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”: