Hot Work and Fire Prevention

Jody Jackson, CSP

Director HSE
Montrose Environmental
Irvine, Ca

1
Fire Prevention - Hot Work

2
 Agenda

 Regulatory background
 Importance of fire prevention during hot work
operations
 Your Experiences
 OSHA’s welding, cutting, and brazing
standard

3
 Regulatory Background

 OSHA’s Welding, Cutting, & Brazing

1910.252
 NFPA 51B-1962 (Welding/Cutting)(INC-
BR)
 OSHA PSM 29 CFR 1910.119
 Various Other OSHA references within
standards

4
Importance of Fire Prevention
During Hot Work Operations
Hot Work is any work involving burning,
welding, or similar operations that are capable of
initiating fires or explosions. Such as:
 Welding Processes
 Heat Treating
 Grinding
 Thawing Pipe
 Powder-Driven Fasteners
 Hot Riveting
 Similar Applications Producing a Spark, Flame or
Heat
5
 Importance of Fire Prevention
During Hot Work Operations
March 23, 2005:
An explosion occurred at a BP Refinery in Texas City, Texas.
Over 100 were injured, and 15 were confirmed dead, including
employees of the Jacobs Corporation as well as BP.

BP has since accepted that its employees contributed to the

accident. Several level indicators failed, leading to overfilling
of a knock out drum, and light hydrocarbons concentrated at
ground level throughout the area. A nearby running diesel truck
set off the explosion.

What does this have to do with biogas? Everything!

6
 Importance of Fire Prevention
During Hot Work Operations
 Philippines, gas incident 4 deaths .
 UK, gas incident 1 death & 11 Serious
Injuries (including serious burns from
explosions and near fatal gas-related
injuries) .
 13 other noted Injuries (including 11
firemen – mainly gas related)

7
Your HW Experiences?

Discussion

8
 DEFINITIONS
FIRE WATCH

 An individual who is trained in the proper use of fire

extinguishers and is familiar with the fire alarm system
and/or emergency notification procedures. The fire watch
must be present during work, breaks, and at least 30
minutes after the work has ended to guard against fire.

FUEL GAS

 Anything flammable or combustible.

9
Fire Watching

10
 DEFINITIONS

HOT WORK

 Work performed with heat-producing equipment, such as

heat guns, soldering tools, welding tools, electric arc
cutting equipment, oxygen-fuel gas cylinders, etc.

HOT WORK PERMIT

 A form that is often completed to document
responsibilities and precautions during hot work, where
combustible materials are/may be present.

11
Example – Hot Work Permit

12
OSHA’s and NFPA’s Welding,
Cutting and Brazing Standards
 Required basic precautions including:
 responsibility for hot work;
 protection of personnel;
 removing, guarding, or shielding combustibles;
 trained and equipped fire watch/es;
 designated welding areas;
 authorized written hot work permits and;
 training and communication.
13
 General Procedures for Hot Work
1. PLAN YOUR WORK!!!!!
2. Assign a fire watch.
3. Complete a hot work permit.
4. Make sure at least one portable fire extinguisher with an A-
B-C rating is in place no more than 25 feet from the work
area. Minimum of 20 lbs.
5. Inspect the area and all tools and equipment, including
personal protective equipment (PPE).
6. Combustible materials must be located a minimum distance
of 35 feet beneath or horizontally away from the
cutting/welding area. When work or combustible materials
cannot be relocated, the material must be protected from
possible sparks by fire-resistant shields or noncombustible
covers.
14
 General Procedures for Hot Work
7. LEL (Lower Explosive Limit) must be zero (0).
8. Hot Work cannot be performed on containers, vessels,
production equipment, tanks of anything that contain or that
previously contained flammable fluids, gases, or solids unless
these areas/equipment have been thoroughly cleaned, inverted,
purged and tested for Zero (0) LEL. (Hot-Tap Exception).
9. Goggles, or other suitable eye protection, are required at all
times while performing hot work. Other PPE, such as gloves,
face shields, helmets, foot protection, and clothing will be worn
as required, depending on the task.

15
11/19/22
 General Procedures for Hot Work
10. When oxy-acetylene welding and cutting is to be performed, all
equipment, connections, cylinders, and hoses shall be inspected
prior to use.
11. One must make sure hands/gloves are free of oil or grease
(hydrocarbons) prior to handling oxygen cylinders and
apparatus.
12. All compressed gas cylinders must legibly identify the gas
content. Cylinders that have missing or illegible labels must be
returned to the supplier. Cylinders must have the valve
protection cap on when not in use and must be transported, used,
and stored in an upright position. When not in use, oxygen
cylinders must be stored a minimum of 20 feet away from
acetylene, propane, natural gas, or any other fuel gas. 
13. All cylinders must be stored in areas where they will be
protected from tampering or physical damage, heat in excess of
130 degrees Fahrenheit and must be chained, strapped or
otherwise secured to prevent them from being tipped over.
16
Procedures For Performing Hot Work
14. The fire watch must observe the area for a minimum of 30
minutes after work is completed to ensure that there is no
hazard of fire.
15. Upon the completion of the work and post-job fire watch,
note the time and sign the last section of the Hot Work
Permit to close out the permit.
16. While the Hot Work is being performed, the Hot Work
Permit will be kept at the work.
17. Atmospheric testing must be performed throughout the work
cycle.
18. After completion of the Hot Work and the Post-Work Fire
Watch, the “work completion area” of the Hot Work Permit
will be competed and reviewed by the supervisor or PIC.
19. The completed Hot Work Permit will be maintained for at
least one year and reviewed.

17
11/19/22
 Common Mistakes
 Don’t prepare equipment for hot work
properly.
 Purging
 Inadequate gas testing (too little)
 Improper gas testing (wrong place)
 Inadequate isolation
 Not knowing how to use gas instruments (how
much 02 is required?)
 Failure to identify low-points and high-points

18
 Common Mistakes
 Don’t prepare equipment for hot work
properly.
 Don’t anticipate the impact of hot work on
space or workers
 Don’t consider alloy being welding on or with
 Don’t look at the bigger picture
 Don’t cover drains
 Don’t gas test adjacent areas
 Fail to train fire watch properly

19
Flammable Measurement – Simplify It
 Don’t get hung up in the science behind what
the flammable range is in a digester. Use the
KISS method and choose a proper instrument
that reads % LEL, NOT % Methane when
measuring LEL.
 Ensure when measuring LEL that you have
sufficient O2 for your instrument.

20
 Responsibilities
 Permit Authorizing Individual
Responsibilities cont…
 determining that fire protection and extinguishing
equipment is properly located at the site;
 making sure a fire watch is available at the site
and;
 where a fire watch is not required, making a final
check 30 min. after the completion of hot work to
detect and extinguish possible smoldering fires.

21
 Responsibilities

 Fire Watch Responsibilities

 being aware of the inherent hazards of the
work site and of the hot work;
 ensure that safe conditions are maintained;
 have the authority to stop the hot work if
unsafe conditions develop;

22
 Responsibilities
 Fire Watch Responsibilities cont…
 having fire extinguishing equipment, as well as
attending required training;
 sounding and being familiar with alarm procedures
in the facilities in the case of an uncontrolled fire
and;
 watching for fires in all exposed areas, during hot
work operations and for at least 30 min. after
completion, and trying to extinguish them only when
they are within the scope of their training and
equipment.

23
 Responsibilities

 Supervisor Responsibilities
 Plan the work, communicate the plan;
 ensuring all employees who perform hot work
are trained on the Hot Work Program and it’s
requirements;
 safe handling and use of equipment, as well as
determining any combustible or hazardous
areas that are present in the work area;

24
 Responsibilities

 Supervisor Responsibilities cont…

 protecting combustibles from ignition by
having the work moved to a location free from
combustibles, moving combustibles to a safe
distance, or properly shielding against ignition;
 seeing that Hot Work is not scheduled to be
performed during operations that might expose
combustibles to ignition;

25
 Responsibilities

 Supervisor Responsibilities cont…

 obtaining a hot work permit from the PAI and
determining that the hot work operator secures
his approval that conditions are safe before
performing any hot work;
 ensuring that fire protection and extinguishing
equipment are properly located at the site and
employees are trained in its use;
 making a fire watch available if needed;

26
 Responsibilities

 Employee (Persons Performing Hot Work)

Responsibilities
 completely adhering to the requirements of this
program and attending required training;
 understanding the emergency procedures in the
event of a fire and shall have an awareness of the
inherent risks involved;

27
 Responsibilities

 Employee (Employee Performing Hot Work)

Responsibilities cont…
 having the PAI's and supervisor's approval before
starting the hot work operations;
 stopping hot work operations and notifying
management if an unsafe condition is identified;
 Returning completed hot work permits to issuer.

28
 Welding Areas
 Designated areas
 a designated fire resistant area or areas made
of noncombustible construction.
 Permit required areas
 an area that requires a written hot work permit
and shall be made safe by removing or
protecting combustibles from ignition sources.

29
 Welding Areas

 Non-permissible welding areas

 areas not authorized by management;
 sprinklered buildings while such protection is
impaired;
 in the presence of an explosive atmosphere,
including improperly prepared drums that
once contained flammable materials and;
 areas near storage of large quantities of
exposed, readily ignitable materials.

30
 Other Precautions

 Confined Spaces
 To prevent accidental contact, when arc
welding is to be suspended for any substantial
period of time, such as during lunch or
overnight, all electrodes shall be removed
from the holders and the holders carefully
located so that accidental contact cannot occur
and the machine be disconnected from the
power source.
31
 Other Precautions

 Confined Spaces cont…

 In order to eliminate the possibility of gas
escaping through leaks or improperly closed
valves, when gas welding or cutting, the torch
valves shall be closed and the gas supply to the
torch positively shut off at some point outside the
confined space area whenever the torch is not to
be used for a substantial period of time, such as
during lunch hour or overnight. Where practical,
the torch and hose shall also be removed from the
confined space.
32
 Other Precautions

 Confined Spaces cont…

 When welding or cutting is being performed
in any confined space, the gas cylinders and
welding machines shall be left on the outside.
Before operations are started, heavy portable
equipment mounted on wheels shall be
securely blocked to prevent accidental
movement.

33
Questions?

34