Hot Work Policy

Scope

Indiana University Insurance, Loss Control & Claims (INLOCC) and Indiana University Environmental Health and Safety (IUEHS) have developed these management procedures to prevent accidental fires, loss of life, injury, or loss or damage to property from “hot work” as defined below. These procedures are intended to comply with the Indiana Fire Code Chapter 35 and the Occupational Safety and Health Administration (OSHA) Standards contained in 29 CFR 1910.252.

These procedures apply to all hot work operations performed on Indiana University property, including but not limited to construction or renovation projects.

Standards

Anyone performing hot work must obtain and complete a hot work permit to perform hot work operations. The only exceptions are processes performed in designated areas or during an immediate emergency situation.

Training

Online training is offered (IU Expand) . This is a valuable tool for learning more about hot work procedures and why they are required.

Definitions

University Safety Official: A University Safety Official is anyone from:

• INLOCC
• IUEHS
• University Architect’s Office (UAO)
• Indiana University Police

Building Fire Protection System(s): The alarm system(s) and sprinkler system(s) in a University building.

Campus Alarm Technicians: Indiana University employees who are responsible for the maintenance of fire alarms and related equipment or who have been given the authorization to take specified alarm heads out of service in appropriate circumstances (commonly referred to as “zone out”).

Control Desk: Will track the Hot Work process and information. Provides for communication between IU trades, outside contractors and INLOCC fire inspectors via phone/radio.

Designated Hot Work Area: A permanent area that has been designated by INLOCC for the performance of hot work operations such as welding, torching, grinding, cutting, etc. This may include areas such as zone maintenance shops, art facilities, or laboratories and does not require a daily permit to perform hot work. These areas, except for outside areas at construction sites, will be designated by appropriate signage.

Fire Watch Personnel: The person(s) who maintains awareness for the presence of fire or hazardous conditions within the hot work area before, during, and for at least 30 minutes after the hot work is completed. Depending on the project, Fire Watch Personnel may be a University employee or a contractor’s employee. Fire Watch Personnel shall be trained on:

• Hazards of the hot work jobsite in correlation with the hot work
• Use of an appropriate fire extinguisher
• Procedures for initiating the fire alarm and calling 911
• Practices to safely extinguish any small fire using the extinguisher or welding blankets at the jobsite

Fire watch training is available through INLOCC.

Hot Work/Hot Work Operations: Any operation (including but not limited to temporary maintenance, renovation and construction) using gas or electric powered equipment which produces flames, sparks, or heat that is sufficient to start a fire or ignite flammable/combustible materials. This includes, but is not limited to, cutting, welding, Thermit welding, brazing, open–flame soldering, oxygen cutting, grinding, arc welding/cutting, oxy–fuel gas welding, hot taps, thermal spraying, thawing pipe, and torch applied roofing.

Ignition Source Examples: Open flame, torch, welders, molten slag or metal, or sparks from such work. (This is not an exhaustive list.)

Issuing Unit: The University department, as identified below, responsible for issuing hot work permits within University–Controlled Hot Work Zones.

Hot Work Area: The area exposed to sparks, hot slag, radiant heat, or convective heat as a result of the hot work.

Hot Work Equipment: Electric or gas welding or cutting equipment use for hot work.

Hot Work Permits: A document that will be required when the task requires the use of a flame, sufficient heat or sparks to generate or serve as a source of ignition. Permits are issued by the responsible person at the facility under the hot work permit program permitting welding or other hot work to be done in locations referred to in Chapter 35 of the IFC 2014 edition or like codes in other states where they apply.

Supervisor: Person who makes/oversees assignments involving work to be performed, including hot work.

Undesignated Hot Work Area: An area in which hot work operations will be performed that is not considered a designated hot work area. An undesignated hot work area requires the issuance of a daily hot work permit.

