Did you know that OSHA still does NOT require an actual Hotwork Permit, UNLESS you are doing the Hotwork in, on, or adjacent to a PSM covered process? It's true, 1910.252(a)(2)(iv) uses the phrase "preferably in the form of a written permit". It was not until OSHA put the Process Safety Management Standard (PSM) in place in 1992 that an actual "written permit" was REQUIRED. So what should we actually be doing to ensure hotwork is done safely and in full compliance with 1910.119(k) and 1910.252(a)? Let's start with the basics...
If you have a process on site that falls under 1910.119 (PSM) or EPA's Risk Management Plan (RMP) rule then the facility where this process is located will need a WRITTEN Hotwork Permit (and program/procedure). And man have we seen a variation in permits over the years; from in-house created works to insurance company permits; which in most cases are pretty darn good and FREE! - but beware, the insurance company does not have to issue permits that comply with 1910.252(a) and often times there will be minor omissions on the insurance company permits.
So once we get our procedures and permit implemented, OSHA states the permit is to be authorized by a person who has designated by management as an individual responsible for authorizing cutting and welding operations in areas not specifically designed for such processes. This means that management has identified either people or positions within the organization that can authorize the HW permits. Some businesses do it by name (not recommended) and many do it by title(s). Either way, it must be clear as to who can authorize hotwork within the facility; keeping in mind that the facility may have to be sectioned off and specific positions assigned to specific sections within the facility. What do I mean by this? Just because you are a supervisor in the "QC Lab" does not mean you are qualified to issue a HW permit in the Flammable Liquids processing or tankfarm area! I have always stated that it is the supervisor responsible for the area where the Hotwork will be done to give the final authorization for the work to begin (this in NO WAY means the supervisor is responsible for prepping the area, training the contractors, etc. - just that before the first arc is struck or torch lit, the area supervisor will authorize the start of HW in his/her physical area of responsibility). PLEASE be VERY CAREFUL allowing any contractors to issue/authorize their own HW permits!!!! If the contractor will be doing HW in an area where a permit is required, that contractor should be getting the AUTHORIZATION from the "individual responsible for authorizing cutting and welding operations in areas not specifically designed for such processes"!
So now that we've gotten the high level requirements of having a written permit and who must authorize the permit out of the way, let's discuss what a HW permit will look like in order to comply with PSM/RMP. OSHA really did make it quite easy (not simple!) on us; we just have to ensure that the permit will meet or exceed the requirements of 1910.252(a). This is much easier said than done, but here it goes anyway...
The best way for me to lay this out is to use the PSM Compliance Directive for Section (K). In this PSM CPL OSHA basically created a checklist for the CSHO to use to ensure the HW permit meets all the requirements of 1910.252(a). They use it like recipe checklist and it is pretty straight forward. I will try to expand on the requirements in the hopes that if we can understand what the requirement is trying to achieve, then maybe folks will accept them more widely!
The intent of 1910.119(K) Hot work permit is to require employers to control, in a consistent manner, non-routine work conducted in process areas. Specifically, this sub-paragraph is concerned with the permitting of hot work operations associated with welding and cutting in process areas. Minimum requirements include:
- that the employer issue a hot work permit for hot work operations conducted on or near a covered process and
- that hot work permits shall document compliance with the fire prevention and protection requirements of 29 CFR 1910.252(a).
But here are the specifics that MUST be part of the written HW permit and permitting process:
1) Do the hot work permits indicate the date(s) authorized for hot work performed? This is pretty straight forward... put the date the HW is being authorized for. This is to ensure that permits are not issued days in advance, or an old permit from days earlier is not used, and to help prevent excessive time frames the permit may be issued for. Although OSHA does not specifically state how long a HW permit may remain active, it is not a generally accepted practice to write permits that will exceed the shift they are authorized on. There are a couple of reasons why allowing a permit to exceed shift change is not widely accepted, but it is primarily the "change in personnel" and the potential for changes in process conditions that worry many safety professionals. I am not saying the permit can not be extended, but the written HW program MUST include procedures for how this is to be done if a business wishes to take this approach.
2) Do the hot work permits describe the object on which the hot work is to be performed? For some reason this is a HUGE gap in the vast majority of permits we have audited. I know in talking with CSHOs, it is also a widely found error in their inspections. When we weld/cut/braze in process areas we are ALMOST ALWAYS doing it on a piece of equipment. After all, if we were doing on a piece of metal that could be MOVED FROM THE PROCESS AREA to a safe HW area we would not be needing a permit!!! So OSHA wants the permit to clearly identify what the HW will be done on (e.g. pipe, tank/vessel, cooling tower, etc.). You can include the area where the work will be done on the permit, BUT WE MUST STATE the SPECIFIC object(s) on which the hotwork is to be performed! And please be as specific as possible! Use vessel numbers, names, pipe circuts, etc. to ensure that the workers doing the work know without a doubt what they are allowed to weld/cut/braze/grind on.
