Hot work is any activity that generates a source of ignition. Burning, welding, cutting, brazing, soldering, grinding, use of spark-producing tools or any spark-producing industry process (in foundries, steel mills, oil and gas, commercial kitchens, etc.) are examples that generate sources of ignition. Hazards that could result include but are not limited to fires, harmful light, noxious gases, toxic fumes or high heat. An additional explosion hazard may exist when flammable or combustible gases, liquids or solids are present.
According to National Fire Protection Association (NFPA) 51B Standard for Fire Prevention During Welding, Cutting and Other Hot Work, hot work can be conducted in either fixed designated or mobile permit required areas. Organizations must determine if they need to perform hot work and if so where the work will be performed. Effective controls to eliminate or reduce exposure to the known hazards of hot work must be in place in both fixed designated and mobile permit required areas.
Hot Work Statistics
Every year, fire resulting from hot work ranks among the leading causes of property loss. A report issued in June of 2021 from NFPA titled “Structure Fires Caused by Hot Work” found that organizations need to eliminate or control fire hazards posed by hot work to ensure employees are not injured or killed, and that property is not damaged or destroyed.
This same report revealed valuable insights for both home and non-home fires:
- US fire departments responded to an average of 4,580 structure fires caused by hot work per year from 2014–2018
- Of the 4,580 hot work-related fires, 43% (1,980) occurred in or around residential homes, and 57% (2,600) occurred in or around non-residential properties
- Further insight on non-residential property fires showed:
- Leading areas of origin for the fire: roofs (12%), processing/manufacturing areas/workrooms (11%), maintenance/paint shop areas (8%), garage/vehicle storage areas (5%) and other (5%)
- Items first ignited: flammable or combustible liquids (17%), exterior roof coverings (10%), insulation within structural areas (9%), structural members or framing (8%), dust/fiber/sawdust (5%) and other (5%)
- Contributing factors to ignition: cutting/welding too close to combustibles (40%), heat source too close to combustibles (40%), mechanical failure (8%), electrical failure (7%) and equipment not operated properly (4%)
OSHA regulates hot work activities in general industry under their Welding, Cutting, and Brazing standard found in 29 CFR 1910 Subpart Q and 29 CFR 1910.252(a)(1) fire prevention and protection, which states that the basic precautions introduced in NFPA 51B must be followed.
The purpose of NFPA Standard 51B is to provide minimum requirements for all persons who manage, request, authorize, perform or supervise hot work. It covers provisions to prevent injury, loss of life and loss of property from fire or explosions as a result of hot work.
Hot Work Controls
Learning how to safely conduct and manage hot work is essential to reducing the risk of potential fires. All hot work controls start with a hot work program which focuses on three objectives:
- Recognizing and determining if fire risks exist before hot work is started
- Evaluating and determining if hazards are present
- Controlling and preventing hot work ignition sources from coming into contact with flammable and combustible material
According to Factory Mutual (FM) Global “Pocket Guide to Hot Work Loss Prevention”, sixth edition a hot work program is generally comprised of four elements:
- Implementing a management system
- Training employees and contractors
- Establishing a hot work permitting system
- Preparing the hot work area
The first step in implementing a hot work management system is creating a hot work policy and getting executive and senior level management to endorse the policy. The policy must ensure that all hot work tasks being done in the facility are supervised. According to FM Global “Pocket Guide to Hot Work Loss Prevention”, sixth edition, all hot work fires and explosions are directly linked to lack of supervision.
The hot work policy should include specific responsibilities, accountability and consequences for failure to follow procedures. The policy should include work procedures that begin with consideration of cold work and relocation to fixed designated areas first then hot work permitting as last resort. The policy should also generally provide details on:
- Location(s) of work permit areas
- Permit authorizing
- Permit expiration
- Contractor supervision expectations
- Training requirements
- Incident and near miss reporting
- Document retention and auditing
Finally, all employees should be aware the hot work policy exists, is audited at least annually and is available to anyone affected by hot work in the facility.
Train Employees and Contractors
All employees involved in hot work activities should receive initial training and refresher training at least annually. According to FM Global “Pocket Guide to Hot Work Loss Prevention”, sixth edition , training should be comprised of both general hot work management topics and facility-specific elements such as:
- Hot work permitting areas
- Permit authorizing process
- Permit expiration and reauthorization process
- Contractor supervision expectations
- Maintaining records of all employee and contractor training
All contracts with contractors should be reviewed. Part of the review should include hot work program requirements detailed in the hot work policy.
Hot Work Permitting System
Hot work permits are critical to helping plan, perform, control, and monitor any mobile hot work operation involving open flames or production of heat and/or sparks that can serve as an ignition source for flammable and combustible material in the area.
The hot work permit tagging system is based on the FM hot work permit system F2630: