Noor Paper Arts: Safety Inspectorate

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Executive Summary

Noor Paper Arts (NPA) is engaged in the manufacturing of handmade paper, which is an eco-friendly product. The handmade paper manufacturing process requires plenty of water and considering this aspect, the manufacturing facility was based at Jebel Ali Free Zone. Its factory is located in Jebel Ali Free Zone. Even though the company is doing a good job by promoting eco-friendly paper products, the situation inside its manufacturing facility is alarming. The workers do not follow any safety or precautionary measures and as such, are prone to several risks and hazards.

The process being followed during paper manufacturing is primitive and outdated machines are being used. The raw material is not of good quality that has dust and other foreign particles in it. The positioning of motors is not safe and their belts are worn out. There is no provision of masks for the workers who work in dust and deal with hazardous chemicals. The manufacturing facility does not have a sufficient number of fire extinguishers. Moreover, there is no fire exit in the shed. The floor is wet due to water spillage. Tanks are kept open that pose a risk of workers falling into them. Machines are handled manually and there is a risk of the workers getting caught in them. Workers even smoke within the factory premises, which can lead to a fire.

A little care and investment can help in getting rid of all such problems. Inspection of the factory premises and the manufacturing process were conducted by competent personnel of the company. This report contains the observations of the inspection. Recommendations based on these observations are also included in the report.


This report is a result of the rigorous inspection of the manufacturing facility of NPA that was conducted on 15th September 2014. The motive behind this inspection was to ascertain that all the required safety measures were being followed. The inspection also aimed at identifying potential discrepancies and drawbacks in the manufacturing process and the installed machinery/equipment. It was conducted by the company’s ‘Health and Safety Officer’ and his subordinates.

The factory has a workforce of 150 skilled, 200 semi-skilled, and 100 casual/unskilled people. The work is carried out in three shifts; the night shift workers are given some extra payment. The business activity includes manufacturing handmade paper and various gift products made out of it. The raw material used is hosiery waste.

Main findings

NPA has more weaknesses than strengths as far as complying with the UAE government’s guidelines is concerned. The strengths include its being eco-friendly product-based industry and water conservation. Among the weaknesses, where government guidelines are breached, the following are the major ones:

Risk of the respiratory problem – observations 1, 6, and 16

The UAE Labour Law (Article 19) has strict guidelines for employers regarding occupational diseases. In the handmade paper-making process, there are certain areas where the operators and other laborers are prone to respiratory problems. This is due to the dust that emanates from the hosiery waste (cotton rags) and chemicals. Such instances can be avoided by taking a little extra precaution and requesting the vendors also to send better quality hosiery waste that is free of dust. There is no additional cost involved in following such precautions and as such, there should not be any problem or hindrance (such as approval from the management or board). For hazardous chemicals, airtight containers should be procured for storage purposes. This would cost around 1000 dirham.

Risk of falling from height and/or slipping on the floor – observations 9, 10, 12 & 13

Handmade paper making is a labor-intensive industry. As such, during the manufacturing process, to reduce the use of machines, the beater is installed at a height so that the pulp can flow into the storage tanks by way of gravity. At the same time, a lot of water is used during the beating process. As of now, the water spillage cannot be controlled (due to certain shortcomings and lack of proper technology in this industry), which leads to wet steps and floors.

During ascending and/or descending the steps, the operators and other laborers are prone to falling from height. This might be a cause of bone injuries. It is worth mentioning that Article 13 of UAE Labour Law has a provision for employers’ prosecution in case of injuries to employees during work hours.

Since water spillage cannot be controlled (as of now), the best thing that can be done is to depute the required number of workers for sweeping the floor and keeping it as dry as possible. This particular step would cost only the wages of the deputed people. Considering the size of the shed, two workers in every shift should be enough to take care of the issue. Three shifts mean six workers. On average, the monthly salary of six workers would be six to seven thousand dirhams. Another alternative could be to replace the floor surface with anti-skid tiles. This would cost around 20,000 Dirham and would be a one-time investment.

Risk of noise pollution – observation 8

In the complete handmade paper-making process, the rag chopper is the only machine that makes a lot of noise. There is no way to stop this noise because the process involves steel blades rubbing against each other. The only precaution that can be taken is to provide the operators and other laborers with appropriate preventive aids such as hearing protection devices. Purchasing such devices should not cost more than 5,000 dirhams. This would be a recurring investment (every six months). It should be noted that Article 54 of the UAE ‘Federal Law # 24 of 1999 for the Protection and development of the Environment’ has prescribed certain limits for noise levels by machines and other equipment.

Fire risk – observations 7, 24 & 29

Since the factory is situated in Jebel Ali Free Zone, it comes under the jurisdiction of Ports, Customs & Free Zone Corporation (PCFC). All businesses that come under PCFC have to adhere to the ‘Health, Safety & Fire Protection Regulations & Standards’ laid out by the Dubai government. There are a couple of instances at NPA that are related to fire risk. First of all, the fire extinguisher is not calibrated. Secondly, laborers have the habit of smoking inside the shed. Finally, there is no separate fire exit. Making provision for a fire exit would incur expenses that might amount to 5,000 dirhams.

Risk of electrocution – observations 5 & 11

The motor of the rag chopper and the agitator pump are kept open. This could lead to the operator getting entangled in the motor v-belts, which might be a cause of electrocution and/or fatal injuries. The motors should be shifted to a safe place (probably a corner) and covers should be provided. Shifting the motors would cost around 2000 dirham and providing covers would amount to an additional 1000 dirham. According to Article 96 of UAE Federal Law # (8) of 1980, all businesses must take precautionary measures to prevent hazards about electricity.


This report brings forward certain issues that need immediate attention. The worst drawback in the factory is non-compliance with safety measures. The main findings suggest that several areas/processes need to be rectified. The major issues are related to health hazards such as respiratory problems, fall injuries, noise pollution, fire risk, and electrocution. Though these issues are very significant, rectifying them would need just a little care.

Workers working in areas where a lot of dust emanates from the process do not wear any face masks to protect themselves from inhaling it. The floor is wet and can be a cause of severe fall injuries. Certain machines make a lot of noise and the operators do not have any hearing protection device to put on. The factory shed does not have any fire exit, which can prove to be fatal during times of emergency. Electric motors and pumps are kept unguarded and can cause electrocution.

The report includes some recommendations that should help improve the working conditions and safety of the workers. Such measures will surely increase the workers’ trust in their organization, which is bound to increase productivity.


