The risks in sampling activities can be off the charts without engineering controls, Administrative Controls, and PPE. This post shares my sampling system. I learned this the hard way, and I hope some will take this advice and reduce the risks when we ask operators to collect a sample from a “live process”.
As I have written about many times, OPENING a process, whether it’s a “routine opening” like catching a sample, or a “non-routine” opening like replacing a valve, the RISKS associated with these openings are usually off the charts. But for those “routine openings”, we can apply a simple engineered sampling system, write a solid SOP, and train personnel annually on said SOP(s), and require a level of PPE that, should something go wrong, protects our people. One of those incidents listed in the OSHA Alert was early in my career as a safety engineer in the chemical industry. It was my first serious incident, and it was a simple “process opening”; something that had been done thousands of times over the history of the plant (50+ years). Yet it came with catastrophic consequences, and hence my strict practices for ALL process openings (routine vs. non-routine.