Recently I was asked to help an organization with their Line Break/Process Opening Procedure and Permit. Anyone who has been through this process quickly realizes there is ZERO guidance from OSHA or any RAGAGEP as to what needs to be in the program and most notably the scope of the program. This organization has several hazardous materials that will fall within the scope of this program, but the “oh no” moment came when we were explaining the scope and impacts with regards to the refrigeration process with the refrigeration personnel. The “deviation” I am going to lay out in this article is common in a lot of refrigeration systems that utilize a “relief valve header system” in the design of their relief systems; although, this deviation applies to ALL processes that utilize a “relief valve header system”. Here’s is the potential issue…