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)…