"But It’s Only an Instrument!”: Issues with Classifying Research Equipment
Richard Palluzi
Pilot Plant and Laboratory Engineering, Safety, and Design Consultant at Richard P Palluzi LLC
How we classify things often makes us treat them differently. A pair of pliers in the hardware section is a tool; a similar device in the houseware section is a kitchen device. Both often look similar, perform similarly and often can be used the same (within certain limits). The same is often true for pilot plants, microunits and laboratory equipment.
Many organizations have more stringent safety and operational requirements for larger scale research equipment. So pilot plants are required to meet these additional requirements while laboratory equipment are exempt. There is a justifiable logic to this as more complex equipment with more numerous and more significant potential hazards and with larger volumes of hazardous materials should be treated more carefully than simple equipment with few potential hazards and very low hazardous material volumes. However, this often leads to issues with trying to draw the dividing line(s).
A large unit with numerous feeds that occupies several large skid or frames in an open bay clearly stands out as a pilot plant. A GC sitting on a lab bench, connected to helium and receiving a manual microliter sample similarly stands out as a piece of laboratory equipment. Much in between is, sadly, less clear. How does one classify the small microunit in a hood. It has 2-3 feeds but very small volumes. It does operate at temperature and pressure but with restricted or limited flow rates. How about the specialty analytical equipment that needs 6-10 different gases, some of which are flammable and/or toxic? Is it a small pilot plant? A large piece of laboratory equipment? Or something else?
More challenging is the small assembly of glass equipment typically connected by plastic tubing inside a hood. The flask on a hot plate connected to a glass condenser seems like a piece of laboratory equipment. The round bottom flask with two gas feeds connected to a knock out, a condenser, and a sampling system certainly begins to feel different and probably has more and different potential hazards.
Organizations often tie themselves up in knots trying to decide what is the most appropriate classification for these situations so as to determine which set of rules should be followed. And while wanting to avoid over working the simple, low hazard operations is commendable, failing to worry those that, upon analysis, are perhaps not quite as low risk can be very dangerous. And, as any homeowner or do it yourselfer knows, it is all too easy to start something assumed to be easy only to discover hazards or problems one failed to recognize and address.
I think the answer is often much simpler. One coherent set of rules applied to all equipment regardless of the size or purpose. I can feel the rolling eyeballs as researchers shudder over the prospect of having to produce reems of documentation for incredibly simple experiments and operations. But I think the truth may be much simpler. The large pilot plant described above will require P&ID’s, electric wiring diagrams, operating instructions and usually detailed layouts, safety shutdown matrixes, and a detailed hazard analysis and risk assessment. The GC described above should require the same. However, the P&ID will be hand drawn, the operating instructions may just be a photocopy of one or two pages of the manual with perhaps a few lines explaining the specific procedure, the wiring diagram will be “plug it in”. The shutdown matrix will be a note saying turn off the power button or pull the plug. The hazard analysis and risk assessment will be a paragraph summarizing the commissioning or prestart up review that identifies handling the needle as probably the only real hazard and identify the procedures to protect the operator. The pilot plant’s documentation will take days to weeks to develop. The GC’s documentation probably less than a day. The pilot plant’s hazard analysis and risk assessment may take days to complete, the GC’s probably an hour or less.
If you look at the issue from this perspective, then suddenly how you classify the unit is immaterial. Larger, more complex, more hazardous operations will take more effort than simpler, smaller, and less hazardous ones. More importantly, it will begin to capture those operations, like the more extensive glass operation described above, and perhaps force them to be more rigorously assessed more in line with their potential hazards and risks than their perceived classification. If a pilot plant should have a posted emergency contact list, for example, can you really argue that the beaker being heated unattended should not? The former may require more work as more scenarios may have to be addressed while the later may be simply “pull the plug”. Both, however, need the concerns (what to do it something is wrong, who to call in the event of a problem, what are the hazards that may or may not be obvious to the discoverer) addressed.
This approach may take some getting used to. It certainly will need folks to gain some familiarity. But I don’t think it really is anywhere near as onerous as some suspect. And the time saved arguing what rules should be followed will usually, I have found, balance the slight extra work.
For additional discussions on this and similar issues see:
· Safe Where It Is; Safe Where It Is Going: The Often Unrecognized Hazards of Moving Research Equipment
· How Big Do I Need To Build A Pilot Plant: The Vexing Question of Scale
· Periodic Overall Cold Eyes Safety Inspections: An Overlooked Tool in Pilot Plant and Laboratory Safety
· Classifying Pilot Plants
· What is a Pilot Plant
For more information on this and similar issues affecting laboratories, you might also want to consider these University of Wisconsin courses:
Pilot Plant and Laboratory Safety 1: Basic Principles and Code Compliance, April 8-10, 2019, Houston, Texas
Pilot Plant and Laboratory Safety 2: Real Hazards, Proven Solutions , April 10-12, 2019, Houston Texas
https://epd.wisc.edu/course/pilot-plant-and-laboratory-safety-2-real-hazards-proven-solutions/