Are you confident in your Hot Work Program, Permit, and Training?

In the process safety arena, OSHA’s PSM Standard (and EPA’s RMP rule) made it official… doing “hot work” in/on/adjacent to the “covered process(s)” required a WRITTEN PERMIT. Before PSM/RMP, OSHA only “preferred” the permission to perform Hot Work be in written form. OSHA PSM (and RMP)intent was to require employers to control, in a consistent manner, nonroutine work conducted in covered process areas. Specifically, they are concerned with the permitting of hot work operations associated with welding and cutting in covered process areas. Minimum requirements include: 

  1. that the employer issue a hot work permit for hot work operations conducted on or near a covered process and
  2. that hot work permits shall document compliance with the fire prevention and protection requirements of 29 CFR 1910.252(a)

And here is CPL 02-00-035 items as to how OSHA would word their citations for matters not meeting the minimum requirements found in 1910.252(a)…

 

29 CFR 1910.252(a)(1)(i): When the object to be welded or cut could not be readily moved, all movable fire hazards in the vicinity were not taken to a safe place:

29 CFR 1910.252(a)(1)(ii): When the object to be welded or cut could not be moved and all the fire hazards could not be removed, guards were not used to confine the heat, sparks, and slag to protect the immovable fire hazards:

29 CFR 1910.252(a)(1)(iii): Welding or cutting was performed, when the requirements stated in 29 CFR 1910.252(a)(1)(i) and 29 CFR 1910.252(a)(1)(ii) could not be followed:

 

29 CFR 1910.252(a)(2)(i): Wherever there were floor openings or cracks in the flooring that could not be closed, precautions were not taken so that no readily combustible materials on the floor below would be exposed to sparks which might drop through the floor:

29 CFR 1910.252(a)(2)(i): Precautions were not taken so that no readily combustible materials on the floor below would be exposed to sparks which might drop through cracks or holes in walls, open doorways and open or broken windows:

29 CFR 1910.252(a)(2)(ii): Suitable extinguishing equipment was not maintained in a state of readiness for instant use:

 

29 CFR 1910.252(a)(2)(iii)(A): The employer did not provide fire watchers whenever welding or cutting was performed in locations where other than a minor fire might develop:

29 CFR 1910.252(a)(2)(iii)(A)(1): The employer did not provide fire watchers whenever welding or cutting was performed, where appreciable combustible material in building construction or contents was closer than 35 feet (10.7 m) to the point of operation:

29 CFR 1019.252(a)(2)(iii)(A)(2): The employer did not provide fire watchers whenever welding or cutting was performed, where appreciable combustibles were more than 35 feet (10.7 m) away but could be easily ignited by sparks:

29 CFR 1910.252(a)(2)(iii)(A)(3): The employer did not provide fire watchers whenever welding or cutting was performed, where wall or floor openings within a 35 foot (10.7 m) radius exposed combustible material in adjacent areas including concealed spaces in walls or floors:

29 CFR 1910.252(a)(2)(iii)(A)(4): The employer did not provide fire watchers whenever welding or cutting was performed, where combustible materials were adjacent to the opposite side of metal partitions, walls, ceilings, or roofs and were likely to be ignited by conduction or radiation heat:

 

29 CFR 1910.252(a)(2)(iii)(B): The employer did not ensure that assigned fire watchers had fire extinguisher equipment readily available and were trained in its use:

29 CFR 1910.252(a)(2)(iii)(B): The employer did not ensure that assigned fire watchers were familiar with the facilities for sounding an alarm in the event of a fire:

29 CFR 1910.252(a)(2)(iii)(B): The employer did not ensure that fire watchers watched for fires in all exposed areas and tried to extinguish them only when obviously within the capacity of the equipment provided, or otherwise sounded the alarm:

29 CFR 1910.252(a)(2)(iii)(B): The employer did not ensure that fire watch was maintained for at least a half hour after completion of welding or cutting operations to detect and extinguish possible smoldering fires:

 

29 CFR 1910.252(a)(2)(iv): Cutting or welding was permitted in areas before the areas were inspected by the individual responsible for authorizing cutting and welding operations:

29 CFR 1910.252(a)(2)(iv): The individual responsible for authorizing cutting or welding operations, did not designate precautions to be followed in granting authorization to proceed preferably in the form of a written permit:

