The Hot Work Permit element of both OSHA’s PSM standard and EPA’s Risk Management Plan is one of the shortest elements’ of the 14 elements. Its presence is to require a written permit to be issued when performing Hot Work in/on/adjacent to a covered process. Some may not fully understand the need for this element, but if we go back and look at 1910.252(a), it uses the following wording…
(emphasis by me)
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1910.252(a)(2)(iv) Authorization Before cutting or welding is permitted, the area shall be inspected by the individual responsible for authorizing cutting and welding operations. He shall designate precautions to be followed in granting authorization to proceed PREFERABLY IN THE FORM OF A WRITTEN PERMIT. |
That is correct; OSHA NEVER required a HW permit until the PSM standard was promulgated in 1992. Most facilities utilized a written permit because of their property conservation insurers’ demands. When the PSM standard came about, OSHA simply included an element titled 1910.119(k) Hot Work Permit
This element has ONLY two (2) requirements:
- issue a hot work permit for hot work operations conducted on or near a covered process.
- permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations
This last requirement, meeting all of 1910.1252(a) requirements, is where most fall short. Of course, a facility may choose to comply with NFPA 51B instead of .252(a) – but as I have discussed before, NFPA now requires a 1-hour fire watch at the conclusion of Hot Work.
Notice the requirement is that the “permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented“. 1910.252(s) reads like a checklist, and OSHA expects that all of the items listed in (a) of the standard be present on the written permit. We use OSHA’s old PSM PQV Checklist in our audits, and that checklist (albeit no longer used by OSHA as it was too labor intensive) takes section (a) and lists each item for the OSHA CSHO to “check off” the written HW permit contains the said item(s).
We come across a lot of HW permits that fail to include all of .252(a) requirements and these failures almost always come with 1 of 2 arguments:
- the item is “not applicable” to the specific workplace, or
- it may not be on the written permit, but it is covered in our HW safety training
The 1st argument is almost always lost when we point out that the “control room” is part of the covered process.
The 2nd argument is almost always lost when we point out that the standard requires the items to be on the written HW permit.
Having the items on the permit assures that ALL the items are addressed. There is no way every person authorized to issue HW permits can remember more than a dozen items each and every time they issue a permit. This is the fundamental basis for having work permits; they are a checklist to ensure that all applicable items are addressed before the permit is authorized. Annual training is great, but it can not replace a well-organized and detailed HW permit.