[NEW OP–initial posting 3/28/25]
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Operating Policy and Procedure

OP 60.30: Hot Work Permit Process

DATE: March 28, 2025

PURPOSE: The purpose of this Operating Policy/Procedure (OP) is to ensure that hot work is safely conducted. The hot work program describes procedures for approving and monitoring hot work and meets the requirements of the National Fire Protection Association (NFPA) 51B standard and the Occupational Safety and Health Administration (OSHA) standards 29 CFR 1910.252 and 29 CFR 1926.352.

REVIEW: This OP will be reviewed every two years after publication by the Assistant Vice President for Environmental Health & Safety and the Senior Safety Officer responsible for Operations Division with substantive revisions forwarded to the Fire Marshall, the Assistant Vice President for Operations Facilities & Construction, the Senior Associate Managing Director of University Student Housing, and the Senior Associate Athletics Director / Facilities & Event Operations.

POLICY/PROCEDURE

1.  Intent and Scope

This document has been developed to ensure that hot work outside of designated areas is conducted safely and information regarding such work is conveyed to appropriate personnel. The hot work program describes policies for all organizations and individuals involved with hot work on Texas Tech University (TTU) properties, sites, or projects and applies to all hot work conducted outside of designated areas for hot work on behalf of TTU.

2.  Definitions

a.    Hot work – Any activity or process involving open flames or that generates heat or sparks. This includes welding and associated processes, brazing, heat treating, grinding, cutting, thawing pipes, powder-driven fasteners, hot riveting, and torch applied roofing. It does not include cooking or the use of heat-generating laboratory equipment.

b.    Designated area for hot work – An area in a shop or a worksite designated for hot work where the following conditions are met:

• The area and its furnishings are constructed of non-combustible materials, and it is clear of combustible materials; flammable gases, vapors, or liquids; or explosive atmospheres;
• The area is at least 35 feet horizontally in radius and is clear at least 15 feet vertically;
• The area is segregated, identified through signage, has minimal foot or vehicle traffic, and does not possess the sole emergency exit for the facility; 
• The area is equipped with a fire extinguisher and ventilation to control airborne particulates; and
• The area has been inspected by the Fire Marshal’s Office. 

c.    Competent person – An individual capable of recognizing existing or predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them.*

d.    Permit authorizing individual (PAI) – The individual designated to authorize hot work. The PAI is permitted to be TTU project managers or supervisors, or the general contractor’s project executive, supervisor, foreperson, or designated safety administrator. The PAI CANNOT be the hot work operator, except as permitted in NFPA 51B.

e.  Construction work – Work for construction, alteration, and/or repair, including painting and decorating.^†

f.    Fire watch – Individual responsible for monitoring work area for fire hazards associated with hot work and implementing emergency procedures should a fire occur.

3.  Responsibilities and Functions

a.    TTU project managers and inspectors shall be responsible for and receive training in the following:

• Ensuring relevant TTU entities are informed of an intent to perform hot work by contractors;
• Ensuring projects that employ hot work follow the requirements in this OP and the TTU hot work permit; and
• Inspecting hot work sites (as needed) to ensure that provisions of the permit are being implemented appropriately or hot work has been safely concluded.

b.    TTU managers and supervisors shall be responsible for and receive training in the following:

• Ensuring relevant TTU entities are informed of an intent to perform in-house hot work;
• Ensuring in-house hot work projects follow the requirements in this OP and the TTU hot work permit; and
• Inspecting hot work sites (as needed) to ensure that provisions of the permit are being implemented appropriately or hot work has been safely concluded.

c.    TTU Environmental Health & Safety (EHS) staff are responsible for the following:

• Conducting training for personnel involved in hot work outside designated areas;
• Reviewing and updating the hot work policy to conform to current standards; and
• Conducting an annual review of hot work permits implemented.

d.    Contractors performing hot work on TTU locations are responsible for the following:

