OSHA AI Agent
Get instant answers to any safety question.
Request Demo
OSHA 1910.261

Pulp and paper mills scope

Subpart R

50 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.261(a)(1) — Where does the pulp, paper, and paperboard mills standard apply and what is explicitly excluded?

Yes — the rule applies to establishments where pulp, paper, and paperboard are manufactured and converted, and it does not apply to logging or to transporting logs to mills. See the Application in 1910.261(a)(1).

Under 1910.261(a)(3) — Do pulp and paper mills have to follow the listed ANSI/ASME/NFPA standards, and how are they incorporated?

Yes — the listed consensus standards are incorporated by reference and employers at affected mills must follow them where specified. See the General incorporation of standards at 1910.261(a)(3) and the specific incorporated standards in 1910.261(a).

Under 1910.261(b)(1) — When must an employer use lockout or blocking before maintenance, and what devices are acceptable?

You must lock out or block the power or material flow before maintenance that requires entering or close contact with equipment. Acceptable devices include padlocks, blank flanges, or similar blocking devices placed at the main disconnect switch or valve controlling the equipment. See the lockout requirement in 1910.261(b)(1). Also note OSHA’s guidance on temporary re-energization and required protective steps in the minor servicing exception clarification when power must be restored briefly for testing.

Under 1910.261(b)(2) — Where is emergency lighting required in pulp and paper mills?

Emergency lighting is required where employees must remain at machines or stations to shut down equipment during a power failure, and at stairways, passageways, or aisleways used for emergency exits. See the emergency lighting requirement in 1910.261(b)(2).

Under 1910.261(c)(1) — What extra protection is required for forklift operators handling pulpwood with large lift trucks or clam-jaws?

If a large forklift or a lift truck with clam-jaws can block escape through the side doors, the operator must have an enclosed cab with an escape hatch. See the handling pulpwood with forklift trucks requirement in 1910.261(c)(1).

Under 1910.261(c)(2)(i) and (ii) — What clearance distances must be kept when using locomotive cranes to handle pulpwood?

Maintain at least 24 inches clearance between the pile and the end of any locomotive crane cab in any working position, and keep the pile at least 8½ feet from the centerline of a standard-gauge track. See 1910.261(c)(2)(i) and 1910.261(c)(2)(ii).

Under 1910.261(c)(2)(iii) — How must logs be piled with respect to walkways and stability?

Logs must be piled in an orderly, stable manner with no projection into walkways or roadways so they do not create tripping or collapse hazards. See the piling requirement in 1910.261(c)(2)(iii).

Under 1910.261(c)(2)(vi) — Can employees walk under suspended loads or hooks?

No — the standard clearly prohibits anyone from walking beneath a suspended load, bucket, or hook. See the prohibition at 1910.261(c)(2)(vi).

Under 1910.261(c)(3)(iii) — What must be done before personnel enter a ship's hold, tanks, or closed vessels when handling pulpwood from ships?

You must test the air in the hold, tanks, or closed vessels for oxygen deficiency and for toxic or explosive gases and vapors before anyone enters. See the air testing requirement in 1910.261(c)(3)(iii). For additional guidance on oxygen-deficient atmospheres in workplaces, see OSHA’s interpretation on Oxygen-deficient atmospheres in HVAC, which discusses how to treat low-oxygen conditions under OSHA respiratory protection rules.

Under 1910.261(c)(4)(iii) and (iv) — What safe sequencing and areas are required when cutting stakes or steel straps on flatcars?

When cutting stakes on a flatcar, partially cut stakes on the unloading side first and then cut binder wires on the opposite side; no one may be on the dumping side after stakes are cut. If steel straps without stakes are used, cut the straps from a safe area to prevent employees from being struck by falling logs. See 1910.261(c)(4)(iii) and 1910.261(c)(4)(iv).

Under 1910.261(c)(4)(v) and (vi) — What must be done to cars during unloading to prevent movement and protect employees?

All flatcars and other cars must be chocked during unloading (use rail clamping chocks if equipment lacks hand brakes), and a derail must be used to prevent movement of other rail equipment into cars where people are working. See 1910.261(c)(4)(v) and 1910.261(c)(4)(vi).

