For those of you at PSM/RMP covered facilities, this OSHA standard is a baseline requirement; however, this OSHA standard does NOT require a Hotwork permit. It merely “prefers” the authorization be “in the form of a written permit”. It was not until OSHA’s Process Safety Standard (and EPA’s RMP) that OSHA/EPA actually REQUIRE a hotwork permit be issued when hotwork operations are “conducted on or near a covered process”. I like to use the PSM phrase “on, in, or adjacent to a covered process” when I define the locations where a permit is required. But I digress, I want to lay out 1910.252(a) as this is the standard that both PSM and RMP reference as the BASELINE requirements for Hotwork (HW) and we continue to see misunderstandings of how this standard MUST BE IMPLEMENTED at PSM/RMP covered facilities.