One of the PSM/RMP safe work practices I try and get anyone who I cross paths with to implement on ALL of their hazardous materials (regardless of PSM/RMP applicability) is the Line Break and Equipment Opening procedure and permit process. Too often I learn of incidents in processes where the HHC/EHS was under the PSM/RMP TQ’s so the facility did not have such a program or PTW system for this extremely hazardous task. Although the “process” may not exceed the OSHA/EPA TQ’s, it certainly does not mean the HHC/EHS is any less dangerous while performing certain tasks, such as Line Break and Equipment Opening. In line with my series of post to bring light to this hazardous task and to provide evidence that the HAZMAT does not have to be an HHC or an EHS, here is the latest FATAL posting to OSHA’s database…