Each instrumented safeguard exists for a reason, protecting against some hazard to personnel, the environment, or to assets. The potential consequence of improper bypassing or jumpering of safeguards is the occurrence of the very hazard the safeguard was there to prevent or miti-gate. These hazards typically include fires, explosions, catastrophic overpressure events, toxic releases, or exposure to personnel to hazards inherent to the process equipment.
Some things to consider:
- Most instruments and controls were installed for a reason, are you able to confirm the reason for the device that you are considering to bypass?
- What does your process safety information (PSI) say? Have you referred to interlock specification sheet, Process Hazard Assessment (PHA), etc. to verify the purpose for the device that you are considering to bypass?
- Don’t forget, bypassing a device is a change to your process safety information PSI. Therefore, have you captured the bypass in your MOC program like you would any other process change?
- Recognize that many devices may be identified in your PHA as a safeguard to manage/mitigate risk. Therefore, bypassing is such a device is essentially elevating risk. Are you authorized to bypass the device and increase risk?
- Does your authorization process define a specific communication/approval protocol required/developed to ensure safe review, design/implementation of interim measures, etc.?
- There may not be a direct pathway from the bypassing of a device to an incident. In some instances, even if it is bypassed, you may not even see an event. How are you preventing normalization of deviation associated with this phenomenon (i.e., it hasn’t happened before)?
- Be aware that such bypassing without consequences could lead to a false sense of security with operating and maintenance personnel (i.e., it hasn’t happened before)?
Property Damage (Fire / Explosion)
- A release of hazardous material resulting from bypassing or jumpering an instrument or control device can cause property damage if released materials are flammable. Depending on the surrounding area, the released material may find an ignition source and cause a fire or an explosion.
Personal Injury (Safety/Human Health)
- Bypassing or jumpering an instrument or control device, if not done properly, can lead to release of hazardous materials and personnel exposure with serious injuries or fatalities
- Exposure to corrosive materials (i.e. acids or caustic) causing chemical burns
- Exposure to toxic materials (i.e. benzene, hydrogen sulfide, phenol)
- Exposure to hot materials (i.e. steam) causing thermal burns
- Release of material under pressure causing an injury
- If these materials are flammable the release may find an ignition source leading to a fire or an explosion.
Chemical Release/Environmental Release (On-Site)
In addition to the Property Damage and Personal Injury consequences stated above, facilities must also consider the potential for escaltion that could result in environmental damamge or additional personal injuries occurring on-site.
- Environmental damage due to releases to the air, soil, or bodies of water resulting from line or equipment opening hazardous material releases
- Personnel injuries outside of the immediate area due the release of toxic materials from line or equipment opening activities
- Personal injuries outside of the immediate area due to fire or explosions resulting from possible ignition of flammable materials released during line or equipment opening.
Chemical Release/Environmental Release (Off-Site)
In addition to the Property Damage and Personal Injury consequences stated above, facilities must also consider the potential for escaltion that could result in environmental damamge or additional personal injuries occurring off-site.
- Environmental damage due to releases to the air, soil, or bodies of water resulting from line or equipment opening hazardous material releases
- Personnel injuries outside of the plant boundaries due the release of toxic materials from line or equipment opening activities