Hazards and Control

“Hot work” is the term used to define activity that involves open flame or that produces heat and/or sparks that are capable of initiating fire or explosions. Examples of such work include welding, grinding, brazing, polishing, cutting, soldering, and using torches.

Hot work represents one of the most significant health and safety risks in industrial and commercial settings and is a main cause of fires and explosions. Most people inherently understand the danger fire represents. However, in many industrial/commercial settings, fires are even more dangerous given the likely presence of flammable gases and liquids, numerous employees and other people in close proximity to the hot work, high amounts of ordinary combustibles (such as paper, cardboard, wood, dust and plastics), and the size of the commercial/industrial building itself. In these settings, external contractors are likely to perform most of the hot work; and these contractors are often unfamiliar with specific site procedures – such as evacuation routes, muster points, and type/location of emergency equipment like fire extinguishers and emergency pull stations (alarm activation). For these reasons, a detailed Hot Work Policy/Procedure and effective, targeted training are required to maintain effective operational control over this significant safety and health hazard.

Controlling Risk and the Permit System

To effectively control hot work risks, the first question to ask is whether the hot work can be avoided entirely. For example, instead of using a torch to cut, can shears be used? Instead of welding or radial saw cutting, can bolts or mechanical cutting be used? Can the hot work be performed off-site? If hot work cannot be avoided and must be conducted on-site, can these activities be performed in areas specifically designed for such work?

If hot work must be performed on-site, effective hazard control is especially important. All  individuals utilizing hot work equipment should be trained on its proper use, the site-specific Hot Work Policy/Program, emergency action plan(s), fire-extinguisher use, and alarm activation procedures. Other training may be required depending on the type of work being performed and site-specific policies and hazards.

Using a permit system is a good way to not only maintain operational control, but also to inform management and people in the immediate area that hot work is taking place. Permits should contain instructions for performing hot work; the date, time, location and type of hot work being performed; names of individuals involved and their specific roles; date and time of permit expiration; and any other pertinent site-specific requirements. Many examples of hot work permits exist on OSHA’s website (www.osha.gov) and on the Internet.

Hot work permits should be required for anyone at the site, whether they are employees or contractors. Trained staff should be assigned tasks under the following categories:

Permit Authorizing Individual (PAI)

• Is a supervisory-level company employee (not a contractor)
• Has overall responsibility for proper implementation/management of hot work program
• Issues hot work permits after adequately assessing risks in proposed work area
• Completes final safety inspection of hot work area; gives final sign-off of permit

Hot Work Operator

• Is properly trained in safe use of hot work equipment and the associated hazards
• Verifies hot work equipment is in good operating condition
• Works with the PAI to follow established hot work procedures
• Restricts use of hot work to stated conditions and areas only
• Leaves hot work area in safe condition after work is completed

Fire Watch

• Watches for any stray sparks, smoldering fires, or other fire hazards; ready to provide initial fire response
• Has portable fire extinguisher and/or fire hose readily available; adequately trained in their use
• Works with operator to ensure safe conditions are maintained during and after hot work
• Has authority to stop work if unsafe conditions develop
• Is completely familiar with site-specific fire alarm locations and emergency notification procedures

Permit Procedure

All employees and contractors involved with hot work activities should receive training (at least annually) and certification. The site-specific hot work procedure should be reviewed at least annually to assess the effectiveness of the program and make any needed improvements/modifications.

Many hot work permits contain a checklist, reminding the individuals involved to look for certain hazards and employ specific control measures. These checklists are a type of job-specific, real-time risk assessment that requires those involved to think the job through and implement at least one control measure for each identified hot work related risk.

Here are key steps in the hot work permit procedure:

• Hot work permits should be issued only by adequately trained employees and only for a fixed period of time, not to exceed a single work shift. Reissuing permits at work shift changes ensures that all work is clearly communicated from one work shift to another and that any changes in plant conditions are addressed.
• Following satisfactory inspection of the work area, the PAI issues a signed permit to the hot work operator. The PAI designates a person as Fire Watch.
• Copies of hot work permits should be posted in the hot work area and in another designated location (such as the office of the PAI, control room, maintenance office, etc.) until the job is complete and the permit closed. This allows the PAI (and all other interested parties) to immediately access the permit to identify the type and location of hot work being performed in the facility.
• A fire watch should be maintained for at least 30 minutes after completion of hot work in order to detect and   extinguish any smoldering fires. However, risk control guidance from property insurance carriers typically requires a longer period for the fire watch.
• Upon completion of the fire watch, the hot work permit should be returned to the PAI. Completed permits are to be retained for at least one year for review by property insurance carriers or regulatory agencies and to assist with the annual procedure review and update.

For additional guidance refer to 29 CFR 1910 subpart Q – Welding, Cutting, Brazing. NFPA 51B, www.osha.gov

HETI…Helping Manage Risk

Through our risk management consulting practice, we offer a technical staff of experienced safety professionals with proven capabilities to deal with a full range of risk control issues, including hot work hazards and controls.

HETI can assist with assessing the workplace for hot work health and safety hazards. In addition, we can provide assistance with site-specific Hot Work Policy/Procedure development, emergency action planning, hot work permit procedure implementation, etc. If hazard control methods are already in place, HETI can conduct an evaluation to document their effectiveness.