There is one PSM/RMP task that continues to cause problems and is still heatedly debated within process safety circles. In all of the PSM/RMP requirements from OSHA and EPA standards, Line Break/Process Opening is the one area where there is no Recognized and Generally Accepted Good Engineering (RAGAGEP) for how the task is to be done. There is no federal OSHA standard setting minimum requirement for the task. Some facilities make the task a “permitted task”, meaning that the workers are doing the task under a safe work permit issued by their supervisor or some other qualified person; however, since there is no specific OSHA standard for the task (like there is for LOTO, PRCS, etc.) and the task is only mentioned in 1910.119(f)(4) as a task requiring a safe work practice, we have a lot of lost facilities out there! Such that in 1996, nearly 4 years to the day that the PSM standard became active, OSHA issued a “hazard information bulletin” on the topic in the hopes of providing some guidance on the matter. I want to point out that OSHA uses the term “permitted” in this bulletin, so it is clear that they are encouraging the implementation of a “Line Break Permit” and they do so when discussing the hazard control measures with the “permit” being the first line of defense. Not sure why this document is not referred to more often, but I encourage those who are struggling with having a solid line break/process opening procedure to use the advice in this bulletin…