Procedures

1. Authority and Responsibility
   1. Issuing Unit
      1. IUB: INLOCC
      2. IUPUI: Campus Alarm Technicians
      3. IUN: INLOCC
      4. IUSB: INLOCC
      5. IUK: INLOCC
      6. IUE: Facilities Services
      7. IUC:INLOCC
      8. IUS: INLOCC
   2. Supervisors are responsible for:
      1. Notifying all employees engaged in hot work operations and contractors of the purpose and intent of the Hot Work Management Program;
      2. Making periodic jobsite inspections to determine compliance with hot work procedures; and
      3. Attending required training provided by the University.
   3. Employees engaged in hot work operations are responsible for:
      1. Understanding the University’s Hot Work Management Program;
      2. Notifying the Control Desk when a hot work permit is needed; and
      3. Complying with the procedures defined within the Program.
   4. University Architects Office (UAO) and Facilities Renovations (Project Managers) are responsible for:
      1. Notifying all contractors of the purpose and intent of the Hot Work Management Procedures;
   5. Contractors and sub–contractors are responsible for:
      1. Understanding the University’s Hot Work Management Procedures;
      2. Complying with applicable fire and building codes;
      3. Maintaining their own companies’ written Hot Work Management Program and complying with it, or the University’s Hot Work Management Program, whichever is more rigorous, during projects on campus;
      4. Submitting appropriate shutdown notifications for Fire Alarm systems and building systems that may be affected by Hot Work activities;
      5. Submitting requests for hot work permits from, as applicable, UAO or the University Project Manager prior to conducting hot work operations;
      6. Assuming the role of Fire Safety Supervisor for each permit; and
      7. Making periodic jobsite inspections of areas where the hot work is being conducted to determine that procedures are being used.
      8. Required fire extinguisher(s) shall be provided by the contractor and/or sub–contractor. University fire extinguishers shall not be used.
   6. Insurance, Loss Control and Claims (INLOCC) is responsible for:
      1. Reviewing the Hot Work policy and procedures to determine compliance;
      2. Enforcing the applicable fire and building codes;
      3. Conducting random inspections of employee hot work projects to determine if the applicable fire and building codes are being met;
      4. Identifying all designated hot work locations and conducting annual inspections of those locations;
      5. Conducting random walk–throughs of contractor projects and notifying the job superintendent if any potential fire or building code violations are observed; and
      6. Assisting in training of employees engaged in hot work operations.
2. Prohibited Hot Work Areas/Operations
   1. Hot work shall not be performed under the following circumstances:
      1. In areas not authorized by INLOCC
      2. When the building’s fire–safety systems are impaired (this does not include zoning out affected smoke heads or having the sprinkler system out of service if work is being performed on the sprinkler system);
      3. In the presence of explosive atmospheres (mixtures of flammable gases, vapors, liquids or dusts in air);
      4. In the immediate area of combustible materials
3. Designated Hot Work Areas
   1. A designated hot work area shall be:
      1. Non–combustible, fire–resistive construction, essentially free of combustibles and flammables; this requirement also applies to the working surface for the use of the soldering and brazing operations (i.e., laboratory bench top, Duraboard, tile, etc.);
      2. Suitably segregated from adjacent areas;
      3. Equipped with a fire extinguisher(s);
      4. Equipped with a heat detector rather than a smoke detector;
      5. Equipped with mechanical ventilation to control smoke and fumes; and
      6. Inspected and approved by INLOCC prior to use of the site as a designated hot work area.
4. The following conditions must be maintained at all times at a designated hot work area:
   1. All combustible materials, papers, notebooks and chemicals must be removed from the surrounding (35 foot clearance).
   2. Inspect the oxy–acetylene hoses for holes, pinched points, cracks, or any other defects and determine that the hoses fit securely on the gas valve and the burner/torch.
   3. Hoses having any defects must be replaced before using.
   4. Loose clothing, long hairs or dangling jewelries must be tied at the time of using the burner.
   5. All other shop/lab personnel must be notified that the burner/torch will be in use.
   6. The open burner/torch must not be unattended.
   7. Always shut off the gas supply when done.
   8. If the oxy–acetylene is not going to be used for an extended period of time, remove regulators and secure cylinders with protective cylinder caps if equipped.
5. Program Elements for Undesignated Hot Work Areas
   1. Jobsite Inspection:
      1. 1. Prior to making a request for the issuance of the hot work permit,
            1. The Responsible Supervisor shall visit the jobsite to determine if the hot work can be avoided.
            2. If the hot work involves open flame cutting, the Responsible Supervisor shall consider whether an alternative method of conducting the work (e.g., hand saw, pipe cutter) is feasible.
            3. If an alternative method of conducting the work is not feasible, the Responsible Supervisor shall ensure the hot work site is safe.
         2. Prior to beginning work at any hot work jobsite each day, the Responsible Supervisor shall authorize the job and requests issuance of a hot work permit from the Issuing Unit.
         3. Prior to issuing a hot work permit for that day, the Issuing Unit shall conduct a jobsite review. All hot work jobsites are inspected using the checklist contained on the daily hot work permit.
      