3) Have the hot work permits identified openings, cracks and holes where sparks may drop to combustible materials below? [Criteria Reference .252(a)(2)(i)] PLEASE see my other articles on Hotwork Safety to fully understand what the 35' fire safe area rule is all about. The most basic requirement of doing hotwork is to CONTROL IGINITION SOURCES and we do this by establishing a FIRE SAFE area (e.g. 35' radius) and we do not let any combustibles or flammables within this area AND we ensure none of our sparks get out of this area. This permit requirement is almost always checked off as completed, but I will bet anyone that a HW permit issued above ground level will have flaws, as any one of us could walk the 35' fire safety area and find a floor opening to the lower level. It is TOUGH to do, but it is a MUST DO on EVERY PERMIT. This single requirement may be the driver in making the prep work for a HW permit go from 5 minutes to 5 hours!
4) Have the hot work permits described the fire extinguisher required to handle any emergencies? [Criteria Reference .252(a)(2)(ii)] One of my favorites to cite in audits. What do we think OSHA meant when they used the phrase "described the fire extinguisher required to handle emergencies"? Do we think that having the word "fire extinguisher" with a check box on the HW permit "describes the fire extinguisher required to handle any emergencies"? What type of extinguisher is needed for the area? Is there a type of extinguisher that is PROHIBITED from being used in the area? Think water reactive chemicals!!!! How big of a fire extinguisher will be needed? A tip that I have found extremely useful... establish an absolute minimum size and type in your written program and permit! It just drives me crazy when I audit a HW permit and the one fire watch is watching 20 welders at all different elevations, sparks flying everywhere, and there at his/her feet is a five pound first alert kitchen counter fire extinguisher!!!! Man is this one of my safety buttons!
5) Have the hot work permits assigned fire watchers whenever welding is performed in locations where other than a minor fire might develop? [Criteria Reference .252(a)(2)(iii)] We still see facilities making the argument that a fire watch is not needed in all situations and I have to admit I have been convinced once or twice on this matter; but, in this article I am talking about HW permits that will be issued within a chemical processing area that handles, transfers, or stores a highly hazardous chemical. I am not sure how any fire in this environment could be called a "minor fire". If your process is covered by PSM/RMP because it is a flammable liquid or gas OR your process requires a lot of raw material staging and this involves pallets and boxes I just find it hard to definitively state that there area areas within my process battery limits that a serious fire may occur (maybe I have just been brained wash that any fire is serious!). We need to get beyond the hair splitting and bite the bullet and require that any HW permit issued in, on, or adjacent to a covered process will come with a trained fire watch. (my opinion)
6) Are the hot work permits being authorized, preferably in writing, by the "individual" responsible for all welding and cutting operations? This is one of OSHA errors in their CPL! They just took the text from .252(a) and used it to make a checklist, so using the phrase "preferably in writing" should not be in this line item, as it is NOT 1910.252 that requires the written HW permit, but rather 1910.119(k). This is why the title of section (k) is "Hot Work Permit" to clearly establish that an actual "permit" is now required for any HW done within a covered process. Section (k) is one of the shortest sections of the standard, but one of the requirements of section (k) is 1910.119(k)(1) The employer shall issue a hot work permit for hot work operations conducted on or near a covered process. Don't think for a minute that a written HW permit is not required - IT IS, I promise you and encourage those who think I am crazy to contact your local OSHA office and discuss with them.
7) Is authorization preceded by site & inspection and designation of appropriate precautions? [Criteria Reference .252(a)(2)(iv) & .252(a)(2)(xiii)(A)] Permits can NOT be properly issued from an office, control room, break room, truck, etc.!!!!! It is a REQUIREMENT that the person that will "authorize" the HW permit conduct a site inspection BEFORE doing so. This means that all of the requirements on the HW permit (that are applicable) have been met or exceeded. I have always established a time frame for when the inspection is done and the HW begins. What I mean by this is that we have had some serious fires and when the question is asked of the supervisor "did you inspect the area before signing the permit" we would get the answer... "of course, I walked through the area on my 2:00 a.m. walk through so I thought it would still be OK". Require the inspection to be completed within 30 minutes of when HW begins. Trust me, in a large plant with a lot of workers, conditions can dramtically change in a short period of time. The supervisor may have done a GREAT job inspecting the area and found no flaws, but 10 minutes after he/she left the area a forklift driver drops off a pallet of flammable liquids within 10' of the HW job. The workers are blind to it and I walk up to find sparks bouncing off flammable liquid drums!!!! The inspection is a VERY CRITICAL PATH to success in HW permitting!
8) Have the hot work permits described precautions associated with combustible materials on floors or floors, walls, partitions, ceilings or roofs of combustible construction? [Criteria Reference .252(a)(2)(v) & .252(a)(2)(ix] Again we must DESCRIBE the precautions taken on the permit should we have to do HW in areas where there are combustible materials on floors or floors, walls, partitions, ceilings or roofs of combustible construction. This is usually done by shielding the combustible construction; but we must use rated fire blankets when doing so. I have lost count of the number of times I have seen Dime Store plastic tarps strung up to act as fire blankets - heck these actually increase the fire load, rather than provide any level of fire prevention! Some older facilities will have wooden floors and these MUST be protected as well. I have seen sand be used successfully on many occasions on wooden/combustible flooring.