Under 1910.261(c)(5)(iii) — If binder chains and crane slings are used on trucks, what must the hooker do before signaling to move the load?

The crane slings must be attached and taut before releasing binder chains, and the hooker must visually confirm the helper is clear before signaling movement. See 1910.261(c)(5)(iii).

Under 1910.261(c)(6) and (c)(7) — What steps are required before dumping pulp chips from railway cars or trucks?

All cars, trucks, or trailers must be securely fastened in place and all employees must be in the clear before dumping begins. See 1910.261(c)(6) and 1910.261(c)(7).

Under 1910.261(c)(8)(ii) and (iii) — What safety devices and clearances are required for yard cranes?

Cranes must have a heavy chain or cable (or an approved telescoping device) fastened to the boom and frame to prevent the boom from snapping back if lifting cables break, and cranes must not operate where any part may come within 10 feet of overhead powerlines unless those lines are deenergized. See 1910.261(c)(8)(ii) and 1910.261(c)(8)(iii). For head protection when crane operators work under overhead hazards, see OSHA’s Head protection for crane operators interpretation.

Under 1910.261(c)(8)(v) — Who may signal the crane operator?

Only one crew member may be authorized to give signals to the crane operator to avoid confusion and reduce risk. See 1910.261(c)(8)(v).

Under 1910.261(c)(9)(i) and (ii) — What are the flagging and warning requirements around tracks and spotted cars?

A flagman must direct movement of cranes or locomotives across tracks and remain in sight of the operator; after cars are spotted for loading or unloading, warning flags or signs must be placed in the center of the track at least 50 feet away and a derail set to protect workers. See 1910.261(c)(9)(i) and 1910.261(c)(9)(ii).

Under 1910.261(c)(10) — When is artificial illumination required for loading or unloading?

Artificial illumination must be provided when loading or unloading is performed after dark, and it must conform to the referenced ANSI lighting practice. See 1910.261(c)(10).

Under 1910.261(c)(12) and 1910.261(e)(12) — If barking drums are used in the yard, where are the applicable rules located?

When barking drums are employed in the yard, the specific requirements of 1910.261(e)(12) apply as cross-referenced by 1910.261(c)(12). Employers must follow those detailed rules for barking devices.

Under 1910.261(c)(13) — What must be done to wood hook handles to prevent rotation?

Handles of wood hooks must be locked to the shank so they cannot rotate during use, preventing slippage and injury. See 1910.261(c)(13).

Under 1910.261(c)(14)(i) and (c)(14)(ii) — How must woodpiles be built and what controls apply if explosives are used to loosen piles?

Woodpile ends must be properly sloped and cross-tiered (do not use upright poles), and if explosives like dynamite are used to loosen piles, only authorized personnel may handle and detonate them using approved detonators or safety fuses as specified; the explosives guidance is incorporated from the IME pamphlet referenced in the rule. See 1910.261(c)(14)(i) and 1910.261(c)(14)(ii).

Under 1910.261(c)(15)(iii) and (iv) — What guarding and emergency stopping features are required for belt conveyors handling pulpwood?

All conveyors for pulpwood must guard inrunning nips between chain and sprockets and turning drums, and every belt conveyor must have an emergency stop cable running the length of the conveyor or stop buttons within 10 feet of each workstation. See 1910.261(c)(15)(iii) and 1910.261(c)(15)(iv), which references ANSI B20.1.

Under 1910.261(c)(16) — What signage is required where conveyors cross walkways or roadways?

Employers must erect signs reading "Danger—Overhead Conveyor" or an equivalent warning where conveyors cross walkways or roadways, as required in 1910.261(c)(16).

Under 1910.261(d)(1) — When must respirators with goggles or protective masks be provided for handling raw materials (alum, clay, lime, etc.)?

Respirators with goggles or protective masks must be provided and worn when source control of dust, fumes, or gases is not possible while handling alum, clay, soda ash, lime, bleach powder, sulfur, chlorine, and similar materials, and when opening rag bales. Employers should first attempt control at the source per the referenced ANSI practice. See 1910.261(d)(1).

Under 1910.261(d)(2)(i) — What aisle clearance is required when piling materials inside a building and on platforms?

When materials are piled inside a building or on platforms, provide an aisle clearance at least 3 feet wider than the widest truck in use to ensure safe passage. See 1910.261(d)(2)(i).

Under 1910.261(d)(2)(ii), how close can baled paper and rags be stored to walls, partitions, or sprinkler heads inside a building?

Baled paper and rags stored inside a building must be at least 18 inches away from walls, partitions, and sprinkler heads. See 1910.261(d)(2)(ii).

  • Keep piles 18 inches (or more) clear to allow sprinkler spray to operate and to reduce fire spread risks.
  • Mark storage limits and train staff so stacking never encroaches on the 18-inch clearance.

Under 1910.261(d)(3)(i), what are the piling rules for wet lap pulp regarding stepping back, interlapping, and clearance from sprinkler heads and pipes?

Piles of wet lap pulp must be stepped back one-half the sheet width for every 8 feet of pile height, sheets must be interlapped to secure the pile, and pulp must not be piled over pipelines, overload floors, or within 18 inches below sprinkler heads. See 1910.261(d)(3)(i).

  • "Stepped back" means each successive course narrows by half a sheet width per 8 feet of height to reduce collapse risk.
  • Interlapping reduces shifting; enforce procedures and inspect piles regularly.
  • Ensure floor capacity is known and loads do not exceed it (see related requirement in 1910.261(d)(3)(iii)).

Under 1910.261(d)(3)(ii) and (iii), what protections are required when unpiling pulp and how must floor capacities be handled?

Piles of pulp must not be undermined when being unpiled, and floor load capacities must be clearly marked on all floors. See 1910.261(d)(3)(ii) and 1910.261(d)(3)(iii).

  • Do not remove supporting material from beneath piles (undermining) because that can cause sudden collapse.
  • Post floor capacity signs and use them in lift planning; inspect and update markings when building use changes.

Under 1910.261(d)(4)(ii)–(iii), what chocking is required when rolls are stored pyramided or decked in pulp and paper operations?

When rolls are pyramided two or more high, chocks must be installed between each roll on the floor and at every row; when rolls are decked two or more high, the bottom rolls must be chocked on each side to prevent shifting. See 1910.261(d)(4)(ii) and 1910.261(d)(4)(iii).

  • For smooth processing-area floors use rubber chocks with wooden cores as specified in 1910.261(d)(4)(ii).
  • Inspect chocks routinely and replace any that are worn or missing to prevent roll movement and crushing injuries.

Under 1910.261(e)(1) and (e)(2), what guarding and lockout requirements apply to gang and slasher saws and slasher tables?

Gang and slasher saws must have guards in front to protect workers from wood thrown by saws and guards over tail sprockets, and saws must be stopped with power switches locked out and tagged whenever a person is on the slasher table. See 1910.261(e)(1) and the requirement in the text that "Saws shall be stopped and power switches shall be locked out and tagged whenever it is necessary for any person to be on the slasher table."

  • Use fixed guards that prevent ejected wood from striking workers and guard tail sprockets.
  • Follow lockout/tagout procedures (see OSHA lockout/tagout guidance and the minor servicing LOI for when temporary re-energization may be allowed for testing).

Under 1910.261(e)(4), what fall and walking-surface protections are required for the runway from the pond or unloading dock to the slasher table?

The runway to the jack ladder or slasher table must have standard handrails and toeboards, inclined portions must have cleats or equivalent nonslip surfacing that complies with [subpart D] and protective equipment must be provided for persons working over water. See 1910.261(e)(4).

  • Handrails and toeboards protect against falls and falling objects.
  • Use cleats or other non-slip measures on inclines and provide personal floatation or rescue plans for work over water.

Under 1910.261(e)(5) and related provisions, what guarding is required under slasher tables and around slasher saw undersides?

Where the slasher saw underside is not protected by the machine frame, the underside must be enclosed with guards. See 1910.261(e)(5).

  • Ensure guards fully enclose moving parts under the table to prevent contact and contain debris.
  • Inspect guards for secure attachment and integrity; do not operate the machine with guards removed.

Under 1910.261(e)(6) and 1910.261(c)(15)(iv), how must conveyors in pulpwood and rag operations be guarded?

