2.3 - Hot Work

2.
3 Hot work
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TABLE OF CONTENTS:
(Click on any topic below to follow the hyperlink)
PURPOSE:........................................................................................................................................ 2
SCOPE:............................................................................................................................................. 2
DEFINITIONS:.................................................................................................................................. 2
I. STANDARDS:................................................................................................................................ 3
II. PROCEDURES:............................................................................................................................ 3
Hot Work area classification.............................................................................................................. 3
Restrictions on Hot Work................................................................................................................... 4
Re-classification of Hot Work Areas.................................................................................................. 4
Flammable Area Preparation............................................................................................................. 4
General Area Preparation.................................................................................................................. 5
Clearing the Area............................................................................................................................... 5
Fire extinguishing equipment............................................................................................................. 5
Use of Enclosures............................................................................................................................. 5
Safe Work Permitting for Hot Work.................................................................................................... 5
When an SWP is required for Hot Work........................................................................................... 6
Prior to the high energy Hot Work in a Flammable Area....................................................................6
Fire watch.......................................................................................................................................... 6
The Fire watch shall.......................................................................................................................... 7
Designation of Fire watch.................................................................................................................. 7
Purging.............................................................................................................................................. 7
Flammable Atmospheric Monitoring.................................................................................................. 7
Hot Work Operating Procedure......................................................................................................... 8
Documentation Requirements........................................................................................................... 9
Audit Requirements........................................................................................................................... 9
III. TRAINING:................................................................................................................................... 9
Following personnel shall receive working level training...................................................................9
Fire Watch......................................................................................................................................... 9
Re-training on requirement.............................................................................................................. 10
Awareness level training.................................................................................................................. 10
IV. ACCOUNTABILITIES:............................................................................................................. 10
Department Manager....................................................................................................................... 10
Fire watch........................................................................................................................................ 10
Person Issuing SWP........................................................................................................................ 10
Person Accepting SWP................................................................................................................... 10
V. REFERENCES:........................................................................................................................... 10
APPENDIX A (GENERAL EXEMPTIONS)......................................................................................11
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PURPOSE:
To provide requirements for doing work that has the potential to generate a source of ignition in
areas where flammable or combustible materials may be present.
SCOPE:
These requirements apply to all Hot Work done by all personnel in the facilities owned or operated
by EQUATE. Exemptions are listed in Appendix-A.
DEFINITIONS:
Term
Definition
Combustible
Combustible materials include:
All liquids that can burn with a flash point above 37.8 C.
All solids (wood, polymer, scaffolding boards, coal, charcoal, straw,

leaves, etc.) that can burn.
Exempt Area
Outside Battery Limits (OSBL) and greater than 10 meters from a Potential
Source of flammable materials and free of Combustible materials. (For
example: maintenance and shop areas and office areas free of
Combustible and flammable materials, road ways and parking lots, marked
smoking areas). Note: These areas fall outside the scope of this policy.
Flammable Area
Within 10 meters of a Potential Source of flammable materials
Flammable
Flammable materials include:
Any gas that will burn in air.
All liquids with a flash point at or below 37.8C.
Any solid dusts that when suspended in air can be ignited.
General Area
Inside Battery Limits (ISBL), or within 10 meters of a Potential Source of

Combustible materials, but greater than 10 meters of a Potential Source of
flammable materials. Note: Warehouses and other non-process buildings
may be considered General Areas provided that the only source of
flammable materials are room heaters that use fuels that have good
physical warning properties at levels well below the LEL of the flammable
material (example natural gas used for heating).
High Energy Ignition

Source (High Energy
Hot Work)
Includes activities that generate open flames and/or sparks and activities
that could provide an ignition source after an immediate removal of the
energy supply (for example: welding, flame cutting, grinding metals, fired
heaters, etc).
Hot Work
Work that has the potential to generate a source of ignition in areas where
flammable or Combustible materials may be present.
Ignition Source
Any Potential Source that could ignite flammable or Combustible materials.

For example: burning, welding, flame cutting, heating with an open flame
or an electrical device, operating internal combustion engines and the use
of any other spark, flame or high temperature producing equipment or tools
such as pneumatic hammers, grinders, electric drills, etc This includes
Low Energy Ignition Sources and High Energy ignition sources.
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Term
Definition
Low Energy Ignition

Source (Low Energy
Hot Work):
Includes activities that generate heat or have the potential to generate

sparks and activities that generally do not provide an ignition source after a
removal of the energy supply (for example: electrical/battery operated
tools, non-intrinsically safe portable equipment - including mobile phones
and pagers, cameras, abrasive blasting, air driven tools, soldering irons,
internal combustion engines and motor vehicles, extension cords, or the
use of hand tools that could generate sparks - like chisels and hammer
wrenches, etc)
Potential Source of
Flammable Materials
A valve, flange, sample point, vessel, tank, vent, overflow, drain or relief
device etc that has a potential to release flammable materials, either to
the atmosphere or into the equipment being worked on.
A source of flammable materials is only a Potential Source if it is within 10
meters of Hot Work and has a direct path to the source of ignition used
during the Hot Work - either through piping or un-restricted atmosphere.
(For example: if a physical barrier - wall, building, etc is blocking the
atmospheric path between the source of flammable materials and the
source of ignition then it may not be reasonable to consider it a Potential
Source of flammable materials.)
Restricted Area
An area in which there is a continuous presence of flammable materials in

the atmosphere. Hot Work shall not be done. (For example: floating roof
tank, directly over sewer drains, etc with flammables present.)
I. STANDARDS:
Refer to the Global Hot Work standard of Dow.
II. PROCEDURES:
A. Hot Work area classification:

1.
Hot Work areas are classified as Restricted, Flammable, General or

Exempt. (See definitions).
2.
Department Managers shall document the Hot Work classification of each

specific area of their facility. Department Manager shall review this list annually.
3.
Hot Work classifications shall be determined based upon proximity to

flammable and combustible materials.
Note: Flammable materials brought into the area to do Hot Work do not affect
the area classification. Example: cylinders that feed welding / cutting torches.
B. Restrictions on Hot Work:

1.
Hot Work shall not be done in a Restricted Area.
2.
Hot Work shall be done in Flammable or General Areas only if there is no

other practical means to do the job or if the equipment to be worked on can not be
removed to an Exempt Area.
C. Re-classification of Hot Work Areas: Appendix-B shall be completed for

reclassification of areas.
1.
Department Manager may temporarily re-classify a Restricted Area as a

Flammable Area only when:
a)
The potential sources of flammable materials have been removed from

the area, or
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b)
The process is currently not operating, all flammable materials have

been isolated and flammable materials are not detectable in the Hot
Work area.
2.
A Restricted Area that has been temporarily re-classified as a Flammable

Area shall not be further re-classified as a General or Exempt Area.
3.
Department Manager may temporarily re-classify a Flammable or General

Area as an Exempt Area only when:
a)
There are currently no potential sources of flammable materials within

10 meters, and
b)
The area is Inside Battery Limits (ISBL) but the process is currently not
operating or the area is Outside Battery Limits (OSBL).
D. Flammable Area Preparation: Prior to any High Energy Hot Work, and when
Combustible or flammable materials are potentially present in, below or above the Hot
Work in a Flammable Area then:
1.
Those combustible or flammable materials that can be moved shall be

removed to a distance of 10 meters, or
2.
The equipment to be worked on that can be moved shall be removed to an

Exempt Area, or
3.
Guards shall be used to minimize contact with the source of ignition. For
example, the following in order of preferred method:
a)
A 5 sided (4 walls plus floor) spark containment structure utilizing fire

resistant tarp material, or
b)
A 4-sided containment (walls only) spark containment structure when

the floor is concrete, gravel or other non-Combustible material and it is
free of Combustible hazards, or
c)
Water sprays on the Potential Source of flammable materials, or
d)
Wetted fire tarps on the Potential Source of flammable materials.
E. General Area Preparation: Prior to any High Energy Hot Work, and when Combustible
materials are present in, below or above the Hot Work in a General Area then the
following shall be considered:
1.
Combustible materials that can be moved are removed to a distance of 10

meters, or
2.
The equipment to be worked on that can be moved is removed to an

Exempt Area, or
3.
Guards are used to minimize contact with the source of ignition. See
procedure D3 above.
F.
Clearing the Area:
1.
During Hot Work in a Flammable or General Area, the area around the Hot
Work shall be clear of all persons not directly involved.
2.
Barricades shall be used when there is a potential for the people who are
not directly involved in the high energy Hot Work to enter the area.
G. Fire extinguishing equipment (for example: fire extinguishers) shall be identified,

