The requirement to issue a hot work permit, including documentation of necessary fire protection and prevention measures, is currently in the RMP regulation only for Program 3 processes. Under 40 CFR 68.85(b), “The permit shall be kept on file until completion of the hot work operations.”
Under the existing RMP regulations, it can be difficult for implementing agencies to determine if the facility has been conducting hot work in compliance with the requirements of 40 CFR 68.85, unless the facility is conducting hot work at the time of the inspection and has hot work permits on file. Adding a requirement to retain hot work permits after the completion of operations would address this issue.
Therefore, EPA is proposing to require the retention of hot work permits for…