 

29 CFR 1910.252(a)(2)(v): Where combustible materials such as paper clippings, wood shavings, or textile fibers were on the floor, the employer did not ensure that the floor was swept clean for a radius of 35 feet (10.7 m) from the cutting or welding operations:

29 CFR 1910.252(a)(2)(v): Cutting or welding was permitted in areas where combustible floors were not kept wet, covered with damp sand, or protected by fire-resistant shields:

29 CFR 1910.252(a)(2)(v): Where floors had been wet down, personnel operating arc welding or cutting equipment were not protected from possible shock:

 

29 CFR 1910.252(a)(2)(vi)(A): Cutting or welding was permitted in areas not authorized by management:

29 CFR 1910.252(a)(2)(vi)(B): Cutting or welding was permitted in sprinklered buildings while such protection was impaired:

29 CFR 1910.252(a)(2)(vi)(C): Cutting or welding was permitted in the presence of explosive atmospheres (mixture of flammable gases, vapors, liquids, or dusts with air), or explosive atmospheres that could develop inside uncleaned or improperly prepared tanks or equipment which had previously contained such materials, or that could develop in areas with an accumulation of combustible dusts:

29 CFR 1910.252(a)(2)(vi)(D): Cutting or welding was permitted in areas near the storage of large quantities of exposed, readily ignitible materials such as bulk sulfur, baled paper, or cotton:

29 CFR 1910.252(a)(2)(vii): Where practicable, combustible materials were not relocated at least 35 feet (10.7 m) from the cutting or welding operation work site :

29 CFR 1910.252(a)(2)(vii): Where relocation of combustible was impracticable, cutting or welding was permitted when combustible were not protected with flameproofed covers or otherwise shielded with metal, asbestos guards, or curtains:

 

29 CFR 1910.252(a)(2)(viii): Cutting or welding was permitted where ducts and conveyor systems that might carry sparks to distant combustibles were not suitably protected or shut down:

 

29 CFR 1910.252(a)(2)(ix): Where cutting or welding was done near walls, partitions, ceiling or roof of combustible construction, fire-resistant shields or guards were not provided to prevent ignition:

NOTE: Where violation of 29 CFR 1910.252(a)(2)(x) exist, you may wish to look at 29 CFR 1910. 252(a)(2)(vii), OPTION 1 and 29 CFR 1910.252 (a)(2)(iii)(4) for fire watchers and group both apparent violations.

29 CFR 1910.252(a)(2)(xi): The employer did not prohibit any attempt to weld on a metal partition, wall, ceiling, or roof having a combustible covering nor on walls or partitions of combustible sandwich-type panel construction:

29 CFR 1910.252(a)(2)(xii): Cutting or welding on pipes or other metal in contact with combustible walls, partitions, ceilings, or roofs was undertaken where the work was close enough to cause ignition by conduction:

29 CFR 1910.252(a)(2)(xiii): The employer did not recognize its responsibility for the safe usage of cutting or welding equipment on its property, in accordance with 29 CFR 1910.252 (a)(2)(xiii)(A) through 29 CFR 1910.252(a)(2)(xiii)(D):

29 CFR 1910.252(a)(2)(xiii)(A): The employer did not recognize its responsibility for the safe usage of cutting or welding equipment, and based on fire potentials of plant facilities, did not establish areas for cutting and welding, and did not establish procedures for cutting and welding, in other areas:

29 CFR 1910.252(a)(2)(xiii)(B): The employer did not recognize its responsibility for the safe usage of cutting or welding equipment, and did not designate an individual responsible for authorizing cutting and welding operations in areas not specifically designed for such processes:

29 CFR 1910.252(a)(2)(xiii)(C): The employer did not recognize its responsibility for the safe usage of cutting or welding equipment, and did not insist that cutters or welders and their supervisors were suitably trained in the safe operation of their equipment and the safe use of the process:

29 CFR 1910.252(a)(2)(xiii)(D): The employer did not recognize its responsibility for the safe usage of cutting or welding equipment, and did not advise all contractors about flammable materials or hazardous conditions of which they may not be aware:

