One of the debates we routinely have with fellow process safety professionals is the adoption of NFPA 51B vs. meeting 1910.252(a) requirements for their Hot Work safe work practice. I am a huge fan of NFPA 51B, as it is much more up-to-date than OSHA's 1910.252; which by the way was based off of the the first edition of NFPA 51B in 1962. As I have stated many times before, niether PSM (nor RMP) allows for "cherry picking" parts and pieces of codes and standards so that we can avoid certain aspects that may not be "friendly" to our business. Of course, some parts of these codes/standards may not be applicable to our business/process, but when we go back and forth between codes/standards to better suit our needs we are making a huge mistake.

With that said, I would like to point out a common issue we find with orgnizations that want to use NFPA 51B (FREE Access) as their RAGAGEP for Hot Work Safe Work Practice. What these businesses often times over look is that NFPA 51B, since 2003, has incorporated NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations (FREE Access).

NOTE: in the 1999 edition, the use of Hot Work to apply roofing materials was speciffically exempted from NFPA 51B requirements. The 2003 edition is when hot work during roofing became applicable to NFPA 51B.

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