Recommendation Resources (Manpower/Time/Costs) involved Priority Time frame (Date)
Request vendors to send good quality hosiery cutting that is free from dust and other foreign particles. Manpower: The procurement department has to communicate and persuade the vendors.
Time: One day to convince vendors
Costs: 100 dirhams for telephone call charges
High Immediate
September 2014
Procure airtight containers that are suitable for hazardous material and are labeled accordingly. Manpower: Procurement officer to the source container
Time: 2 days to gather quotations
Costs: 1000 dirham to purchase containers and 200 dirhams towards the salary of the procurement officer
High Immediate
September 2014
Depute workers regularly clean up the spillage from the beating and vat process areas. Also, to put a “Wet Floor” warning sign Manpower: The HR department would depute such workers.
Time: One day to shortlist workers
Costs: It would cost around 6,000 dirhams monthly.
High Immediate
September 2014
Replace floor surface with anti-skid tiles Manpower: Procurement officer to gather quotations for civil work and anti-skid tiles.
Time: Two days to obtain the quotations and ten days to complete the civil work.
Costs: Anti-skid tiles would cost 15,000 dirhams and labor charges for replacing would be 5,000 dirhams. In addition, the salary of the procurement officer would be 200 dirham
High Immediate
September 2014
Make covers for tanks.
Warning signs to be placed near the tanks.
Manpower: Procurement officer to obtain quotations for tank covers and fitting charges.
Time: Two days to obtain the quotations and 5 days for fitting work
Costs: The two covers would cost 8,000 dirhams and fitting charges would be 2,000 dirhams. The time devoted by the procurement officer would amount to 200 dirhams.
High Immediate
September 2014
Procure hearing protection devices Manpower: Procurement officer to obtain quotations for hearing protection devices
Time: two days to gather quotations
Costs: The cost of purchasing such devices would be 5,000 dirham
High Immediate
September 2014
Arrange for calibration of fire extinguisher Manpower: Procurement officer to send fire extinguisher for calibration
Time: Two days for calibration
Costs: This would cost around 20 dirhams and another 100 dirhams for transportation and the salary of the person who will go.
High Immediate
September 2014
Install at least 6 new fire extinguishers in different areas in the shed. Manpower: Procurement officer to obtain quotations for new fire extinguishers
Time: 2 days to obtain quotations
Costs: The cost of purchasing 6 new fire extinguishers would be 900 dirhams and the salary for the procurement officer would be 200 dirham
High Immediate
September 2014
Make factory premises a no-smoking area. Put signboards at various places. Manpower: The administration will issue strict guidelines with a penalty clause. Procurement officer to arrange for the signboards.
Time: Two days to get signboards ready
Costs: The signboards would cost 100 dirham
High Immediate
September 2014
Make provision for the fire exit.
Signboards to be put at appropriate places
Manpower: Procurement officer to obtain quotations for the fire exit door and its fixing charges.
Time: Two days to obtain quotations and one week to fix it
Costs: The fire exit door would cost 3000 dirham and the fixing charges would be 2000 dirham.
The time devoted by the procurement officer would amount to 200 dirham
High Immediate
September 2014
Shift the motors to a safe place, probably a corner. Manpower: Procurement officer to obtain a quotation for the civil and electric work involved in the proposed shifting.
Time: Two days to obtain the quotations and 2 days to complete the shifting work
Costs: Shifting the two motors would cost 2,000 dirhams and the salary of the procurement officer would be 200 dirham
High Immediate
September 2014
Make covers for motors. Manpower: Procurement officer to obtain quotations for the motor covers
Time: Two days to obtain the quotations and another 2 days to make them.
Costs: Making covers would cost 1,000 dirhams and the salary of procurement officer will be 200 dirham
High Immediate
September 2014
Replace the existing rag chopper with a new and advanced version. Manpower: Procurement officer to obtain a quotation from international suppliers.
Time: One week to get the desired number of quotations
Costs: A new rag chopper would cost 25,000 dirhams. The cost for installing the new rag chopper would be 2000 dirham. The salary of a procurement officer would be 500 dirhams.
Medium Intermediate
(2 months)
Change motor v-belts that are worn out. Manpower: Procurement officer to obtain quotations for v-belts.
Time: Two days to obtain quotations
Costs: Recurring cost every six months will be 2,000 dirham
Medium Long term
Procure protective gloves for workers. Manpower: Procurement officer to purchase protective gloves from the local market.
Time: one day to purchase the gloves
Costs: Recurring cost every month will be 500 dirham
Medium Long term
Install exhaust fans near machines such as rag chopper, beater, and hydraulic press. Manpower: Procurement officer to obtain a quotation for exhaust fans. Factory electrician to fix the fans
Costs: The cost of four exhaust fans would be 2,000 dirham and fitting charges would be 200 dirham
Low Intermediate
(two weeks)

Management Report


Observations Control measures Time-scale
  1. plenty of dust in hosiery waste.

Since the operators do not wear any masks, there is a risk of dust inhalation by them.
The dust can cause respiratory problems such as asthma.

The vendors should be instructed to send clean raw material
The operators and other laborers should be provided with protective gear
Immediate (next shipment)


  1. et all pieces in hosiery waste.

Blades can break.
The flying blade parts might cause fatal injuries to the operator such as cuts to skin and piercing of eyes from flying debris and even death from being hit by the flying blade.

The vendor should be instructed to take extra care.
Some sort of magnetic implement can be used to take out metallic objects.
Immediate (next shipment)


  1. updated rag chopper

There is a lot of vibration during the rag chopping process and there are chances of the nuts getting loose
This could prove to be very dangerous for the workers standing nearby.

Stop work on the rag chopper immediately and send it to the maintenance department. Replace rag chopper with a new version that has low vibration Intermediate
  1. Motor v-belts was worn out

Risk of v-belts getting broken
Injuries to the operator

Use good quality v-belts
Change v-belts periodically
Depending on the condition of v-belts (every 6 months)
  1. Rag-chopper motor installed very near to the feeder

The operator’s clothes might get entangled.
Electrocution and/or severe injuries.

Shift the motor away from the feeder. Intermediate (one week)
  1. laborers not wearing masks

Dust can be inhaled by workers
Breathing problems such as asthma

Arrange respiratory masks Immediate (1-2 days)
  1. Fire extinguisher not calibrated

It might not work properly
This could be a cause of the uncontrollable fire.

Arrange for fire extinguisher calibration Immediate (1-2 days)
  1. Rag chopper makeslot of noise

No precaution for the operator
Hearing impairment of the operator.

Arrange earplugs for the operators Immediate (1-2 days)
  1. Wet floor

Floor slippery
Workers might fall and it can generate bacteria as well.

Make such arrangements that the water does not spill.
If at all there is any spillage, the water should be restricted to small areas.
Assign duty to the appropriate number of workers to mop and clean the surface at regular intervals
Within one week

Within one week


  1. No cover for agitator tank

Workers can fall into the tank
The rotating blades can be very dangerous

Make a cover for the agitator tank Within one week
  1. agitator pump uncovered

Workers’ clothes can get entangled
Electrocution or other injuries.

Arrange a cover for the agitator pump
Shift the agitator place to a corner
Immediate (1-2 days)

Within one week

  1. Beater tank kept open

The operator might slip and fall into the tank.

Cover the beater tank and keep a small opening for the operator to check the pulp. Within one week
  1. Beater is installed at a height

Steps are slippery due to extensive use of water and as such, workers might slip.
Broken bones and/or other fatal injuries.

Avoid water spilling
Keep the floor dry
Replace the floor surface with anti-skid tiles.
Within 2-3 months
  1. Waste pulp kept near the beater tank

Chances of bacteria development
Harmful from a health point of view

Arrange for lifting waste pulp and dumping at a distant area. Immediate
  1. laborerss put chemicals in the beater tank with bare hands.

Some chemicals are very hazardous.
Can harm the skin.

Laborers should be provided with protective gloves that are chemical resistant. Within 1-2 days
  1. hazardous chemicals left open.

Possibility of inhalation.
Severe respiratory problems.

Arrange airtight containers for such chemicals
Arrange respiratory masks for the operators and laborers.
Within 1-2 days

Within 1-2 days

  1. not enough exhaust fans in the shed

Rise in humidity.
Health problems.

Install exhaust fans near all the machines Within one week
  1. No protective hand gloves

Hands always wet
Waterborne diseases

Arrange protective hand gloves for the vat workers Within 1-2 days
  1. wallpaper stack inserted in the hydraulic press more than its capacity

Oil seal in the hydraulic press could burst
Oil could erupt, causing injuries.

Instruct the laborers to reduce the number of wet papers in the stack
Arrange for a heavy-duty hydraulic press that is capable of handling large paper stacks.

Within one month

  1. paper drying is done in an open area.

Laborers are exposed to direct sunlight for long hours.

Arrange protective gear for these laborers
Arrange cold water so that the laborers do not get dehydrated
Immediate (1-2 days)
  1. No protection forthe operator of the Calendar machine.

Body parts could get trapped between rollers
Fatal injuries

Make some sort of blockage to stop the operator’s hands from getting caught in the steel rollers.
Arrange a calendar machine that operates on the latest technology.
Within one week

Within one to two months

  1. Paper cutting machine is manual

Manual feeding risky
Hands could get cut by blades

Arrange an automatic paper cutting machine. Within one month
  1. No proper cleaning

Bacteria development
Health problems

Depute someone to keep the area clean Immediate
  1. laborerss smoking inside the shed

Paper products are inflammable
Huge fire.

Strict guidelines to all the employees not to smoke within the factory premises.
Keep fire extinguishers at every ten to twelve meters’ distance.

Within a week

  1. Manualloading and unloading.

Could cause sprains.
Muscular and/or bone problems.

Arrange a forklift to take care of the loading and unloading Immediate (within a week)
  1. No fire exit

Chaos during mishaps

Make a fire exit that could be used during emergencies. Immediate (within a week)

Good Practices

Observations Control measures Time-scale
  1. Eco-friendly product: handmade paper uses hosiery waste (rags) and indirectly saves forests by not using wood pulp.
Continue the use of environment-friendly and safe products. Ongoing
  1. finished products kept in a separate room: if by chance there is any fire, it would not spread easily because the finished products are stored in a separate room: most of the paper making process involves water and as such, there are remote chances of a fire. The only major cause of the spreading of fire could be the finished products (but they are stored separately).
Ensure procurement policy is updated to reflect the use of eco-friendly products as a priority. Monitor costs Ongoing
  1. the factory has three shifts so that laborers have ample rest.
Keep up the good work Ongoing
  1. Waterconservation through recycling. By recycling the used water, the factory is helping in the conservation of this precious resource.
Keep recycling water and conserving precious natural resources. Ongoing
  1. Labourers provided with appropriate accommodation within the factory premises.
Keep up the good work Ongoing

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