Hot Work Program

I. Purpose/Scope

The CSUN Hot Work Program has been established to protect the safety of CSUN employees and property by establishing appropriate hot work procedures and designated areas for hot work operations.

CSUN campus employees who complete hot work or work in areas where hot work is taking place, must follow the procedures outlined in this program. This includes, but is not limited to, campus maintenance workers, Recreation, DPS, Campus Housing/University Apartments, Athletics, as well as employees and students who complete hot work in campus laboratories, shops, or performing arts and recreational/sports facilities.

II. Definitions

Authorized Personnel - Includes employees who are trained to perform hot work activities. (Managers, Supervisors, Faculty, Students, Leads, Competent Persons, PAI’s, Operator’s, and Fire Watch personnel)
Affected Personnel - This refers to any person who is not performing Hot Work, including employees, students, or contractors, but may be in the vicinity of Hot Work being performed. These individuals do not play any roles in Hot Work practices (i.e., Operator, Fire Watch or PAI). Duties include wearing proper personal protective equipment when needed.
Combustible – generally refers to materials with a flash point above 100 degrees Fahrenheit.
Designated Hot Work Area - a permanent location designed for safe hot work operations not requiring a hot work permit.
Fire Watch Log – a log identifying each building, or area, under the Fire Watch. The Fire Watch Log shall be kept readily accessible for review for the Fire Marshall. See Attachment 2 for Fire Watch Log Template.
Flammable –Materials with a flash point below 100 degrees Fahrenheit.
Hot work – any operation which requires use of an open flame, or which produces sparks or heat sufficient to ignite nearby materials; hot work operations include cutting, welding, brazing, soldering, induction welding, grinding, thermal spraying, installation of torch-applied roofing, or any other activity that uses open flame or generates temperatures sufficient to ignite materials.
Hot work permit - a document issued for the purpose of verifying the safety of an area where hot work is to be conducted, as per the requirements of this hot work program. See attachment 1 for Hot Work Permit Template.
Non-Designated Hot Work Area – any area where Hot Work is being performed that has not been designated as a permanent Hot Work location.
Non-ionizing radiation – ultraviolet light, and infrared light that is generated during hot work.
Qualified person - a person who by reason of training, education, and experience, has been determined by their supervisor to be knowledgeable in the operations to be performed and is competent to identify and control the hazards involved.
Soldering / Brazing - In soldering, an alloy of lead and tin is used known as solder. In brazing an alloy of copper and zinc is used as filler metal.
Welder - any operator of electric or oxy-fuel gas welding or cutting equipment, or person performing allied processes.
Welding curtain/Blanket - a heat-resistant hanging barrier placed in areas designed to contain hazards that result from hot work including, but not limited to, sparks and ultraviolet light.
Welding pads - a heat-resistant fabric mat designed to protect materials underneath it against ignition; pads are placed on the surface of flammable materials directly under a hot work operation where hot debris might cause damage or start fires.

III. Exceptions/Exclusions

The following operations are excluded from this program and its requirements:

Ovens specifically designed and built by a reputable manufacturer with a Nationally Recognized Testing Laboratory (NRTL) certification (such as Underwriters Lab (UL) for heat treatment or annealing.
Electric soldering irons used for electronics and small electrical work.
Kitchens and food preparation areas that have been designed and built for the purpose of cooking. Ansell fire suppression systems should be in place where all open flames or high heat (fryers) are located to prevent accidental fire. Appropriate fire extinguishers shall be located in direct vicinity in all kitchen areas.
Catering operations where open flames/BBQ are used for scheduled events.
Bunsen burners used in classrooms and research laboratories.
Heat guns used for shrinking, drying or curing.

