

19. Making Paper Safely has wide acceptance within the industry and is being used to guide discussions within the CEN working group responsible for the development of EN standards for the safety requirements of papermaking and finishing machines. Many mills have fitted excellent safeguards in response to MPS and it is important to continue to ensure a consistent approach. Any inspector who identifies an issue that cannot be resolved locally is encouraged to refer the matter to the Sector, and/or to suggest that the mill contacts the Confederation of Paper Industries (CPI) for advice.

20. The Sector would appreciate feedback on this enforcement guidance, and information on action taken, including copies of any notices served.

Diversity

21. HSAOs and inspectors should be aware of the diversity needs of the target group. They should give consideration to, and factor in issues such as literacy, English as a second language and disability (e.g. access needs).

22. The Diversity pages give more information on these areas.

Cancellation of instructions

23. SIM 03/2002/68 - cancel and destroy.

• Appendix 1 - Tail feeding - common factors
• Appendix 2 - Paper & printing sector bulletin: June 2001 - Making paper safely - Q&A