National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 Fax: 617-770-0700 www.nfpa.org M E M O R A N D U M TO: FROM: NFPA Technical Committee on Hot Work Operations Joanne Goyette, Administrator, Technical Projects DATE: March 16, 2012 SUBJECT: ROP TC Letter Ballot (A2013) The ROP letter ballot for is attached. The ballot is for formally voting on whether or not you concur with the committee s actions on the proposals. Reasons must accompany all negative and abstention ballots. Please do not vote negatively because of editorial errors. However, please bring such errors to my attention for action. Please complete and return your ballot as soon as possible but no later than Friday, March 30, 2012. As noted on the ballot form, please return the ballot to Joanne Goyette either via e-mail to jgoyette@nfpa.org or via fax to 617-984-7110. You may also mail your ballot to the attention of Joanne Goyette at NFPA, 1 Batterymarch Park, Quincy, MA 02169. The return of ballots is required by the Regulations Governing Committee Projects. Attachments: Proposals Letter Ballot
51B-1 Log #CP1 Technical Committee on Hot Work Operations, Review entire document to: 1) Update any extracted material by preparing separate proposals to do so, and 2) review and update references to other organizations documents, by preparing proposal(s) as required. The documents or portions thereof listed in this chapter are referenced within this standard and shall be considered part of the requirements of this document. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471. NFPA 10, Standard for Portable Fire Extinguishers, 2013 NFPA 25,, 201108 edition. NFPA 51, Standard for the Design and Installation of Oxygen Fuel Gas Systems for Welding, Cutting, and Allied Processes, 201307 edition. NFPA 55,, 201305 edition. NFPA 241,, 201304 edition. 2.3.1 ANSI Publications. American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036. ANSI Z49.1,, 2005., 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003. NFPA 1,, 201209 edition. A document issued by the authority having jurisdiction for the purpose of authorizing performance of a specified activity. [, 201209] The following documents or portions thereof are referenced within this standard for informational purposes only and are thus not part of the requirements of this document unless also listed in Chapter 2. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169 7471. NFPA 1,, 201209 edition. NFPA 241,, 201304 edition. NFPA 326,, 201005 edition. NFPA 655,, 201207 edition. American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036. ANSI/FM 4950,, 2007. ANSI Z49.1,, 20051999. American Society of Mechanical Engineers, Three Park Avenue, New York, NY 10016-5990. ASME B31.8,, 201000. American Welding Society, 550 N.W. LeJeune Road, Miami, FL 33126. AWS F-4.1,, 20071994. The following documents or portions thereof are listed here as informational resources only. They are not a part of the requirements of this document. NFPA 56 (PS),, 2012 edition NFPA 61,, 1
201308 edition. NFPA 122,, 201004 edition. NFPA 306,, 2009 edition. NFPA 312,, 201106 edition. NFPA 909,, 201005 edition. To conform to the NFPA Regulations Governing Committee Projects. 51B-2 Log #9 1.1.1 This standard shall cover provisions to prevent personal injury, loss of life and/or property from products of combustion, fire or explosion as a result of hot work. A hot work operation can also be the source of a personal injury such as burns, blindness and intoxication. Products of combustion from these operations that may be harmful include: intense light, heat, toxic fumes, smoke, metal air bone particles, vapors, dust, and gases. The prevention to injury, loss of life and/or loss of property from products of combustion (smoke, vapors, heat, etc) is outside the scope of the committee. The Committee agrees with the submitter that the document currently addresses preventing injury during hot work operations. See Committee Proposal 51B-3 (Log #CP2) for the expansion of the document scope to include prevention of injury. 51B-3 Log #CP2 Technical Committee on Hot Work Operations, 1.1.1 This standard shall cover provisions to prevent injury, loss of life and/or loss of property from fires or explosions as a result of hot work. The committee wanted to emphasize the importance of addressing personal safety during hot work operations. Without proper precautions, hot work that results in a fire can be a source of injury such as burns. The committee expanded the scope to clarify that the document currently has provisions that prevent injuries and not just loss of life during hot work operations. 2
51B-4 Log #10 1.2 Purpose. This standard shall provide safety guidance for persons, including outside contractors and property managers, who manage, supervise, and perform request, authorize, perform and supervise hot work. Provisions presented in the standard are safety-related and need not to be confused with performance driven provisions. People who have the empowerment to request and authorize hot work need to be acquainted with the precautions set forth in the standard. Revise text and add annex material as follows: 1.2* Purpose. This standard shall provide minimum requirements guidance for all persons including outside contractors and property managers, who manage, supervise, and perform request, authorize, perform or supervise hot work. A.1.2 Persons that manage, request, authorize, perform or supervise hot work could include but not be limited to contractors, employees, and property managers. The committee disagrees with the submitter to add in the term "safety" as part of the purpose of this standard. By adding the term "safety", the purpose of the standard would then be limited. The committee believes that this standard includes both the performance and the safety of hot work operations. The committee removed the term "guidance" and replaced it with "minimum requirements". The committee wanted to avoid any confusion that would arise with the term "guidance" and clarify that this standard, like all NFPA standards, provides minimum requirements. Additionally, the committee wanted to clarify that everyone who would be involved in the hot work operations would be covered by this document. The Committee added annex material for some examples of who may be involved in hot work operations. 51B-5 Log #11 Add new text to read as follows: 1.3.2 This standard shall not apply to the following: (7) Lockout / tagout procedures during hot work (8) Cleaning and purging of flammable gas piping systems in preparation for hot work NFPA 56 (PS), Standard for Fire and Explosion Prevention During Cleaning and Purging of Flammable Gas Piping Systems covers the referenced topic. The Committee agrees that NFPA 56 (PS),, covers cleaning and purging of flammable gas piping systems. However, NFPA 56(PS) requires that all hot work be in accordance with this standard. The Committee believes that adding in this recommended section would cause confusion to users who go to this standard from NFPA 56(PS). The user upon reading the application section of could get the misconception that does not apply for the particular hot work being performed on the gas piping system. Additionally, it is not necessary to include the recommended section because this standard specifically prohibits hot work to be done in the presence of flammable gases, section 5.3. 3
51B-6 Log #12 Delete the following text: 1.4.1 Unless otherwise specified, the provisions of this standard shall not apply to facilities, equipment, structures, or installations that existed or were approved for construction or installation prior to the effective date of the standard. Where specified, the provisions of this standard shall be retroactive. Hot work is an operation an intangible service rather than a physical product and unlike facilities, equipment, structures, or installations; completed hot work operations cannot be modified. It is thus not possible to rule that a new precaution be provided for a hot work operation that was performed anytime in the past. In this case new provisions can only be applied to present and future (planned) operations and therefore any retroactive clause does not apply. 51B-7 Log #13 Add new text to read as follows: 2.2 NFPA Publications. NFPA 55, 2005 edition. NFPA 56 (PS), Cleaning and purging of flammable gas piping systems is needed prior to conduct any hot work operation in such systems. See action on 51B-1 (Log#CP1), the reference was added to the informational annex, C.2. NFPA Manual of Style requires that the references in Chapter 2 be mandatory references, i.e. references in the mandatory sections of the standard (Chapters 1 through 7 in this standard). 4
51B-8 Log #14 3.3.2 Hot Work. Work involving burning, welding, or a similar operation that is capable of initiating fires or explosions. Hot work is defined as an operation that meets the following conditions: a. It produces heat, flames or sparks b. It is conducted outside a designated area c. It is a non-routine operation Work that it is capable of initiating fires or explosions, such as those listed in Section 1.3.1, are examples of hot work. Some industrial settings; automobile manufacturing for example; use automated welding extensively in their production processes. These operations produce heat, flames and sparks but they are conducted in areas with proper precautions that prevent a fire from occurring. These operations are conducted on a routine basis; a condition that reinforces the need for a safe environment. Operations conducted under these circumstances do not pose a significant fire hazard and therefore do not qualify as hot work. The conditions stated in the submitter's recommended definition is describing a Permit Required Area. Hot work can be performed in a designated area, the work does not depend on the location of where the work is being performed. Additionally, the submitter's substantiation is describing an example of a designated area. The Committee does not want to exclude routine hot work from this standard. 51B-9 Log #15 3.3.4 Permit. A document issued by the authority having jurisdiction for the purpose of authorizing performance of a specified activity. [1, 2009 2012] The 2012 edition of NFPA 1 has already been issued. See action on 51B-1 (Log#CP1). 5
