Exerpts on Line Breaks from OSHA’s Guidelines for Process Safety Management

OSHA published a pamphlet to help employers understand Process Safety Management regulations. OSHA Pamphlet #3133 covers the employer responsibility on the hazards and technology of process systems. It also reviews operating procedures, employee training, and written procedures, among many other topics. Below are a few “generic, non-exhaustive” excerpts that could apply directly to the regulations for a line break on a functioning pipe system.

To read the full pamphlet, follow this link: https://www.osha.gov/Publications/osha3133.html.

“The major objective of process safety management (PSM) of highly hazardous chemicals is to prevent unwanted releases of hazardous chemicals especially into locations that could expose employees and others to serious hazards.’

“Operating procedures provide specific instructions or details on what steps are to be taken or followed in carrying out the stated procedures. The specific instructions should include the applicable safety precautions and appropriate information on safety implications. For example… using operating instructions to properly implement operating procedures is in starting up or shutting down the process. In these cases, different parameters will be required from those of normal operation. These operating instructions need to clearly indicate the distinctions between startup and normal operations, such as the appropriate allowances for heating up a unit to reach the normal operating parameters. Also, the operating instructions need to describe the proper method for increasing the temperature of the unit until the normal operating temperatures are reached.’

“Hands-on training, where employees actually apply lessons learned in simulated or real situations, will enhance learning. For example, operating personnel, who will work in a control room or at control panels, would benefit by being trained at a simulated control panel. Upset conditions of various types could be displayed on the simulator, and then the employee could go through the proper operating procedures to bring the simulator panel back to the normal operating parameters. A training environment could be created to help the trainee feel the full reality of the situation but under controlled conditions. This type of realistic training can be very effective in teaching employees correct procedures while allowing them also to see the consequences of what might happen if they do not follow established operating procedures.’

“Non-routine work conducted in process areas must be controlled by the employer in a consistent manner. The hazards identified involving the work to be accomplished must be communicated to those doing the work and to those operating personnel whose work could affect the safety of the process. A work authorization notice or permit must follow a procedure that describes the steps the maintenance supervisor, contractor representative, or other person needs to follow to obtain the necessary clearance to start the job. The work authorization procedures must reference and coordinate, as applicable, lockout/tagout procedures, line breaking procedures, confined space entry procedures, and hot work authorizations. This procedure also must provide clear steps to follow once the job is completed to provide closure for those that need to know the job is now completed and that equipment can be returned to normal.’

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