How does your facility manage this? These days most facilities use written Hot Work Permits, either because of regulatory requirements or they are required by their insurance company. And most facilities also assign a fire watch for each permit. But this is where the similarities end and how the fire watch personnel are managed is the common flaw in the execution of a safe hotwork job. In this post I will cover the OSHA requirements and the errors made in fire watch assignments.
OSHA requires fire watches to
have fire extinguishing equipment readily available and be trained in its use. They shall be familiar with facilities for sounding an alarm in the event of a fire. They shall watch for fires in all exposed areas, try to extinguish them only when obviously within the capacity of the equipment available, or otherwise sound the alarm. A fire watch shall be maintained for at least a half hour after completion of welding or cutting operations to detect and extinguish possible smoldering fires.
Let’s break down these requirements and examine potential issues:
Fire watchers shall have fire extinguishing equipment readily available and be trained in its use.
Do your hot work permits require a MINIMUM SIZE fire extinguisher be available? How about the type of fire extinguisher? Do the personnel who authorize hot work permits inspect the fire extinguisher the fire watch will be using to see if it has met the fire extinguisher monthly and annual inspection/maintenance requirements? All of these questions regarding the fire extinguisher are critical and should have been answered YES. It is not uncommon to find a 5-pound fire extinguisher being used on large hotwork jobs, and sadly enough many times these extinguishers have not been inspected within the past 30 days or had their annual maintenance completed. We even, from time to time, find extinguishers that are dead/empty, but they are being used none the less. And how about the fire watch training? Do we at least ask if the person who will be filling this critical role has been trained in how to use the extinguisher? Does your facility require hands-on fire extinguisher training for fire watches? How often do you require the extinguisher training for the fire watches? And PLEASE do not forget your contractors! These same questions would apply to ANYONE filling the role of a fire watch. It is my experience that many contractors assign the critical role of fire watch to the less experienced, youngest, and lowest paid worker on the job. I have even found teenagers of the job foreman working the summer with Dad be assigned the fire watch!!! Needless to say the young man had not been trained in the requirements of being a fire watch.
They shall be familiar with facilities for sounding an alarm in the event of a fire.
This means that the fire watch has to be trained in at least the Emergency Action Plan for the facility and even if the facility does not have an EAP, they have to be trained in how to sound the facility fire alarm. If the facility has pull stations, then the nearest pull station needs to be pointed out during the permitting process. If the facility uses an intercom system, the fire watch should be instructed how to access the intercom (e.g. what special sequence of numbers he/she has to dial to make an announcement), as well as the permit authorizer should verify that the nearest phone is actually working. If the facility has an emergency phone number, I always liked to have it printed on the bottom of the permit; Global FM’s permit has a spot for a phone number on the back of the field copy of their permit. Lastly, if your facility issues “air horns” for the fire watch to sound an alarm, just be sure that your cans are NOT EXPIRED. The bottom of the Coast Guard Approved cans will have the expiration date.
They shall watch for fires in all exposed areas, try to extinguish them only when obviously within the capacity of the equipment available, or otherwise sound the alarm.
“In all exposed areas” is a wide-open statement, so let’s break it down a little bit. We should be preparing a fire-safe area that extends 35′ in all directions from the point(s) of hotwork. Within this fire safe area we should close all openings with some form of fireproofing material to ensure that all sparks stay within our 35′ fire safe work area. If we can not do this for any reason then we MAY NEED TO assign more than one fire watch to the job so that ALL areas (e.g. all levels) that sparks could get to are monitored by a trained fire watch. Notice that this requirement also contains a training element for the fire watch in that they are ONLY to “try to extinguish them only when obviously within the capacity of the equipment available”. Do your fire watches understand fire extinguisher ratings? What does it mean when a fire extinguisher has a rating of 2-A or 2-B? Do class C and D extinguishers have ratings and what does 2-A or 2-B mean; then I would argue they do not know the “capacity of their equipment” and thus would not be qualified to be a fire watch (my personal strict interpretation and standard).
A fire watch shall be maintained for at least a half-hour after completion of welding or cutting operations to detect and extinguish possible smoldering fires.
First, this 30 minute time period is often not enough for most property insurers, as many insurance companies now require 45 minutes and some even require an hour. Most insurers also require a four-hour final inspection before the permit is closed. OSHA only requires the 30 minutes, but even this minimum requirement causes many problems for businesses. Often times the personnel doing hotwork forget about this requirement during breaks and lunch. It should be made clear during the permitting process that this is a strict requirement the ENTIRE TIME the permit is active and it includes all breaks. Now I do make a slight exception after the hotwork is done and allow the fire watch to assume other duties while they remain in the area for these 30 minutes; BUT THEY MUST REMAIN in sight of the hotwork fire-safe area! During the hotwork process, the fire watch MUST BE RELIEVED of ALL OPERATIONAL duties so as to be able to focus on 100% on the job of being a fire watch.
Here are a couple of other items to consider regarding fire watch duties:
1) does your facility allow the fire watch to use fire extinguishers mounted in the area or do they have to bring a different extinguisher into the area to be their fire watch extinguisher? My position has always been that hot work increases the fire risks in the area and therefore we need to increase the level of fire protection, so a new/additional extinguisher is required. I also have serious concerns of personnel removing extinguishers from their mounted location. Should there be a need from someone else, that someone would find an empty hook once they got to the fire extinguisher location!
2) Fire Watch protection from UV hazards. Just like the welder(s), the fire watch needs to be protected from UV. How many times have you walked up on a welding job to find the welder suited up properly only to have the fire watch standing 10′ away in short sleeves and clear safety glasses? I am a big fan of the transparent welding curtains that have UV protection! This allows the fire watch to be outside the UV hazard area, yet still be able to visually monitor for sparks in the fire safe area. ALSO, do not forget to include “welding” in your Certified PPE Hazard Assessments and I like to include the fire watches in this as well.
3) If your fire watch is going to use a fire hose as their extinguishing agent, their training should include the use of a fire hose and nozzle. Fire hose training is considerably different than fire extinguisher training, so PLEASE do not think one training fits all!!