29 CFR 1910.252(a)(2)(xiv)(A): The employer did not ensure that the supervisor was responsible for the safe handling of the cutting or welding equipment and the safe use of the cutting or welding process:

29 CFR 1910.252(a)(2)(xiv)(B): The employer did not ensure that the supervisor determined the combustible materials and hazardous areas present or likely to be present in the work location:

29 CFR 1910.252(a)(2)(xiv)(C)(1): The employer did not ensure that the supervisor protected the combustibles from ignition by having the work moved to a location free from dangerous combustibles:

29 CFR 1910.252(a)(2)(xiv)(C)(2): The employer did not ensure that if the work could not be moved, the supervisor had the combustibles moved to a safe distance from the work or had the combustibles properly shielded against ignition:

29 CFR 1910.252(a)(2)(xiv)(C)(3): The employer did not ensure that the supervisor saw that cutting and welding was so scheduled that plant operations that might expose combustibles to ignition were not started during cutting or welding:

29 CFR 1910.252(a)(2)(xiv)(D): The employer did not ensure that the supervisor secured authorization for cutting or welding operations from the designated management representative:

29 CFR 1910.252(a)(2)(xiv)(E): The employer did not ensure that the supervisor determined that the cutter or welder secured his approval that conditions were safe before going ahead:

29 CFR 1910.252(a)(2)(xiv)(F): The employer did not ensure that the supervisor determined that fire protection and extinguishing equipment were properly located at the site:

29 CFR 1910.252(a)(2)(xiv)(G): The employer did not ensure that where fire watchers were required, the supervisor saw that they were available at the site:

29 CFR 1910.252(a)(2)(xv): Cutting or welding was permitted not only in areas that were or had been made fire safe:

 

29 CFR 1910.252(a)(3)(i): Welding, cutting, or other hot work was performed on used drums, barrels, tanks, or other containers that had not been cleaned so thoroughly as to make absolutely certain there were no flammable materials present or any substances such as greases, tars, acids, or other materials which where subjected to heat, might produce flammable or toxic vapors:

29 CFR 1910.252(a)(3)(i): Welding. cutting, or hot work was performed on pipe lines or connections to the drum or vessel that had not been disconnected or blanked:

29 CFR 1910.252(a)(3)(ii): All hollow spaces, cavities, or containers were not vented to permit the escape of air or gases before preheating, cutting, or welding was performed:

 

29 CFR 1910.252(a)(4)(i): In a confined space area, when arc welding was to be suspended for any substantial period of time, such as during lunch hour or overnight, all electrodes were not removed from the holders and the holders were not carefully located so that accidental contact could not occur and the machine could be disconnected from the power source:

29 CFR 1910.252(a)(4)(ii): In a confined space area, in order to eliminate the possibility of gas escaping through leaks or improperly closed valves, when welding or cutting, the torch valves were not closed and the gas supply to the torch was not positively shut off at some point outside the confined area whenever the torch was not to be used for a substantial period of time, such as during lunch hour or overnight:

29 CFR 1910.252(a)(4)(ii): In a confined space area, whenever the torch was not to be used for a substantial period of time, such as during lunch hour or overnight, where practicable, the torch and hose were not removed from the confined space:

 

29 CFR 1910.252(b)(1)(i): A welder or helper working on platforms, scaffolds, or runways was not protected against falling:

29 CFR 1910.252(b)(1)(ii): Welders did not place welding cable and other equipment so that it was clear of passageways, ladders, and stairways:

 

29 CFR 1910.252(b)(2)(i)(A): Helmets or hand shields were not used during all arc welding or arc cutting operations:

29 CFR 1910.252(b)(2)(i)(A): During arc welding or arc cutting, helpers or attendants were not provided with proper eye protection:

29 CFR 1910.252(b)(2)(i)(B): Goggles or other suitable eye protection were not used during all gas welding or oxygen cutting operations:
NOTE: Spectacles without side shields, with suitable filter lenses, are permitted for use during gas welding operations on light work, for torch brazing or for inspection.

