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Safety Is No Accident

By John Kiefner

March 20, 2023

For those who have never stepped foot into a corrugated plant, it’s quite an eye-opening experience once past the front office. If I could turn back time, I would seek a safety consultant internship in a corrugated plant because no other industry offers anywhere near the variety of severe risk exposures.

While the frequency of injuries in the corrugated industry is often led by sprains or strains, trips, and cuts, the severe exposures are what keep me up at night. Rather than go through the Occupational Safety and Health Administration (OSHA) standards word for word, let’s look at some practical considerations for addressing five severity exposures in the corrugated industry.

1. Caught in Machinery


Entanglement within machinery can occur in a split second when allowing any of the following items to be brought onto the plant floor: hooded sweatshirts, loose jewelry, long hair, lanyards without breakaway straps, and rags wrapped around the hand. A written policy should be in place prohibiting all of the above, and managers should strictly enforce the policy with employees and temps.

When assessing machine guarding, keep it simple. Anything beneath 7 feet that can catch clothing, hair, body parts, etc., should be guarded. Where physical guarding is used, it must be fixed (tool used for securing) or interlocked. Other types of guards may include light curtains, pressure-sensitive matting, pull cords, etc. Although not required by OSHA, it is strongly recommended that interlocks and presence-sensing devices be placed on a testing schedule as the failure of these devices does not always lead to a fail-safe outcome. Lack of a testing schedule will eventually result in an injury or a willful OSHA violation. While conveyor rollers are not designed as machine guards, they often function as such, protecting moving parts beneath. While the focus may be placed on production machinery, do not treat missing conveyor rollers lightly. Conveyors should not be in operation without all rollers in place.

OSHA’s lockout/tagout (LOTO) standard is designed to prevent “caught in machinery”-type injuries. However, minimum compliance with the standard is not sufficient in the corrugated industry. There are complexities within corrugated machinery that the LOTO standard does not account for. Keys, rather than locks, are used to de-energize many pieces of equipment. It is essential to verify that no two keys are cut the same for other equipment or for sections of the same equipment. It is also recommended that employees be trained annually rather than just upon their hire and when new equipment is introduced. LOTO machine-specific procedures should be reviewed annually for accuracy, in addition to the “periodic inspection” requirement of the standard. When reviewing machine-specific procedures, pay particular attention to the “verify isolation” step, which ensures the lockout was conducted properly, leaving the equipment completely de-energized.

2. Struck by Forklift


Although forklift injuries are infrequent, the injury outcome is almost always severe. Aside from required training (upon hire and every three years) and pre-shift inspections, additional steps can be taken to lessen the chance of a pedestrian being struck by a forklift. Where possible, protect pedestrians from forklift traffic with walls, protective rails, bollards, etc. For pedestrian and forklift intersections, strobes triggered by oncoming forklifts can be effective, as well as strategically placed mirrors. All forklifts should be equipped with blue light systems, which shine a blue dot on the floor ahead of the oncoming forklift. High-visibility shirts and vests can also help make pedestrians more visible to drivers. There are so many variables with forklift and pedestrian interaction that a variety of preventive measures need to be considered.

3. Fall From Heights

Employees conducting work above 4 feet must be protected by a railing or must wear a fall-arrest system. The former is preferred over the latter as there are many variables to a fall-arrest system, including the fact that the user must put it on. Areas of fall exposure in the corrugated industry are as follows:


Where product is loaded or staged on overhead platforms, mezzanine safety gates should be considered instead of removable rails or chains. Flip gate systems provide 100% protection during this task.

Loading Docks

If above 4 feet, dock doors must be closed when the dock is empty. All unprotected areas of the dock should be equipped with an approved railing (42-inch top rail, 21-inch midrail).

Roof Work

Roof work performed within 6 feet of the edge on a flat roof requires a fall-arrest system. When working 6–15 feet from the edge, a warning line must be installed. When working on a pitched roof, a fall-arrest system is always required.

Fixed Ladders

Fall protection systems are required to be installed on fixed ladders greater than 24 feet in height. Existing fixed ladders are grandfathered until 2036, at which time they must also be equipped. Self-closing safety gates are recommended at the top of each fixed ladder.

