Hot Work Safety

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The purpose of this policy is to establish minimum requirements for performing hot work during maintenance and construction activities in accordance with Occupational Safety and Health Administration (OSHA) regulations 29 CFR 1910.252, 1910.253, and 1910.254; Governer’s Executive Order 2000-292; and the NFPA 51B.


This program is designed to prevent injury and loss of property from fire or explosion as a result of hot work in all UA Little Rock spaces and activities. It covers welding, brazing, soldering, heat treating, grinding, powder-actuated tools, hot riveting, and all other similar applications producing a spark, flame, or heat. This program does not cover use of candles, laboratory activities, pyrotechnics or special effects, cooking equipment, electric soldering irons, or torch-applied roofing (See NFPA 241).

Hot work operations in confined spaces require additional safeguards and are addressed in the EHS Confined Spaces Policy. Hot work on and near building systems and piping may require additional safeguards and are addressed in EHS Lockout/Tagout Policy.

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All employees, students, volunteers, and contractors working under UA Little Rock supervision shall comply with the elements of the UA Little Rock Hot Work Safety Program. Any work involving burning, welding, torch cutting, grinding where sparks are produced, soldering, or brazing in construction, maintenance, and fabrication activities shall follow the UA Little Rock Hot Work Safety Program.

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Competent Hot Work Supervisor (CHWS). For UA Little Rock employees, the CHWS shall have successfully completed competent person training and examination to be considered competent. For outside contractors, the hot work supervisor shall be identified and the name provided to the project manager. The CHWS cannot be the hot work operator. Failure to properly adhere to UA Little Rock Hot Work Procedures shall result in suspension of competent person authority and possible disciplinary action.

Designated Area. Permanent location designed for or approved by a CHWS for hot work operations to be performed regularly.

Hot Work. Any work involving welding, brazing, soldering, heat treating, grinding, powder- actuated tools, hot riveting, and all other similar applications producing a spark, flame, or heat, or similar operations that are capable of initiating fires or explosions.

Hot Work Permit. A document issued by the CHWS for the purpose of authorizing a specified activity.

Hot Work Operator. An individual designated by UA Little Rock to perform hot work under the authorization of a CHWS.

Welding & Allied Processes. Those processes such as arc welding, oxy-fuel gas welding, open-flame soldering, brazing, thermal spraying, oxygen cutting, and arc cutting.

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Environmental Health and Safety (EHS) is responsible for:

  1. Developing, maintaining, distributing, and providing oversight in accordance with all applicable federal and state regulations and best industry practices
  2. Halting any unsafe practices not in accordance with this policy
  3. Assisting departments in developing appropriate hot work safety plans, providing technical guidance, and assisting with employee training

The Competent Hot Work Supervisor (CHWS) is responsible for:

  1. Establishing permissible areas for hot work
  2. Ensuring that only approved apparatus, such as torches, manifolds, regulators, and pressure reducing valves, are used
  3. Ensuring that all individuals involved in the hot work operations are familiar with UA Little Rock Hot Work requirements
  4. Ensuring that all individuals involved in the hot work operations are trained in the safe operation of their equipment and the safe use of the process; these individuals must have an awareness of the risks involved and understand the emergency procedures in the event of a fire.
  5. Determining site-specific flammable materials, hazardous processes, or other potential fire hazards present or likely to be present in the work location
  6. Ensuring combustibles are protected from ignition by the following means:
    1. Moving the work to a location free from combustibles
    2. If the work cannot be moved, ensuring the combustibles are moved to a safe distance, or have the combustibles properly shielded against ignition
    3. Ensuring hot work is scheduled such that operations that could expose flammables or combustibles to ignition do not occur during hot work operations
    4. If any of these conditions cannot be met, then hot work must not be performed.
  7. Determining that fire protection and extinguishing equipment are properly located and readily available
  8. Ensuring sufficient local exhaust ventilation is provided to prevent accumulation of any smoke and fume
  9. Ensuring that a fire watch is posted at the site when:
    1. Hot work is performed in a location where other than a minor fire might develop or where the following conditions exist
    2. Combustible materials in building construction or contents are closer than 35 ft to the point of hot work
    3. Combustible materials are more than 35 ft away but are easily ignited by sparks
    4. Wall or floor openings are within 35 feet and expose combustible materials in adjacent areas; this includes combustible materials concealed in walls or floors.
    5. Combustible materials are adjacent to the opposite side of partitions, walls, ceilings, or roofs and are likely to be ignited
  10. Where a fire watch is not required, the CHWS shall make a final inspection 1/2 hour after the completion of hot work operations to detect and extinguish possible smoldering fires.

