Disconnecting “process hoses” are by definition a “Line Break/Process Opening” task (Chlorine)

Most, unfortunately not all, process safety professionals will agree that doing a “line break” on an actual process pipe containing the PSM/RMP covered chemical (HHC/EHS) falls within 1910.119(f)(4) or 68.69(d).  But when it comes to “process hoses”, there remain many application questions.  For me, any time the “process” is opened I break the task down into either “Routine Opening” that will be covered by an annually certified SOP and “Non-Routine Opening” that will be covered by a line break/opening safe work permit.  Disconnecting a hose is without a doubt (in my eyes) “opening the process”; how we decide to manage the risks associated with this task is open for debate and discussion.  For example, we would not issue a safe work permit each time we disconnect an unloading hose associated with unloading a tanker truck; however, this task and its hazards would be covered in the annually certified PSM/RMP Truck Unloading SOP.  Here is an incident from OSHA’s Case Files demonstrating the hazards of disconnecting “process hoses”:

At 11:30 p.m. on March 25, 2017, an employee was holding a hose that was being replaced by a coworker. The employee was sprayed with chlorine liquid as a coworker unscrewed a transfer hose. The employee suffered chemical burns from the chlorine liquid.