Purpose and Scope
Hot work operations include welding, brazing, torch cutting, grinding, and torch soldering. These operations create heat, sparks, and hot slag that have the potential to ignite flammable and combustible materials in the area surrounding hot work activities. Hot work is covered by 29CFR 1910.252 and NFPA 51B. The United States averages 12,630 hot work fires resulting in $308.9 million in property damages and 31 deaths per year. Hot work is regularly performed in Bates College facilities. The college Hot Work Permit was developed in accordance with OSHA regulations and NFPA recommendations with the goal of preventing hot work fires.
Hot Work Operators (HWO) are employees or contractors who perform hot work operations. An HWO must always obtain a Hot Work Permit before beginning hot work.
A Fire Watch is posted to monitor the safety of hot work operations and watch for fires. Fire watches are posted by a PAI if the situation requires one, during hot work, and for at least 30 minutes after work has been completed. Any employee who has successfully completed hot work safety training can serve as the Fire Watch.
Bates EHS Responsibilities
Bates EHS oversees the program and are the Permit Authorizing Individuals (PAI) who issue hot work permits. A PAI inspects hot work sites prior to the start of hot work operations using the checklist found on the hot work permit form. When a fire watch is required, the PAI will document the individual to serve as Fire Watch. Once all requirements on the forms have been satisfied and the form is signed by all responsible parties, the document becomes a Hot Work Permit and must be posted in the area where hot work is to be performed.
The 35-Foot Rule
- All flammable and combustible materials within a 35-foot radius of hot work must be removed.
- When flammable and combustible materials within a 35-foot radius of hot work cannot be removed, they must be covered with flame-retardant tarps and a fire watch must be posted.
- Floors and surfaces within a 35-foot radius of the hot work area must be swept free of combustible dust or debris.
- All openings or cracks in walls, floors, or ducts that are potential travel passages for sparks, heat, and flames must be covered.
Fire Detection and Suppression
- A fire extinguisher must be readily available and accessible.
- Entire building smoke detection and alarm systems cannot be shut down. Instead, smoke detectors in the area of hot work may be covered or disabled for the duration of hot work to prevent false alarms.
- Automatic sprinkler systems may not be shut down to perform hot work. Instead, individual sprinkler heads in the area of hot work may be covered with wet cloth to prevent accidental activation.
A Fire Watch must be posted by a PAI if the following conditions exist:
- Combustible materials cannot be removed from within a 35-foot radius of the hot work.
- Wall or floor openings within a 35-foot radius of hot work expose combustible materials in adjacent areas, including concealed spaces in walls or floors.
- Combustible materials are adjacent to the opposite side of partitions, walls, ceilings, or roofs and are likely to be ignited.
Hot Work Permit Guidelines
- Work should be performed using alternative methods other than hot work whenever possible.
- How work should be performed in designated hot work rooms whenever it is practical.
- A Hot Work Permit is valid for one day and one area and should be posted in the area of hot work for the duration of the activity.
- A copy of every permit shall be filed and kept by the PAI in a designated location for at least six months.
- A fire extinguisher must be present when performing hot work.
Designated Hot Work Rooms
A designated hot work room is a permanent location designed for hot work. These rooms do not require a permit to perform hot work. For a room to be classified as a designated hot work room, it must meet the following requirements:
- It must be of noncombustible fire-resistive construction, essentially free of combustible and flammable contents.
- It must be suitably segregated from adjacent areas.
- It must be equipped with fire extinguishers.
- It must be inspected and approved.
Upon request, EHS will inspect departmental hot work locations to receive Designated Hot Work Area status. Designated Hot Work Areas must be inspected and certified by Bates EHS. All hot work completed in areas not certified by EHS must be performed under the Hot Work permitting process. Designated Hot Work Areas will be re-inspected and certified by EHS annually.
Operations Not Requiring a Hot Work Permit
Operations that produce a flame, sparks, hot slag or enough heat to ignite combustible materials should be considered hot work with a few exceptions. The following operations do not require a Hot Work Permit:
- Bunsen burners in laboratories
- Fixed grinding wheels
- Electric soldering irons
- Cooking operations
All operations that produce open flames, hot sparks, or metals that could ignite combustible materials should be handled with care and treated with fire safety in mind.
If you are unsure if an operation is considered hot work, please contact Environmental Health and Safety at 207-786-6413.
Non-permissible Hot Work Situations
Hot work is not permitted when the following conditions exist:
- In sprinklered buildings where the entire sprinkler system is impaired.
- When an entire building fire detection system is shut down.
- In the presence of explosive atmospheres where mixtures of flammable gases, vapors, liquids, or dusts may exist.
- In tanks, drums, or other containers and equipment that contain or previously contained materials that could create explosive atmospheres.
Individuals involved in hot work are required to complete hot work training, including supervisors, permit authorizing individuals, hot work operators, and fire watch personnel. The following EHS training must be completed:
- Hot Work Permit Training – required upon initial assignment and refresher training required every five years
- Fire Extinguisher Training – required once a year. The hands-on classroom training must be completed for the initial class. A refresher training course may be completed for the yearly refresher requirement.
Managers may train employees on departmental Hot Work Permit procedures and specific safety procedures for the type of hot work equipment used. The training shall be completed upon initial assignment and cover the following subjects:
- Safety procedures specific to the equipment used.
- Required personal protective equipment for job tasks.
- Identification of Permit Authorizing Individuals and how they can be contacted.
- Where to file copies of complete Hot Work Permits.
- Locations of designated hot work rooms where a Hot Work Permit is not required.