Hot Work: Retain Permits For One Year to Demonstrate Compliance

Fires and explosions can occur when hot work is performed in areas with proven combustible properties. Given the level of risk associated with hot work, the Occupational Safety and Health Administration (OSHA) provides regulations concerning its use in the grain handling standard (1910.272(f)) and the welding, cutting, and brazing standard (1910.252).

Additional information can be found in the National Fire Protection Association (NFPA) 61 Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities (chapter 9, Management Systems).

Hot work is defined as any work process that produces flames or sparks that present a fire ignition hazard to the surrounding environment and personnel.

This definition encompasses electric and gas welding, plasma and torch cutting, as well as brazing and other similar extreme heat- or flame-producing activities. Within the grain and feed industry, the list normally is expanded to include spark-producing tasks, such as grinding and electrical arcing from portable power tools.

Hot Work Permits

It is inevitable that certain situations will require hot work to complete a task appropriately. However, if it is possible to complete the task using hand tools or other methods, then avoiding hot work and its associated risks should be considered.

OSHA 1910.272(f) regulations allow hot work to be performed without a permit in the following situations:

• When the employer or a representative (who would otherwise authorize the permit) is present while the hot work is being performed.

• In welding shops authorized by the employer.

• In hot work areas authorized by the employer located outside the grain handling structure (50 feet or greater from the grain handling facility).

When possible, it is best to move items requiring hot work to a location where a permit is not required. When removal is not an option and a permit must be issued:

• The area within 35 feet of the work shall be cleaned of dust.

• Other combustibles within 35 feet shall be moved or protected with cover, guards, or shields.

• Combustible floors or equipment in or below the work area shall be saturated or covered with wet sand, metal shields, or fire-retardant blankets or tarps.

• Floor and wall openings within 35 feet of the work shall be covered or closed, and all open spouts in the work area shall be sealed or plugged.

• Personal protective equipment (PPE) shall be appropriate for the task and be in good working order. Those involved in the hot work operation should assess their PPE usage by considering exposure and environmental conditions.

If a permit is required, the person who completes it must certify that the requirements of Section 1910.252 have been met and fully implemented prior to hot work being performed. The permit must be kept until completion of the hot work operations. It is a good practice to retain the permit for a longer time period (e.g., one year) to demonstrate compliance.

Roles and Responsibilities for Hot Work Personnel

The employee:

• Prepares the work area and reports any safety issues to the supervisor.

• Follows fire prevention and other safety-related procedures, such as lockout/tagout.

• Uses PPE and project equipment correctly and safety.

The supervisor:

• Conducts hazard assessment and identifies safety precautions.

• Communicates and enforces safety procedures.

• Assigns fire watch and secures permit authorization.

• Assures equipment is in good repair and tells employee when to proceed.

The employer:

• Appoints a qualified supervisor and advises contractors of hazards.

• Assures employee training is satisfactory.

• Establishes the proper locations, policies, and procedures for the hot work program.

This article is one in a series of Safety Tips published by the National Grain and Feed Association (NGFA), Arlington, VA (202-289-0873). To view more NGFA Safety Tips, go to and click on Issues.

- From the September/October 2021 GRAIN JOURNAL