Hot Work
Hot Work
Hot Work
Hot Work
1. Purpose
Hot work is work that could produce a source of ignition, such as sparks, flames, or temperatures high
enough to cause the ignition of flammable gases or combustible materials.
The purpose of this policy is to define the requirements for performing hot work that requires a permit and the
responsibilities of individuals serving in roles regarding hot work operations.
2. Scope
This policy applies to all employees and contractors while performing hot work for USPL.
The following policies in this safety manual are either referenced or are applicable to this policy and should be
consulted for specific related requirements and guidance:
3. Minimum Requirements
Supporting
Minimum Requirements
Documentation
1. A Hot Work Permit shall be completed and issued prior to conducting Sections 6 and 7,
Primary Source Ignition (PSI) hot work (except in a designated area or performing Appendices I and
shielded PSI outside a Class 1 area); and Secondary Source Ignition (SSI) Class 1 hot II
work.
2. All Hot Work Permits shall be issued by an Asset Operator or Asset Operator Designee Section 5
and shall be received by a Performing Authority. Self-permitting is prohibited.
3. An Area Monitoring Plan shall be developed and implemented before Class 1 hot work is Section 10,
performed. Section A of Hot
Work Permit
4. Air monitoring for the presence of flammable gas shall be conducted prior to conducting Section 10,
Class 1 hot work and shall be performed continuously while performing PSI Class 1 hot Appendices III
work, and if LEL > 0% while performing SSI Class 1 hot work. and IV
5. If air monitoring (initial or continuous) detects the presence of flammable gas (LEL > 0%), Section 10,
hot work shall not proceed until an LEL Mitigation Plan is developed and implemented to Section A of Hot
identify the source of the flammable gas and verify that the LEL is less than 10%. Work Permit
6. Hot work is prohibited in explosive atmospheres (LEL ≥10%). Section 8 and 10
7. Designated areas shall be kept free of combustible materials and shall be physically Section 6
marked around the perimeter.
8. A Fire Watch is required while PSI Class 1 hot work is being performed and additionally Section 11,
Revision Date: July 8, 2014 Effective Date: December 31, 2014
Next Review Date: July 8, 2019
Paper copies are uncontrolled and valid only at the time of printing. The controlled version of this document can be found in DRM
in the HSSE Policies folder.
BP U.S. Pipelines and Logistics (USPL) Hot Work
Safety Manual Page 2 of 20
during PSI non-Class 1 hot work performed within 35 feet of shielded combustible Appendix V
materials.
9. Individuals performing hot work roles shall be trained to execute their responsibilities as Section 12
defined in this policy
10. All personnel performing hot work on behalf of USPL have the responsibility and authority Section 7
to stop any work they consider to be unsafe.
4. Definitions
Asset Operator (AO)—A BP employee who is responsible for the operation of the asset where work is being
performed. The Asset Operator shall be accountable for the asset equipment being in a safe condition for the
scope of work to be performed. The Asset Operator or an Asset Operator Designee (if used) is responsible for
the completion of the ATW form.
Asset Operator Designee (AOD)—A BP employee or contractor individual who is authorized to issue ATWs
and / or permits on behalf of the Asset Operator.
Note: Reference the Authorization to Work policy for additional information
Authorized Gas Tester—An individual responsible for operating air monitoring equipment to monitor the area
where hot work will be performed for the presence of flammable gas.
Class 1 area—An area in which flammable gases or vapors are or might be present in the air in quantities
sufficient to produce explosive or ignitable mixtures. For the purposes of this policy, Class 1 areas are defined
to include Division 1 and Division 2 classified areas. Consult Facility Hazardous Area Classification diagrams
to identify where Class 1 areas are defined. For hot work not performed at a facility, such as on the Right-of-
Way the following are examples of Class 1 areas:
• Within 100 feet of all leak sites or pipeline repair operations where a line will be or has been
opened. This can be expanded due to the size of the leak.
• Within 10 feet of any at-grade or below-grade sumps or drains.
• Within 50 feet horizontally in all directions from any edge of pumps located outdoors where
pressure > 275 PSIG.
• Within 10 feet horizontally of an outdoor valve, flange, manifold, meter, or scraper trap.
Combustible material—A material that, in the form in which it is used and under the conditions anticipated,
will ignite and burn.
Designated area—A specific location designed and approved for hot work operations that is maintained fire-
safe, such as a maintenance shop or a detached outside location, that is of noncombustible or fire-resistive
construction, essentially free of combustible and flammable contents, and suitably segregated from adjacent
areas. Hot work performed in a designated area does not require a Hot Work Permit.
Note: Class 1 areas are never designated areas.
Note: Designated areas are not required to be “structures”.
Fire Watch—An individual who is assigned the responsibility of monitoring hot work and the surrounding area
for incipient fires and changing conditions.