Conveyors and their drive belts and pulleys must be fully enclosed or, if open and within 7 feet of the floor, constructed and guarded in accordance with 1910.261(c)(15) and the mechanical power-transmission standard at 1910.219. See 1910.261(e)(6).

  • If conveyors are open and reachable from the floor, follow guard design and spacing in 1910.219 to prevent contact with moving parts.
  • Keep guard fastenings secure and require removal only by authorized personnel during lockout/tagout.

Under 1910.261(e)(8), what equipment and personal protective equipment (PPE) are required for barker feed operations?

Each barker must have a feed and turnover device so the operator does not hold a bolt or log by hand during barking, and the operator must be provided with eye, ear, and head protection as required by [1910.261(b)(2)]. See 1910.261(e)(8).

  • Install mechanical feed/turnover devices to eliminate hand-holding of material.
  • Provide and require eye protection, hearing protection, and head protection consistent with 1910.261(b)(2); see also 1910.134 if respirators are needed for airborne contaminants.

Under 1910.261(e)(10), what must be done when knives are being changed on slasher or similar equipment?

All control devices must be locked out and tagged when knives are being changed. See 1910.261(e)(10).

  • Follow full lockout/tagout procedures: isolate energy, apply locks/tags, verify de-energization before changing knives.
  • The LOTO interpretation explains when temporary re-energization may be allowed for testing, but knife changes themselves require locks/tags.

Under 1910.261(e)(12)(i)–(iii), what guarding, walkways, and lock/tag practices apply to continuous barking drums?

When platforms or floors allow access to drum sides, a standard railing must be constructed around the drums; proper walkways with standard handrails must be provided between drums arranged side by side in accordance with [1910.23]; sprockets, chains, gears, and trunnions must have guards per [1910.219]; and if a worker must go inside a drum the driving mechanism must be locked and tagged at the main disconnect. See 1910.261(e)(12)(i), 1910.261(e)(12)(ii), and 1910.261(e)(12)(iii).

  • Build railings and walkways to meet 1910.23 for means of access and guarding.
  • Guard power-transmission parts per 1910.219.
  • Use lockout/tagout before anyone enters a drum, as required in 1910.261(e)(12)(iii).

Under 1910.261(e)(13)–(15), what special controls and protections are required for intermittent barking drums, hydraulic barkers, and splitter blocks?

Intermittent barking drums must have a device that can be locked to prevent drum movement while being emptied or filled; hydraulic barkers must be enclosed with strong baffles at the inlet and outlet and the operator must be protected by at least five-ply laminated glass; splitter blocks must have corrugated surfaces or other means to prevent wood slipping. See 1910.261(e)(13), 1910.261(e)(14), and 1910.261(e)(15).

  • Fit drums with positive-locking devices to prevent unexpected rotation.
  • Install baffles and laminated glass for hydraulic barker operator protection and maintain them regularly.
  • Use corrugation or equivalent on splitter blocks to prevent workpiece slip and related pinch injuries.

Under 1910.261(e)(18) and 1910.95, what protections are required for chipper spouts and noise exposure for chipper operators?

Chipper spouts must be arranged so the operator does not stand in a direct line with the spout, enclosed to at least 42 inches from the floor or operator's platform, and when other protection is not sufficient the operator must wear a safety belt line to prevent falling into the throat; ear protection must be worn if noise may be harmful per [1910.95]. See 1910.261(e)(18) and 1910.95.

  • Enclose spout to 42 inches and position feed equipment to keep operators out of the ejection line.
  • Provide and require hearing protection when noise exposures reach levels covered by 1910.95.
  • If belts/safety lines are used, ensure they are rigged so the operator cannot fall into the chipper throat.

Under 1910.261(f)(1)(i)–(ii), how must hand knives, scissors, and sharpening steels be handled and stored in rag and paper preparation areas?

Hand knives and scissors must have blunt points, be fastened to the table with a chain or thong when in use, and not be carried on the person; they must be placed in racks or sheaths when not in use, and hand knives and sharpening steels must have guards at the junction of the handle and blade. See 1910.261(f)(1)(i) and 1910.261(f)(1)(ii).

  • Use tool racks or sheaths for safe storage and prevent carrying sharp tools on clothing.
  • Ensure guards at handle-blade junctions are intact to reduce hand laceration risk.