IV. Responsibilities

a. Managers, Supervisors, Principle Investigators, Faculty, Department Safety Coordinators and Laboratory Managers

For work performed in designated hot work areas, supervisors must monitor the designated area and ensure that it is maintained to the standards outlined by this written program.
For work performed in Non-designated hot work areas, Supervisors, Managers, and principle investigators:
- Ensure that only qualified and trained authorized employees perform hot work activities.
- Designate individuals to perform the programmatic roles of “permit authorizing individual (PAI)”, “operator”, and “fire watch”.
- Designate individuals on all shifts who can approve hot work activities and issue permits in non-designated areas.
- Ensure that a hot work permit is issued by a permit authorizing individual (PAI) before the hot work starts.
- Ensure that a fire watch is present at all times and present for at least 30 minutes after Hot Work has been completed.
- Develop safe usage protocols for all heat, flame, and spark-producing equipment.
- Ensure employees comply with all procedures described in this program.
- Retain records of all trainings.
- Retain all hot work permits for six months.

b. Permit Authorizing Individuals (PAIs)

The permit authorizing individual (PAI) must:
- Be a manager, supervisor, faculty or Department Safety Coordinator. Can be a competent person appointed by the manager.
- Either act as fire watch or verify that a fire watch is on site and has signed the hot work permit.
- Never act as the operator.
- Ensure that only qualified and trained authorized employees perform hot work activities.
- Perform the initial safety assessment of the hot work area, as well as daily re-assessments before hot work resumes, for each day that the hot work permit is in effect.
- Based on the scope of work and local conditions, the PAI must determine the length of time for which the hot work permit is valid and note this on the permit.
- Determine if the work can be completed or moved to a designated hot work area.
- If the work cannot be moved to a designated hot work area:
  - Communicate to affected employees regarding hot work activities that may be occurring around their area to ensure their safety.
  - If needed, contact the appropriate personnel to turn off fire alarms in the area the hot work is to be performed.
  - Ensure all combustible materials in the vicinity are removed.
  - If all combustible materials cannot be removed, ensure that guards are in place to confine the heat, sparks and slag.
  - Complete and sign the hot work permit.
- If approval for hot work is granted, issue and post hot work permits visibly at the job site.
- Ensure compliance with the safe work requirements required by this program each day that the hot work permit is in effect; inspect Hot Work Permit area at least once per day.
- The PAI may enlarge or reduce the fire-safe work area, farther than 35 feet, as local conditions allow (i.e. weather), and must describe these deviations from protocol on the hot work permit.
- Establishing a fire watch during and for no less than 30 minutes after completion of the hot work.
- If the Hot Work project lasts for more than 4 hours, Ensure the presence of a Fire Watch Log. Refer to Hot Work Procedure Section for details.

c. Fire Watch Personnel

A “fire watch” is required for all hot work activities outside of a designated hot work area. The fire watch must understand hazards associated with the type of hot work being performed and the limitations that are placed on the work operation by the hot work permit. The fire watch must make certain the hot work area is maintained in a fire-safe condition throughout performance of the hot work and must stop the hot work if unsafe conditions are observed. If it is not possible for one fire watch to observe the entire area for potential fire hazards, additional fire watches must be assigned to ensure that all exposed areas are monitored (2019 California Fire Code 3504.2.2).
Persons acting as fire watch must:
- Receive and maintain current annual training on the safe operation of fire extinguishers.
- Understand the basic hazards of any flammable/combustible construction and materials.
- Keep a fire extinguisher with a minimum rating of 2A:20B-C.
- Know where and how to activate the fire alarm pull station.
- Maintain proper isolation of all hot work operations from flammable and combustible materials.
- Mitigate fire exposure hazards that hot work creates to areas adjacent to, above, or below the hot work operation.
- Watch for fires in all exposed areas and monitor adjacent areas for fires.
- Extinguish small, controllable fires with extinguishing equipment available in hot work area
- Activate the fire alarm if an uncontrollable fire occurs.
- Maintain fire watch for the duration of hot work and for at least 30 minutes after completion of the hot work. The responsible PAI under this program is authorized to extend the fire watch based on the hazards or work being performed.
- Ensure the usage of a Fire Watch Log if the Hot Work project lasts for more than 4hours.
- Contact a supervisor and request a trained replacement if they must leave for any reason.
- Ensure that the PAI has conducted a final inspection after the fire watch period has concluded and signs off on the permit.
- The fire watch may also act as the PAI, but never the operator on the same job.

