In “general industry” workplaces OSHA has a “General Requirements” standard for conducting Welding, Cutting, and Brazing activities (1910.252). For those working within the battery limits of a PSM/RMP covered process, both OSHA (1910.119(k)(2) and EPA (68.85(b) reference 1910.252(a) as the basics of safely conducting these HW activities. But there is one (1) requirement that we almost always see missing from every aspect of a facilities HW program, permitting, and even training, and that is…