51B-10 Log #8 Marcelo M. Hirschler, GBH International A heat-resistant fabric designed to be placed in the vicinity of a hot work operation. Intended for use in horizontal applications with light to moderate exposures such as that resulting from chipping, grinding, heat treating, sand blasting, and light horizontal welding. Designed to protect machinery and prevent ignition of combustibles such as wood that are located adjacent to the underside of the blanket. A heat-resistant fabric designed to be placed in the vicinity of a hot work operation. Intended for use in vertical applications with light to moderate exposures such as that resulting from chipping, grinding, heat treating, sand blasting, and light horizontal welding. Designed to prevent sparks from escaping a confined area. A heat-resistant fabric designed to be placed directly under a hot work operation such as welding or cutting. Intended for use in horizontal applications with severe exposures such as that resulting from molten substances or heavy horizontal welding. Designed to prevent the ignition of combustibles that are located adjacent to the underside of the pad. Intended for use in horizontal applications with light to moderate exposures such as that resulting from chipping, grinding, heat treating, sand blasting, and light horizontal welding. Designed to protect machinery and prevent ignition of combustibles such as wood that are located adjacent to the underside of the blanket. Welding blankets are required to be listed, approved, or the equivalent for such use. One such listing includes ANSI/FM 4950,. Intended for use in vertical applications with light to moderate exposures such as that resulting from chipping, grinding, heat treating, sand blasting, and light horizontal welding. Designed to prevent sparks from escaping a confined area. Welding curtains are required to be listed, approved, or the equivalent for such use. One such listing includes ANSI/FM 4950,. Intended for use in horizontal applications with severe exposures such as that resulting from molten substances or heavy horizontal welding. Designed to prevent the ignition of combustibles that are located adjacent to the underside of the pad. Welding pads are required to be listed, approved, or the equivalent for such use. One such listing includes ANSI/FM 4950,. The NFPA Manual of Style requires definitions to be in single sentences. The added sentences should not be part of the definition (and in this case they are simply added explanations) but should be in the body of the document or in an annex note, as recommended in this proposal. A heat-resistant fabric listed, approved, and designed to be placed in the vicinity of a hot work operation. Intended for use in horizontal applications with light to moderate exposures such as that resulting from chipping, grinding, heat treating, sand blasting, and light horizontal welding. Designed to protect machinery and prevent ignition of combustibles such as wood that are located adjacent to the underside of the blanket. A heat-resistant fabric listed, approved, and designed to be placed in the vicinity of a hot work operation. Intended for use in vertical applications with light to moderate exposures such as that resulting from chipping, grinding, heat treating, sand blasting, and light horizontal welding. Designed to prevent sparks from escaping an a confined area. A heat-resistant fabric listed, approved, and designed to be placed directly under a hot work operation such as welding or cutting. Intended for use in horizontal applications with severe exposures such as that resulting from molten substances or heavy horizontal welding. Designed to prevent the ignition of combustibles that are located adjacent to the underside of the pad. Welding blankets are required to be listed, approved, or the equivalent for such use. One such listing includes ANSI/FM 4950,. Welding curtains are required to be listed, approved, or the equivalent for such use. One such listing includes ANSI/FM 4950,. 6
Welding pads are required to be listed, approved, or the equivalent for such use. One such listing includes ANSI/FM 4950,. The NFPA Manual of Style does not limit definitions to a single sentence. The added sentences provide the distinction between the definitions of welding blanket, curtain, and pad. The committee added third party validation of the performance of the welding blankets, curtains, and pads to ensure that the appropriate requirements are met. 51B-11 Log #18 4.1* Responsibility Management. Management or a designated agent shall be responsible for the safe operations of hot work activity. along with those who request, authorize, perform and supervise hot work operations, shall all recognize their responsibility for safety in this type of operations. As stated in section 4.6, all persons involved in hot work operations should be responsible for safe practices; there is no need to have two sections with the same provision and section 4.6 should be deleted in favor or a revised version of section 4.1. The submitter's recommendation is a duplicate of the existing requirement in section 4.6. The Committee believes that the submitter's intent is addressed in the current text. Additionally, Chapter 4 gives the requirements on the responsibilities and roles of each person involved in the hot work operations. The addition of the recommendation is not consistent with the rest of the format of the chapter. 51B-12 Log #16 Add new text to read as follows: 4.1.1 Management. Management shall issue a hot work policy and help establish formal procedures, form permits and an audit system to help manage hot work operations. A policy is needed to prevent discretionary use of the system; formal procedures are needed to eliminate room for confusion on what needs to be done regarding hot work; form permits are needed to help ensure that relevant precautions are not being overlooked, through a checklist, and also serve as proof of adherence to the system; an audit system will help detect and correct any deviations in the use of the established procedures. The Committee believes the current text adequately address what the submitter is intending. Section 4.1 describes the responsibilities for management. Additionally, the submitter's recommendation on hot work permit forms is addressed in section 5.4 which requires a written hot work permit before hot work is to be performed outside a designated area. 7
