Hot Work Standard

Code #: Author: Tony Ogunsanya Approvers: Miguel Arenas Rev. No. [0]
HSE-S-03
Reviewers: Milton Godin Rev. Date

Content
1. Scope and Applicability ................................................................................................................................ 2
2. Purpose ......................................................................................................................................................... 2
3. Roles and Responsibilities............................................................................................................................ 2
4. Definitions and acronyms ............................................................................................................................ 4
Acronyms .......................................................................................................................................................................... 5
5. Standard and Guidance ................................................................................................................................ 5
5.1 Hot Work Management .......................................................................................................................................... 5
6 Key Performance Indicators (KPIs) .................................................................................................................. 9
7 Training ......................................................................................................................................................... 9
7.1 Refresher Training ............................................................................................................................................ 9
8 Continuous Improvement ...............................................................................................................................10
8.1 Program Evaluation and Audit ............................................................................................................................10
9 References ..................................................................................................................................................10
10 Revision history ..........................................................................................................................................10

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 1. Scope and Applicability
The Hot Work Standard defines the safety requirements relating to hot work at Orbia
Polymer Solutions sites. This standard applies to all employees and contractors at Orbia
Polymer Solutions sites in the belief that the risks associated with hot work can be reduced
through the implementation of an effective hot work program. Where a specific requirement
of this standard differs from the requirements of applicable local or national standard, the
most restrictive requirement governs.

2. Purpose
This standard is preserves assets and ensure the safety of employees and contractors at
Orbia Polymer Solutions sites during hot work activities. Hot work is any activity that
generates a source of ignition. The risks associated with hot work are magnified in areas
where combustible or flammable gases or liquids are present. This standard outlines the
required steps for the prevention of the risks associated with hot work, such as fire, harmful
light, noxious gases, toxic fumes, high heat, and explosion. This standard is intended to:

 Preserve the safety of the workers performing hot work,

 Ensure the safety of all personnel on site,
 Prevent accidental ignition of property, and
 Prevent accidental activation of the site’s fire detection system.

3. Roles and Responsibilities

3.1 Site Manager has the ultimate responsibility for the safety and wellbeing of employees and
contractors at their site. Therefore, the site manager shall:
3.1.1 Appoint a Hot Work Program Administrator to implement, direct, manage, monitor, and
evaluate the hot work program.
3.1.2 Provide adequate and timely resources to support the hot work program.
3.1.3 Protect employees and contractors from exposure to hazardous or toxic environment
that could impair their safety, and health.

3.2 Hot Work Program Administrator (usually the site HSE Manager or his/her designee) shall
possess the knowledge, training, and experience to implement, direct, manage, and evaluate
the hot work program. In addition, the program administrator shall:
3.2.1 Ensure the site has a written hot work procedure or adopt this standard in lieu of a site-
specific procedure.
3.2.2 Ensure a risk assessment is conducted prior to the commencement of any hot work at
sites under their purview.
3.2.3 Establish and assign program responsibilities as outlined in this standard to trained and
qualified individuals and keep a current list of hot work permit issuers for each area of
the plant.

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 3.2.4 Recognize the limitations of workers to ensure that such limitations are not exceeded
while conducting hot work-related activities.
3.2.5 Ensure fire watch is available and stationed before and at least one hour after the
completion of hot work where there is a risk of fire.

3.3 Hot Work Permit Issuer (usually a HSE professional) is an individual who through training and
professional experience has an in-depth knowledge of the risks associated with hot work and
the controls to reduce or eliminate such risks. The hot work permit issuer authorizes and
terminates hot work and has the overall responsibility for safe hot work activity in their work
area. The hot work permit issuer is additionally responsible for:
3.3.1 Ensuring a risk assessment of pending hot work is conducted to determine the types of
hazards and risks present and the appropriate hazard abatement methods necessary to
keep the hot work safe.
3.3.2 Permitting the hot work activity to start
3.3.3 Terminating hot work activity and returning the work area to operations or other
departments as appropriate.
3.3.4 Ensuring adequate and functional control measures are in place prior to hot work
commencement.
3.3.5 Checking ongoing hot work at least every four hours to verify and document that permit
requirements are observed.

3.4 Hot Work Operator is an employee or contractor that is permitted by the Hot Work Program
Administrator to conduct hot work at the site. The hot work operator shall:
3.4.1 Submit request to perform hot work.
3.4.2 Participate in the hot work permitting process.
3.4.3 Understand and adhere to the hot work permit requirements.
3.4.4 Remain vigilant to the hazards that could occur while engaged in hot work.
3.4.5 Use the personal protective equipment required by the permit.
3.4.6 Immediately stop hot when:
3.4.6.1 ordered to do so by the fire watch or anyone in any of the preceding roles,
3.4.6.2 there is a noticeable or recognizable hot work associated hazard,
3.4.6.3 a prohibited condition exists, or
3.4.6.4 the alarm system sounds.

3.5 Fire Watch is the individual or individuals responsible for continuously observing hot work
activities for the detection of, and response to fire. The fire watch shall have a good
understanding of when to attempt fire extinguishment and when to summon assistance. In
addition, the fire watch shall:
3.5.1 Perform no other duties while assigned as fire watch.
3.5.2 Stop work when changes occur during hot work that have the potential to result in or
contribute to the spread of fire.
3.5.3 Have a functioning fire extinguishing equipment and be ready to use it when needed.

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 3.5.4 Be familiar with the site emergency alarm system and how to summon help or to alert
others to an emergency.
3.5.5 Be present and vigilant throughout the duration of the hot work and for at least one
hour after the hot work to detect and extinguish possible smoldering fires.

3.6 Designated Hot Work Area is an area within the plant that is designed for hot work. Hot
work permit and fire watch are not required for hot work done in the Designated Hot Work
Area. The Designated Hot Work Area shall meet or exceed the following requirements:
3.6.1 Constructed of noncombustible, fire-resistant materials,
3.6.2 Free of combustible and flammable contents,
3.6.3 Segregated from adjacent areas that may contain combustible or flammable materials,
3.6.4 Equipped with appropriate fire extinguisher,
3.6.5 Inspected and approved by the HSE Office.

4. Definitions and acronyms

4.1 Arc Welding is a process where similar materials are joined with heat from an electric arc. In
the most common use, a filler metal is melted to adhere the parts being joined. The heat
generated must be high enough to melt the base metals (the metal being joined) and the filler
metal.
4.2 Brazing is a process of joining two materials with a filler metal that creates a metallurgical
bond with the surfaces of the metals being joined. Unlike welding, brazing does not melt the
base metals, only the filler metal is melted. Therefore, brazing temperatures are significantly
lower than welding temperatures.
4.3 Flammable or potentially flammable atmosphere is an atmosphere that contains airborne
concentration of gases, dust, or fibers high enough that it continues to burn after ignition. A
concentration less than 10% of the Lower Explosive limit or Lower Flammable Limit of the
airborne material is not often high enough to ignite or support burning.
4.4 Hot Work is:
 Work involving burning or sparks that is capable of initiating fires or explosions.
 Any activity involving flame, spark, or heat.
 Welding and allied processes including, arc welding, oxy-fuel gas welding, open
flame soldering, brazing, thermal spraying, oxygen cutting and arc cutting.
 Vehicle entry into process area containing flammable materials.
 Use of electrical devices such as tools, motors, switches, and test equipment
 Grinding, power sanding, abrasive blasting
 Use of heaters (gas, electric, catalytic heater)
 Internal combustion engine
 Powder actuated tools (Hilti Gun)
 Roof torch on waterproofing
 Non-Approved electronic devices

4.5 Hot Work Permit is a written or printed authorization to perform a hot work activity.

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 4.6 Lower Explosive limit /Lower Flammable Limit (LEL/LFL): This is the lowest concentration
of gas, fumes, or vapors required to produce fire in the presence of an ignition source.
LEL/LFL varies from gas to gas. The lower the LEL/LFL of a gas the more flammable is the
gas.
4.7 Oxygen Enriched Atmosphere: An atmosphere containing more than 23.5% oxygen by
volume.

Acronyms
 LEL – Lower Explosive Limit
 LFL – Lower Flammable limit

5. Standard and Guidance

5.1 Hot Work Management
5.1.1 Risk Assessment
Prior to the issuance of a hot work permit, the permit process should be designed to
prompt the permit issuer to conduct a risk assessment that:

5.1.1.1 Determines whether the eventual goal of the task can be accomplished without
hot work.
5.1.1.2 Determine if fire risk exists. That is, determine whether hazards that could fuel a
fire are present, such as flammable and/or combustible materials.
5.1.1.3 Determine the appropriate steps to eliminate or reduce the hazards or to prevent the
hot work ignition source from reaching the flammable or combustible materials.
5.1.1.4 The risk assessment should include options for control methods. The hierarchy
of controls should be used when assessing control options. The first option of control
method is to determine whether hot work can be avoided and still able to achieve the
goal of the project. Alternatives to hot work for cutting or joining materials include:
 Screwed, flanged, or clamped pipe,
 Manual hydraulic shears,
 Mechanical bolting or mechanical pipe cutting,
 Compressed air-actuated fasteners.

