Line Breaking and Equipment Opening (LEO) hazards are oftentimes not well recognized or respected, even in PSM/RMP-covered processes. Once we are removed from a “covered process,” the lack of recognition and lack of respect only increases. But in my career, some of the more serious accidents involving LEO on lines/equipment did NOT involve processes covered by PSM/RMP; instead, they were on “utilities”, most notably steam. In 2020, we saw a horrific accident in a recycling plant that collects and recycles cooking oil and meat byproducts, which is commonly used in the manufacture of dog food when two (2) maintenance technicians were attempting to remove a clog from a piece of equipment that utilized high-pressure steam. They knew the equipment was normally pressurized with steam and they knew the machine was “clogged” and decided to relieve the steam by cracking open a flange on the bottom of the equipment’s pressure vessel. But they forgot one important safety procedure before doing so and their attempt resulted in their deaths. The two workers were 51 and 56 years old.
NOTE: the citations are being contested by the employer