In the grain handling industry, the phrase “hot work” can evoke a sense of anxiety among elevator managers, safety leaders, property insurers, and employees. Hot work, which includes activities like brazing, cutting, grinding, soldering, and welding, has been the cause of numerous fires and grain dust explosions. The heat generated from these activities can ignite combustible dust on surfaces and in suspension, resulting in smoldering fires, flash fires, and potentially catastrophic explosions. This post will explore the necessary precautions related to hot work, as required under OSHA Welding, Cutting, and Brazing Standard 1910.252 and OSHA Grain Handling Standard 1910.272.
Permit Authorization
OSHA’s Grain Handling Standard requires a hot work permit for all hot work performed within or near grain handling and storage areas. However, there are exceptions, such as when the employer or a representative is present during the hot work, or when the work takes place in welding shops or designated hot work areas outside the grain handling structures. Many companies opt to issue hot work permits for all work in or near grain handling areas as a best practice. It is essential to take a conservative approach to hot work in these environments.
A hot work permit includes details such as the work’s location, the nature of the task, and the name of the person performing the work. The permit requires the signature of an authorized person (e.g., a supervisor or fire safety officer), signifying that they have examined the area and confirmed all necessary precautions are in place before proceeding with the work.
Required Precautions
Hot work permits reflect the minimum safety precautions required under OSHA’s Welding, Cutting, and Brazing Standard 1910.252 (a) and are also referenced in the Grain Handling Standard. The precautions listed on the permit must be implemented before any hot work is allowed. These precautions are divided into several sections, including requirements for the area within 35 feet of hot work, equipment conditions, and fire watch considerations. Some of the common precautions include:
- Ensuring that sprinklers and hose streams are operational.
- Ensuring hot work equipment is in good condition (e.g., welding leads, torches).
- Ensuring fire extinguishers, hoses, and other firefighting tools are operable.
- Removing or covering combustible materials, including grain dust and oily deposits.
- Ensuring that explosive atmospheres are eliminated.
- Covering floors and walls with fire blankets or damp sand.
- Protecting ducts, conveyors, bucket elevators, and other equipment that may carry sparks to distant combustible materials.
These precautions must be clearly marked on the permit, and the responsible person must confirm their implementation.
Fire Watch Requirements
OSHA’s standards for fire watch specify that fire watchers must be present whenever hot work is performed in locations where fires could develop. Specifically, a fire watch is required when:
- Combustible materials are within 35 feet of the work area.
- Combustible materials are more than 35 feet away but can easily be ignited by sparks.
- There are floor or wall openings within 35 feet that could expose combustible material to sparks.
- Combustible materials are adjacent to metal partitions, walls, or ceilings, where conduction or radiation could cause ignition.
Many companies go beyond the OSHA minimum and require a fire watch whenever hot work is conducted. Fire watch personnel must be trained in using fire-extinguishing equipment and know how to initiate evacuation procedures if necessary. OSHA mandates that fire watch be maintained during and for at least 30 minutes after the completion of the hot work to detect and extinguish potential smoldering fires. However, many grain handling facilities and insurance providers recommend extending the fire watch period to monitor for up to several hours after the work is completed, as grain dust can smolder for a long time after the visible heat has dissipated.
Hot work poses significant fire hazards in grain handling facilities. While OSHA standards set the minimum requirements, these guidelines should not be seen as a ceiling. Given the extreme risks associated with grain dust, it’s vital to adopt a conservative and proactive approach. Going above and beyond the minimum requirements is essential to protect employees, contractors, and the facility. Remember: don’t play with fire—take the necessary precautions, issue hot work permits, ensure proper fire watch, and continuously monitor for hazards.