I love the Line Break and Equipment Opening (LEO) SWP because it is one of the most hazardous tasks a worker will perform within a covered process AND the fact that there is no OSHA standard dictating how a business manages these risks. This lack of “OSHA Control” spoon-feeding us safety requirements causes most management groups to be lost in the risk and allows us (safety engineers/professionals) to use traditional risk controls without having to show “what does OSHA require“. Throughout my career, my facilities utilize some of the most toxic HAZMATs and with each company, I learned more and more about the hazards of breaking open the smallest of “tubing” associated with the highly toxic and flammable HHC/EHSs.
One controversial item that we always come across in LEO discussions/training is how we isolate a pipe run or piece of equipment before we “open” it. From my first day on the job as a safety engineer, using single valve isolation on pipe/equipment that had contained an EHS/HHC was NEVER allowed when the process was “live” on the other side of the valve. And trust me, when PSM came online and we began having to have a formal safety plan for each “break” we ran into this routinely!
In this article, I will explain the risks of using a single valve for LEO isolation, which oftentimes means hundreds of thousands of pounds of the HHC/EHS is on the other side of the valve and the process is LIVE (pressure, temps, etc.). BUCKLE UP buttercup as this is going to be a wild ride in real safety engineering!