Yes, there is a safety program called the car-seal program. In most chemical processing plants, a car-seal program is a CRITICAL program in their PSM/RMP program; however, this program has uses in almost any type of facility with relief valves, cooling water systems, eyewash/safety showers, etc. This program is designed as an administrative control technique to maintain safety-critical valves in their SAFE POSITION.
The program will usually contain an inventory of valves, their SAFE position (e.g., open or closed), their locations, and their size. It will also contain an audit/inspection element that will dictate a schedule for verifying that these valves are in their SAFE position. But the most important part of the program is the procedures that MUST BE FOLLOWED in order to place one of the safety-critical valves in a deviant position (e.g., closing a valve that had been sealed open).
These procedures will be EXTENSIVE and layered to ensure that more than one set of eyes is involved and more than one brain is analyzing the risks associated with closing the valve. The program is called a “car-seal” program as these valves will have a “tag” hanging on them, and they are “sealed” in their safe position with either a metal or plastic strap that must be cut off to deviate the valve position. Some facilities use oversized fluorescent-colored tags and seals, and some may use metal straps and dog tags; either way, it is OBVIOUS to anyone wishing to operate the valve that they MUST SEEK permission to operate it.
By the way, the word car-seal comes from the railroad and tank truck industries and are the seals used to secure a railcar or tank truck hatch closed after it has been filled.
Had the facility in the above CSB Incident Report had such a program, there is a very good chance the incident would have never happened! Members can download a Car Seal program from the SAFTENG Document Library in the member’s area of the site. You can Click Here to see what a Car Seal device looks like.
You can quickly search at www.OSHA.gov and see all the citations issued for failing to have a car seal program for a PSM/RMP-covered process.