Creating OSHA Work Permits for Hazardous Jobs
A number of OSHA health and safety regulations require some type of formal documentation, often in the form of a work permit. A "permit" under OSHA rules is a bit different than permits under US EPA or US DOT hazardous materials regulations. These other agencies issue permits to businesses to allow the businesses to perform certain activities, like discharging pollutants or transporting certain explosives. An OSHA "permit" is an employer-created and signed document that details the safeguards in place to protect an employee who's been assigned a particularly dangerous job function like working in a confined space, welding and cutting, or working on "live" electrical equipment. While the 29 CFR OSHA safety standards don't provide employers with a standard form or template to use to create a work permit, they do include "samples" that show what OSHA expects in the permits for different regulated activities.
29 CFR 1910.146 Permit-required Confined Spaces and 29 CFR 1926.1206 Confined Spaces in Construction
OSHA has issued two separate confined space standards. Determining which standard you must follow depends on the type of work being performed. Activities that meet the definition of "construction" are expected to abide by the recently published standard found at 29 CFR 1926, Subpart AA.
Employers covered under OSHA's general industry regulations should follow the rules at 29 CFR 1910.146. These two sets of OSHA rules are similar, and both contain specific guidance on what needs to be included in the permit. To see a full breakdown of the confined spaces permit requirements under OSHA's General Industry and Construction standards, read this feature online at Lion News.
|Permit Content||Required by General Industry||Required by Construction||Comments|
|Permit space to be entered||Y||Y||Location, equipment ID number, etc.|
|Purpose of entry||Y||Y||Description of work to be performed|
|Length of time permit is valid||Y||Y*||Start/stop times, during 1st shift, etc. *Permits may be suspended (if conditions change) instead of cancelled|
|Name/ID of authorized entrant(s)||Y||Y|
|Method used to ventilate, or inert space to eliminate/control atmospheric hazards||Y||Y||Natural ventilation vs. mechanical|
|Method of detecting increased atmospheric hazards if ventilation system stops||N||Y|
|Name of attendant(s)||Y||Y|
|Name and signature/initials of entry supervisor||Y||Y||Person who authorizes entry into the space|
|Identified hazards of space to be entered||Y||Y|
|Steps taken to eliminate/control hazards before entry||Y||Y||Includes isolating/barricading the space|
|Acceptable conditions for entry into space||Y||Y|
|Testing/monitoring results||Y*||Y*||Includes testers initials and time measurements were recorded (*differences indicated below)|
|Contact information for rescue team or emergency services personnel||Y||Y|
|Means of two-way communication between entrant and attendant||Y||Y|
|Required personal protective equipment, monitoring equipment, alarm systems, etc.||Y||Y|
|Additional permits (e.g., hot work)||Y||Y|
With respect to atmospheric monitoring, there are a few differences between the standards. The recently published construction standard incorporates a more conservative approach to monitoring for atmospheric hazards. It requires continuous monitoring of airborne hazards, unless this is not feasible, in which case periodic monitoring must be documented. In addition, OSHA's new confined space standards for construction calls for continuous monitoring of hazards recognized as potential engulfment hazards, like an upstream water source that could run downstream and fill an occupied space.
The general industry and construction confined space standards adopt the same hierarchy when it comes to testing the air for hazardous conditions. First, the air in and around the permit space should be tested for oxygen content; second for combustible gases (expressed as a % of the lower explosive limit), and lastly for toxic vapors and/or gases.
29 CFR 1910.252 Welding, Cutting, and Brazing (Hot Work)
Unlike the confined space standards, OSHA's "Welding, Cutting, and Brazing" standard does not have a specific section dedicated to written permits. Rather, OSHA describes throughout the standard the various precautions employers must take prior to starting "hot work" activities. Hot work includes a number of activities aside from cutting and welding. Basically, any "flame or spark-producing operations" are covered.