29 CFR 1910.252(b)(2)(i)(C): All operators and attendants of resistance welding or resistance brazing equipment did not use transparent face shields or goggles, depending on the particular job, to protect their faces or eyes, as required:

29 CFR 1910.252(b)(2)(i)(D): Eye protection in the form of goggles were not provided where needed for brazing operations not covered in 29 CFR 1910.252(b)(2)(i)(A) through 29 CFR 1910.252(b)(2)(i)(C):

29 CFR 1910.252(b)(2)(ii)(A): Helmets and hand shields being used were not made of material which is an insulator for heat and electricity:

29 CFR 1910.252(b)(2)(ii)(A): Helmets, shields, and goggles being used were readily flammable:

29 CFR 1910.252(b)(2)(ii)(A): Helmets, shields, and goggles being used were not capable of withstanding sterilization:

29 CFR 1910.252(b)(2)(ii)(B): Helmets and hand shields being used were not arranged to protect the face, neck, and ears from direct radiant energy from the arc:

29 CFR 1910.252(b)(2)(ii)(C): Helmets were not provided with filter plates and cover plates designed for easy removal:

29 CFR 1910.252(b)(2)(ii)(D): All parts for protectors were not constructed of a material which would not readily corrode or discolor the skin:

29 CFR 1910.252(b)(2)(ii)(E): Goggles being used were not ventilated to prevent fogging of the lenses as much as practicable:

29 CFR 1910.252(b)(2)(ii)(F): All glass for lenses were not tempered, substantially free from striae, air bubbles, waves and other flaws:

29 CFR 1910.252(b)(2)(ii)(F): When a lens was not ground to provide proper optical correction for defective vision, the front and rear surfaces of lenses and windows were not smooth and parallel:

29 CFR 1910.252(b)(2)(ii)(G): Lenses did not bear some permanent distinctive marking by which the source and shade could be readily identified:

29 CFR 1910.252(b)(2)(ii)(I): All filter lenses and plates did not meet the test for transmission of radiant energy prescribe in ANSI Z87.1-1968, American National Standard Practice for Occupational and Educational Eye and Face Protection:

29 CFR 1910.252(b)(2)(iii): Where the work permitted, the welder was not enclosed in an individual booth painted with a finish of low reflectivity such as zinc oxide (an important factor for absorbing ultraviolet radiations) and lamp black, or where the work did not permit, the welder was not enclosed with noncombustible screens similarly painted like the individual booth:

29 CFR 1910.252(b)(2)(iii): Workers and other persons adjacent to the welding area were not protected from the rays by noncombustible or flameproof screens or shields:

29 CFR 1910.252(b)(2)(iii): Workers and other persons adjacent to the welding area were not required to wear appropriate goggles, to protect them from the rays when noncombustible or flameproof screens or shields were not used:

29 CFR 1910.252(b)(3): Employees exposed to the hazards created by welding, cutting, or brazing operations were not protected by personal protective equipment in accordance with the requirements of 29 CFR 1910.132:
NOTE: Appropriate protective clothing required for welding operation will vary with the size, nature and location of the work to be performed.

 

29 CFR 1910.252(b)(4)(iii): When welding or cutting was being performed in any confined spaces, the gas cylinders and welding machine were not left on the outside:

29 CFR 1910.252(b)(4)(iii): Before operations were started in a confined space with welding or cutting equipment, heavy portable equipment mounted on wheels had not been securely blocked to prevent accidental movement:

29 CFR 1910.252(b)(4)(iv): Where the welder must enter a confined space through a manhole or other small opening, means was not provided for quickly removing the welder in case of emergency:

29 CFR 1910.252(b)(4)(iv): When safety belts and lifelines were used for quickly removing of welder from a confined space in case of emergency, the safety belt and lifeline were not so attached to the welder’s body that his body would not be jammed in a small exit opening:

29 CFR 1910.252(b)(4)(iv): An attendant with a preplanned rescue procedure was not stationed outside a confined space opening to observe the welder at all times in case of emergency:

29 CFR 1910.252(b)(4)(iv): An attendant with a preplanned rescue procedure stationed outside a confined space opening to observe the welder at all times in case of emergency was not capable of putting rescue operations into effect:

29 CFR 1910.252(b)(4)(vii): After welding operations were completed, the welder did not mark the hot metal or provide some other means of warning other workers that the metal was hot:

 

29 CFR 1910.252(c)(1)(ii): When welding had to be performed in a space entirely screened on all sides, the screens were not so arranged that no serious restriction of ventilation exited:

29 CFR 1910.252(c)(1)(iii): Local exhaust or general ventilating systems were not provided and arranged to keep the amount of toxic fumes, gases, or dusts below the maximum allowable concentration as specified in 29 CFR 1910.1000:

29 CFR 1910.252(c)(1)(iv): The employer did not ensure that suppliers of welding materials had determined the hazard, if any, associated with the use of their materials in welding, cutting, etc.:
NOTE: You may wish to check 29 CFR 1910.1200 for additional violations and consider grouping with a violation of this requirement.