The Hot Work Operator (HWO) is responsible for:

  1. Handling the equipment safely and performing work so as not to endanger lives and property
  2. Not conducting hot work without specific written authorization from the CHWS via completion of the Hot Work Permit
  3. Ceasing hot work operations if unsafe conditions develop
  4. Notifying the CHWS for reassessment of the situation in the event of suspected unsafe conditions or concerns expressed by affected persons

The Fire Watch is responsible for:

  1. Watching for fires, smoldering material, or other signs of combustion
  2. Being aware of the inherent hazards of the work site and of the hot work
  3. Ensuring that safe conditions are maintained during hot work operations and stopping the hot work operations if unsafe conditions develop
  4. Having fire-extinguishing equipment readily available and being trained in its use
  5. Extinguishing fires when the fires are obviously within the capacity of the equipment available; if the fire is beyond the capacity of the equipment, sound the alarm immediately.
  6. Being familiar with the facilities and procedures for sounding an alarm in the event of a fire
  7. A fire watch shall be maintained for at least 1/2 hour after completion of hot work operations in order to detect and extinguish smoldering fires.
  8. More than one fire watch shall be required if combustible materials that could be ignited by the hot work operation cannot be directly observed by a single fire watch (e.g. in adjacent rooms where hot work is done on a common wall).

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Operational Requirements

Hot work is allowed only in areas that are or have been made fire-safe. Hot work may only be performed in either designated areas or permit-required areas.

A designated area is a specific area designed or approved for such work, such as a maintenance shop or a detached outside location that is of noncombustible or fire-resistive construction, essentially free of combustible and flammable contents, and suitably segregated from adjacent areas.

A permit-required area is an area made fire-safe by removing or protecting combustibles from ignition sources.

Hot work is not allowed in the following:

  1. In sprinklered buildings if the fire protection system is impaired
  2. In the presence of explosive atmospheres or potentially explosive atmospheres ( e.g. on drums previously containing solvents)
  3. In explosive atmospheres that can develop in areas with an accumulation of combustible dusts (e.g. grain silos).

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Hot Work Permit

Before hot work operations begin in a non-designated location, a completed hot work permit prepared by the CHWS is required. Based on local conditions, the CHWS must determine the length of the period, not to exceed 24 hours, for which the hot work permit is valid.

The following conditions must be confirmed by the CHWS before permitting the hot work to commence:

  1. Equipment to be used (e.g. welding equipment, shields, personal protective equipment, fire extinguishers) must be in satisfactory operating condition and in good repair.
  2. The floor must be swept clean for a radius of 35 ft if combustible materials, such as paper or wood shavings, are on the floor.
  3. Combustible floors (except wood on concrete) must be:
    1. Kept wet or be covered with damp sand (note: where floors have been wet down, personnel operating arc welding or cutting equipment shall be protected from possible shock) OR
    2. Be protected by noncombustible or fire-retardant shields.
  4. All combustible materials must be moved at least 35 ft away from the hot work operation. If relocation is impractical, combustibles must be protected with fire-retardant covers, shields, or curtains. Edges of covers at the floor must be tight to prevent sparks from going under them, including where several covers overlap when protecting a large pile.
  5. Openings or cracks in walls, floors, or ducts within 35 ft of the site must be tightly covered with fire-retardant or noncombustible material to prevent the passage of sparks to adjacent areas.
  6. If hot work is done near walls, partitions, ceilings, or roofs of combustible construction, fire-retardant shields or guards must be provided to prevent ignition.
  7. If hot work is to be done on a wall, partition, ceiling,or roof, precautions shall be taken to prevent ignition of combustibles on the other side by relocating combustibles. If it is impractical to relocate combustibles, a fire watch on the opposite side from the work must be posted.
  8. Hot work must not be attempted on a partition, wall, ceiling, or roof that has a combustible covering or insulation or on walls or partitions of combustible sandwich-type panel construction.
  9. Hot work that is performed on pipes or other metal that is in contact with combustible walls, partitions, ceilings, roofs, or other combustibles must not be undertaken if the work is close enough to cause ignition by conduction.
  10. Fully charged and operable fire extinguishers that are appropriate for the type of possible fire shall be available immediately at the work area. These extinguishers should be supplied by the group performing the hot work. The fire extinguishers normally located in a building are not considered to fulfill this requirement.
  11. If hot work is done in proximity to a sprinkler head, a wet rag shall be laid over the head and then removed at the conclusion of the welding or cutting operation. During hot work, special precautions shall be taken to avoid accidental operation of automatic fire detection or suppression systems (for example, special extinguishing systems or sprinklers).
  12. Nearby personnel must be suitably protected against heat, sparks, and slag.

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Work Closeout

  1. A fire watch shall be maintained for at least 30 minutes after completion of hot work operations in order to detect and extinguish smoldering fires.
  2. The CHWS shall inspect the job site 30 minutes following completion of hot work and close out the permit with the time and date of the final check.
  3. The completed hot work permit shall be retained for 6 months following completion of the project.

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