UPDATE: EPA’s RMP Hot Work Permit retention period

In 2015 and 2022, I mentioned that the EPA proposed updating 68.85 by requiring Hot Work permits to be retained for five (5) years, where that frequency came from, and why they wanted to update the standard.  Members can read…

EPA proposing a retention period for Hot Work Permits

and

How long do you keep your hot work permits?

As it went through public comments, the EPA settled on a different retention period that aligns with the RMP Audit Function frequency.

 

ยง 68.85 Hot work permit.

(a) The owner or operator shall issue a hot work permit for hot work operations conducted on or near a covered process.

(b) The 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; it shall indicate the date(s) authorized for hot work; and identify the object on which hot work is to be performed.

(c) The permit shall be retained for three years after the completion of the hot work operations.

 

as amended at 89 FR 17691, Mar. 11, 2024

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