Flammable gas—A term used for brevity in this policy to include all combustible and flammable gases and
vapors that burn in air when the concentration of the gas or vapor is within the range of concentration where
combustion can occur.
Hot work—Work that could produce a source of ignition or temperatures high enough to cause the ignition of
flammable gases and combustible materials. Examples of hot work include but are not limited to:
Arc welding
Sandblasting
Grinding
Using electrical and electronic equipment that is not certified or intrinsically safe or explosion-proof
(such as mobile phones, cameras)
Using internal combustion engines (including vehicles) in a Class 1 area (e.g., a tank dike)
Thermite brazing (e.g. Thermite welding, Cadwelding, welding test leads.)
Applying hot coatings(e.g. shrink sleeves, Tapecoat 20)
Using holiday detectors for checking coating integrity
Using torches to remove casing from line pipe
Using torches to solder test lead wires
Installing vent pipes to a casing
Note: Pneumatic tools are considered a safer alternative to other power tools but consideration must be given
to heat generated at the point of operation.
Hot work operator—An individual who operates hot work equipment to perform hot work operations.
Lower Explosive Limit (LEL)—The minimum concentration (percentage) of a flammable gas that will
propagate a flame in the presence of an ignition source. The more explosive the gas, the lower the LEL. A
mixture below this level is considered too “lean” to burn. LEL is usually expressed as a percentage (from zero
to 100% explosive) and is often used interchangeably with Lower Flammability Limit (LFL).
Performing Authority (PA)—A BP employee or contractor individual who receives a permit issued by the
Asset Operator or Asset Operator Designee.
Note: Reference the Authorization to Work policy for additional information.
Permit Issuance—The act of the Asset Operator or Asset Operator Designee issuing a permit to a
Performing Authority. Permit Issuance is documented in Section C of the ATW form.
Note: Reference the Authorization to Work policy for additional information
Non-permissible Area—An area where hot work is prohibited.
Primary Source Ignition (PSI) hot work—Work with equipment and tools that, when used in a normal
manner, are likely to ignite a flammable or combustible atmosphere, solid materials, and liquids. PSI hot work
is often referred to as “naked flame” hot work. High energy is present in the form of a flame, electric arc, or
incandescent sparks. Examples of PSI hot work include but are not limited to the following:
Primary Source Ignition (PSI) Class 1 hot work—PSI hot work that is performed either inside a
Class 1 area or outside a Class 1 area that could be impacted by the hot work.
Note: PSI hot work such as grinding has been known to generate sparks with enough force to
transport them up to 35 feet from the point of the hot work; therefore, it is possible to perform PSI hot
work up to 35 feet away from a Class 1 location and yet still introduce an ignition source into a Class
1 area.
Primary Source Ignition (PSI) non-Class 1 hot work—PSI hot work that is performed outside of
and will not impact a Class 1 area.
Secondary Source Ignition (SSI) hot work—Any work with equipment and tools that, when used in a
normal manner or due to errors or malfunctions, may create lower-energy sparks and ignite a flammable or
combustible atmosphere. SSI hot work is also referred to as “spark potential” hot work. Examples of SSI hot
work include but are not limited to the following:
Using electrical and electronic equipment that is not intrinsically safe or explosion-proof (e.g., most
electronic communication devices, flashlights, power tools)
Using internal combustion engines (including vehicles) in a Class 1 area (vehicle entry into tank
dike)
Using a rotating steel brush
Electrical isolation testing
Producing a friction spark, typically from a rusty surface
Note: The use of hand tools such as hammers and chisels is not considered hot work.
Note: The use of watches, hearing aids, and other medical devices are specifically exempted as SSI sources.
Secondary Source Ignition (SSI) Class 1 hot work—SSI hot work that is performed inside a Class
1 area.
Secondary Source Ignition (SSI) non-Class 1 hot work—SSI hot work that is performed outside a
Class 1 area. SSI non-Class 1 hot work does not require a Hot Work Permit.
Shall—Is used where a provision is mandatory
Should—Is used where a provision is preferred
F. Stops hot work if at any time air monitoring readings are > 10% of the LEL
Note: Refer to the Air Monitoring policy for additional information regarding the Authorized Gas Tester
and air monitoring equipment.
6. Designated Areas
The purpose of a designated area is to provide a safe area where PSI hot work can be performed without
permitting. A designated or “free burn” area does not require a Hot Work Permit, a Fire Watch, or air
Revision Date: July 8, 2014 Effective Date: December 31, 2014
Next Review Date: July 8, 2019
Paper copies are uncontrolled and valid only at the time of printing. The controlled version of this document can be found in DRM
in the HSSE Policies folder.
BP U.S. Pipelines and Logistics (USPL) Hot Work
Safety Manual Page 6 of 20
monitoring because the procedures for establishing the designated area eliminate or effectively control
flammable and combustible hazards.
A. Designated areas shall be:
1. located at least 35 feet from a Class I area;
2. kept essentially free of combustible materials; and
3. physically marked around the perimeter.
inspecting the hot work area for any change in previous conditions and conducting and documenting
air monitoring if PSI hot work is to recommence in a Class 1 area.
G. If permit conditions are exceeded (e.g. LEL > 10%) work and the permit shall be suspended until
the Asset Operator determines if changes can be made to the permit or if the permit should be
cancelled and a new permit issued.
1. If the Asset Operator / Asset Operator Designee determines that changes to the permit can be
made, he/she shall document their approval of the changes by initialing the changes where
they are documented on the permit
H. The Hot Work Permit should be at the job site until the hot work is completed or the permit expires.
At the Asset Operator’s discretion, the Hot Work Permit may be kept at an alternate location, e.g. in
the office for the permit for cutting grass.
I. All personnel involved in the hot work operation have the authority and responsibility to stop work
that they consider to be unsafe.
J. The original completed Hot Work Permits shall be retained locally for a minimum of one year.
8. Non-Permissible Areas
A. Hot work is prohibited in the following areas:
1. In areas prohibited by management.
2. In sprinkler-equipped buildings where sprinklers are impaired, unless the requirements of
NFPA 25 are met, specifically Chapter 15 – Impairments.
3. In the presence of explosive atmospheres (≥10% of the LEL).
4. In the presence of uncleaned or improperly prepared tanks, vessels, or other containers and
equipment that have previously contained flammable or combustible materials when their
contents might be exposed to an ignition source.
a) Reference the Confined Space Entry policy for requirements regarding post-cleaning
certification of a gas / product space.
4. The location of the hot work relative to combustible and flammable materials and classified
areas will determine the need for a Fire Watch, as outlined in this policy (see Section 11).
9.1.1. Welding, Torch Cutting, and Brazing in a Confined Space or Partially Enclosed Space
A. When welding, cutting, or brazing operations are to be conducted in a confined space or partially
enclosed space the following ventilation requirements shall apply:
1. General mechanical ventilation at a rate of 2,000 cubic feet per minute (cfm) per welder shall
be provided; or
2. Local mechanical ventilation using freely movable hoods placed by the welder as near as
practicable to the work being welded and provided with a rate of air-flow sufficient to maintain a
velocity in the direction of the hood of 100 linear feet (30 m) per minute in the zone of welding
when the hood is at its most remote distance from the point of welding shall be provided.
3. Local mechanical ventilation or airline respirators are required when welding, cutting, or
brazing on hazardous metals (e.g. galvanized, stainless, chrome-molly, metals containing lead
other than as an impurity).
4. All replacement air shall be from a clean source outside of the confined space or partially
enclosed space.
Note: Refer to Appendix VII General Mechanical Ventilation Guidance for Welding, Cutting and
Brazing in Confined Spaces or Partially Enclosed Spaces for additional information.
B. If the minimum rates stated above cannot be achieved, supplied air respiratory protection shall be
worn by all entrants in the confined space or partially enclosed space in conjunction with ventilation.
Note: For the purposes of this policy, a partially enclosed space is a space that does not meet the
definition of a confined space but is configured in a manner that would cause the accumulation of
welding fumes without mechanical ventilation.
c) Hot work in a confined space requires air monitoring for flammable gas throughout the
entire space (see the Confined Space Entry policy).
2. Potential sources of flammable gas within the area to be monitored.
Note: Examples of potential sources of flammable gas include sumps, drains, flanges, valves,
liquid boots, excavations, and all confined areas and equipment located within them, such as
floating roof pontoons, piping, excavations, and vessels.
3. The wind direction.
C. A second Fire Watch shall be required if one Fire Watch cannot directly observe combustible
materials that could be ignited by the hot work operation.
13. References
1. American Petroleum Institute, API Recommended Practice 500, “Classification of Locations for Electrical
Installations at Petroleum Facilities Classified as Class I, Division 1 and Division 2,” 2nd ed., November
1997.
2. American Petroleum Institute, API Recommended Practice 2009, “Safe Welding, Cutting, and Other Hot
Work Practices in the Petroleum and Petrochemical Industries,” 7th ed., February 2002.
3. BP GP 44-60, “Guidance on Practice for API RP 500 Area Classification.”
4. Facility Hazardous Area Classification diagrams.
5. National Fire Protection Association, NFPA 25, “Standard for the Inspection, Testing, and Maintenance of
Water-Based Fire Protection Systems,” 2002.
6. National Fire Protection Association, NFPA 51B, “Standard for Fire Prevention during Welding, Cutting,
and Other Hot Work,” 2003.
7. OSHA, U.S. Department of Labor, 29 CFR 1910.252, “Welding, Cutting, and Brazing: General
Requirements.”
