I am curious to know how other facilities manage this situation. Having been a FPE for several years in my career, I grew up learning that if there is one “sacred rule” regarding hot work it is that Hot Work is NEVER EVER done when the sprinkler system is out of service. It was one of those rules you did not even ask for a “variance” as you would be looked upon in a bad way. We can also point to OSHA’s minimum requirements for Hot Work in 1910.252(a) where it is stated: (emphasis by me)
1910.252(a)(2)(vi) Prohibited areas. Cutting or welding shall not be permitted in the following situations:
1910.252(a)(2)(vi)(A) In areas not authorized by management.
1910.252(a)(2)(vi)(B) In sprinklered buildings while such protection is impaired.
That makes it pretty clear, does it not?
Now we can look to a couple of other standards that imply there is a way we could do Hot Work in a sprinkled area while the sprinkler is impaired.
2015 International Fire Code
This code has been adopted by many states in a revised form as their “fire code” and this code permits Hot Work in a sprinkled area while the sprinkler is out of service or impaired… (emphasis by me)
Sprinkler protection. Automatic sprinkler protection shall not be shut off while hot work is performed. Where hot work is performed close to automatic sprinklers, noncombustible barriers or damp cloth guards shall shield the individual sprinkler heads and shall be removed when the work is completed. If the work extends over several days, the shields shall be removed at the end of each workday. The fire code official shall approve hot work where sprinkler protection is impaired.
As we can see, “impaired” is different than “shut-off” in this code, but the bottom line is that our “fire code official” could grant us permission to do hot work while the sprinkler system is impaired. I am not sure if we could actually find a fire code official who would grant this permission, but the code does appear to allow it.
NFPA® 51B – Standard for Fire Prevention During Welding, Cutting, and Other Hot Work
This NFPA standard’s 1962 edition is actually the foundation for OSHA’s 1910.252 and a lot of businesses have chosen to use this NFPA standard (NOT the 1962 edition!) as the basis for their hot work safe work practice. This world-class standard also appears to allow Hot Work in a sprinkled area while the sprinkler is impaired
5.3* Nonpermissible Areas. Hot work shall not be permitted in the following areas:
(1) In areas not authorized by management
(2) In sprinklered buildings where sprinklers are impaired, unless the requirements of NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, are met
However, a search of NFPA 25 does not really state any specific requirements that must be met in order to do Hot Work in a sprinkled area while the sprinkler is impaired. It does have “Chapter 15 Impairments”, but even in that chapter, it makes no mention of requirements that must be met in order to do hot work safely while the sprinker is impaired. Bottom line though is that NFPA 51B does permit Hot Work in a sprinkled area while the sprinkler is impaired.
Whether OSHA would accept either standard as an acceptable standard that would allow 1910.252(a)(2)(vi) Prohibited areas to be circumvented is a question that I do not have the answer to.