FIRE PROTECTION: Implement a Hot Work Permit Program
Certain kinds of work are more likely to cause a fire than other jobs. For example, so-called “hot work” is any work that produces or uses flames, arcs, sparks, heat, friction or other sources of heat or ignition, such as welding, cutting, riveting or grinding. When hot work is done in the presence of flammable or combustible materials or gas, a fire or explosion can result. For example, workers in Manitoba were welding from an above position when sparks fell onto an air handling unit. The unit’s filters and a tarp caught fire. Luckily, the workers were able to extinguish the fire.
One way to manage the risks associated with hot work and to adequately protect workers doing such work is through a hot work permit program. A hot work permit identifies the work to be done, the hazards involved in that work and the safety precautions to be taken. Here’s a look at the law on hot work permits and the key elements of these safety documents.
Defining Our Terms
In response to several incidents involving hot work around or in tanks, the US Chemical Safety Board issued a hazard alert containing these seven safety tips:
1. Use alternatives. Whenever possible, avoid hot work and consider alternative methods.
2. Analyze the hazards. Before the start of hot work, perform a hazard assessment that identifies the scope of the work, potential hazards and methods of hazard control.
3. Monitor the atmosphere. Conduct effective gas monitoring in the work area using a properly calibrated combustible gas detector before and during hot work, even in areas where a flammable atmosphere isn’t anticipated.
4. Test the area. In work areas where flammable liquids and gases are stored or handled, drain and/or purge all equipment and piping before hot work is conducted. When welding on or in the vicinity of storage tanks and other containers, properly test and, if necessary, continuously monitor all surrounding tanks or adjacent spaces—not just the tank or container being worked on—for the presence of flammables and eliminate potential sources of fires and explosions.
5. Use written permits. Ensure that qualified personnel familiar with the specific site hazards review and authorize all hot work and issue permits specifically identifying the work to be conducted and the required precautions.
6. Train thoroughly. Train personnel on hot work policies and procedures, proper use and calibration of combustible gas detectors, safety equipment and job specific hazards and controls.
7. Supervise contractors. Provide safety supervision for outside contractors conducting hot work. Inform contractors about site-specific hazards, including the presence of flammable materials.
Although there are some variations, the definitions of hot work are pretty consistent across Canada. In this article, we’ll use the term to refer to any work where a flame is used or a source of ignition, such as a spark, may be produced. In addition, this article will address hot work in general, not any special requirements for when such work is done in confined spaces or mines.
LAW ON HOT WORK PERMITS
Alberta is the only jurisdiction that specifically requires hot work permits in its OHS regulations. Sec. 169(2) of the OHS Code 2009 requires an employer to ensure that hot work isn’t begun until a hot work permit is issued that indicates, at a minimum:
- The nature of the hazard;
- The type and frequency of atmospheric testing required;
- The safe work procedures and precautionary measures to be taken; and
- The PPE required.
However, several jurisdictions, such as BC, MB, NB, NL and NS, adopt CSA W117.2, Safety in Welding, Cutting and Allied Processes, which notes that to ensure that appropriate safety precautions have been taken, a hot work permit system may be used as an assessment and prevention tool. (You can view the standard for free at ohsviewaccess.csa.ca.) The standard explains that a hot work permit program should be tailored to the specific hazards of the job site and recommends that the permit, which should be given before welding or cutting starts, include the following information:
- Person performing the job (worker or contractor);
- Nature of the job;
- Date of the job and job number, if applicable;
- Location of the work;
- Name of the person performing the hot work;
- Date and time of permit expiration;
- Person responsible for authorizing the work; and
- A precautions checklist.
In addition, all jurisdictions require employers to implement appropriate safety measures and have safe work procedures for hot work. For example, Sec. 363(1)(b) of Saskatchewan’s OHS Regulations say that where a flammable substance is or is intended to be handled, used,
stored, produced or disposed of at a place of employment, an employer must develop written procedures to ensure the health and safety of workers who perform hot work where there’s a risk of fire. And a hot work permit program can be used to ensure compliance with such procedures.
Lastly, because a hot work permit program ensures that all hazards and precautions have been considered before such work begins, such a program can help you exercise due diligence as to the hot work requirements. And the permits themselves are documentary proof that you took all reasonable steps to protect workers and ensure compliance with the OHS laws.
Bottom line: Even where a hot work permit program isn’t required, implementing one is an effective way to ensure compliance with the hot work requirements in your jurisdiction and with your safe work procedures for such work. And courts may very well consider it to be a best practice.
3 KEY ELEMENTS OF A HOT WORK PERMIT
Your hot work permit program should explain when permits are required, the procedures for issuing a permit, what’s to be done with the permits and training on the program. For example, the permits should always be available at the workplace or worksite. And the program should permit hot work permits to be issued only by a “competent person” who’s completely familiar with the work or situation covered by the permit and who has control over changes in that work area, such as a supervisor. (For more information on who qualifies as a “competent person,” see “Compliance 101: What Makes a Worker a ‘Competent Person’ under OHS Laws?” Sept. 2008, p. 11.).
Example: At a chemical facility in Buffalo, NY, a contract welder and foreman were repairing a support on top of an atmospheric storage tank containing flammable vinyl fluoride, which exploded. The welder died instantly from blunt force trauma; the foreman received first-degree burns and minor injuries. The US Chemical Safety Board’s investigation of the incident concluded that the facility’s employee who signed the hot work permit had no knowledge of the process to which the tank was connected or its associated hazards.
General Safe Work Permit Checklist
A permit system can be used for other kinds of especially hazardous work. For example, some jurisdictions specifically require the use of confined space permits. In general, a safe work permit should include the following information:
- Name of worker
- Location of the work
- The specific work to be done
- Date and time the work is to start and end
- Hazards involved in the work
- Any preparatory actions required, such as atmospheric testing, locking out equipment, etc.
- Safe work procedures
- PPE required
- Emergency procedures
- Emergency equipment needed
- Telephone number to call for help and where the nearest phone’s located
- Signature of person issuing the permit
- Signature of worker to indicate that he understands the hazards involved and know the precautions to be taken
- Date and time the permit is issued
A hot work permit has three key elements or sections:
General information about the work. The permit should contain basic information about the work, including:
- The location of the work;
- The nature of the work to be done, such as welding, grinding, etc.;
- Who’s doing the work, whether an employee or contractor; and
- When the permit was issued and when it expires.
Assessment of the hazards. As with all work, to adequately protect workers, you must assess the hazards associated with the hot work. For example, you need to determine whether there are flammable or combustible materials or gases in or near the location where the hot work will be done. An inspection of the location will identify many hazards, such as pieces of cloth or wood that could ignite. But you may not be able to detect some hazards with just your eyes—or nose.
Example: A worker in BC was welding the transom on an aluminum boat, not realizing that there was flammable gasoline vapour under the deck. The vapour exploded, throwing the worker about three metres and injuring him. The boat’s deck hit the ceiling. A WorkSafeBC investigation concluded that the employer inadequately assessed the potential for flammable vapour ignition and explosion. Instead of using instruments to test for the presence of flammable vapours, it inappropriately relied on the sense of smell.
So make sure that you test the atmosphere to determine whether combustible gases, dusts or vapours are present that could ignite when the hot work is done. And include the steps you took in your assessment and the results in the hot work permit.
Safety precautions to be taken. Lastly, the hot work permit should spell out all of the safety precautions to be taken both before and during the hot work. For example, if there’s combustible dust in the location, require it to be dampened, swept up or otherwise removed before the work is done. Also, indicate what PPE, if any, the worker is required to wear while performing the hot work, such as a welding helmet or appropriate eye protection.