In just about all our audits, we get this question. We all know that OSHA requires us to maintain our PRCS Entry Permits for one year to be used in our annual program review, but they do not mention HW permit retention. We always advise maintaining HW permits on a rolling 12-month schedule; however, at some very large facilities, this can take a lot of filing cabinets! So I am asked by legal “what is officially required,” and that is where I go to one of my most trusted sources… State Fire Code. I am unaware of any state not having a fire code, even when most adopt the International Fire Code(s). For example, in my home state of Ohio, we are REQUIRED by our code to keep our hotwork permits for…
1301:7-7-26 Welding and other hot work.
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(C) Section 2603 General requirements
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(3) 2603.3 Hot work program permit. Hot work permits, issued by an approved responsible manager under a hot work program, shall be available for review by the fire code official at the time the work is conducted and for 48 hours after work is complete.
So in Ohio, just about every single business is REQUIRED to issue hotwork permits. Those permits must be maintained for at least 48 hours after the HW is completed. Why 48 hours? Well, seeing how most significant HW fires start AFTER the HW is completed, I am pretty sure this is for investigation purposes (crumb trail of sorts). But nonetheless, 48 hours is the minimum retention period for HW permits issued in the state of Ohio. What do your state fire code requirements for HW Permit Retention?
PSM/RMP facilities should really consider the rolling 12-month schedule or something like “the last 100 permits” so that during 3-year audits, there is a viable sample size to review (See PSM 2006 LOI). I also recommend keeping HW permits issued during turnarounds/shutdowns so that permit issuing during these periods can be compared to normal operational periods.
By the way, anyone looking to beef up their Hotwork program requirements should consider studying Ohio’s code as well as OSHA Construction Standard on Hotwork. OSHA actually has several different requirements in their 1926 Hotwork standards vs. their 1910 Hotwork standards.
NOTE: Even the PSM/RMP standards require the permit to be “on file” while the HW is taking place. Nothing about retaining these permits.
It should also be noted that facilities not under PSM/RMP may believe they are not required to have a written permit since 1910.252(a)(2)(iv) only “prefers” written permission; however, in most states, the state fire code will require a written permit – even when OSHA’s 1910.252 merely recommends it.
Links to helpful resources:
1301:7-7-26 Welding and other hot work
Welding, Cutting, and Brazing General requirements (1910)