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.

Now some of you may be asking yourself, what does all this mean and how does it impact me and my Hot Work practices. Well that depends on how long your Hot Work Program/Permit requires a Fire Watch to stay on watch after the hot work as ended. For most of us, we go by the 30-minute rule, which is also the minimum time period set by OSHA in their 1910.252, General requirements standard. I should also point out that NFPA 51B latest edition also uses the 30-minute time rule (5.5.2). But the similarities end there.

If we have adopted 51B as our HW RAGAGEP, we also are now required to comply with NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations in which we find a 2-hour fire watch requirement for torch-applied roofing operations. This change came about in the 2009 edition of NFPA 241. (see NFPA 241, 5.1.3.2 and 9.3.9)

So as a facility using NFPA 51B as your adopted RAGAGEP (vs. using 1910.252(a) we would have to have some means in our program and on our permit so that when the hot work involves "torch-applied roofing operations" that the Fire Watch requirement is 2-hrs and not the normal 30 minutes as required by both 51B and .252(a)(2)(iii)(B).

For the record, there are a lot of insurance providers already requiring extended fire watch periods so meeting this 2-hr requirement may not be a major change for some; but for most, the 30-minute period is the standard and making the move to 2-hrs can be significant, even when it ONLY applies to "torch-applied roofing operations".

 
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