d. Operators

The operator is the person using the equipment that produces a potential ignition source.
Operators have the following responsibilities:
- Must be qualified by their supervisor to operate the hot work equipment.
- Must be trained on the processes of this program.
- Ensure all persons within the hot work area are wearing appropriate PPE prior to performing hot work.
- Wear all required personal protective equipment (PPE).
- Inspect hot work equipment prior to use and verify that it is safe to use.
- Perform the hot work in accordance with hot work procedures and all precautions listed on the hot work permit.
- Must stop work and inform their supervisor if conditions change after the hot work permit is issued.
When working in Non-designated hot work area, operators have the following additional responsibilities:
- Must not begin hot work until the hot work permit has been completed, signed, and posted on site by the PAI and fire watch.
- Must only perform hot work while the fire watch is present. If the fire watch leaves the area, the operator must stop work.

e. Contractors

Any contractor conducting hot work activities on campus and at any CSUN owned building must abide by their company’s hot work program which at minimum meets Cal/OSHA and NFPA standards. If a contractor does not have their own Hot Work Permit, they must obtain one and will not be allowed to use CSUN’s Hot Work Permit.
Must be able to provide training records (at CSUN’s Request) in Hot Work practices and Fire Extinguisher use. Each contractor’s company must provide their own fire extinguisher and Fire Watch.

f. EH&S

CSUN Environmental Health and Safety (EH&S) is responsible for the annual review of this program and program components. Audits of Hot Work Permits may be conducted by an EH&S representative at any time. EH&S will act as a resource for campus clients and off campus entities in the understanding and compliance of this program. EH&S has the authority to temporarily stop work for jobs being performed by CSUN employees if the Safety representative deems the job site Immediately Dangerous to Life and Health (IDLH) and/or the area is in clear violation of the CSUN Hot Work Program. If EH&S observes or is notified of a concern on a contractor’s worksite, the Project Manager (PM) associated with that job will be contacted. It is the responsibility of the PM to ensure the contractor is abiding by their company’s Hot Work Program and all state and federal regulations.

V. Procedures

a. Designated Hot Work Areas

A designated hot work area is an area specifically designed and approved for hot work by CSUN EH&S and the State Fire Marshal. These areas do not require Hot Work Permits. Designated hot work areas must be inspected upon initial assignment and after any fire related incident or near miss. Re-inspections must be completed every two years. Departments are required to get in contact with CSUN Environment Health & Safety 30 days prior to re-inspection date.
Physical Design and Maintenance of Designated Hot Work Areas
- Must be constructed of non-combustible or fire-resistive walls, doors and floor surfaces.
- Openings or cracks in walls, floors, ducts or shafts must be tightly covered to prevent the passage of sparks to adjacent or hidden areas. If they cannot be covered, they must be shielded by metal fire-resistance guards. Fire-safe curtains must be provided to prevent passage of sparks or slag out of the designated hot work area.
- Designated hot work areas must be segregated from other areas of the building with non-flammable partitions. Partitions must be securely connected to the floor with no gaps between the floor and the partition.
- Openings in partitions must be protected by welding-grade curtains or other permanent physical barriers either attached to the structure or of rugged portable construction.
- Adjacent hot work stations must be separated with flame-resistant screens or shields.
- Hot work areas must be separated from affected personnel in adjacent areas with use of flame-resistant screens or shields.
- Flammable materials must be removed (within 35ft of designated hot work area) or isolated from adjacent areas by appropriate shielding to prevent ignition from sparks, slag or heat.
- Designated Hot Work Areas must be equipped with:
  - adequate ventilation or smoke filtration
  - both portable fire extinguishers and fire alarm systems
  - signage labeling the area “Designated Hot Work Area.” This signage must only be posted once the area is approved by CSUN EH&S
- Equipment that contains (or has contained) flammable materials must be thoroughly cleaned, dried and purged prior to performing hot work.
- Good housekeeping must be maintained.
- Only individuals who have been trained on the procedures of this program may utilize Designated Hot Work Areas.
The following areas have been designated as approved hot work areas. Hot work may be performed in these areas without the issuance of a hot work permit. Even though a permit is not required in these areas, authorized personnel must inspect the area for combustibles and other hazards before beginning hot work operations.
- Soraya Scene Shop Welding Area – TS 0158

