Die Cutting SWMS (Printing / Packaging)

Die cutting on flat-bed and rotary converting equipment is one of the highest-risk operations in the Australian printing and packaging sector, combining stored mechanical energy, sharp tooling and high-speed material feed in a single work envelope. Platen presses close with forces sufficient to amputate fingers in milliseconds, while rotary die stations present continuous in-running nip points at feed and delivery rollers. Die changes expose operators to razor-edge steel rule, and jam clearance routinely tempts workers to bypass interlocks under production pressure. Under WHS Regulation 2025 Part 3.2 (Plant), a PCBU operating powered plant of this class must identify foreseeable hazards, apply the hierarchy of control, and document the safe system of work before the press is started. A Safe Work Method Statement is mandatory because die cutting meets the high-risk construction/plant criteria under section 291 and because plant-related crush injuries remain a leading cause of serious notifiable incidents in converting facilities.

Hazards identified

7 hazards covered, sorted by priority.

Control measures

Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.

1. 1Elimination — Where production volume permits, replace manual die cutting with pre-cut stock supplied by the substrate vendor, removing the cutting hazard from the site entirely.
2. 2Elimination — Remove the need to enter the platen envelope during jams by specifying automated waste extraction and matrix stripping integrated with the press feeder system.
3. 3Substitution — Replace traditional sharp-rule steel dies with magnetic flexible dies on rotary stations, reducing edge exposure during tool change and storage handling.
4. 4Engineering — Install Category 4 light curtains and two-hand control devices on platen presses, interlocked to AS 4024.1601 standards to prevent closure when the danger zone is occupied.
5. 5Engineering — Fit fixed perimeter guarding with interlocked access gates on all rotary nip points, ensuring guards meet reach-distance requirements of AS 4024.1801.
6. 6Engineering — Provide acoustic enclosures and damped delivery chutes to reduce operator noise exposure below the 85 dB(A) eight-hour exposure standard under WHS Reg 2025 r58.
7. 7Administrative — Implement a documented lockout-tagout procedure for all die changes and jam clearances, with personal locks issued to each authorised operator and verified zero-energy state.
8. 8Administrative — Restrict press operation to workers holding verified competency assessment, with daily pre-start inspection logged on the SWMS sign-on sheet before production commences.
9. 9PPE — Provide cut-resistant gloves rated EN 388 Level D for die handling, removed before press start to prevent entanglement, plus Class 5 hearing protection.
10. 10PPE — Supply safety footwear with steel toe and metatarsal guard rated to AS/NZS 2210.3, with high-visibility vests where mobile plant operates in the converting bay.

Applicable Codes of Practice

High-Risk Construction Work triggered

Worked example

At a mid-sized corrugated packaging plant running a flat-bed clamshell die-cutter on the night shift, the leading hand opens the pre-start brief by walking the four-person crew through this SWMS at the press. The operator confirms the light curtain self-test has passed and signs the daily inspection block on page two. During the brief, the apprentice raises that the previous shift left a partial waste matrix in the delivery — the leading hand cross-references the slip hazard line item and directs the apprentice to clear the bay before start-up, logging the corrective action on the SWMS variation page. Two hours into the run, a board jam stops the press. Rather than reaching through the guard opening, the operator applies the documented lockout sequence shown in the controls section: presses emergency stop, isolates the main disconnect, applies his personal lock and tag, bleeds pneumatic pressure, and only then enters the platen envelope wearing cut-resistant gloves to clear the jam. After clearance, the second operator independently verifies the energy-isolated state before locks are removed and production resumes. The SWMS sign-on sheet is updated with the jam event and time, creating the audit trail required if a notifiable incident review later examines isolation discipline on the line.

Related legislation

• WHS Act 2011 (model)
• WHS Regulation 2025
• AS 2550 — Cranes, hoists and winches; AS 1418 series

Frequently asked questions