Under 1910.261(f)(2), what guarding and feeding protections are required for shredders, cutters, and dusters?

Rotating heads or cylinders must be completely enclosed except for a feed opening sized to permit only entry of stock; enclosures must extend over the top of feed rolls and be bolted or locked. A smooth-pivoted idler roll must be provided in front of feed rolls unless the operator cannot stand closer than 36 inches, and manually fed cutters must use idler rolls or special hand-feeding tools. See 1910.261(f)(2)(i), 1910.261(f)(2)(ii), and 1910.261(f)(2)(iii).

  • Enclosures must prevent contact and contain flying particles; secure with bolts or locks.
  • Provide feeding aids (idler rolls or hand-feeding tools) to keep hands away from feed openings.
  • Ensure hoods have exhaust ventilation as required by 1910.261(f)(2)(iv).

Under 1910.261(f)(3)(i)–(ii), what safeguards apply to blowers used for transporting rags and their discharge outlets?

Blowers used for transporting rags must have feed hoppers with outer edges located at least 48 inches from the fan, and the discharge outlets must be arranged so material will not fall on workers. See 1910.261(f)(3)(i) and 1910.261(f)(3)(ii).

  • Keep hopper openings and feed points at least 48 inches from the fan to reduce the risk of operator contact with fan suction or ingestion hazards.
  • Direct discharge paths away from worker areas and provide guards or barriers where material could fall.

Under 1910.261(f)(6)(i)–(ii) and (iv), what procedures and attendants are required when workers must enter rag cookers for cleaning or inspection?

Before entry, all steam and water valves or other controls must be locked and tagged in the closed or "off" position (blank flanging is acceptable), and one person must be stationed outside to observe and assist in case of emergency; rag cookers must also have safety valves meeting the ASME Boiler and Pressure Vessel Code. See 1910.261(f)(6)(i), 1910.261(f)(6)(ii), and 1910.261(f)(6)(iv).

  • Use lockout/tagout or blank flanging to isolate energy and prevent accidental steam/water release.
  • Post an attendant outside the cooker as required so help is immediately available in emergencies.

Under 1910.261(g)(4)(i)–(ii) and 1910.134, what steps and respiratory protections are required before allowing workers to enter acid tanks?

Acid tanks must be washed out and fresh air blown in before allowing entry; workers entering must be provided with supplied-air respirators, lifebelts, attached lifelines, and a person stationed outside to summon assistance. See 1910.261(g)(4)(i) and 1910.261(g)(4)(ii). Also follow the Respiratory Protection Standard at 1910.134. The oxygen-deficient atmospheres LOI explains that civilian employees covered by OSHA must follow 1910.134 for supplied-air respirators and IDLH conditions.

  • Vent and wash tanks before entry and verify atmosphere is safe or provide supplied-air respirators as required.
  • Use lifelines and an outside attendant to meet the rescue/observation requirement in 1910.261(g)(4)(ii).
  • Comply with 1910.134 for respirator selection, fit testing, and maintenance.

Under 1910.261(g)(12)(i) and (12)(iv), how must digester blowoff valves and digester blow valves be arranged during the cooking period?

The blowoff valve of a digester must be arranged so it can be operated from another room remote from safety valves, and digester blow valves must be pinned or locked in the closed position throughout the entire cooking period. See 1910.261(g)(12)(i) and 1910.261(g)(12)(iv).

  • Ensure remote operation capability so personnel are not exposed to valve blowoff hazards.
  • Lock or pin blow valves closed for the entire cook to prevent accidental release; inspect locking devices before each cook.

Under 1910.261(g)(13)(ii)–(iii) and (13)(i), what safe access, signaling, and opening requirements apply to blow pits and blow tanks?

Blow pits should have side openings when possible or small top openings protected per subpart D; a special ladder must be constructed so the pit door cannot be closed when the ladder is in place and other means must prevent closing while anyone is in the pit; and a signaling device must be installed in the digester and blow-pit rooms and chip bins to warn before and during digester blows. See 1910.261(g)(13)(i), 1910.261(g)(13)(ii), and 1910.261(g)(13)(iii).