29 CFR 1910.252(c)(1)(iv)(A): All filler metals and fusible granular materials did not carry the following notice, as a minimum, on tags, boxes, or other containers:

CAUTION Welding may produce fumes and gases hazardous to health. Avoid breathing these fumes and gases. Used adequate ventilation. Use adequate ventilation. See ANSI Z49.1 – 1967 Safety in Welding and Cutting published by the American Welding Society.
NOTE: You may wish to check 29 CFR 1910.1200 for additional violations and consider grouping with this requirement.

29 CFR 1910.252(c)(1)(iv)(B): Brazing (welding) filler metals containing cadmium in significant amounts did not carry the following notice on tags, boxes, or other containers:
WARNING CONTAINS CADMIUM – POISONOUS FUMES MAY BE FORMED ON HEATING Do not breathe fumes. Use only with adequate ventilation such as fume collectors, exhaust ventilators, or air-supplied respirators. See ANSI Z49.1 – 1967. If chest pain, cough, or fever develops after use call physician immediately.

NOTE: You may wish to check 29 CFR 1910.1200 for additional violations and consider grouping with this requirement.
2 29 CFR 1910.252(c)(1)(iv)(C): Brazing and gas welding fluxes containing fluorine compounds did not have cautionary wording to indicate that they contained fluorine compounds:

CAUTION CONTAINS FLUORIDES This flux when heated gives off fumes that may irritate eyes, nose and throat. 1. Avoid fumes-use only in well-ventilated spaces. 2. Avoid contact of flux with eyes or skin. 3. Do not Take internally.

NOTE: You may wish to check 29 CFR 1910.1200 for additional violations and consider grouping with this requirement. The above cautionary wording is recommended by the American Welding Society for brazing and welding.

29 CFR 1910.252(c)(2)(i): Mechanical ventilation was not provided when welding or cutting was done on metals not covered in 29 CFR 1910.252(c)(5) through 29 CFR 1910.252 (c)(12):

29 CFR 1910.252(c)(2)(i)(A): Mechanical ventilation was not provided in a space of less than 10,000 cubic feet (284 m3) per welder:

29 CFR 1910.252(c)(2)(i)(B): Mechanical ventilation was not provided in a room having a ceiling height of less than 16 feet (5 m):

29 CFR 1910.252(c)(2)(i)(C): Mechanical ventilation was not provided in confined spaces or where the welding space contained partitions, balconies, or other structural barriers to the extent that they significantly obstructed cross ventilation:

29 CFR 1910.252 (c)(2)(ii): Mechanical ventilation provided did not meet the minimum rate of 2,000 cubic feet (57 m3) per minute per welder:
NOTE: Exception where local exhaust hoods and booths as per 29 CFR 1910.252(c)(3), or airline respirators approved by the Mine Safety and Health Administration and the National Institute for Occupational Safety and Health, pursuant to the provisions of 30 CFR part 11, are provided. Natural ventilation is considered sufficient for welding or cutting operations where restrictions in 29 CFR 1910.252(c)(2)(i) are not present.

29 CFR 1910.252(c)(4)(i): All welding and cutting operations carried on in confined spaces were not adequately ventilated to prevent the accumulation of toxic materials or possible oxygen deficiency:
NOTE: This applies not only to the welder but also to helpers and other personnel in the immediate vicinity. You may wish to check 29 CFR 1910.252 (b)(4)(ii) for possible additional violation in support of this requirement.

