OSHA (State Plan) issues GDC citation regarding “Hot Bolting”

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). 

Imagine this scenario, during normal rounds an operator notices a flange leaking, “just a drip” – but it is leaking.  They attempt to tighten the bolts on the flange to stop the “drip”.  Sound familiar?  That operator just performed “hot bolting”.  Happens like clockwork in most facilities.  But on this occasion, what the operator does not know is that while he was on vacation basking on a sandy beach the week prior, that flange had been tightened over a dozen other times for the same “drip”.  The business did not recognize “hot bolting” work as a hazardous task so there was no permitting, no PPE Hazard Assessment, and more importantly no communications regarding this “dripping flange”.  Can you see what is being set up?  We have talked many times about “torque values” on pipe flange joinments: too much and not enough!  In this scenario, we are going to see “too much”…

NOTE: please recognize that the material in the pipe does not need to be an HHC/EHS.  I had an LTA in my career when this practice was being performed on a steam utility line to a heat exchanger and the work we being done from an extension ladder.

NOTE2: the employer is contesting this GDC citation, as I am sure they are still in the belief that this is an “industry practice” and having to “permit” this work like “line opening” would be too cumbersome.  

At 10:04 a.m. on November 13, 2020, Employee #1, employed by an industrial building construction company, was working at a multi-employer project, a chemical production plant. He was hot bolting a connection in an area of the plant where hydrochloric acid was being generated. A release of hydrochloric acid from a graphite nozzle connected to a heat exchanger occurred, and the employee sustained chemical burns. Employee #1 was transported to the hospital and admitted for treatment of hydrochloric acid burns to his right side underarm, buttocks, and leg.