  • Design ladders and doors to physically prevent closing while the ladder is installed.
  • Provide audible/visual warning systems so workers know when digesters will blow and can clear the area.

Under 1910.261(g)(11)(ii) and (iii), what emergency equipment must elevators in digester buildings have?

Elevators in digester buildings must be equipped with gas masks for the maximum number of passengers and an alarm system to advise of failure. See 1910.261(g)(11)(ii) and 1910.261(g)(11)(iii).

  • Maintain and inspect gas masks so they provide adequate protection against sulfurous acid and chlorine gases as required by 1910.261(g)(10) and 1910.134.
  • Ensure elevator alarms are tested and working to warn occupants of failures.

Under 1910.261(g)(15)(ii), what ventilation and respiratory protection must be provided when workers enter a digester for inspection or repair?

Fresh air must be blown into the digester continuously while workers are inside, and supplied-air respirators must be available if that fresh air supply fails or is inadequate. This is required by 1910.261(g)(15)(ii).

  • Practical steps employers should take: ensure a reliable fresh-air ventilation system dedicated to the digester during entry; keep supplied-air respirators staged nearby and inspected; train workers on donning and emergency use.
  • Cross-reference: respirator selection, fit-testing, and use requirements apply under 1910.134, so follow that standard for program elements and maintenance.

Under 1910.261(g)(15)(iii), what personal safety and rescue precautions are required before an inspector enters a digester?

An inspector must wear a safety belt with a securely fastened lifeline and must be attended by at least one experienced employee stationed outside to handle the line and summon help; ladders and lifelines must be inspected before each use. This requirement is set out in 1910.261(g)(15)(iii).

  • Practical actions: assign a trained attendant before entry, test and document lifeline and ladder condition before each entry, and rehearse rescue procedures so the attendant knows how to respond.
  • Additional PPE: the standard also requires protective headgear for everyone entering digesters (1910.261(g)(15)(iv)).

Under 1910.261(g)(14)(ii)–(iii), may the hand plate be removed during a digester blow and what PPE and communications are required?

The hand plate must not be removed while a digester blow is in progress; the blowoff valve must be left open and the hand plate is only removed after the digester cook signals the blow‑pit man that the blow is complete. If it becomes necessary to remove the hand plate to clear stock, operators must wear eye protection and protective clothing to guard against burns. These rules appear in 1910.261(g)(14)(ii), and the cook-to-chip-bin signal requirement is in 1910.261(g)(14)(iii).

  • Practical checklist: confirm the digester cook’s clear signal before any hand-plate removal; provide and require ANSI-compliant eye protection and heat-resistant clothing; train workers on the signaling procedure and what to do if stock must be cleared during a blow.

Under 1910.261(g)(19)(iii), what must be done to isolate a blow line before inspecting or repairing a digester when multiple blow lines join one pipe?

The cock or valve of the blow line from the tank being inspected or repaired must be locked or tagged out, or that line must be disconnected and blocked off. This is required by 1910.261(g)(19)(iii).

  • Implementation note: use lockout/tagout procedures consistent with 29 CFR 1910.147 when isolating energy or flow that could endanger workers; see OSHA's clarification of lockout/tagout and temporary energization procedures in the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21 for guidance on sequencing, employee protection, and when temporary re-energization is allowed.
  • If lines are disconnected/blocked, verify positive isolation (blanking/bleeding) and post clear tags and tests before permitting entry or repairs.

Under 1910.261(h)(2)(iii) and (h)(3)(iii), what respiratory protection is required for emergency or rescue work involving chlorine in bleach operations?

For emergency and rescue operations involving chlorine, employers must provide employees with self-contained breathing apparatuses (SCBA) or supplied-air respirators and ensure employees use them, as required by 1910.261(h)(2)(iii) and 1910.261(h)(3)(iii).

  • Program requirements: follow the respiratory protection program elements in 1910.134 — selection, fit testing, training, inspection, and maintenance.
  • Additional guidance: OSHA’s interpretation on oxygen-deficient atmospheres and the application of 1910.134 (https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16) explains how to treat immediately dangerous to life or health (IDLH) atmospheres and supports using SCBA or equivalent supplied-air systems in such emergency conditions.