b. Non-Designated Hot Work Areas

For all hot work performed in any location that is not a designated hot work area, a completed and signed hot work permit must be visibly posted on the job site. The permit must be issued by a permit authorizing individual (PAI). A separate permit must be issued for jobs that occur in both indoor and outdoor locations.

c. Personal Protective Equipment (PPE)

Appropriate PPE must be worn for the task being performed as decided by the Qualified Person performing the work.
Example of PPE include:
- Eye and face protection
  - Helmet with filter lens and cover plate that complies with ANSI Z87.1
  - Safety glasses with side shield under helmet
- Head and ear protection
  - Fire-resistant welder’s cap under helmet
  - Ear-plugs or muffs
- Foot Protection
  - Leather, steel-toed, high-topped boots in good condition and that meet the requirements of ASTM F2412 and ASTM F2413
  - Do not wear pants with cuffs. The bottoms of pants should be worn over the tops of the boots
- Hand Protection
  - Dry, hole-free, insulated and flame-resistant welding gloves
- Body protection
  - Oil-free protective clothing made of wool or heavy cotton
  - Clothing should allow for freedom of movement and should prevent skin exposure
  - Leather aprons, leggings, capes and sleeves as needed

d. Hot Work Procedure

For any hot work location that is in a non-designated hot work area, a completed and signed hot work permit must be posted at the job site. The permit must be issued by a permit authorizing individual (PAI). Indoor and outdoor jobs require separate Hot Work permits, as the different environments require additional precautions.
Before a hot work permit is issued, the following safe work conditions must be verified by a PAI:

Per (CFC 3504.3), an area inspection is required before conducting any hot work activities. This must be done on the day the Hot work is being performed.
Hot work equipment should be inspected prior to use and must be in safe operating condition and good repair.
Fire extinguishers must be fully charged, operable, and readily accessible at all times during the work and for a minimum 30 minutes after the job has concluded. Must meet the 2A-20BC minimum requirement and be readily accessible within 30 feet of work area. Any fire extinguisher used for Hot work must be brought to the site by the Fire Watch, the building fire extinguishers cannot be used.
All combustible materials within a 35-foot radius from the hot work must be relocated. If relocation is impractical, the materials must be protected by an NRTL-approved welding curtain, welding blanket, welding pad, or equivalent spark resistant barrier.
- To prevent the sparks from passing underneath spark resistant barriers, the covers must fit tightly against the floor and held securely in place. Any covers that may overlap over a pile of combustible material must be tightly clipped together.
The floor must be swept clean for a radius of 35 feet from hot work in areas that contain combustible materials such as paper, wood shavings, textile fibers, or rubber.
Combustible floors must be kept wet, covered with damp sand, or protected by an NRTL-approved welding blanket, welding pad, or equivalent barrier.
- Where floors have been wet down, operators must be electrically-isolated from equipment and protected from possible shock.
Openings or cracks in walls, floors, or ducts within 35 feet of the Hot Work site must be covered or sealed with approved flame resistant or non-combustible material to prevent the passage of sparks to adjacent areas.
Ducts and conveyor systems that might carry sparks to distant combustible materials must be shielded with approved material or, preferably, shut down.
If hot work is done near walls, partitions, ceilings, or roofs of combustible construction, they must be protected by an approved welding curtain, welding blanket, welding pad, or equivalent barrier.
If hot work is done on one side of a wall, partition, ceiling, or roof, precautions must be taken to prevent ignition of flammable materials on the other side by relocating the materials. If it is impractical to relocate the materials, a second fire watch must be provided on the side opposite from where the work is being performed.
Hot work must not be attempted on a partition, wall, ceiling, or roof that has a flammable covering or insulation, or on walls or partitions with flammable “sandwich type” panel construction.
Hot work that is performed on pipes or other metal that is in contact with flammable walls, partitions, ceilings, roofs, or other materials must not be performed if the work is close enough to cause ignition by heat conduction.
Access to the permitted hot work area by people not involved in the work must be controlled.
Curtains, closed doors, barricades or other means must be used to prevent any ultraviolet radiation from leaving the permitted area.
A fire watch is required at all times including when the fire alarm systems have been taken offline.
For Hot Work activities conducted on roof tops, ensure work is not being performed near any air intakes. If there is no way to avoid an air intake, PAI shall notify the appropriate personnel.
If personnel change during Hot Work activities a new permit should be created before activities can resume.
Special precautions must be taken to avoid accidental activation of automatic fire or smoke detection or suppression systems such as sprinklers or other special extinguishing systems. When conducting hot work in close proximity to a fire sprinkler, damp cloth guards must be laid over the sprinkler head during hot work and removed at the conclusion of the operation.