9) Has hot work permitting been successful in prohibiting welding in unauthorized areas, in sprinklered buildings while such protection is impaired, in the presence of explosive atmospheres, and in storage areas for large quantities of readily ignitable materials? [Criteria Reference .252(a)(2)(vi)] This was a weird way to word this question, but what OSHA is looking for here is some trigger to remind the person authorizing the permit, that HW is PROHIBITED in areas where a sprinkler has been removed from service. Yes this means that either the person authorizing the permit MUST KNOW the sprinkler is out of service OR they will have to go to the sprinkler riser to ensure the sprinkler has not been red tagged and out of service for some reason. This line item also makes it clear that HW is not permitted in some percentage of LEL registering on a calibrated direct read instrument! What this maximum percentage is, I have no idea - I like ZERO, but like the PRCS standard, OSHA uses 10% of the LEL to define a hazardous atmosphere within a PRCS; so one "could assume" that this same level could be applied outside of a space.
10) Have the hot work permits required relocation of combustibles where practicable and covering with flameproofed covers where not practicable? [Criteria Reference .252(a)(2)(vii)] Again this is FUNDAMENTAL to HW safety efforts. In fact 1910.252(a) sets this in motion: A) if we can move the object to a safe location to do the HW then we MUST do this; B) if we can not move the object to be welded on, then we move all the combustibles/flammables away from the are at least 35'; and C) if we can not do A or B, then we must use fire proof shields/covers to prevent the sparks from coming into contact with the combustibles! PLEASE keep in mind that OSHA uses the term "practicable" in the standard and this has caused more HW fires than I can name! "Practicable" is a very subjective term and I can assure you that it is one that the safety professional pushing HW safety and the manager trying to save time and $ will rarely agree on. I was involved in a very large loss fire (entire 1MM sq ft warehouse) lost because stored materials in cardboard boxes on wooden pallets were not removed from a section of racking while a roof fan was being installed above the racks. The reason, "it was just crazy to spend hours moving all that product for a couple of hours of welding and cutting". Ironically, the roof fan was being installed at the request of the insurance company as part of a fire protection/smoke measure (I kid you NOT!). Sparks rained down on to the combustible packaging and with no "in rack sprinklers" and the firewatch in the basket with the welder and no firewatch on ground level it took just 20 minutes of off and on welding to start a fire that in 32 hours consumed over $50 million in lost inventory and another $10 million in buidling losses. OSHA did not conduct an inspection since no one was injured, but they did ask why the racks were not emptied under the area where the work was to take place; the response from the warehouse manager... did not think it was necessary as that was the way they always did HW at the facility.
11) Have hot work permits identified for shutdown any ducts or conveyors systems that may convey sparks to distant combustibles? [Criteria Reference .252(a)(2)(viii)] Back to the fundamentals of keeping the sparks contained within the 35' fire safe area!!! The concern, and it is a very legitimate concern, is that a conveyor or air duct (HVAC, LEV, etc.) will carry a spark or hot slag outside of our fire safe area and introduce the slag/spark to a combustible/flammable material. A spark that gets pulled into a dust collection system is going to make VERY BAD day for someone. This little bitty spark will be glowing red when it reaches the bag house (e.g. cotton bags none the less) and either blows up the bag house or burns it to the ground. I do not have numbers/stats on this type of incident, but I know it happens and it happens more than we hear! Conveyors are a problem as they will conveyor the smoldering slag/spark into a pile of combustibles and often times this ignition source can lie in that pile and not cause a noticeable fire for hours and hours. So be sure that your permit specifically calls out that ducts and conveyors within the 35' fire safe area have been shutdown or shielded to ensure no sparks or slag get carried outside the fire safe area.
12) Have hot work permits required precautions whenever welding on components (e.g., steel members, pipes, etc,) that could transmit heat by radiation or conduction to unobserved combustibles? [Criteria Reference .252(a)(2)(x) & .252(a)(2)(xii)] We all know that metal conducts heat, as we have all grabbed a metal spoon that is in hot soup or a metal fire place poker that has been left in the fire. Well when we weld or use a torch we are using a tremendous heat source and this heat will be transferred down the steel members or pipes (any metal objects). If there is some combustible materials touching this metal we could heat it up to it's ignition temperature and ignite it; even though it is far away from the actual point of hotwork.
13) Have hot work permits identified hazards associated with welding on walls, partitions, ceilings or roofs with combustible coverings or welding on walls or panels of sandwich-type construction? [Criteria Reference .252(a)(2)(xi)] All I can say is see this recent incident from my incident alerts and you will understand why this is a requirement Fire at VFW post injures 10.
So that is it... just 13 easy requirements that must be spelled out in our HW permitting process. Remember, the true valve of any permitting process is the attention to detail! Pencil whipping permits actually do more damage than personnel just bypassing the process altogther!