8. National Fire Protection Association, NFPA 101, “Life Safety Code,” 2012.
Appendix I
Hot Work Permit
This example of the Hot Work Permit is for reference only. Yellow highlighting represents revisions made to the permit
and will not appear on the printable form. For a downloadable version of the permit, go to DRM. The electronic
version can be filled out online or printed and completed as hard copy.
Appendix II
Hot Work Permit Applicability
Is there an acceptable
alternative to hot work? Yes Complete job with cold work. Hot
Work Permit is not required.
No
Is the hot work specifically Yes Hot Work Permit is not required.
exempted, e.g. transport
loading, SSI non-Class 1?
No
Will hot work be performed Yes Examine the designated area, then
in a designated area? complete hot work there. Hot Work
Permit is not required.
No
Is the proposed hot work to Yes Hot work and permit are not
be performed in a non- authorized.
permissible area?
No
Appendix III
Hot Work Permit Requirements
Appendix IV
Initial and Continuous Hot Work Air Monitoring
Requirements
Yes No
Yes
Primary Source Ignition Hot work will be performed in a
(PSI) hot work? Yes Class 1 area or may impact Class
1 area?
Initial and continuous air monitoring
No required. Complete Area Monitoring
Plan in Section A of Hot Work Permit
No No
Air monitoring not required.
Continuous air monitoring not
Yes required unless flammable gas is
suspected.
Implement controls to No
reduce LEL to < 10
%. Hot Work may not No LEL < 10% ? Yes Continue continuous monitoring
proceed if LEL > 10% for duration of hot work
Appendix V
Situations Requiring a Fire Watch
Will PSI Class 1 hot work be performed? Yes Fire Watch Required
No
No
Will hot work be performed where wall or floor openings are within Yes
35 feet and combustibles in adjacent areas will be exposed?
No
Yes
Will hot work be performed where combustibles are adjacent to
partitions, ceilings, or roofs that will be worked on?
No
Are fire alarms and fire suppression systems being disabled for Yes
the hot work?
No
Appendix VI
Types of Hot Work
Example: Tank Dike
The entire area inside the tank dike is a Class 1 area, so hot work performed inside the dike area is Class 1 hot work.
Hot work performed outside the dike is non-Class 1 hot work.
Appendix VII
General Mechanical Ventilation Guidance for Welding,
Cutting and Brazing in Confined Spaces or Partially
Enclosed Spaces
The following table provides guidance in determining the appropriate fan/blower configuration to achieve the required
2,000 cfm per welder:
No. of Size/Type of Fans or Horns with Minimum CFM Ratings per Maximum
Fans or Number of Welders in the Confined Space Number of
Horns Welders in a
Confined Space
1 20” air-driven entryway-mounted reaction fan = 10,000 cfm 4
2 20” air-driven entryway-mounted reaction fan = 20,000 cfm 8
3 20” air-driven entryway-mounted reaction fan = 30,000 cfm 12
1 24” air-driven entryway-mounted reaction fan = 15,000 cfm 6
2 24” air-driven entryway-mounted reaction fan = 30,000 cfm 12
1 Model 3 HP Coppus air horn = not adequate cfm 0
2 Model 3 HP Coppus air horn = 2,500 cfm 1
3 Model 3 HP Coppus air horn = 2,500 cfm 1
1 Model 6 HP Coppus air horn = 2,500 cfm 1
2 Model 6 HP Coppus air horn = 7,500 cfm 3
3 Model 6 HP Coppus air horn = 12,500 cfm 5
1 Model 8 HP Coppus air horn = 5,000 cfm 2
2 Model 8 HP Coppus air horn = 10,000 cfm 4
3 Model 8 HP Coppus air horn = 17,500 cfm 7
1 Model 9 HP Coppus air horn = 7,500 cfm 3
2 Model 9 HP Coppus air horn = 15,000 cfm 6
3 Model 9 HP Coppus air horn = 22,500 cfm 9
The maximum number of welders allowed in a confined space or partially enclosed space in the above table was
calculated using the total airflow (cfm) provided by the manufacturer for each model of air mover. An inlet air pressure
of 80 psi to drive the air movers was used. This must be maintained at the site for all the air movers. Because of
ventilation inefficiencies and losses due to entryway attachments, internal airflow restrictions, and variations in the
actual air inlet pressure, a safety factor of 0.75 was incorporated into the equation to determine the maximum number
of welders.
There must be enough fresh, breathable, makeup air entering the confined space or partially enclosed space to
balance the volume being exhausted to effectively “flush” the space with clean air. Consequently, some entryways
and nozzles should be left open to allow clean air to enter the space. Open entryways and nozzles should preferably
be located at the lower levels and the exhaust air fans/blowers at higher levels above the work. Most welding fumes
are heavier than air and adding ducting near the floor or work area to the Coppus-type fan is recommended to move
the fumes away from the welder.