One of the debates we routinely have with fellow process safety professionals is the adoption of NFPA 51B vs. meeting 1910.252(a) requirements for their Hot Work safe work practice. I am a huge fan of NFPA 51B, as it is much more up-to-date than OSHA’s 1910.252, which, by the way, was based on the first edition of NFPA 51B in 1962. As I have stated many times before, PSM (nor RMP) does NOT allow for “cherry-picking” parts and pieces of codes and standards so that we can avoid certain aspects of other codes and standards that may not be “friendly” to our business. Of course, some parts of these codes/standards may not be applicable to our business/process, but when we go back and forth between codes/standards to better suit our needs, we make a huge mistake.
That said, I would like to point out a common issue we find with organizations that want to use NFPA 51B as their RAGAGEP for Hot Work Safe Work Practice. What these businesses often overlook is that NFPA 51B has incorporated NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations, since 2003.
1.3 Application.
1.3.1 This standard shall apply to the following hot work processes:
(1) Welding and allied processes
(2) Heat treating
(3) Grinding
(4) Thawing pipe
(5) Powder-driven fasteners
(6) Hot riveting
(7)*Torch-applied roofing in conjunction with the requirements of NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations
(8) Similar applications producing or using a spark, flame, or heat
NOTE: in the 1999 edition, the use of Hot Work to apply roofing materials was specifically exempted from NFPA 51B requirements. The 2003 edition is when hot work during roofing became applicable to NFPA 51B.
Now, some of you may be asking yourself, what does all this mean, and how does it impact me and my current Hot Work practices? Well, that depends on how long your Hot Work Program/Permit requires a Fire Watch to stay on watch after the hot work has ended. For most of us, we go by the 30-minute rule, which is also the minimum time period set by OSHA in their 1910.252 General Requirements standard, as well as 51B latest edition (5.5.2). But the similarities end there!
If we have adopted 51B as our HW RAGAGEP, we also are now required to comply with NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations in which we find a 2-hour fire watch requirement for “torch-applied roofing operations”.
5.1.3 Fire Watch.
5.1.3.1 Fire watches shall be assigned no other duties.
5.1.3.2 A fire watch shall be posted for the duration of the work and for 2 hours thereafter for torch-applied roofing operations (see 9.3.9).
…
9.3.9* Fire Watch. A fire watch shall be conducted for at least 2 hours after torches have been extinguished.
This change came about in the 2009 edition of NFPA 241. So, as a facility using NFPA 51B as the adopted Hot Work RAGAGEP (vs. using 1910.252(a), it would have to have some means in their program and on their hot work permit so that when the hot work involves “torch-applied roofing operations” the Fire Watch requirement is 2-hrs and not the normal 30-minutes as required by both 51B and .252(a)(2)(iii)(B). For the record, there are a lot of insurance providers already requiring extended fire watch periods so meeting this 2-hr requirement may not be a major issue for some; but for most, the 30-minute period is the standard, and making the move to 2-hrs can be significant, even when it ONLY applies to “torch-applied roofing operations”.