      1. All items included in the jobsite review include, but are not limited to, the following:
         1. Persons engaged in hot work operations and fire watch personnel are trained in the safe operation of their equipment;
         2. Fire watch personnel understand the requirements of a fire watch;
         3. Apparatus used for the hot work is in good condition;
         4. Hot work operator(s)/fire watch personnel understand the emergency procedures in the event of a fire or general emergency;
         5. Fire protection and extinguishing equipment are properly located onsite;
         6. Hot work operator(s) are utilizing personal protective equipment;
         7. A determination that the proposed work does not jeopardize the health and safety of the hot work operator or others; and
         8. Campus alarm systems have been prepared for the hot work and the permit is signed by the appropriate issuing unit.
      2. The Issuing Unit shall not issue a permit for that day’s work until all procedures are satisfactorily met.
      3. All permits must be prominently displayed at the hot work jobsite.
      4. The Responsible Supervisor shall issue a shutdown of hot work operations upon request by a University Safety Official in order to issue a hot work permit and to evaluate the need to disarm any portions of the building fire protection system.
      5. Any questions concerning hot work management should be directed to INLOCC.
   2. Fire Watch:
      1. IFC Chapter 35 requires a fire watch when hot work is performed in a location where the following condition(s) exist:
         1. Combustible materials in building construction or building contents are closer than 35 feet to the point of operation of the hot work;
         2. Combustible materials are more than 35 feet away, but are easily ignited by sparks;
         3. Wall or floor openings within a 35 feet radius expose combustible materials in adjacent areas, including concealed spaces in walls or floors;
         4. Combustible materials are adjacent to the opposite side of partitions, walls, ceiling, or roofs and are likely to be ignited.
      2. A trained fire watcher is required to be present at all times while hot work is being conducted, armed with portable fire extinguishers. Contractors are required to provide their own fire watchers and fire extinguishers.
      3. IFC Chapter 35 will be used as the standard on IU projects at out–of–state locations unless that state’s regulations are more restrictive.
      4. The fire watch shall:
         1. Be aware of the inherent hazards of the work site;
         2. Actively monitor whether safe conditions are being maintained during the hot work operation;
         3. Have the authority to stop the hot work operations if unsafe conditions develop;
         4. Have fire extinguishing equipment immediately available and be trained on how to use it; and
         5. Activate emergency response in the event of a fire.
      5. Once the hot work is completed, the fire watch shall remain in the area of the hot work jobsite for at least 30 minutes to monitor the worksite and make certain that there is no smoldering combustion taking place. After the 30–minute monitoring period is complete, the fire watch shall sign Part Two of the permit which states: “The work area was observed for at least 30 minutes after work was completed and found to be safe.” The fire watch shall return the completed Permit to the Responsible Supervisor.
      6. Upon receipt of Part Two of the Permit, the Responsible Supervisor shall do a walk–through of the hot work jobsite and will then contact the Issuing Unit so that alarm and/or sprinkler systems can be returned to service as needed.
6. Prohibitions:
   1. With the sole exception of handheld MAPP or Map–Pro gas cylinders, propane gas shall not be used for hot work in any occupied University buildings.
   2. A hot work permit shall not be issued for the following areas until the conditions prohibiting hot work have been eliminated:
      1. In the presence of explosive atmospheres, or in situations where explosive atmospheres may develop inside contaminated or improperly prepared tanks or equipment which previously contained flammable liquids;
      2. In areas with an accumulation of combustible debris, dust, lint or oily deposits;
      3. In areas near the storage of exposed, readily ignitable materials such as combustibles;
      4. On a container such as a barrel, drum or tank that contained materials that will emit toxic vapors when heated;
      5. In a confined space, until the space has been inspected and determined to be safe. Contact IUEHS for more information.
7. Storage of Equipment:

   Equipment and supplies related to hot work operations shall be stored in a manner that will prevent the creation of hazardous conditions. Refer to the Compressed Gas Cylinder Program (https://psia360.iu.edu/sites/ehsdocs/?search=&type=&id=55 ) for information regarding the storage of compressed gas cylinders.

8. Training

   Employees affected by this program shall be trained on all aspects of this program by INLOCC.

References

Indiana Fire Code Chapter 35 — Welding and Other Hot Work

29 CFR1910.252 Occupational Safety and Health Administration (OSHA) Welding, Cutting, Brazing.

History

New document: 7-30-2014

Last reviewed: 6 February 2024 and combined into omnibus policy FIN-INS-16.