29 CFR 1910.252(c)(4)(i): Where ventilation was being used during welding and cutting operations in a confined space, all replacing air redrawn was not clean and respirable:

29 CFR 1910.252(c)(4)(ii): In such circumstances where it was impossible to provide such ventilation, airline respirators or hose masks approved by the Mine Safety and Health Administration and the National Institute for Occupational Safety and Health, pursuant to the provisions of 30 CFR part 11, for this purpose, were not used:

29 CFR 1910.252(c)(4)(iii): In areas immediately hazardous to life, hose masks with blowers or self-contained breathing equipment were not used:

29 CFR 1910.252(c)(4)(iv): Where welding and cutting operations were carried on in confined spaces and where welders and helpers were provided with hose masks, hose masks with blowers or self-contained breathing equipment approved by the Mine Safety and Health Administration and the National Institute for Occupational Safety and Health, a worker was not stationed on the outside of such confined spaces to ensure the safety of those working within:
NOTE: You may wish to look at 29 CFR 1910.252 (b)(4)(iv), OPTIONs 1 through 3 for additional violations to support this requirement.

29 CFR 1910.252(c)(4)(v): Where welding and cutting operations were carried on in a confined space, oxygen was used for ventilation:

 

29 CFR 1910.252(c)(5)(i): In confined spaces, welding or cutting involving fluxes, coverings, or other materials which contain fluorine compounds was not done in accordance with 29 CFR 1910.252(c)(4):
NOTE: A fluorine compound is one that contains fluorine, as an element in chemical combination, not as a free gas.

29 CFR 1910.252(c)(6)(i): In confined spaces, welding or cutting involving zinc-bearing base or filler metals or metals coated with zinc-bearing materials was not done in accordance with 29 CFR 1910.252(c)(4):

29 CFR 1910.252(c)(6)(ii): Indoors, welding or cutting involving zinc-bearing base or filler metals coated with zinc-bearing materials was not done in accordance with 29 CFR 1910.252(c)(3):

29 CFR 1910.252(c)(7)(i): In confined spaces, welding involving lead base metals (erroneously called lead-burning) was not done in accordance with 29 CFR 1910.252(c)(4):

29 CFR 1910.252(c)(7)(ii): Indoors, welding involving lead-base metals was not done in accordance with 29 CFR 1910.252(c)(3):

29 CFR 1910.252(c)(7)(iii): In confined spaces or indoors, welding or cutting involving metals containing lead, other than as an impurity, or involving metals coated with lead- bearing materials, including paint was not done using local exhaust ventilation or airline respirators.

29 CFR 1910.252(c)(7)(iii): Outdoors, welding or cutting operations involving metals containing lead, other than as an impurity, or involving metals coated with lead-bearing materials, including paint was not done using respiratory protective equipment approved by the Mine Safety and Health Administration and the National Institute for Occupational Safety and Health, pursuant to the provisions of 30 CFR part 11, for such purposes:

29 CFR 1910.252(c)(7)(iii): In all cases, workers in the immediate vicinity of the cutting operation were not protected as necessary by local exhaust ventilation or airline respirators:

 

29 CFR 1910.252(c)(8): Welding or cutting indoors, outdoors, or in confined spaces involving beryllium-containing base or filler metals was not done using local exhaust ventilation and airline respirators, when atmospheric test under the most adverse conditions had not established that the workers’ exposure was within the acceptable concentrations defined by 29 CFR 1910.1000:

29 CFR 1910.252(c)(8): In all cases, workers in the immediate vicinity of the welding or cutting operation involving beryllium-containing base or filler metals were not protected as necessary by local exhaust ventilation or airline respirators:
NOTE: There is an exception to this requirement when the atmospheric tests have established that the workers’ exposure is within the acceptable concentrations defined by 29 CFR 1910.1000.

29 CFR 1910.252(c)(9)(i): Welding or cutting indoors or in confined spaces involving cadmium-bearing or cadmium-coated base metals was not done using local exhaust ventilation or airline respirators, when atmospheric tests under the most adverse conditions had not established that the workers’ exposure was within the acceptable concentrations defined by 29 CFR 1910.1000:

29 CFR 1910.252(c)(9)(i): Outdoors, welding or cutting involving cadmium-bearing or cadmium-coated base metals was not done using respiratory protective equipment such as fume respirators approved by the Mine Safety and Health Administration and the National Institute for Occupational Safety and Health, pursuant to the provisions of 30 CFR part 11, for such purposes:

