THE COHEN GROUP
  Environmental Health & Safety Consulting Services

The Cohen Group Newsletter - Volume 7  Issue 1, Article 5.  January, 2005

Hot Work Permits
By Joel Cohen, CIH

 A change to Cal/OSHA’s Petroleum Safety Orders became effective in December. The new regulation, which can be found in Title 8 CCR §6777 is essentially a re-write and re-ordering of the existing requirements for issuance of a hot work permit before an ignition source (e.g., welding, cutting torch, etc.) is used, however, some additions have been made. The change was initiated as a result of a Cal/OSHA Appeals Board, Decision After Reconsideration (94-R3D5-2087) where it was suggested the language be revised to clarify safety precautions an employer must take before introducing an ignition source. As in the older version of the regulation, fixed-fired equipment; hot work required for operating purposes in laboratories and pilot plants; hot work within designated or posted areas; and hot work in locations outside of the plants where it would be safe to smoke are exempt from the new requirement.

Except under limited conditions, a written and dated hot work permit is to be completed, signed and issued by the employer or his authorized agent before a source of ignition can be used. The amended regulation now requires as part of the hot work permit issuance procedure, the employer to verify that all of the required preliminary safety and testing procedures are followed before issuing a permit. There is a new requirement that prohibits a source of ignition from being used where concentration of flammable gases or vapors exceeds 20% LEL.

Upon completion of all preliminary approvals, the permit is to be provided to the affected employee or posted in the work area and a copy of the permit is to be kept on site until the work is completed. As in the older version, the amended regulation is specific as to the items that must be included on the hot work permit.