The Hot Work Permit element of both OSHA’s PSM standard and EPA’s Risk Management Plan is one of the shortest elements’ of the 14 elements. Its presence is to require a written permit to be issued when performing Hot Work in/on/adjacent to a covered process. Some may not fully understand the need for this element, but if we go back and look at 1910.252(a), it uses the following wording…
(emphasis by me)
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1910.252(a)(2)(iv) Authorization Before cutting or welding is permitted, the area shall be inspected by the individual responsible for authorizing cutting and welding operations. He shall designate precautions to be followed in granting authorization to proceed PREFERABLY IN THE FORM OF A WRITTEN PERMIT. |
That is correct; OSHA NEVER required a HW permit until the PSM standard was promulgated in 1992. Most facilities utilized a written permit because of their property conservation insurers’ demands. When the PSM standard came about, OSHA simply included an element titled 1910.119(k) Hot Work Permit
This element has ONLY two (2) requirements: