Hot work activities such as welding, cutting, brazing, and grinding create ignition sources that can trigger fires or explosions in areas where flammable or combustible materials are present. Under 29 CFR 1910.119(k), employers must issue hot work permits for any hot work operations conducted on or near a covered process. This element works alongside the fire prevention requirements in 29 CFR 1910.252(a). Ecesis PSM software replaces paper permits with electronic forms featuring approval workflows and centralized record storage.
What OSHA Requires
Under 29 CFR 1910.119(k), the employer must:
- Issue a hot work permit for hot work operations conducted on or near a covered process
- 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
- Identify the object on which hot work is to be performed
- Keep the permit on file until completion of the hot work operations
Step-by-Step Implementation
Design the Hot Work Permit Form
Create a permit form that captures all required information and serves as a checklist for fire prevention measures. Include fields for:
- Date(s) and time(s) authorized for hot work
- Specific location and object on which hot work will be performed
- Type of hot work (welding, cutting, brazing, grinding)
- Fire prevention checklist per 1910.252(a): area cleared of combustibles within 35 feet, flammable liquids and vapors controlled, fire watch assigned, fire extinguisher available, floor openings covered, and combustibles on the other side of walls or floors protected
- Atmospheric monitoring results if applicable
- Signature of person authorizing the permit
- Fire watch sign-off for the required monitoring period after hot work is complete (typically 30 to 60 minutes)
Establish Authorization Procedures
Define who is authorized to issue hot work permits and what pre-work inspections are required:
- Designate specific roles authorized to issue permits (typically operations supervision or safety personnel)
- Require a physical inspection of the hot work area before the permit is issued
- Verify atmospheric conditions in areas where flammable vapors may be present
- Coordinate with operations to confirm process conditions are safe for hot work
- Define conditions under which hot work is prohibited (process upsets, elevated flammable gas readings, insufficient fire protection)
Implement Fire Watch and Post-Work Monitoring
Assign a trained fire watch for all hot work on or near covered processes. The fire watch must:
- Have fire extinguishing equipment available and know how to use it
- Monitor the hot work area continuously during operations
- Continue monitoring for at least 30 minutes after hot work is completed (60 minutes where combustible construction exists)
- Have the authority to stop work if unsafe conditions develop
Document fire watch assignment and completion on the permit form.
File and Retain Permits
OSHA requires permits to be kept on file until completion of the hot work. Best practice is to retain completed permits longer for audit trail purposes. Organize permits chronologically or by work area for easy retrieval during audits. Electronic permit systems provide automatic filing and searchability.
Common Pitfalls to Avoid
How Software Supports This Element
Ecesis PSM software modernizes your hot work permit program:
- Electronic permits: Create customizable hot work permit forms with built-in fire prevention checklists and approval workflows
- Mobile access: Issue and complete permits in the field with electronic signatures and photo documentation
- Automatic filing: Completed permits are automatically stored in a centralized, searchable repository for audit readiness
- Integration: Hot work permits connect with your inspection and audit tools for comprehensive safe work practice management
Frequently Asked Questions
Does every welding job require a hot work permit?
Under PSM, permits are required for hot work operations conducted on or near a covered process. Hot work in designated welding shops that are isolated from process areas may not require a PSM hot work permit, though general industry requirements under 1910.252 still apply.
How long must fire watch continue after hot work?
Per 29 CFR 1910.252(a), fire watch must continue for at least 30 minutes after completion of welding or cutting operations. Where combustible walls, ceilings, or floors are involved, the monitoring period extends to 60 minutes or longer based on conditions.
Can hot work permits cover multiple days?
Permits should specify the authorized dates. Multi-day permits are acceptable for ongoing projects if conditions remain unchanged, but the area should be re-inspected each day before work resumes. Many facilities require daily re-authorization for permits extending beyond one shift.
Who can authorize hot work permits?
OSHA does not specify who must authorize permits, but it should be someone with the authority and knowledge to evaluate fire risks and process conditions. Typically this is an operations supervisor, area superintendent, or safety professional.
How does hot work permitting interact with MOC?
Hot work permits are separate from MOC. However, if hot work is part of a modification to a covered process (such as welding new piping), both the MOC process and hot work permitting apply independently. The MOC addresses the change itself while the hot work permit addresses the fire risk of the work method.
Ecesis PSM Compliance Software
PSM Software
Centralized platform to manage all 14 PSM compliance elements
Management of Change
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Incident Investigation
Report, investigate, and track corrective actions to completion
Training Management
Deliver and track PSM training with comprehension verification
Mechanical Integrity
Schedule inspections, track deficiencies, and manage maintenance
PSM Compliance Calendar
Track deadlines across all 14 elements automatically
