Today (2023/10/23) The United States Bureau of Safety and Environmental Enforcement (BSEE) released Safety Alert No. 470 — Bypass of Emergency Shutdown in Rented Equipment Results in Additional Risk to Personnel and the Environment.
The report notes that an Emergency Shutdown (ESD) in a rented equipment item had been bypassed. The report does not say when the bypass happened, but an inference is that the action occurred before the rental equipment was installed at this particular location.
The report highlights the importance of Management of Change and Lockout/Tagout — fair enough. But this incident raises a bigger concern:
How is a company to know that rented equipment is fit for purpose and that it complies with both SEMS and company standards?
Over the years there has been extensive discussion to do with the management of contract workers, but much less to do with contract equipment. Maybe this is a deficiency that the report could have highlighted.
One of the report’s recommendations is that operators and contractors should ‘inspect generators and critical equipment in accordance with BSEE regulations’.
Once more, fair enough — but an operator may not have the technical capability to inspect rental equipment; indeed, there is a high probability that they are not aware of all the safety issues to do with that itemprecisely because it is not their property. On the contractor’s side, the personnel may not understand the safety issues at that location.
Therefore, I suggest that BSEE should add a recommendation on the following lines to their report.
Prior to it being used, the function of rented equipment at that location should be analyzed by both the operator and equipment supplier in a hazards analysis that complies with paragraph §250.1911 of the SEMS regulation.
