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HOT WORK / HOT TAPPING SAFETY POLICY
INTRODUCTION AND PURPOSE
This Hot Work program provides for the safety and health of employees working on or near the following hazardous tasks in potentially hazardous environments:
· Welding, cutting/burning, soldering
· Use of open flame near flammable atmospheres
· Flaming (such as in hot wrapping)
· Grinding, chipping, sand-blasting
· Breaking concrete
· Hot tapping of lines or vessels
· Use of internal combustion engines (vehicles, generators, etc)
· Use of electrical equipment (heaters, coils, tools, extension cords, motors, lights etc) that is not rated as explosion proof by the National Electrical Code.
A hazardous environment is an environment that contains or has the potential to contain:
· The presence of flammable gases, vapors, and aerosols.
· The presence of combustible and flammable liquids.
· The presence of combustible solids.
RESPONSIBILITIES
The company will provide necessary training, equipment, and resources necessary to allow safe hot work at Company operations. Protect workers from fire and explosion hazards through a permit system.
COMPANY’S RESPONSIBILITIES when another employer (contractor) performs work include:
· Informing the contractor that the work area contains potentially hazardous atmospheres and that hot work is allowed only after a hot work permit is issued.
· Ensuring that the contractor is advised of any precautions or procedures the company has implemented for personnel protection.
· Obtaining a copy of completed hot work permits issued by the contractor and retaining those permits for at least one year from date of issue.
PERMIT USER RESPONSIBILITIES
· Know the hazards that may be faced in the work area and the hot work program and other safety requirements.
· Ensure a hot work permit has been issued for the work to be done and that any deviation from the permit is immediately reported to the Company representative.
· Use non-sparking or intrinsically safe equipment as required. Conform to requirements set out in the permit.
CONTRACTOR RESPONSIBILITIES requirements for contractor issued hot work permits:
· All contractors shall be responsible for preparing their own appropriate hot work permits.
· Permits must be as stringent, where appropriate, as the Company permit.
· The contractor shall have someone who is qualified through training to prepare permits and knowledgeable of the work task specified on the permit.
· Where contractors assume the responsibility of hot work permitting, a Company Supervisor, or designee, shall prepare and sign the hot work transfer of existing worksite to contractor form (Appendix B) and discuss the conditions noted on the form with the contractor's qualified person.
· The contractor's qualified person shall evaluate the worksite and countersign the hot work transfer of existing worksite to contractor form (Appendix B) in the space provided, acknowledging acceptance of the existing worksite and the responsibilities associated with it. The contractor's qualified person shall then prepare, sign, and issue a hot work permit on the contractor's hot work permit form.
· Contractors are responsible for training their personnel in hot work procedures.
· The conditions of the contractor's permit shall be met before beginning hot work.
· Contractors performing hot work activities in conjunction with company employees (working as a mixed crew) shall work under the work permit, supervised by a company employee.
PROCEDURE FOR HOT WORK
HAZARD IDENTIFICATION -- Employees may encounter hazardous environments while performing hot work. Use of atmospheric monitoring, engineering controls, and a hot work permit can identify or control the hazardous environment. Hazardous environments are any atmospheres that contain or have the potential to contain flammable gases, vapors, and aerosols; combustible and flammable liquids; and combustible solids. Examples of areas or activities that may contain or produce hazardous atmospheres are:
· Compressor buildings
· Gas processing plants
· Bermed areas
· Wellheads
· Tanks
· Drilling operations
· Trenches or pits
· Any enclosed space.
HOT WORK PERMIT
The following procedures will be followed in areas requiring a Hot Work Permit:
Duration of Hot Work Permits
• A new Hot Work Permit shall be issued at the beginning of each day or shift (or at the beginning of the welding job) and removed at the end of the day or shift, or at the completion of the job.
• Hot Work permits shall not be transferred from one shift to another or from one person to another.
• If the hot work operations are suspended for a meal break (15 minutes or more) or there are reasons where workers are away from the worksite, the worksite and the surrounding area shall be re-inspected, flammable/toxic gas or other tests shall be taken, as required, and the test results recorded on the permit. The authorized person, or designee, shall initial the permit to verify that the re-testing was done.
