2.9 Nonroutine Work Authorizations (Hot Work Permits)
29 CFR 1910.119 (k)
The employer shall issue a hot work permit for hot work operations conducted on or near a covered process.
The permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252(d) have
been implemented prior to beginning the hot work operations; it shall indicate the date(s) authorized for hot
work; and identify the object on which hot work is to be performed. The permit shall be kept on file until
completion of the hot work operations.
(See also 29 CFR 1910.119 (f) 4, Safe Work Practices)
Work authorizations are required to ensure that appropriate safety measures are taken any time
nonroutine operations are performed on or near covered processes. The intent of this
authorization system is to require DOE contractors to control, in a consistent manner, nonroutine
work conducted in covered process areas that might initiate or promote a release. Routine work
is covered by approved operating procedures and training.
One of the most important nonroutine work authorizations is the hot work permit. Hot work
permits address welding, cutting, and other spark-producing operations. Under the requirements
of the PSM Rule, contractors are required to issue hot work permits for hot work operations
conducted on or near a covered process [Q82]. Hot work permits must document compliance
with the fire prevention and protection requirements contained in 29 CFR 1910.252(d).
If a DOE contractor has a covered process, a hot work permit must be issued whenever a
welding or cutting operation is performed in a location away from a safe area designated by
management for routine welding and cutting operations.
Corresponding DOE Programs and Requirements
DOE O 412.1, WORK AUTHORIZATION SYSTEM, DOE O 430.1B, REAL PROPERTY
ASSET MANAGEMENT, and DOE O 420.1A, FACILITY SAFETY, require a work control
system for maintenance and operations in DOE facilities. DOE contractors must review their
work request systems to verify that adequate safety review is provided for nonroutine operations
in covered process units.
Nonroutine work authorizations important to safety include hot work permits, radiation work
permits, and confined space entry permits. Typical authorizations address procedures, special
administrative and engineering controls, and monitoring and surveillance requirements. Safe
work practices provide a generic approach for conducting many nonroutine activities and are
typically found in safety-related manuals.
Hot work permits are normally included in fire prevention and protection programs at DOE
facilities. They are required by 29 CFR 1910.252(d), which is an OSHA standard prescribed for
DOE compliance under DOE Order 440.1A. This element of the Rule is not expected to require
any change to hot work permit authorizations at DOE sites.