• Providing a copy of contractor’s hot work permit policy;
• Conducting a job site safety analysis/assessment of site where hot work will be conducted and providing it to TTU;
• Providing a copy of the hot work permit to TTU when hot work is deemed necessary;
• Abiding by all federal state, local, and TTU regulations and policies regarding hot work; and
• Ensuring individuals conducting hot work or performing duties as fire watch are equipped with and use the appropriate PPE for the work being performed.

e.    The permit authorizing individual (PAI) shall be responsible for and receive relevant training in the following:

• Inspecting the work site prior to work to determine if permit is required;
• Determining if there is an alternate method that does not require hot work;
• Completing the hot work permit and submitting it to the TTU representative (project manager, inspector, supervisor);
• Ensuring that individuals conducting hot work and fire watch are properly trained to perform their assigned duties and can meet the requirements of the issued permit; and
• Inspecting and supervising hot work being performed.

f.    Individuals conducting hot work shall be responsible for and receive training in the following:

• Hot work and hot work permit policies, procedures, and programs;
• Hazard recognition and abatement of hazards associated with hot work;
• The use of fire extinguishing equipment designated by the hot work permit;
• Within the capabilities of available equipment, attempting to extinguish beginning-stage fires; and
• Alerting employees of fire beyond the incipient stage and activating alarm.

g.    Fire watchers shall be responsible for, receive training in, and have knowledge of the following:

• Hot work and hot work permit policies, procedures, and programs;
• The scope of the hot work permit;
• Hot work location and associated hazards of location;
• Alarm locations if available;
• Firefighting systems designated by the hot work permit;
• Remaining in the hot work area for the duration of the work and at least 60 minutes after its completion and being available to perform fire monitoring for an additional three hours if needed; and
• Alerting employees of fire beyond the beginning stage and activating alarm.

4.  Procedures for Hot Work Outside of Designated Areas

Hot work outside of designated areas is not considered a standard operating procedure; if a reasonable alternative to hot work exists, it should be employed. Should hot work prove necessary, the following provisions must be followed. 

a.    General Provisions

(1)    Personnel involved in implementing the hot work program and performing hot work must be trained to identify and mitigate hot work hazards and demonstrate the ability to implement emergency procedures.

(2)    TTU uses hot work permit documentation from its insurance carrier. For all hot work, the permit will be completed by the contractor’s PAI, the job supervisor, or the project manager. Part 1 of the permit addresses hazard mitigation for the proposed hot work. The PAI keeps Part 1 and issues Part 2 to the individuals conducting the work. Once the hazard mitigation activities have been completed (and noted on the permit), Part 2 should be posted at the job site along with a list of pertinent emergency numbers and project contacts. When the hot work is concluded, the PAI is the final signature to close out the permit.

A copy of Part 1 should be distributed to appropriate staff as part of the workflow process. Due to the variation in projects, actual distribution of Part 1 may vary; at a minimum, a copy will be provided to project managers, EHS, and the Fire Marshal’s Office.

(3)    A competent person should ensure all elements of the permit have been implemented and maintained for the duration of the permit. 

(4)    Dedicated personnel must be available during the execution of hot work to ensure that activities do not result in fire and then, after the work is concluded, that the area is free of sparks, embers, or other ignition sources.

(5)    When a situation that violates the terms of the permit arises, the permit is to be immediately terminated, work must cease, and the Fire Marshal’s Office must be notified.

(6)    Permits are authorized only for the time period listed on the permit up to a maximum of one day. Each hot work activity must have its own permit unless (1) multiple activities are being conducted in proximity to each other and can be monitored by one fire watch and (2) the post-work fire monitoring duration is sufficient to provide coverage for the riskiest hot work being conducted.

(7)    Permits implemented over the year will be reviewed at the end of each year and will be kept by EHS for three years.

b.    Contractor Hot Work

Contractors may use their own hot work program provided it is as comprehensive as the program that TTU employs. General provisions listed above should still be followed as part of the contractor process. Contractors must be informed of TTU’s hot work policy and if they intend to use their own program, they must provide documentation to the project manager prior to starting work.

 

* 29 CFR 1926.32 (f)

^†29 CFR 1926.32 (g)

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