Hot Work Definition and Requirements

Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What is considered hot work and what are the requirements related to hot work?

Hot work means work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations (§68.3). Facilities that perform hot work operations conducted on or near a covered process shall issue a hot work permit, and it must be kept on file until hot work operations are completed. The permit shall document that the fire prevention and protection requirements in 29 CFR §1910.252(a) have been implemented prior to beginning the hot work operations, indicate the date(s) authorized for hot work, and identify the object on which hot work is to be performed (§68.85).

Additional information can be found in Chapter 7, page 7-15, of the General Guidance on Risk Management Programs for Chemical Accident Prevention (40 CFR Part 68) (EPA555-B-04-001). This document is available at the following URL:

https://www.epa.gov/rmp/guidance-facilities-risk-management-programs-rmp#general