
As explained in the attached Safety Alert, BSEE’s risk-based inspection program has identified deficiencies in safety device bypass practices including:
- inadequate documentation
- inoperative data history software
- bypassing more devices than is necessary
- bypassing devices for longer than necessary
- missing audit documentation
- mistakenly bypassing the entire safety system during production
The regulations restricting the bypassing of safety devices are core elements of OCS regulatory and operator management programs. Because they are critical to process safety, these requirements are widely supported and strictly enforced.