Opening the cage (LOPC) allows the animal to roam free

When we think about process safety, we can think of the analogy of a wild animal inside its cage… as long as the cage holds or we don’t open the door on the cage the wild animal is safely contained.  Unfortunately, sometimes the cage was not designed to hold such a powerful animal and believe it or not, we sometimes think it will be OK to open the door of the cage… just for a second or two.  In process safety (PSM/RMP) both OSHA and EPA require that “opening the process” be done via some control mechanism such as an annually certified SOP or Safe Work Practice (usually accompanied with a Safe Work Permit system).  These days, many facilities have recognized “maintenance tasks” that involve “opening the process” as needing to follow some prescribe safe work practice; however, many still continue to view “operational openings” without some type of control as an acceptable practice.  As I mentioned in other posts, even “routine openings” that are part of normal production need to be managed as if we are opening the “animals cage”, case in point:

At 9:00 a.m. on February 16, 2017, an employee was closing the cover of a washer when a small cloud of chlorine dioxide was released.

The employee inhaled some of the vapor. The employee began coughing and experienced shortness of breath. The employee and thirteen other employees were taken to a local hospital and evaluated for exposure to chlorine dioxide vapors.

NOTE: these OSHA citations have been contested