continuously available and easily accessible in the area where High Energy Hot Work
is to be performed.
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H. Use of Enclosures: Requirements of policy 5.4 (CSE), 5.10 (Protection From OxygenDeficient Atmospheres and 5.11 (Enclosed Area) shall be followed when enclosures,
fireboxes, tarps or any other guard is used that has:
I.
J.
1.
The potential for limited ventilation, or
2.
The potential for an oxygen enriched or oxygen deficient atmosphere, or
3.
The potential for vapor, liquid or solid engulfment,
Safe Work Permitting for Hot Work:
1.
Refer to Policy 5.3 for SWP requirements for Hot Work.
2.
Authorized Operating Procedure Users are not required to have an SWP for
Hot Work (as specified by policy 5.3) provided that the work is covered by a
Hot Work Operating Procedure (for example: a furnace/burner light-off by
operations), which shall address all of the requirements of this document.
When an SWP is required for Hot Work:
1.
The exact location of the Hot Work shall be identified during the on-site
SWP inspection, and
2.
The flammable and/or combustible material(s) within the area and the
material(s) last contained in the equipment shall be identified on the Safe Work
Permit.
3.
The Person Issuing an SWP for Hot Work shall ensure that the following
is understood by the Person Accepting an SWP and documented:
a)
The location of the Hot Work, the classification of the area (Flammable
or General, etc),
b)
The potential hazards, and
c)
The necessary precautions to eliminate or minimize the potential

hazards.
K. Prior to the High Energy Hot Work in a Flammable Area, the person issuing the SWP
shall conduct an on-site inspection of the Hot Work area to verify that all following
requirements have been met:
1.
The area where Hot Work is to be done is prepared per the requirements
of this policy.
2.
That the area classification is correct.
3.
The Hot Work area has been cleared of all persons not directly involved in
the Hot Work.
4.
The equipment has been prepared for Hot Work per the requirements of
this policy, including isolation of energy sources and line & equipment opening
requirements.
5.
The potential hazards have been documented and communicated.
6.
The necessary precautions to eliminate or minimize the potential hazards,

including flammable atmospheric monitoring requirements have been documented
and communicated, and
7.
The exact location of the Hot Work has been identified during the on-site
SWP inspection.
L.
Fire watch:
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1.
A Fire watch, other than the person performing the Hot Work, shall be
present during all High Energy Hot Work in Flammable or General Areas when:
a)
There are combustibles or flammables within 10 meters of the Hot

Work, or
b)
There are Combustibles or flammables at a distance of greater than 10

meters that could easily be ignited.
2.
The Fire watch shall be present for at least 30 minutes after all High
Energy Hot Work is done when there are Combustible or flammable materials:
3.
a)
That are contained in walls, partitions, etc.., that could be ignited by

radiation or conduction, or
b)
That could smolder and ignite over time.
Additional Fire watch shall be present when, but not limited to:
a)
There are Combustible or flammable materials at elevations above

and/or below the Hot Work that would be difficult for the first Fire watch
to meet his responsibilities.
b)
The area observed by a Fire watch extends beyond a distance that

would be difficult for the first Fire watch to meet his responsibilities.
M. The Fire watch shall:

1.
Not be assigned any additional duties or tasks which will in any way
conflict with his responsibility as a Fire watch.
2.
Continually observe the actions of the person doing the Hot Work and
surrounding conditions, and
3.
In the event of an injury, fire, gas release or other emergency, shut down
Hot Work equipment, alert the person doing the Hot Work and initiate the proper
response for the situation.
N. Designation of Fire watch: Facility shall document the names of their Fire watches.
Only people who have all of the following shall be designated to be Fire watch for Hot
Work:
1.
Knowledge of his responsibilities, and
2.
Knowledge of the work to be done and the specific tasks and the impact
that these will have on the Hot Work and vice versa, and
3.
Knowledge of the proper procedures for shutting down the Hot Work
equipment in case of emergency, and
4.
Trained on the proper use of flammable atmospheric monitoring equipment

that they will use (if any) and the specific fire extinguishing equipment provided.
O. Purging: When inert purging is used to clear contents to acceptable levels, then the
SWP for Hot Work or the Hot Work Operating Procedure shall:
1.
Indicate the purge gas to be used.
2.
Describe how the purging will be done.
3.
Address considerations for ventilation and personnel protection in a

potentially oxygen deficient atmosphere.
P.
Flammable Atmospheric Monitoring:
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1.
Flammable atmospheric monitoring (LEL) shall be done for all Hot Work in
Flammable Areas.
2.
When a Facility has General Areas that border upon Flammable Areas,
flammable atmospheric monitoring (LEL) shall be done for all High Energy Hot
Work in those General Areas.
3.
Flammable atmospheric monitoring shall be done:
a)
When an SWP for Hot Work is required.
b)
At the time of the on-site inspection.
c)
When the safe working conditions upon which the SWP for Hot Work
are based are not being maintained and/or have changed.
d)
Periodically or continuously as specified on the SWP for Hot Work.
e)
If the SWP for Hot Work is suspended and needs to be re-authorized

because of a work stoppage.
f)
When a Hot Work Operating Procedure is being used as specified in the

Hot Work Operating Procedure.
4.
The date, time, name of the person performing the flammable atmospheric
monitoring and detected level of flammables (LEL) shall be documented.
5.
Hot Work shall not be done when the flammable atmospheric monitoring
has detected a flammable material (for example: the meter has detected a reading
above zero LEL).
6.
When conducting flammable atmospheric monitoring of flammable

materials in an inert atmosphere a meter specifically designed for such
measurement shall be used.
7.
A Hot Work Operating Procedure can be used in place of an SWP for

authorizing Hot Work only when:
a)
The Hot Work Operating Procedure is used by Authorized Operating

Procedure Users only.
b)
The Hot Work Operating Procedure is specific to the Hot Work job.
Q. The Hot Work Operating Procedure shall document and communicate:

1.
The location of the Hot Work.
2.
The flammable and/or combustible material(s) within the area and the
material(s) last contained in the equipment.
3.
The classification of the area (Flammable or General, etc).
4.
The status of the line or equipment to be worked on.
5.
Flammable atmospheric monitoring requirements to include:
a)
The specific needs for flammable atmospheric monitoring, to include

periodic or continuous monitoring needs.
b)
The location of all points where flammable atmospheric monitoring

checks are to be made.
c)
The frequency of flammable atmospheric monitoring checks when

periodic monitoring is to be done.
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d)
e)
The specific needs for subsequent flammable atmospheric monitoring

when:
(1)
There is a work interruption due to an emergency or plant

operating problem.
(2)
The safe working conditions upon which the Hot Work

Operating Procedure is based are not being maintained
and/or have changed.
The potential hazards and the necessary precautions to eliminate or

minimize the potential hazards.
R. Documentation Requirements:
1.
Safe Work Permits and Hot Work Operating Procedures
2.
Hot Work Area Classifications for the Facility.
3.
Documented list of personnel authorized to be fire-watch.
S. Audit Requirements: Annual internal audits shall be carried out to determine if the
Facility complies with the requirements of this policy. The specific minimum Audit
requirements for Hot Work include, but are not limited to:
1.
Does the Facility have a Hot Work program in place that meets the
requirements of this policy?
2.
Are Safe Work Permits and Hot Work Operating Procedures being used?
Do they meet the requirements of this policy?
3.
Is Hot Work being done without incident?
4.
Do people understand and are they meeting their responsibilities?
5.
Has training been done, is it documented and has it been successful?
III. TRAINING:
A. Following personnel shall receive working level training on this policy:

1.
Fire Watch
2.
Person Issuing an SWP
3.
The Person Accepting an SWP
4.
The Authorized Operating Procedure Users
B. Additional Training requirements for Fire Watch:

1.
When needed, the proper operation and use of any flammable

atmospheric monitoring equipment that he/she will use.
2.
The proper operation of fire extinguishing equipment that he/she will use.
3. Re-training whenever these tools, equipment, methods, techniques, or procedures

are modified or changed.
4.
Additionally, the personnel conducting flammable atmospheric monitoring

for Hot Work shall be trained on the use of flammable gas monitoring meters.
C. Re-training on requirement every 3 years or when new or modified procedures or

methods are introduced or when an audit or event indicates a need for re-training.
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D. Awareness level training shall be provided to all other EQUATE personnel as

determined by their respective department manager. These personnel shall be given
re-training whenever the policy is revised.
IV. ACCOUNTABILITIES:
A. Department Manager:
1.
Document and maintain the list of Hot Work Area Classifications for the
Facility.
2.
Document and maintain a list of all personnel designated as fire watches.
3.
Ensure that either an SWP is issued or a Hot Work Operating Procedure is

being used for all Hot Work within the Facility.
B. Fire watch:
1.
Not be assigned any additional duties or tasks which will in any way
conflict with his responsibility as a Fire watch
2.
Continually observe the actions of the person doing the Hot Work and
surrounding conditions, and
3.
In the event of an injury, fire, gas release or other emergency, shut down
Hot Work equipment, alert the person doing the Hot Work and initiate the proper
response for the situation.
C. Person Issuing SWP Refer to procedure-K.