Among the most important elements of the hot-work permit are the pre-work inspection of the area and the authorization to perform the work by a competent individual. OSHA explicitly states that this authorization to proceed with hot work shall be "preferably in the form of a written permit" [1910.252(a)(2)(iv)].
To create a hot-work permit, employers should ask themselves some important questions.
Hot Work Permits: Questions to Ask When Implementing a Permit System
- What are the specifics surrounding the work? (e.g., date/time of permit issue, expiration time)
- What equipment will be used?
- What type of work is to be done (e.g., sand blasting, cutting, welding, etc.)
- Where is the work occurring?
- And many more. For 20 more questions you should ask when creating a hot work permit, read this feature online at Lion News.
- Which department is doing the work?
- Who is performing the hot work?
- Has equipment/lines been cleaned and purged?
- Is equipment/machinery isolated and tagged?
- Have electrical switches/start-ups been locked out and tagged?
- Is work area thoroughly ventilated?
- What are the combustible gas meter readings in the work area?
- Who is assigned to fire watch duty?*
- Are surrounding areas (above and below) protected from sparks?
- Where combustible materials are present (e.g., paper clippings, wood shavings, etc.) have floors been swept clean for a radius of 35 feet?
- Have combustible wastes been removed from area?
- What fire protection measures are in place?
- Which internal departments have been notified that work will be taking place?
- Has equipment been inspected and is free of hazards?
- What PPE is required?
- Has a joint inspection been conducted with Maintenance?
- Do atmospheric conditions permit safe work?
- Are combustible gas tests required during the job?
- Is the permit receiver aware of SDS’s for materials previously contained in equipment/lines?
- Has the permit been signed by both the person issuing the permit and the person receiving it?
- Is there a place to sign once the work is completed and a post-work inspection performed?
Lockout/Tagout–The Control of Hazardous Energy [29 CFR 1910.147]
While OSHA's lockout/tagout standard does not use a permit system like we've seen in the above examples, it's worth mentioning since it is widely practiced and, simply put, saves lives. The purpose of lockout/tagout is to control hazardous energy within a system, piece of equipment, machinery, etc. Employers are expected to identify electrical systems/equipment on the premises and develop written procedures for "shutting down, isolating, blocking and securing machines or equipment to control hazardous energy" [29 CFR 1910.147(c)(4)(ii)]. Specifically, the written procedures must include steps for attaching and removing physical lockout devices and tags as well as verifying that the system has been effectively de-energized.
Live Electrical Work Permit [29 CFR 1910 Subpart S]
Under NFPA 70E, work on "live" energized electrical parts is acceptable only under a very narrowly defined set of circumstances; 1. When de-energizing would interrupt essential life support, emergency alarms or ventilation systems, and 2. When an employer can demonstrate that de-energizing the system would introduce additional or increased hazards or that it is infeasible due to equipment design or operational limitations. OSHA has adopted NFPA's stance on "live" electrical work and requires the use of safety-related work practices within its electrical standard. Many employers have found that the development of a facility-specific Energized Electrical Work Permit is a good way to prepare for this type of work. Below is a general outline for items included on a typical Energized Electrical Work Permit:
- Completed by requester
- Description of circuit/equipment/job location
- Description of work to be done
- Justification of why the circuit/equipment cannot be de-energized or the work deferred until the next scheduled outage
- Completed by electrically qualified persons doing the work
- Detailed job description/procedure to be used in performing the above detailed work
- Description of safe work practices to be employed
- Results of the shock hazard analysis
- Determination of shock protection boundaries
- Results of flash hazard analysis
- Determination of flash protection boundary
- Necessary personal protective equipment to safety perform assigned task
- Means employed to restrict access of unqualified persons from work area
- Evidence of completion of job briefing, including discussion of any job-related hazards
- Agreement by parties involved that the work can be done safely
- Operations manager
- Maintenance/engineering manager
- Safety manager
- Electrically knowledgeable person
- General manager
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