29 CFR 1910.252(c)(9)(ii): Welding (brazing) involving cadmium-bearing filler metals was not done using ventilation as prescribed in 29 CFR 1910.252(c)(3) or 29 CFR 1910.252 (c)(4) when the work was done in a confined space:

29 CFR 1910.252(c)(10): Welding or cutting indoors or in a confined space involving metals coated with mercury-bearing materials including paint was not done using local exhaust ventilation or airline respirators, when atmospheric tests under the most adverse conditions had not established that the workers’ exposure was within the acceptable concentrations defined by 29 CFR 1910.1000:

29 CFR 1910.252(c)(10): Outdoors, welding or cutting involving metals coated with mercury-bearing materials including paint was not done using respiratory protective equipment approved by the Mine Safety and Health Administration and the National Institute for Occupational Safety and Health, pursuant to the provisions of 30 CFR part 11, for such purposes:

 

29 CFR 1910,252(c)(11)(i): In the use of cleaning materials, because of their possible toxicity or flammability, appropriate precautions, such as manufacturers instructions were not followed by the employer:

29 CFR 1910.252(c)(11)(ii): Degreasing and other cleaning operations involving chlorinated hydrocarbons was not so located that no vapors from these operations would reach or be drawn into the atmosphere surrounding any welding operation:
NOTE: In addition, trichloroethylene and perchlorethylene should be kept out of atmospheres penetrated by the ultraviolet radiation of gas-shielded welding operations.

29 CFR 1910.252(c)(12): Oxygen cutting, using either a chemical flux or iron powder or gas-shielded arc cutting of stainless steel, was not done using mechanical ventilation adequate to remove the fumes generated:

29 CFR 1910.252(c)(13): First-aid equipment was not available at all times:

29 CFR 1910.252(c)(13): All injuries were not reported as soon as possible for medical attention:

29 CFR 1910.252(c)(13): First-aid was not rendered until medical attention could be provided:

29 CFR 1910.252(d)(1)(i): During the welding or cutting operations on transmission pipelines the requirements of 29 CFR 1910.252(b) and (c), and 29 CFR 1910.254 were not observed:

29 CFR 1910.252(d)(1)(ii): Where field shop operations were involved for fabrication of fittings, river crossings, road crossings, and pumping and compressor stations, the requirements of 29 CFR 1910.252(a), (b), and (c), and 29 CFR 1910.253 and 29 CFR 1910.254 were not observed during welding or cutting operations:

29 CFR 1910.252(d)(1)(iii): When arc welding was performed in wet conditions, or under conditions of high humidity, special protection against electric shock was not supplied:

29 CFR 1910.252(d)(1)(iv): In pressure testing of pipelines, the workers and the public were not protected against injury by the blowing out of closures or other pressure restraining devices:

29 CFR 1910.252(d)(1)(iv): In pressure testing of pipelines, protection was not provided against expulsion of loose dirt that could have become trapped in the pipe:

29 CFR 1910.252(d)(1)(v): The welded construction of the transmission pipelines was not conducted in accordance with the Standard for Welding Pipe Lines and Related Facilities, API Std. 1104-1968.

29 CFR 1910.252(d)(1)(vi): The connection, by welding, of branches to pipelines carrying flammable substances was not performed in accordance with Welding or Hot Tapping on Equipment Containing Flammables, API Std. PSD No.2201-1963.

29 CFR 1910.252(d)(1)(vii): The use of X-rays and radioactive isotopes for the inspection of welded pipeline joints was not carried out in conformance with the American National Standard Safety Standard for Non-Medical X-ray and Sealed Gamma-Ray Sources, ANSI Z54.1-1963:

29 CFR 1910.252(d)(2)(i): When welding or cutting on mechanical piping systems, the requirements of 29 CFR 1910.252 (a), (b), and (c), and 29 CFR 1910.253 and 29 CFR 1910.254 were not observed:

29 CFR 1910.252(d)(2)(ii): The use of X-rays and radioactive isotopes for the inspection of welded piping joints on mechanical piping systems was not in conformance with the American National Standard Safety Standard for Non-Medical X- ray and Sealed Gamma-Ray Sources, ANSI Z54.1-1963:

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