Please note this citation was issued as a General Duty Clause (GDC) citation by a State OSHA Plan and the incident was not a PSM/RMP incident (at least OSHA did not cite .119). The practice at issue is one that is done routinely in just about all companies and on just about every type of chemical process and utility. This is the first time I have seen it “cited” in an OSHA citation, but this incident caused a hospitalization from hydrochloric acid (HCL) burns. ASME has officially defined “hot bolting” and “half bolting” but the document in which they are defined is not a “code” so many do not recognize these official definitions. But the ASME PCC document is clearly a RARAGEP (as stated by ASME) and thus we should consider these as “official definitions” and meet the RAGAGEP. A typical definition found in many maintenance programs will go something like this:
Hot Bolting is the practice of removing and replacing or freeing and re-tightening bolts on LIVE OPERATING piping and equipment while the system is pressurized.
SAFTENG members should refer to my 2012 article on this matter (ASME and Hot Bolting and Half Bolting Procedures).