Completing the Hot Work Permit Form (Appendix A)
• Evaluation. The qualified person, or designee, shall evaluate whether the work requires a hot work permit.
• Start and expiring AM/PM. The start and expiring times shall be specified in the designated spaces. The times shall be limited to one work shift. The time removed shall be filled in when the permit is removed from the worksite.
• Worksite. Worksite or location shall be entered on the designated lines of the
form.
• Hazardous Material (last product contained). Enter the identity of the product or chemical last contained within the equipment to be heated.
• MSDS available. Indicate the MSDS availability by checking the "Yes" or "No" box on the permit. Enter the location of the MSDS on the designated line. If no MSDS is available and there is any doubt about the nature of extent of the hazard, contact the manufacturer or EHS for a copy of the MSDS.
• Work Description. Specify the nature and extent of the work to be done.
• Authorized Work. Check the appropriate authorized hot work activity(ies).
• Checklist. Evaluate the condition of each item on the checklist initial "Yes" or "No" column to indicate that the listed requirement has been checked. Use "N/A" for items that are not applicable. Print the name of the fire watch on the appropriate line.
• Personal Protective Equipment. Where applicable, the items selected for use shall be noted and checked.
Monitoring and Test Results
• Monitoring instrumentation shall be calibrated according to the manufacturer’s specifications and at the required frequency and operated by trained personnel.
• All instrumentation shall be “zeroed” in a non-hazardous atmosphere.
• The applicable atmospheric monitoring [e.g. oxygen content, lower explosive limit (LEL), and toxicity tests] shall be performed.
• Enter the time and results of the oxygen, LEL, and toxins in the appropriate columns. he individual performing the tests shall initial each entry.
• If no test is required, then enter "Not Required" or "N.R."
• The tester shall note the instrument(s) serial number(s) and print his/her name in the appropriate column.
Safe Work Parameters
• The criteria listed in the following table shall be used to evaluate the atmospheric testing results to determine if hot work shall be authorized. Monitor the area continuously for oxygen, LEL, and toxic contaminants while doing hot work.
TABLE ONE:
ACCEPTABLE ATMOSPHERIC TEST PARAMETERS
GAS TEST / LEVEL / COMMENTOxygen / Greater than 19.5% / Atmosphere is considered safe for
but less than 23.5% / breathing and does not present an
increase fire or explosion risk.
LFL or LEL / Does not exceed 10% / A hot work permit is required anytime a
* / flammable atmosphere is detected above
0%.
Toxics / Less than OSHA Permissible Exposure Limit (PEL) or other established exposure limit. / No action required. Note: Many toxic compounds are also flammable and should be evaluated for the flammability hazard
*Lower Flammability Limit * Lower Explosive Limit
Required Actions for Atmospheres Outside of Safe Work Parameters If an atmosphere is detected outside of the safe work parameters, the following actions must occur:
TABLE TWO:
REQUIRED ACTIONS FOR ATMOSPHERES OUTSIDE OF ACCEPTABLE WORK PARAMETERS
GAS TEST / LEVEL / COMMENTOxygen / Less than 19.5% / Less than 19.5% oxygen is immediately dangerous to life and health (IDLH) and atmosphere must be controlled by ventilation or occupants will need supplemental breathing air.
Oxygen / Greater than 23.5% / Oxygen greater than 23.5% presents a fire and explosion hazard and controls will be required.
LFL or LEL * / Greater than 10% / Hot work is to be suspended at an atmosphere above 10% of the LEL. • Evaluate the source of the
flammable material.
• Isolate the material and purge the job of any flammable materials until the concentration is less than
10% LEL/LFL. • Monitor continuously to ensure LEL/LFL remains below 10%.
Toxics / Greater than OSHA Permissible Exposure Limit (PEL) or other established exposure limit. / Greater that the PEL will require engineering, administrative, or PPE to control employee exposure. Note: Many toxic compounds are also flammable and should be evaluated for the flammability hazard.