If the hot work cannot be eliminated, engineering controls shall be used to prevent
ignition sources from the hot work from reaching flammable or combustible materials.
This can be achieved either by moving the flammable materials to a safer location or by
enclosing either the hot work or the flammable materials or both. Additional
engineering controls should be determined as appropriate.

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 5.2 Hot Work Permit
A hot work permit authorizes hot work, except in a Designated Hot Work Area. The
permit is good for one shift of hot work at a specific location. A hot work permit is issued
by a Permit Issuer who has been designated as such by the Hot Work Program
Administrator. All hot work activities at Orbia Polymers Solutions outside of Designated
Hot Work Areas require a hot work permit.

The permit issuer must be physically present at the hot work area to issue a hot work
permit. The permit issuer should follow the prompts in the hot work permit form
including the risk assessment guidance in section 5.1.1 before issuing a permit. In
addition, the permit issuer should:

5.2.1 Assure test equipment used during the permitting process is calibrated prior to
use and in good working order.
5.2.2 Assure that job hazard evaluations are conducted, and identified hazards are
eliminated or controlled prior to permit issuance.
5.2.3 Assure that firefighting system in the hot work area is operational. If it is
inoperable, ensure that alternatives have been considered, approved and
available.
5.2.4 Assure permit requirements are communicated and fully implemented.
5.2.5 Assure equipment to be worked on is properly identified.
5.2.6 Assure those performing hot work clearly understand which piece of equipment
is to be worked on.
5.2.7 Assure information related to hot work activities including identified hazards,
hazard control measures and job safety requirements are communicated to
employees who may be affected by hot work activities. A review of the
approved hot work permit will meet the communication requirements.
5.2.8 Stop the work if hazardous conditions are identified.
5.2.9 Inspect the area following job completion to assure safe conditions prior to
delivering the work area to others.
5.2.10 All hot work permits should immediately be cancelled, and work stopped, when
a fire alarm or gas release alarm sounds.

5.3 Fire Prevention and Protection

The following basic fire protection precautions should be considered prior to hot work
operations:
5.3.1 Where practical, hot work should be conducted in Designated Hot Work Areas
that are free of flammable and combustible materials.
5.3.2 Any equipment that has been in flammable or combustible service or may be
contaminated with hazardous materials should be decontaminated prior to
conducting hot work on the equipment.

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 5.3.3 Hot work activities that may produce sparks or hot slag, such as welding and
cutting, should be permitted only in areas that have been made “fire safe.”
5.3.4 If the object to be welded or cut cannot be moved, and if all fire hazards in the
vicinity cannot be eliminated, guards or shields should be installed to contain the
sparks, and slag.
5.3.5 An approved device should be used to monitor flammable and combustible gases in
areas surrounding hot work activities and in piping and equipment. A hot work
permit should not be issued if the instrumentation indicates the presence of a
flammable or combustible gas at over 10% LEL (0% LEL in a confined space), or if
the concentration of oxygen is greater than 23.5%.
5.3.6 Monitoring for flammable and combustible gases should be conducted frequently
enough to assure safe hot work activities and should be conducted prior to re-
starting hot work activities following work breaks.
5.3.7 Warning signs should be posted to inform everyone that hot work is in progress.
5.3.8 Evaluate and control potential hazards and associated risks due to simultaneous hot
work in neighboring areas.
5.3.9 If any of the above precautions cannot be met, the hot work should not be
performed without further evaluation, consideration of alternate means of protection
and a higher (Site Manager) level of approval.

5.4 Fire Watch

5.4.1 A fire watch should be provided during any cutting or welding operation where fire
could occur and for all hot work activities when conditions are such as to make it
desirable to take special precautions against fires. A fire watch will not typically be
required in Designated Hot Work Areas.

5.4.2 The fire watch should have extinguishing equipment readily available and be trained
in its use. The fire watch should know how to summon emergency assistance in the
event of a fire and have a good understanding of when to attempt fire
extinguishment.

5.4.3 Additional fire watch should be assigned when there are areas of concern hidden from
the view of the primary fire watch.

5.4.4 A fire watch should be maintained for at least one hour after the completion of
welding/cutting operation to detect any possible smoldering fires.

5.5 Hot Work on Process Systems and Equipment

5.5.1 Process systems or equipment that have contained or have the potential to contain
flammable or combustible materials should be properly isolated and
decontaminated prior to approval of any hot work activity on the equipment. The

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 permit issuer should verify isolation and decontamination prior to permit issuance.
Instrumentation used for verifying decontamination should be checked to ensure
proper operation prior to use.