VI. Training Requirements

Training on this program, Cal/OSHA regulations, and NFPA will be conducted on initial assignment and every 3 years. If there are any major changes to the program and/or occurrence of an incident or injury, employees will be retrained before the 3-yearexpiration date.
Fire Extinguisher training is required to be done annually.
Any employee expired on their Hot work and/or Fire Extinguisher training will not be permitted to perform Hot work or act as Fire Watch.
All levels of staff must be trained and are responsible for staying up to date on that training.

VII. Record Keeping and Auditing

Hot work permits must be kept on file by the issuing department for 6 months. They must be made available for review by regulatory authorities upon request. Please Submit a copy of the completed Hot Work Permit to ehs@csun.edu within 24hrs of completing the job
Training records including rosters and subjects covered must be kept by the department for the duration of attendee’s employment plus three years.
An inventory of designated hot work areas approved by the Campus Fire Marshal is maintained by EH&S.
Respiratory protection program training records must be kept for any employees who use respiratory protection. Training records will be maintained by EH&S.
Audits of Hot Work permits and records may be performed at any time by EH&S.

VII. Resources/references

Title 8, California Code of Regulations (CCR)

§3219 Maintenance of Fire Protection Equipment, Materials and Assemblies
§3221 Fire Prevention Plan
§4845 General Precautions
§4848 Fire Prevention and Suppression Procedure
§4850 Electric Welding, Cutting and Heating –General Requirements
§6777 Hot Work Procedures and Permits

All electrical equipment used to perform electric operations and processes are installed and maintained in accordance with the California Electrical Safety Orders, and chapters 11, 12 and13 of the American National Standards Institute, ANSI/ASC Z49.1-94, Safety in Welding, Cutting and Allied Processes.
All electrical and other hot work equipment must be approved by an NRTL such as Underwriters Laboratory or similar per the Federal OSHA National Recognized Testing Laboratory (NRTL) program list at the following link: https://www.osha.gov/dts/otpca/nrtl/
Hot Work Program-20-Nov 2019American National Standards Institute (ANSI) Z49.1-2012, Safety in Welding, Cutting and Allied Processes
National Fire Protection Association (NFPA) 51B-2020, Standard for Fire Prevention during Welding, Cutting, and Other Hot Work
California Fire Code (2019), Chapter 35, Welding and other Hot Work

Environmental Health and Safety

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