A few weeks back one of my good friends and a hell of a process safety professional contacted me about OSHA’s Hot Work (HW) referenced RAGAGEP, NFPA 51B. He wanted to be sure he was not missing something, as OSHA still references the Year 1962 Edition of NFPA 51B. Just to show how broken OSHA rulemaking is, NFPA 51B has been revised/updated eleven (11) times since!!! And each time OSHA tries to just update their “referenced” standard they get shut down by the rulemaking process. So it is easy for me to say the rulemaking process is broken and if there ever was evidence that OSHA is the “bottom of the safety barrel” it is with 1910.252, General requirements. I have written a lot about Hot Work because it is one of the 14 Elements of the PSM Standard and each year we see massive losses from improper HW practices. I have also sung the praises of FM Global, a SAFTENG Partner in Safety for many years, and their Property Loss Prevention Data Sheets as a world-class best practice that will far and exceed OSHA’s dated requirements. I have even suggested that many smaller businesses that fall under PSM/RMP and can not afford to by some of the rather expensive RAGAGEPS, to use these FREE Property Loss Prevention Data Sheets to raise their safety performance. And today I want to suggest that we leave the boundaries of 1910.252, General requirements and move into the 21st-century safety practices for HW and implement FM Global Property Loss Prevention Data Sheets 10-3, HOT WORK MANAGEMENT.
You no longer have to be a client of FM Global’s to gain access to their Data Sheets; you just have to register with your name and e-mail and job title and you have access to their entire library for FREE!!! I can not stress this enough – READ ALL of the ones applicable to your business as they are a gold mine of best practices. Today we will focus on HW…
So how big of a problem are HW fires? From 1995 to 2014 (a 20-year period), FM Global clients experienced 736 hot work ignited fires or explosions with a total indexed gross of US $1.9 billion in property loss and business interruption, and an average gross loss of US $2.6 million per incident. THAT IS JUST FM GLOBAL CLIENT LOSSES!!!!