Contractors, audits, incident lessons and capstone: a hot work program

Individual precautions only work when an organization makes them routine. A hot work program ties everything in this course together: a written policy, defined roles, permits, training, equipment, contractor management, audits and learning from incidents. This final lesson covers how to manage contractors, how to audit and improve a permit system, what major incidents teach, and then walks through building a hot work program for a manufacturing plant.

The elements of a hot work program

A complete program usually includes the following elements, written down and owned by a named manager.

• Policy and scope: what counts as hot work, where it is allowed, where it is banned, and the commitment to avoid hot work where possible.
• Roles and authority: who may authorize permits, who may act as fire watch, and what training each needs.
• Designated areas: where routine hot work can be done without individual permits, and how those areas are inspected.
• Permit procedure: the form, inspection steps, gas testing rules, fire watch duration, close-out and record keeping.
• Equipment: extinguishers, blankets, screens, gas detectors, cylinder storage and inspection schedules.
• Contractor management: prequalification, orientation, permit rules and supervision.
• Training and competence: initial and refresher training for operators, authorizing individuals and fire watches.
• Audits and review: regular checks of permits and field conditions, and annual review of the program.
• Incident reporting and investigation, including near misses such as small fires put out by a fire watch.

Managing contractors

Many serious hot work incidents involve contractors. They may not know the site, its hidden spaces, its processes or what a tank once held. They may be under pressure to finish quickly. The seventh of the CSB's key lessons is to supervise contractors and make sure they understand the site's hot work requirements and hazards. Good contractor management includes:

• Prequalification: checking the contractor's safety record, hot work procedures and training before awarding work.
• Orientation: telling contractors about the site's hazards, emergency procedures and hot work program before they start.
• Clear rules: contractors work under the site's permit system, not their own, unless the owner has reviewed and accepted the contractor's system.
• Information: the owner tells the contractor what equipment held and what is nearby; the contractor tells the owner what processes and gases they will bring.
• Supervision and audit: someone from the owner checks that permits, fire watches and precautions are actually in place.

Under provincial OHS law, owners, constructors and employers have overlapping duties. On construction projects, the constructor or prime contractor coordinates safety for all employers. In industrial settings, the owner must share hazard information and ensure contractors can work safely. Insurers often require owners to keep control of hot work permits even when contractors do the work.

Learning from incidents

Investigations of major hot work incidents show the same failures again and again. Three cases investigated by the US Chemical Safety Board illustrate them; similar incidents have occurred in Canada and elsewhere.

The CSB's seven key lessons, from its 2010 safety bulletin on hot work, summarize what these cases teach: avoid hot work where possible; analyze the hazards first; monitor the atmosphere with a calibrated detector; test the area, including inside equipment and connected spaces, and drain or purge; use written permits; train thoroughly; and supervise contractors.

Building fires from hot work teach complementary lessons: protect combustibles in the full zone, check concealed spaces and the far side of walls, keep the fire watch for the full time, and do not schedule hot work at the end of the day.

Auditing the permit system

Audits check whether the program works in reality. Two kinds are useful. Document audits review a sample of closed permits for completeness and consistency: were gas tests recorded, was the fire watch named and long enough, was the final check signed? Field audits visit active hot work jobs and compare conditions to the permit: are combustibles actually removed, are openings covered, is the fire watch present and watching, is the extinguisher charged?

Audit results should go back to the people who issue and use permits, with clear actions and follow-up. A high score on paper with poor field conditions is a warning sign that permits are being filled in without real inspection.

The cost case

Programs need resources, and managers often ask what hot work controls cost compared with the risk. A simple comparison helps.

Capstone: building a hot work program for a manufacturing plant

Imagine you have been asked to set up a hot work program for a 200-worker metal fabrication and assembly plant in Ontario. The plant has a welding shop, a paint line using solvent-based coatings, a warehouse of packaged finished goods, a roof with torch-applied membrane due for repair, and maintenance contractors who weld on conveyors and racking several times a week. Work through the steps below.

• Legal requirements: list the Ontario Fire Code Section 5.2 requirements, the Occupational Health and Safety Act and Regulation 851 duties, CSA W117.2 as the technical standard, and the insurer's conditions. Set the fire watch at the longest required time, for example 60 minutes by code or longer if the insurer requires, plus a final check.
• Designated area: confirm the welding shop meets designated-area criteria, with noncombustible construction, screens, local exhaust and extinguishers, so routine shop work runs under an area authorization reviewed monthly.
• Bans and restricted areas: ban hot work in the paint line and solvent storage area unless the line is shut down, cleaned, tested and ventilated under a special permit; ban torch-applied roofing and specify a self-adhered or mechanically fastened membrane for the roof repair.
• Permits: introduce a one-page permit with the job, time, people, a precautions checklist, gas test section, fire watch and close-out signatures. Train five maintenance and production supervisors as permit authorizing individuals.
• Fire watches: designate and train a pool of fire watches, make the role dedicated, and set a rule that hot work outside the shop must finish early enough for the fire watch and final check to be completed during staffed hours.
• Equipment: provide hot work carts with two extinguishers, welding blankets of suitable grades, drain covers and a bump-tested combustible gas detector.
• Contractors: prequalify welding contractors, require orientation, require them to work under the plant's permits, and assign an internal contact to audit their jobs.
• Training: initial and refresher training for operators, authorizing individuals and fire watches, including hands-on extinguisher practice.
• Audits: monthly review of a sample of permits and field audits of active jobs, with results reported to the joint committee or safety committee and the plant manager.
• Review: an annual review of the program, incidents, near misses and audit trends.

When you have worked through the capstone, you should be able to explain each choice in terms of the hierarchy of controls, the legal requirements and the incident lessons in this course. That is the test of a good hot work program: every rule has a reason, and every person knows it.