D. Person Accepting SWP Refer to procedure J-3.
V. REFERENCES:
A. Global Hot Work standard of DOW.
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Document History:
Approved by: VP-Operations
Date: 3 Oct-04
The following information documents at least the last three changes to this document, with
all changes listed for the last 3 months (most current is first).
DActivity by
a
t
e
20 Oct 2005
Sabir
Activity
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1. Document history block added
2. Header/footer modified.
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APPENDIX A (GENERAL EXEMPTIONS)

General exemptions to the requirements of this policy:
A. Exempt Areas
B. Refueling of motor vehicles at a refueling station.
C. Travelling motor vehicles in General or Flammable Areas on road ways
that are Outside Battery Limits (OSBL).
D. Motor vehicles in General or Flammable Areas that are Inside Battery
Limits (ISBL), provided that a vehicle entry procedure exists that
documents the safeguards determined based on the hazards in those
areas.
E. Shop areas may be exempted
1.
from the other requirements of this policy, provided that:
1.
Any flammable liquids or gases used in the shop area have good
physical warning properties at levels well below the LEL of the
flammable material. (Example natural gas used for heating).
2.
All hoses and tanks of fuels used for torches shall be checked for
leaks prior to use.
3.
The area around the Hot Work shall be clear of all persons not
directly involved.
4.
When there is the potential that people who are not directly
involved in the Hot Work can enter the area then barricades shall
be used.
5.
Combustible / flammable materials that can be moved are

removed or protected from ignition.
6.
Fire extinguishing equipment (for example: fire extinguishers)

shall be identified, continuously available and easily accessible in
the area where High Energy Hot Work is to be performed.
7.
In the event of an injury, fire, gas release or other emergency all

Hot Work equipment (welding machines, flame cutting, drilling,
etc.) shall be shut down and Hot Work shall be suspended until
the emergency is cleared.
8.
A procedure shall be in place to ensure all equipment and items

brought into the area are cleaned of all flammable material.
9.
When the shop area is adjacent to Flammable Areas, or when

flammable gases or vapors are suspected, then flammable
atmospheric monitoring shall be performed prior to High Energy
Hot Work and shall be performed prior to re-start if Hot Work is
suspended due to an emergency.
EQUATE restricted
Revision Date: NA

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2.

Issue Date: 31 Dec-04

2.3 Hot work

Combustible materials include:

All solids (wood, polymer, scaffolding boards, coal, charcoal, straw,

Within 10 meters of a Potential Source of flammable materials

Flammable materials include:

Any gas that will burn in air.

All liquids with a flash point at or below 37.8C.

Any solid dusts that when suspended in air can be ignited.

Inside Battery Limits (ISBL), or within 10 meters of a Potential Source of

High Energy Ignition

Any Potential Source that could ignite flammable or Combustible materials.

Issue Date: 31 Dec-04

2.3 Hot work

Low Energy Ignition

Includes activities that generate heat or have the potential to generate

An area in which there is a continuous presence of flammable materials in

A. Hot Work area classification:

Hot Work areas are classified as Restricted, Flammable, General or

Department Managers shall document the Hot Work classification of each

Hot Work classifications shall be determined based upon proximity to

B. Restrictions on Hot Work:

Hot Work shall not be done in a Restricted Area.

Hot Work shall be done in Flammable or General Areas only if there is no

C. Re-classification of Hot Work Areas: Appendix-B shall be completed for

Department Manager may temporarily re-classify a Restricted Area as a

The potential sources of flammable materials have been removed from

Issue Date: 31 Dec-04

2.3 Hot work

The process is currently not operating, all flammable materials have

A Restricted Area that has been temporarily re-classified as a Flammable

Department Manager may temporarily re-classify a Flammable or General

There are currently no potential sources of flammable materials within

Those combustible or flammable materials that can be moved shall be

The equipment to be worked on that can be moved shall be removed to an

A 5 sided (4 walls plus floor) spark containment structure utilizing fire

A 4-sided containment (walls only) spark containment structure when

Water sprays on the Potential Source of flammable materials, or

Wetted fire tarps on the Potential Source of flammable materials.

Combustible materials that can be moved are removed to a distance of 10

The equipment to be worked on that can be moved is removed to an

Clearing the Area:

G. Fire extinguishing equipment (for example: fire extinguishers) shall be identified,

Issue Date: 31 Dec-04

2.3 Hot work

The potential for limited ventilation, or

The potential for an oxygen enriched or oxygen deficient atmosphere, or

The potential for vapor, liquid or solid engulfment,

Safe Work Permitting for Hot Work:

Refer to Policy 5.3 for SWP requirements for Hot Work.

When an SWP is required for Hot Work:

The potential hazards, and

The necessary precautions to eliminate or minimize the potential

That the area classification is correct.

The potential hazards have been documented and communicated.

The necessary precautions to eliminate or minimize the potential hazards,

Issue Date: 31 Dec-04

2.3 Hot work

There are combustibles or flammables within 10 meters of the Hot

There are Combustibles or flammables at a distance of greater than 10

That are contained in walls, partitions, etc.., that could be ignited by

That could smolder and ignite over time.