In “general industry” workplaces OSHA has a “General Requirements” standard for conducting Welding, Cutting, and Brazing activities (1910.252). For those working within the battery limits of a PSM/RMP covered process, both OSHA (1910.119(k)(2) and EPA (68.85(b) reference 1910.252(a) as the basics of safely conducting these HW activities. But there is one (1) requirement that we almost always see missing from every aspect of a facilities HW program, permitting, and even training, and that is…
1910.252(a)(2)(viii) Ducts. Ducts and conveyor systems that might carry sparks to distant combustibles shall be suitably protected or shut down.
For those of you at PSM/RMP facilities reading this, here is the PSM/RMP references:
1910.119(k)(2) 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. The permit shall be kept on file until completion of the hot work operations.
68.85(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. The permit shall be kept on file until completion of the hot work operations.
PSM Compliance Directive Question for the OSHA CSHO…
12. 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)]
Although this requirement is specifically called out, as shown above, our experience tells us this requirement is NOT included in either the written program, permit, and training. Nada… not even a mention! And when we write up a finding against this requirement, whether in a PSM/RMP audit or S&H audit, the amount of push back is quite surprising. We hear everything from “that does not apply to us” to “when did OSHA change that”. But the most common reason for the lack of this item being covered is that the facility is using a program and permit provided by their PROPERTY CONSERVATION INSURER. Even the old Factory Mutual permits did NOT cover this OSHA requirement – FM’s newer permits DO mention ducts and conveyors so check your permit to make sure you are using the NEWEST FM Global permit and not the old stock! A quick Google search of “Hot Work Permits” shows the lack of this requirement on every permit that shows up in the search results. Of course most of these permits belong to universities around the country and appear to be mock ups of the old Factory Mutual HW permits, but even normal occupancies such as a classroom and dorm room have duct work which can convey HW sparks beyond the designated fire safe area.
So why does OSHA require ducts and conveyors be protected or shutdown within the fire safe area (i.e. 35’ radius)? We prepare a fire safe area that is prepared for HW; outside this fire safe area the area is not normally designed or maintained to see sparks. When we have a means that would convey a spark outside our fire safe area (i.e. a conveyor or ductwork) then we must take measures to ensure these systems do not convey a spark to combustibles/flammables.
We have found this to be a HUGE miss when conducting combustible dust assessments. A facility installs a “dust collector” in order to assist in controlling the accumulation of combustible dusts, but in their efforts to manage the Com Dust hazards, they overlooked the impact their hotwork program and permitting has on this new engineering control. As soon as the dust collection system was installed, the HW program, permit, and training should have been updated to include the shutdown or covering of inlets of this dust collection system during the time HW is taking place. But I digress into combustible dust issues, but it is a good example. The last thing we want in our bag house full of combustible dusts is a red hot spark! Many of dust collectors have met their demise from a spark originating a long ways away and yes that spark was a result of HW activities.
Be very careful taking the position that “all of my duct work is at the ceiling so this requirement does not really impact my facility”. One of my sister plants thought that in 1998 and ended up blowing up their bag house. Yes, it is true… all the duct work was elevated, but so was the contractor doing the hotwork! A spark was introduced into the duct work and the results was about $50,000 in damage to a bag house.
Think about all the work places that use conveyors to move products from one production area to another and how many fire walls these conveyors pass through. It can be a daunting task, but if we wish to use the fire rated walls to limit our fire safe area preparations, then we MUST ensure that the spark can not find its way beyond our fire wall(s). “Slag” has been know to travel miles on a conveyor system, only to ignite a coal pile, wood chip pile, etc.
So this rather unknown OSHA requirement for conducting HW activities can play a major role in controlling the risks and hazards associated with conducting HW activities outside of areas NOT SPECIFICALLY designed and maintained for HW. Check your HW permit to ensure this requirement is covered on the permit. You may also want update the written HW program and HW training program so as to explain why this requirement is present in the program and permit and the hazard it poses if not put in place.
FYI… if you are a PSM/RMP facility and this has not been identified in a past audit you may want to review your auditing protocol. If you are needing to make this change, PLEASE consider using your MOC process to manage this change as this can be a significant change for a facility to handle.
Here is a GREAT RESCOURCE from FM Global on HW Safety and it discusses conveyors and duct work extensively. It is FREE from FM Global.