51B-13 Log #17 4.1.1 Management shall establish permissible areas for hot work permission requirements for each area, as follows: a. Permissible areas. Areas as described in Sections 3.3.1 and 5.2.2.1 b. Permit-required areas. Areas as described in Section 5.2.2.2 c. Non-permissible areas. Areas as described in Section 5.3 Designating a fire hazard level for each area, will help prevent room for confusion as to the safety precautions required on each of them. The Committee believes the current text adequately address the submitter's is intent. The intent of the recommendation, hot work permission requirements for an area, is currently addressed in section 5.2 and 5.3. These areas are established by the management. 51B-14 Log #2 Robert Bourke, Northeastern Regional Fire Code Development Committee Add new Section 4.1.6.3 to read as follows: Individuals involved in hot work operations shall be cognizant of weather conditions such as changes and increases in the wind that may necessitate the use of a fire watch and/or hot work permits that may otherwise not have been required prior to the changes in weather conditions. Information added is of a significant concern regarding fire hazard recognition of those individuals involved in hot work operations in that weather conditions oftentimes contribute to fires from wind-driven sparks or hot products that may travel beyond that which was anticipated prior to changes in weather conditions. The Committee believes that the intent of the submitter's recommendation is addressed in sections 4.1.6.2 and 5.4.2(14). 8
51B-15 Log #19 5.2.2.1 3.3.1 Designated Areas. A designated area shall be a specific area designed or approved for hot work, 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. The Designated Area definition in section 5.2.2.1 is more comprehensive than the definition in section 3.3.1; there is no need to have two definitions of the same concept in the standard. Renumber and revise text to read as follows: 1 A permanent specific location designed and or 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. Any location other than a designated area that is approved for hot work. A permit-required area is an area that is made fire safe by removing or protecting combustibles from ignition sources. Delete the following section: 5.2.2.1 Designated Areas. A designated area shall be a specific area designed or approved for hot work 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. 5.2.2.2 Permit-Required Area. 5.2.2.2.1 A permit-required area shall be an area that is made fire safe by removing or protecting combustibles from ignition sources. The committee believes that the recommended text meets the intent of the submitter's recommendation. The expectation of the designated area requires a higher degree of preparation and qualifications than a permitted area. Additionally, the committee added text for clarity of permit-required area versus designated area. 51B-16 Log #20 5.2.2.2.1 3.3.6 A permit-required area shall be an area that is made fire safe by removing or protecting combustibles from ignition sources. Section 5.2.2.1 is a term definition which should be part of Chapter 3. See Committee Action on 51B-15 (Log #19). See Committee Statement on 51B-15 (Log #19). 9
51B-17 Log #4 James Everitt, Western Regional Fire Code Development Committee 5.3* Nonpermissible Areas. Hot work shall not be permitted in the following areas: (6) Elevated Locations where wind can carry hot embers beyond the view of the fire watch unless measures are taken. Personnel experience on a television tower grass fires were breaking out blocks away. 4.4.3. The submitter's concerns are addressed in other parts of the standard, sections 5.4, 4.1.7, and 51B-18 Log #CP3 Technical Committee on Hot Work Operations, Renumber and revise text to read as follows: 5.4.3* Based on local conditions, The PAI shall determine the length of the period for which the hot work permit is valid. 5.4.4 A hot work permit shall not be valid for a period exceeding 24 hours. A.5.4.3 It is advisable that the permit be issued for a maximum period of 24 hours. 5.4.54* The area shall be inspected by the PAI at least once per day shift while the hot work permit is in effect to ensure that it is a fire-safe area. A.5.4.4 In some situations, it is advisable to inspect the area once per shift if conditions warrant. For a period exceeding 24 hours there is a significant chance in the change in personnel and/or conditions. Due to the change in personnel and conditions, routine reevaluation is essential to ensure fire safe environment during hot work operations. 