5.5.2 In situations where piping systems or other process equipment cannot be isolated or
fully decontaminated, alternative precautions, such as purging with inert gases,
should be established to ensure that welding and cutting can be conducted safely.
When inert purge gases are used, precautions should be taken to ensure employees
are not exposed to the purge gases due to potential asphyxiation.

5.6 Hot Work in Confined Spaces

5.6.1 The designated permitting authority (hot work permit issuer and confined space
entry supervisor) must approve hot work conducted in confined spaces.

5.6.2 Confined Space Entry Permit must be granted along with the Hot Work permit.

5.6.3 Lock Out Tag Out (LOTO) procedure must be applied before starting hot work in a
confined space.

5.6.4 Signs must be placed at the entrance of the confined space to inform others of the
presence of personnel inside the confined space.

5.6.5 When arc welding is suspended for any substantial period, such as during lunch or
overnight, all electrodes should be removed from their holders and the welding
machine should be disconnected from the power source.

5.6.6 When torch cutting or welding operations are suspended for a substantial period
such as during lunch or overnight, where practicable, the torch and supply hose
should be removed from the confined space. When it is not practical to remove the
torch and supply hose, the supply hose should be disconnected from the supply
source outside the confined space.

5.6.7 A confined space which contains flammable or toxic chemical must be thoroughly
decontaminated before starting hot work.

5.6.8 Combustible materials inside a confined space, such as residual polymers, packing
materials, and scaffolding must be removed, shielded, or rendered non-combustible
prior to conducting hot work.

5.6.9 The use of welding blankets, welding curtains or welding pads could be needed in
confined spaces where sparks generating hot work is performed.

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 5.6.10 Precautions should be implemented to provide adequate ventilation and respiratory
protection for all workers in confined spaces when respiratory hazards may result
from the type of hot work being performed. These hazards may include, but are not
limited to:

5.6.10.1 Particulate and dust,

5.6.10.2 Vapors and fumes from welding/cutting operations,

5.6.10.3 Inert gases used in welding processes.

6 Key Performance Indicators (KPIs)

The following are recommended KPIs. Additional KPIs may be used at the site as needed.

6.1 Operational Discipline –

6.1.1 Percent Hot Work resulting in an unplanned event =
(# of hot work resulting in an unplanned event/Total # of hot work conducted) X 100
6.1.2 Percent hot work with properly completed Hot Work Permit
6.1.3 Percent hot work with all requirements of the permit fully accomplished.
6.2 Training - Percent personnel (e.g., Permit Issuer, Fire Watch) with up-to-date training in the
duties they perform in the Hot Work program.

7 Training
The program administrator shall ensure that all personnel engaged in the hot work program
receive training in the understanding, knowledge, and skills necessary for the safe performance
of their assigned duties as specified in this standard. This includes those who issue permits, fire
watchers, and those who assess atmospheres for flammability, and those who conduct hot work.
Documentation of the training shall be maintained based on the current records retention schedule.
The documentation shall include the employees’ name, date(s) of training, and the name of the
person conducting the training. Also, any lesson plan, tests, and instructor’s notes must be
retained.

7.1 Refresher Training

7.1.1 Refresher training shall be conducted annually or,
7.1.1.1 When there is a change in procedures or,
7.1.1.2 When there is a change in an employee’s assigned duties associated
with the hot work program or,
7.1.1.3 When assessment results indicate that the procedures are not being
appropriately implemented.
7.1.2 Refresher training shall be documented electronically. The documentation shall
be available for inspection by audit teams. Employee training documentation

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 will be maintained according to established enterprise record retention policies.
Contractors shall maintain training documentation for their employees.

8 Continuous Improvement
8.1 Program Evaluation and Audit
A field evaluation of the Hot Work process will be conducted at least quarterly (1st Party
Audit). The quarterly evaluation will be based on field observations by employees trained in the
application and use of this standard. In addition, 2nd Party Audit shall be conducted by
corporate at least once every three years. For 2nd Party Audit:

8.1.1 An evaluation form shall be completed, and findings recorded in ODISEO.

8.1.2 All deficiencies identified must be corrected immediately and documented in ODISEO
along with their corrective actions.

8.1.3 All completed Hot Work Permits shall be forwarded to the program administrator to be
retained according to established enterprise record retention policies. These
documents shall be utilized by the program administrator in an annual review of the Hot
Work permit process for the program improvement opportunities.

9 References
a. OSHA 1910.252 – General Requirements for Welding, Cutting and Brazing
b. OSHA 1926.352 – Fire Prevention for Welding and Cutting Construction Standard
c. NFPA 51B – Standard for Fire Prevention During Welding, Cutting and Other Hot Work

10 Revision history
Revised on Version Author
Description of the change
(MM/DD/YY) (Number) (3 first name initials)

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