One of the most dangerous tasks that occur within the battery limits of a covered process is “opening the process.” This is commonly called a “Line Break” but also applies to vessels. We won’t find a definition of “Line Breaking” in the PSM Standard; instead, we turn to OSHA’s Permit-Required Confined Space Standards (1910.146 and 1926.1201-.1213). During my career, one of my safety crusades has been to get businesses, even those NOT covered by PSM/RMP, to embrace the extreme hazards of opening a normally closed containment system that handles a HAZMAT. I have seen “tubing” cause fatalities, less than 3 pounds of the hazardous materials involved. So as the OSHA standards imply, “line breaking” is not simply reserved for PSM/RMP covered processes; it applies to: