One of the dangerous and hazardous tasks in the realm of both process safety and safety at all facilities is non-routine process openings, commonly called line breaks. The risks involved in these processes affect the employees performing the task, workers and contractors throughout the entire site, and potentially could even impact off site receptors in the form of people and the environment. Line breaking is the one safe work practice that both the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) mention in their process safety standards, yet these agencies provide no guidance on what a line break process should look like. No Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) or consensus standard exists for guidance either. This paper will provide safety professionals and practitioners guidance on the development of a line break program for their facility based upon best practices.

OSHA's Discussion of Line Break

29 CFR 1910.119(f)(4) The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.

Appendix C (Non-Mandatory)

  • Nonroutine Work Authorizations states…

Nonroutine work which is conducted in process areas needs to be controlled by the employer in a consistent manner. The hazards identified involving the work that is to be accomplished must be communicated to those doing the work, but also to those operating personnel whose work could affect the safety of the process. A work authorization notice or permit must have a procedure that describes the steps the maintenance supervisor, contractor representative or other person needs to follow to obtain the necessary clearance to get the job started. The work authorization procedures need to reference and coordinate, as applicable, lockout/tagout procedures, line breaking procedures, confined space entry procedures and hot work authorizations. This procedure also needs to provide clear steps to follow once the job is completed in order to provide closure for those that need to know the job is now completed and equipment can be returned to normal.

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