Nonroutine Work Authorizations (Hot Work Permits)

DOE-HDBK-1101-96

2.9 Nonroutine Work Authorizations (Hot Work Permits)

29 CFR 1910.119 (k)

(1)

The employer shall issue a hot work permit for hot work operations conducted on or near a covered process.

(2)

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)

Intent

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 ap-

proved 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 5700.7C, WORK AUTHORIZATION SYSTEM, DOE O 440.1, LIFE-CYCLE ASSET

MANAGEMENT and DOE O 420.1, 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 5480.4. This element of the Rule is not expected to require any

change to hot work permit authorizations at DOE sites.