51B-19 Log #3 Robert Bourke, Northeastern Regional Fire Code Development Committee Add new Section to read as follows: Pipes or other metals involved in hot work process are in contact with combustible walls, partitions, ceilings, roofs, or other combustibles that may cause ignition by conduction. This new text incorporates fire hazard recognition common to hot work operations and fire causation resulting from a common heat transfer mechanism. The submitter's recommendation is addressed in section 5.4.2(9) and 5.5.1. Section 5.4.2(9) does not permit hot work if the work is close enough to cause ignition by conduction. Accepting the submitter's recommendation would be in contradiction of 5.4.2(9) because it would require a fire watch where 5.4.2 already did not permit the hot work to be done. 10
51B-20 Log #6 Scott Adams, Western Regional Fire Code Development Committee Each site shall be provided with a portable fire extinguisher of appropriate size and type in accordance with NFPA 10,, and with a pail of water. Gives guidance to user and PAI on the selection and type of fire extinguishers to be used for the given situation and hazard. Each site shall be provided with a portable fire extinguisher of appropriate size and type in accordance with NFPA 10,. and with a pail of water. The Committee agrees with the submitter's recommendation that having an appropriate fire extinguisher for the site. The Committee removed the existing requirement for a pail of water. The pail of water might not be the correct method of extinguishment for the hazard and could create a higher hazard. 51B-21 Log #7 Scott Adams, Western Regional Fire Code Development Committee Add new text to read as follows: When required by the AHJ, permits shall be obtained from the local AHJ. In many jurisdictions local fire codes require the AHJ to issue permits for these types of operations in Public Exhibitions and Demonstrations. By adding this reference, it will assist the user by identifying to PAI to verify that a permit is needed by AHJ. As is, 7.4.3 will result in use of the local permit system as required by the local Fire Department, if and when needed. 11
51B-22 Log #1 Steven E. Daily, Anheuser-Busch Companies Welding blankets are required to be listed or approved or equivalent for such use. One such listing includes ANSI FM4950, Welding curtains are required to be listed or approved or equivalent for such use. One such listing includes ANSI FM4950, Welding pads are required to be listed or approved or equivalent for such use. One such listing includes ANSI FM4950, Combustible floors shall be kept wet, covered with damp sand, or protected by a listed or approved welding blanket or welding pad or equivalent. One such listing includes ANSI FM4950, If relocation is impractical, combustibles shall be protected by a listed or approved welding curtain, blanket, or welding pad or equivalent. One such listing includes ANSI FM4950, If hot work is done near walls, partitions, ceilings, or roofs of combustible construction, they shall be protected by a listed or approved welding curtain, blanket, or welding pad or equivalent. One such listing includes ANSI FM4950, The request is emergency in nature because ANSI FM4950 was not available previously. It is imperative to public safety that users are aware that there is a standard to which their products (welding pads, blankets and curtains for welding) can be listed for the use, thereby contributing to lessening a recognized hazard. The standard is an advance in safeguarding property and life and was previously unavailable to the public. 1. See 51B-10 (Log#8) for additional annex text as recommended. 2. Combustible floors shall be kept wet, covered with damp sand, or protected by a listed or approved welding blanket or welding pad or equivalent. If relocation is impractical, combustibles shall be protected by a listed or approved welding curtain, blanket, or welding pad or equivalent. If hot work is done near walls, partitions, ceilings, or roofs of combustible construction, they shall be protected by a listed or approved welding curtain, blanket, or welding pad or equivalent. Do not add annex to 5.4.2(2)(a), 5.4.2(3)(a), and 5.4.2(6) See the committee's action in 51B-10 (Log #8) for the first part (A.3.3.7, A.3.3.8, and A.3.3.9) of the submitter's. The committee edited the second part of the recommendation to be consistent with the the actions taken for 51B-10 (Log #8), third party validation of the performance of the welding blankets, curtains, and pads to ensure that the appropriate requirements are met. The committee believed that the reference to ANSI FM4950 in the definitions is sufficient and having in 5.4 annex would be redundant. 12
51B-23 Log #1a Technical Committee on Hot Work Operations, Do not incorporate this figure, but consider citing an authoritative reference to add for the next revision. As noted in Gus Manz' comments on the affirmative on this proposal, the apparatus doesn't have the temperature, but rather the flame itself. Additionally, the source should be cited as well as incorporating other information. A Task Group of Mark Blank and Chris Bloom will work on this and will submit a specific proposal for next revision. considering this figure. The committee decided not to add in the figure at this time and investigate further before 13