Scissor and Aerial Boom Lifts

While OSHA mandates the use of fall-arrest systems only when operating an aerial boom lift and not a scissor lift, falls frequently occur from scissor lifts when occupants climb onto the protective railings. It is strongly recommended that company policy mandate the use of fall-arrest systems when working within scissor and aerial boom lifts.

Cleaning on Top of Machinery

If cleaning tasks at heights above 4 feet are not contracted out, physical protection or a fall-arrest system must be considered. If installing a fall-arrest system, it is recommended that an expert in the field be consulted as there are many variables.

4. Confined Spaces

Confined spaces are rarely discussed within the corrugated industry, yet they present a significant risk if handled improperly. Confined spaces in the corrugated industry often include storage tanks, pits beneath machinery, manholes, dust collection systems, and more. Almost all confined spaces can further be defined as “permit required” as they contain an internal hazard (atmospheric, physical, etc.). Dabbling in confined space entry is a recipe for disaster. Therefore, after assessing and labeling the space, the following should be considered.

Prevent the Need to Enter

In many cases, pits beneath machinery are entered for cleaning purposes. Many companies have figured out ways to minimize scrap from entering these pits. In addition, they have utilized manual “grabbers” to pull out larger pieces of scrap and have implemented vacuuming systems to extract the remaining portions.

Contract Out Confined Space Entry

Permit-required confined space entry can be complex and costly. Infrequent entry usually results in improper entry with varied levels of compliance. It is recommended that confined space entries be preplanned and contracted out using a company that specializes in confined space entry.

Temporarily Reclassify the Space as Nonpermit

A permit-required confined space containing physical hazards, not atmospheric hazards, can be temporarily reclassified as nonpermit through proper LOTO procedures. This can occur only if a series of

atmospheric tests have been conducted to determine there is no risk. It is common for pits beneath machinery to contain a physical hazard from moving machinery. In most cases, the pits do not present an atmospheric hazard and can be safely entered once lockout is performed to de-energize the machinery that presents the risk.

5. Combustible Dust


Combustible dust explosions can occur under specific circumstances, producing catastrophic results. The perfect storm includes the “fire triangle”—combustible dust, heat, oxygen—and the dispersion of dust in a confined area. Dust particle size must be fine enough for it to be combustible. Don’t bother testing the dust at your plant because all corrugated plants produce combustible dust through one or more of the following processes: trimming, die cutting, shredding, baling, and more.

Dust Collection

Good housekeeping throughout a plant is the most essential element of a combustible dust prevention program. This includes capturing dust at the source through a dust collection system. When designing a system, utilize a manufacturer and installer with combustible dust expertise so all OSHA and National Fire Protection Association standards are incorporated within the system. In addition to dust collection systems, many within the corrugated industry are incorporating air dust filtration systems to capture the smallest dust particles that escape traditional dust collection systems.

Plantwide Cleaning Schedule

Dust in fine particle size will not only settle where it is produced but will travel throughout buildings and settle on any available flat surface, including machinery, piping, rafters, etc. OSHA has been known to issue citations under its “general duty clause” for dust accumulation that is the thickness of a dime. Setting up a plantwide cleaning schedule is imperative in preventing dust accumulation. When conducting the cleaning in-house, explosion-proof vacuums must be used.

Training and Education

Compressed-air hoses are located on most production lines in corrugated plants. The air hoses, if used incorrectly, present the opportunity for dust dispersion, which is one of the elements leading to combustible dust explosions. Employees must be educated on how dust explosions occur and must be informed that the air hoses are not to be used in a manner that allows dust to be blown into the air. The common practice of “blowing out” a forklift must occur outside and away from the building. Machinery that commonly accumulates dust should be frequently vacuumed rather than blown out.

Stay Vigilant

While frequency trends deserve continued attention, severity exposures often catch companies asleep at the wheel. Make time with your safety committee and management team to individually address each of the top five severity exposures. As you do so, utilize the AICC network for best practices as safety and risk protocol within the corrugated industry is quickly evolving.


John Kiefner, CSP, ARM, is vice president of risk control at Johnson, Kendall & Johnson.


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