Safe Where It Is; Safe Where It Is Going: The Often Unrecognized Hazards of Moving Research Equipment

Research equipment often seems to have a gypsy lifestyle.  Sometimes it seems to be forced to move with a frequency rarely seen in plant equipment. The need to shift equipment inside an existing area to make room for new or modified operations or use the overall space more efficiently, the need to move equipment to a different area to support a new program, the need to relocate equipment or even entire laboratories or organizations to a new facility, and numerous other reasons often require moving research equipment. This may be as small as a bench top instrument picked up and moved to the new spot, as complex as a pilot plant with all its controls and utilities, or as involved as moving an entire research group or site to a new home. One common issue I have seen repeatedly in my 40 years is the belief that if it is safe where it is now, it will be safe where it is going. That, sadly, is often not true.

To be clear, I am not addressing equipment designed to be truly portable and used where needed such as multi-meters, portable hand held pH probes, portable hot plates, portable stirrers, and similar items. I am talking about anything that is expected to be in the same place each day such as GC’s, pilot plants, mass specs, research units, etc.

Why is the equipment (to use a generic term) not safe in the new location? A variety of reasons can create an unanticipated hazard:

·        Because the new location has differences from the old location that are not recognized

·        Because the old location had mitigative measures not provided at the new location

·        Because the equipment was perhaps not as safe in the old location as was thought

·        Because you are changing something about the installation or operation that could create new hazards

·        Because new people are going to use the equipment

If the new location is in the same facility, the same laboratory, and uses the same personnel, then – admittedly – the risks are lower than if the entire laboratory is being relocated to a new facility. However, regardless of the extent of the relocation there is always some risk. Unless you look at it carefully, however, these are often overlooked or ignored. They may be minor (in the case of the move to the next bench) or significant (in the case of a new building or site). Regardless of the extent of the relocation, some questions to consider include the following.

However, small the move (say even across a laboratory to a new bench) it is a change. So is your organization’s management of change process being followed. As some of you roll your eyes at even considering that this requires that level of effort let me simply ask: how can it not be a change? If everything, except the location, is the same then one assumes the review effort would be trivial.) OK painful but still small.)

Is the current documentation up to date? This includes the P&ID’s, operating, start up, and emergency shut down instructions as well as off hours instructions, databases, and similar documentation. I have never (yes, I mean never) traced a unit with piping and found all the P&ID info up to date whether a multiple skid pilot plant or a simple laboratory GC. Most times the differences are minor; sometimes they are not. And no matter how stringent the organization believes it is on controlling management of change does not really change my observation. It just usually changes the annoyance when I show them the differences. Operating instructions are often old and out of date. Emergency response instructions often refer to specifics found only at the old location. Signage showing where emergency equipment is located, or feed system or power shut downs are provided are often wrong, out of date, or at best woefully inaccurate. Feed and utility connections are different from what is shown on the P&ID.  Small ancillary systems from air guns to drain points are not shown. Filling, emptying, or cleaning stations are no longer nearby. Local exhaust is no longer provided. The list is endless.

Does the new location create any additional concerns? The high voltage equipment now near a sink or safety shower could create a shock hazard from actions outside the user’s control. The equipment now a lot further from an eyewash, safety shower, or fire extinguisher, may now be further than acceptable. The specialty neutralizing agent, the special fire extinguisher, the special gloves – where these now located? These type of questions are incredibly numerous. Most times, they are easily answered in a satisfactory fashion. Most is not, however, always.

Are the operating personnel properly trained and qualified? Will new personnel potentially use the equipment who are not? Does the equipment have hazards that new nearby personnel do not recognize nor are adequately aware of? Do the emergency responders need to be advised of special hazards, receive additional training, or obtain specialty equipment?

These are just a few of the many common issues that continually arise. As the new location is more different than the old location, these questions expand exponentially. Relocating existing equipment to a new facility or relocating it to a new home at a different facility is particularly concerning.

Are the emergency response systems adequate for the equipment? Are the first responders adequately trained in the hazards? Do they have the proper equipment? Just assuming both organizations have equivalently equal response systems is often a first step to a problem. The new location may respond in a different manner to the old location. While both are good responses, there often is something about one or the other that does not align with the equipment’s existing risk assessment.

Does the new location meet all applicable codes? Often older sites are “grandfathered” and allowed less stringent requirements than new sites. New sites may fall under different jurisdictions and different rules. This can create significant work to now comply. Often it is not recognized it is a problem until after a safety audit identifies the new installation is in violation.

Are practices, procedures, and polices the same in the two locations? Often, they are not, and this creates problems that crop up during initial operations. This may be a simple as the need for different signage or an additional relief device to protect a house system to as major as not allowing a gas cylinder inside or requiring totally different piping to comply with site standards.

My recommendation for these more extensive relocations is that you must plan on a complete safety review including a new hazard analysis and risk assessment of all equipment before it is moved. For a brand new site or relocation of an entire site this is going to be an expensive and time consuming process. However, I can assure you that it will be a cheaper and less expensive and – more importantly – a safer process.

For more information on this and other safety issues regarding laboratories, pilot plants and research safety you may want to consider some of the University of Wisconsin courses on this subject:

Laboratory Design: Relocations, Modifications and Grassroots

Fall, 2019 location to be determined

Pilot Plant and Laboratory Safety I: Code and Regulatory Issues

https://epd.wisc.edu/course/pilot-plant-and-laboratory-safety-1-basic-principles-and-code-compliance/

April 8-10, 2019               Houston, TX

Pilot Plant and Laboratory Safety II: Real Hazards - Proven Solutions

https://epd.wisc.edu/course/pilot-plant-and-laboratory-safety-2-real-hazards-proven-solutions/

April 10-12, 2019             Houston, TX