Just because we intend to handle minimal quantities of the HHC/EHS, the task of “catching a sample” from a covered process can, in fact be one of the more hazardous tasks our operators perform. Remember, Risk = Frequency X Severity, so operators catch many samples over their shift means this task is a high-frequency task. And as the picture below shows us, we need to ENSURE we are dealing with only smaller quantities of the HHC/EHS. It is this picture that caught my eye, and in the 1990s this may have been an acceptable means to “catch a sample,” but in today’s world of process safety, it should not be.
So the first thing I learned from one of my “sampling” incidents is that when things go bad, they tend to go bad quickly, and they can overcome all of our safety features. With that said, when we design a “sampling station,” we view the task as a “process opening,” and this automatically puts the task into a HIGH-RISK category requiring multiple independent layers of protection. So using our fundamental hierarchy of controls, we first look at the engineering of this station…