* Lower Flammability Limit * Lower Explosive Limit
Signatures
• Qualified Person - The qualified person in charge of the job shall sign the permit on the appropriate line once all of the permit requirements have been completed and he/she is satisfied that there is not significant risk present by proceeding. The qualified person shall sign the permit before posting/issuing it. The permit is not valid without the signature of the qualified person.
• Supervisor's Approval Signature - The supervisor in charge of the field, area, plant or location shall give approval for the work to be done by signing the permit form on the appropriate line. The signature also indicates his/her recognition of any special conditions that may be associated with the area and/or equipment.
• Fire Watch Signature - The fire watch inspects the work area for 30 minutes after the hot work is completed and documents the area is safe by signing on the appropriate line on the Hot Work Permit.
ISSUING HOT WORK PERMITS The qualified person issuing/signing the permit shall advise the welders and other affected employees performing the work of the conditions under which the permit was issued.
REVISING HOT WORK PERMITS The qualified person in charge of the hot work operations can only make additions or changes to the original permit. Before altering the permit, the qualified person shall determine that safety requirements are met.
· Make any modifications to the permit on all copies and the original. The qualified person, and the authorizing supervisor, if available, shall initial any changes to the permit.
· Draw a single line to strike out deletions and initial any permit change.
· Permits that have been prepared but not issued shall be marked VOID across the permit.
REVOKING AND REINSTATING PERMITS
If a hazardous condition develops while doing hot work:
· The person who notices the potential hazard notifies other personnel to cease all work and immediately and to leave the area.
· Notify the qualified person who prepared the permit.
· The qualified person removes and revokes the permit.
· The time the permit is revoked and the nature of the hazard is recorded on the permit.
Work may resume after the qualified person determines that the hazardous condition has been eliminated; rechecks the area for gas, oxygen, and toxic conditions; and reinstates the work permit. Update the permit with the new combustible, oxygen, and toxicity test results. Record the permit reinstatement time on the permit.
HOT TAPPING
“Hot tapping” refers to those procedures which include the welding attachment of tees or nozzles, drilling or tapping operations into in-service piping and/or on-line plugging; pipelines and/or production related equipment which are to remain in service and which have not been depressurized, drained, blinded, purged and otherwise prepared for hot work. The potential hazards associated with this type of activity require careful planning and special precautions above those common to general hot work.
Specific hot tapping procedures will be developed as needed. The procedures will address following:
· Operations parameters
· No welding will be done on equipment operating at, or above their maximum allowable working pressure (MAWP).
· Welding will not be done on facilities which are operating at less than atmospheric pressure.
· No welding will be done on facilities or piping requiring pre-heating without special consideration of the metallurgy and welding involved.
· Welding on operating facilities will be authorized only when:
o Adequate continuous flow can be maintained.
o The contents of the pipe are not explosive, reactive or contain hydrogen sulfide (or other poisons) above the IDLH level.
· When welding on vessels contained hydrocarbon liquids, the liquid level must be three feet or more above the area being welded.
· During welding or tapping a person knowledgeable of the operation must be on location, in the event of a blow-out or breakthrough.
· Equipment being considered for hot tapping shall be tested for metal thickness before work is performed.
o The minimum wall thickness upon which welding will be allowed, for equipment or piping operating at less than ½ of the MAWP is 3/16”.
o The minimum wall thickness upon which welding will be allowed for equipment or piping operating at greater than ½ the MAWP is ¼”.
TRAINING
All employees are required to receive training on the requirements of this Hot Work Program.
TRAINING ELEMENTS
Training elements include but are not limited to:
o Recognizing hazardous atmospheres
o Recognizing hazardous tasks
o Requirements of the Hot Work Program
o Permit issuance (Hot Work)
o Personal protective devices
o Atmospheric monitoring instrumentation
o Non-sparking and intrinsically safe equipment
o Atmosphere ventilation procedures
TRAINING FREQUENCY
Employees will receive training upon initial hiring and periodic refresher training.
TRAINING DOCUMENTATION
The company will keep records of employees’ initial training and any subsequent refreshers.
RECORDKEEPING
Copies of completed hot work permits shall be maintained in the production area for a period of at least one year from the completion of the hot work.