Hot work: A permit is only a piece of paper
Take extra precautions when fire risk is involved
Workers who perform hot work can quickly become complacent. They don’t realize that simply “pencil whipping” the permit without making the area safe for hot work can place them and their coworkers at risk. It’s human nature that the more frequently you perform a task the more comfortable you become with it. Before you know it, you let your guard down, skip steps, or decide you needn’t worry about safety because it will just take a minute — and then the unthinkable happens. Even the best hot work program can’t prevent a fire or explosion if it isn’t used, steps are missed, or hazards are ignored.
What is hot work?
Hot work is any process that can be a source of ignition when flammable or combustible material is near. Anytime employees work with equipment that produces a spark or open flame, or a process that generates excessive heat, there is a risk of fire.
Hot work is either done in a designated fire safe area or a permit-required area. A designated fire safe area is a location an employer assesses and maintains to conduct hot work without the need for special precautions or a hot work permit. A permit-required area is a temporary area the employer has made fire safe or assigned a fire watch to watch for and prevent fires.
When these tasks are done outside of a fire safe area, an employer is required to evaluate the potential risk. A hot work permit is used to complete the evaluation.
Before hot work starts, the employer must determine four things:
- Is hot work prohibited in the area?
- Is the area safe to do hot work?
- Can the task be moved to a fire safe area?
- Can the area be made fire safe?
An employee is assigned the task of answering the above questions. Employers pick an employee that has the knowledge and training to identify hazards and take steps to eliminate the hazards or safeguard the area. This employee is often called a fire safety supervisor (FSS) or a permit-authorizing individual (PAI).
The PAI inspects the permit-required area and ensures:
- All combustibles and flammables are moved a minimum of 35 feet away from work.
- Extremely hazardous combustibles and flammables moved 35 feet away or protected should still have a fire watch.
- Combustibles and flammables that cannot be moved must be protected by shields, blankets, etc.
- If combustibles and flammables cannot be moved and protection is not effective, a fire watch is required.
- Other employees or passersby are protected from physical and visual (UV exposure) hazards.
- Floor and wall gaps are covered and ventilation and conveyor systems are shut down.
The PAI must also consider floor and wall construction and understand the special precautions required for wood or grated floors, metal walls, etc.
A well-designed hot work permit helps the PAI inspect the area and identify hazards. Using a written permit reminds the PAI of what to look for, what precautions to take, if a fire watch is needed, and can provide proof the area is safe to do hot work.
Permits help the PAI identify if a fire watch is needed, how many are required, and where they should be located.
Employees sometimes complain that the fire watch work is boring. The fire watch is there for only two reasons: to see if anything starts on fire; and if it does, put the fire out or sound the alarm. Once hot work begins, it is the most important job in the facility.
A fire watch failing to see a fire, not knowing how to use a fire extinguisher, how to fight an incipient fire, or when to activate a fire alarm, can injure or kill employees and destroy a business.
Training is less about the permit and more about employees’ ability to recognize the risks of doing hot work. A permit is just a piece of paper.
One question employers often ask is what training do employees need for hot work permits? Training can be broken into three parts: the operator; the PAI/FSS; and the fire watch.
The operator must know how to set up and operate the equipment or process that the hot work permit covers. The training information is obtained in the manufacturer’s operating manual, classroom instruction, and hands-on training. OSHA leaves it up to the employer to determine the most effective way to train the operator to do hot work safely.
The PAI/FSS must be trained on a wide range of information. Each workplace faces unique hazards and this is the information the PAI/FSS must understand, be able to identify, and know how to protect against. One-size-fits-all PAI/FSS training is not appropriate. Along with the hazards to look for, the PAI/FSS must know when a fire watch is required; how many are needed; and what locations they should watch.
Although it is very important, the person responsible for a fire watch should know more than just how to use a fire extinguisher or extinguishing medium. They should also know the hazards, what is prohibited, and how to protect the area. A fire watch must remain vigilant and understand why they must watch the assigned area for at least 30 minutes after work concludes.
Not understanding the sometimes-deadly effects of doing hot work in a hazardous, unprepared, or prohibited area puts employees and their coworkers at risk. No matter how well developed, if a permit is pencil whipped, ignored, or misunderstood it cannot protect employees or a company.