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Safety Management

Hot Work Safety

8/26/21
Quick Tips #404

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%)

Regulations

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

Management System

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:

Part 1 (above left): Establishes the hot work plan prior to start of work. This should be posted in a central, visible location within the facility to alert personnel in the area an active hot work permit is in use.

Part 2 (above right): Tracks the details of each job. This includes the exact location the hot work task is taking place, work to be done, each step during work and post-work, approval signature, date and time permit is authorized for and emergency contacts. This should be hung in the hot work area and used as a reference for the fire watch to record completed actions from the hot work plan and act as a warning.

The one issuing the permit (typically the host employer) owns the permitting process, including ensuring the hot work plan is appropriate for the hazards present and the required precautions are in place prior to starting work.

Preparing the Hot Work Area

FM Global Property Loss Data Sheet 10-3 Hot Work Management provides details on fixed designated areas (Section 2.4) and mobile permit-required areas (Section 2.5) These details should be provided in writing in the hot work program.

Section 2.4 outlines specifics for fixed designated area locations, construction, occupancy, protection, operation and maintenance. Section 2.5 addresses mobile hot work permit authorization and general required precautions and required precautions before, during and after hot work, as outlined in the table below.

 

 

Pre-Work During Work Post-Work
Define the area Designate fire watch schedule to cover entire length of hot work Determine the appropriate fire-watch and monitoring period to ensure no fire can start due to hot spots
Remove combustible and flammables Ensure ignition sources remain in defined area After fire watch continue to monitor for up to five hours depending on activity performed
Remove combustible accumulations Maintain required precautions on permit  
Test area for presence of flammable vapors Notify emergency contacts if necessary  
Shut down ventilation equipment to prevent travel of ignition sources Stop all work if unsafe conditions are identified  
Identify interconnect equipment and piping that contain flammables    
Drain or purge all equipment of flammable material    
Ensure fire protection equipment is present    

Frequently Asked Questions

Q: What is considered hot work?

A: 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 (foundries, steel mills, oil and gas, commercial kitchens, etc.) are examples that generate sources of ignition.

Q: What is the difference between a fixed designated area and mobile permit-required area?

A: A fixed designated area is a specific location designed and approved for hot work operations that is maintained fire-safe, is of noncombustible or fire-resistive construction, essentially free of combustible and flammable contents, and segregated from adjacent areas. Hot work permits are not required in fixed designated areas. Hot work that cannot be done in a fixed designated area is done in a mobile permit-required area. A permitting program ensures the area is made fire-safe by removing or protecting combustibles and flammables from igniting.

The information contained in this article is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This article is not a substitute for review of current applicable government regulations, industry standards, or other standards specific to your business and/or activities and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.

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