OSHA's safety management guidelines offer safety managers a framework for preventing hot work injuries and fatalities.
by Laura H. Rhodes, Ed.D., CSP, and David P. Rhodes, M.A., CSP, CPCU, PHR
Cutting and welding tasks are performed either on a routine or infrequent basis in all industrial and commercial environments by maintenance personnel or contractors during the fabrication process, equipment repair or facility maintenance operations. OSHA reports that welding, cutting and brazing are hazardous activities that pose a unique combination of both safety and health risks to more than 500,000 workers in a wide variety of industries. The risk from fatal injuries alone is more than four deaths per 1,000 workers over a working lifetime.1 Up to 25 percent of fatalities in shipyards result from fires and explosions caused by hot work, according to the U.S. Bureau of Labor Statistics (BLS).2
An example of the result of uncontrolled safety and health hazards and poor work practices is reviewed in OSHA Fatal Facts Accident Summary No. 25. A welder entered a steel pipe (24-inch diameter) to grind a bad weld at a valve about 30 feet from the entry point. Before he entered, other crewmembers decided to add oxygen to the pipe near the bad weld. He had been grinding intermittently for about 5 minutes when a fire broke out and enveloped his clothing. Another crewmember pulled him 30 feet to the pipe entrance and extinguished the fire. However, the welder died the next day from his burns.
Tragedies such as these can be prevented if companies develop a welding and cutting safety program in the workplace using OSHA's Safety and Health Program Management Guidelines issued in January 1989 as a point of reference.3 These voluntary guidelines outline what OSHA has established to represent the contents and framework for safety and health program excellence. The guidelines stem from OSHA's experience in evaluating worksites through its state-run consultation projects and Voluntary Protection Programs.
The guidelines outline a management system to identify and control hazards on a proactive basis using four major program elements:
- Management leadership and employee involvement;
- Worksite analysis;
- Hazard prevention and control; and
OSHA defines "hot work" as any work that involves burning, welding, using fire or spark-producing tools, or that produces a source of ignition.4 We'll use these four basics elements of a safety and health program to identify the hazards associated with hot work activities and the hazard controls and associated best practices required to prevent injuries and illnesses in the general industry work environment. OSHA has developed a Safety and Health Management System eTool an interactive, Web-based training tool available at www.osha.gov to provide guidance to employers on the recommended components of an occupational safety and health program.
Management Leadership and Employee Involvement
Management leadership and employee involvement are complementary. Management leadership provides the motivating force and the resources for organizing and controlling activities within an organization. In an effective program, management regards worker safety and health as a fundamental value. Employee involvement provides the means through which workers express their own commitment to safety and health, for themselves and their fellow workers.
Management should develop and implement written policies and procedures that outline the work practices and rules required for performing welding and cutting tasks safely in the workplace. OSHA standard 29 CFR 1910.252, Welding, Cutting and Brazing General Requirements, requires that management recognize its responsibility for the safe use of cutting and welding equipment on its property and, based on fire potentials of plant facilities, establish areas for cutting and welding as well as establish procedures for cutting and welding in other areas. In addition, management must designate an individual responsible for authorizing cutting and welding operations in areas not specifically designed for such processes, and insist that cutters or welders and their supervisors are suitably trained in the safe operation of their equipment and the safe use of the process.
Employee involvement provides opportunities for workers to develop and express their own commitment to safety and health, for both themselves and their co-workers. Management should strive to involve employees in all aspects of welding and cutting safety. Examples of employee participation include:
- Participating in safety committees that conduct site inspections to identify welding and cutting related hazards;
- Preparing safe welding and cutting practices or controls to eliminate or reduce exposure; and
- Performing a pre-use or change analysis for new welding and cutting equipment or processes in order to identify hazards up front before use.
Worksite analysis involves a variety of worksite examinations to identify not only existing hazards, but also conditions and operations in which changes might create hazards. Effective safety management practices actively analyze the work and the worksite to anticipate and prevent harmful occurrences. Routine site safety and health inspections are designed to catch hazards missed at other stages. This type of inspection should be done at regular intervals, generally on a weekly basis. The OSHA Small Business Handbook (OSHA Publication 2209) provides a Welding, Cutting and Brazing Checklist (see excerpt above) that can be used as a point of reference by personnel performing self-inspections of the workplace.
A job hazard analysis (JHA) is another workplace analysis technique that can be used to identify potential hazards in the workplace. A JHA is a technique that focuses on job tasks as a way to identify hazards before they occur. It focuses on the relationship between the worker, the task, the tools and the work environment. Ideally, once uncontrolled hazards are identified, you will take steps to eliminate or reduce them to an acceptable risk level. OSHA publication 3071, "Job Hazard Analysis," provides employers with the framework and necessary tools to perform a JHA of welding and cutting tasks performed in their workplace.
Hazard Prevention and Control
After detection, all current and potential health and safety hazards must be prevented, corrected or controlled. OSHA's recommended systems used to prevent and control hazards include engineering controls, safe work practices, administrative controls, personal protective equipment (PPE) and emergency preparation.
Engineering controls are the first and best strategy to control the hazard at its source and can be used to control health hazards from welding, cutting and brazing operations. These hazards include employee exposures to metal fumes and to ultraviolet (UV) radiation. Local exhaust ventilation installed at a welding station for the purpose of removing air contaminants generated during the welding process is an example of an engineering control. The segregation of welding and cutting from other operations in the workplace to prevent employee exposure can be achieved by use non-combustible barrier walls and portable welding screens. Oxygen cylinders in storage can be separated from fuel-gas cylinders or combustible materials (especially oil or grease), by a noncombustible barrier at least 5 feet (1.5 meters) high having a fire-resistance rating of at least a half-hour.
Safe work practices include the company's general workplace rules and other operation-specific rules. Management should establish a written rule that only authorized and trained personnel are permitted to use welding, cutting or brazing equipment. Supervisors should ensure that each operator have a copy of and follow the appropriate welding and cutting equipment operating instructions.
While safe work practices can be considered forms of administrative controls, OSHA uses the term administrative controls to mean other measures aimed at reducing employee exposure to hazards. Rotation of workers performing welding and cutting tasks and fire watch tasks is an example of an administrative control. The rotation of workers will limit their potential exposure to safety hazards from welding, cutting and brazing operations including burns, eye damage, electrical shock, cuts and crushed toes and fingers.
Prior to performing hot work tasks, employers should instruct employees in the use of PPE, fire prevention and protection requirements and the safe use of welding/cutting-related equipment. The workplace safety coordinator should conduct a PPE assessment of hot work tasks that will be performed by employees in the workplace. OSHA standard 29 CFR 1910.132(d)(1) requires "that the employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of" PPE, and this activity must be documented by the employer. Furthermore, OSHA's cutting and welding-related standards have specific PPE requirements. Hazards associated with welding and cutting may include employee exposure to:
- Ultraviolet and infrared radiation
- Metal fumes and welding gases
- Electrical current
- Hot metal
OSHA publication 3077, "Personal Protective Equipment (PPE)," is an excellent reference for training employees on the use of PPE in the workplace. PPE should not be used as a substitute for engineering, work practice or administrative controls. Personal protective equipment should be used in conjunction with these controls to provide for employee safety and health in the work place. PPE includes all clothing and other work accessories designed to create a barrier against workplace hazards. The basic element of any management program for PPE should be an in-depth evaluation of the equipment needed to protect against the hazards at the workplace. Management dedicated to the safety and health of the employees should use that evaluation to set a standard operating procedure for personnel, and then train employees on the protective limitations of PPE, and on its proper use and maintenance.
As a result of the PPE assessment, employees should be required to use PPE including protective eyewear, hand protection and protective clothing. The Cooperative Extension at the University of Arizona advises that it is essential that the operator and helpers be properly clothed and protected because of the heat, ultra-violet rays and sparks produced by the arc welder as illustrated below.5
Respiratory protection should be provided only if engineering controls are not feasible in the work environment. OSHA's Technical Manual TED 01-00-015 [TED 1-0.15A] (Jan. 20, 1999) includes a section on sampling for welding fumes. Local exhaust or general ventilating systems should be provided and arranged to keep the amount of toxic fumes, gases or dusts below the maximum allowable concentration as specified in 29 CFR 1910.1000.
Management should become aware of possible emergencies and plan the best way to control or prevent the hazards they present. Specific written hazard control programs including a fire prevention plan, emergency action plan and hot work permit program should be developed and implemented in the workplace to address welding and cutting hazards. The fire prevention plan describes the fuel sources (hazardous or other materials) on site that could initiate or contribute to the spread of a fire, as well as the building systems (such as fixed fire extinguishing systems and alarm systems) in place to control the ignition or spread of a fire. An emergency action plan (EAP) is designed to facilitate and organize employer and employee actions during workplace emergencies. The OSHA Emergency Plans and Procedures eTool provides guidelines on the development of these essential safety plans. It includes an Emergency Action Plan Expert System that will help an employer to create a simple EAP.
The National Fire Protection Association (NFPA) establishes scientifically based fire prevention and protection consensus codes and standards. An excellent resource for the development of a Hot Work Permit Program is the NFPA 51B Standard for Fire Prevention in Use of Cutting and Welding Processes.6 These standards review the basic precautions and special precautions that should be followed to prevent loss of life and property from uncontrolled welding and cutting loss exposures. In addition, these standards address the fire protection and prevention responsibilities of welders and cutters, their supervisors (including outside contractors) and those in management on whose property cutting and welding are to be performed.
An employer should develop a "Permit for Cutting and Welding with Portable Gas or Arc Equipment" using NFPA 51B, Appendix A "Suggested Form of Written Cutting and Welding Permit," as a point of reference. This NFPA standard covers the provisions to prevent loss of life and property from fire or explosion as a result of hot work. Before cutting or welding is permitted, the area must be inspected by the individual responsible for the welding and cutting operations, to ensure that it is a fire safe area. The individual shall designate precautions to be followed in the form of a written permit or other equivalent means. In addition, NFPA 51B requires that the individual verify all fire prevention precautions have been taken; they include that welding and cutting equipment is in good operating condition; no combustible material is within 35 feet; and that nearby personnel and building walls and ceilings are suitably protected against heat, sparks, slag, etc.
The establishment of a fire watch is critical in welding and cutting tasks. Although the cutter or welder has the best opportunity to avoid fire or injury by proper control of the equipment he is using, there are many circumstances in which fire, explosion, or severe injuries would be inevitable if an oxy-fuel gas torch or an electrode were used. Such circumstances can arise in which the cutter or welder may not be aware of (1) proximity or the flammable nature of nearby combustible solids, liquids or dusts; (2) the presence or development of possible explosive mixtures of flammable gases or vapors and air; or (3) the presence of an oxygen-enriched atmosphere in the location where the work will be performed. The precautions taken by the welder or cutter often will be governed by the desire of others for speed or economy in his work or by the failure of management to emphasize the possible extent or seriousness of a fire in the work area. Therefore, all three the cutter or welder, his supervisor and management share the responsibility for the safe use of cutting and welding equipment.7
Employees should be provided necessary training prior to being assigned to perform hot work tasks. Specifically, that means how to recognize and evaluate hazards, and the controls to prevent injuries to employees performing welding and cutting tasks in the workplace. OSHA Publication 2254, "Training Requirements in OSHA Standards and Training Guidelines," provides a review of mandatory OSHA training required for employees engaged in welding and cutting tasks. These requirements are summarized below:
Management. Management shall recognize its responsibility for the safe usage of cutting and welding equipment on its property and insist that cutters or welders and their supervisors are suitably trained in the safe operation of their equipment and the safe use of the process.
Personnel. Workers in charge of the oxygen or fuel-gas supply equipment, including generators and oxygen or fuel-gas distribution piping systems shall be instructed by their employers for this important work before being left in charge. Rules and instructions covering the operation and maintenance of oxygen or fuel-gas supply equipment including generators and oxygen or fuel-gas distribution piping systems shall be readily available.
In addition, workers designated to operate resistance welding equipment shall have been properly instructed and judged competent to operate such equipment.
Instruction. Workers designated to operate arc welding equipment shall have been properly instructed and qualified to operate such equipment.
In summary, hot work tasks can create many hazards in the workplace that if left unchecked by an employer may result in serious employee injury and/or illness and significant property damage. An employer can utilize the OSHA Voluntary Safety and Health Program Management Guidelines as a template to develop a welding and cutting safety program in their workplace.
3 U.S. Department of Labor, Washington, Occupational Safety and Health Administration, "Safety and Health Program Management Guidelines (Issuance of Voluntary Guidelines; Notice." Federal Register, Vol. 54, No. 16, Jan. 26, 1989, pp. 3904-3916).
5 "Arc Welding Safety, NASD Review:" 04/2002. This document is 8818, a series of the Cooperative Extension, the University of Arizona, Tucson, AZ 85719. Publication date: May 1989. Lance Fluegel, safety coordinator and Bradley Rein, engineering specialist, the College of Agriculture, the University of Arizona, Tucson, AZ 85719. www.cdc.gov/nasd/docs/d000801-d000900/d000873/d000873.html
6,7 NFPA 51B Standard for Fire Prevention in Use of Cutting and Welding Processes, Chapter 2, Responsibility for Cutting and Welding, 2-1 General, 2003 Edition.
Dr. Laura Helmrich-Rhodes, CSP, is an associate professor at Indiana University of Pennsylvania's Department of Safety Sciences where she teaches both graduate and undergraduate courses; recently developing and delivering a duel-level course "Current Issues in Safety." She is an OSHA-authorized instructor, where a majority of her teaching load rests. Rhodes also oversees senior interns at major corporations in the United States. She is advisor to the Safety Science Honor Society Rho Sigma Kappa. Her doctoral dissertation, from the University of Pittsburgh in Administrative and Policy Studies, focused on the intersection of the human resources and safety professions.
David P.Rhodes, MA, CSP, CPCU, is an assistant professor/safety consultant at IUP. He is the safety supervisor for the PA/OSHA Consultation Program administered through the Department of Safety Sciences. He has taught undergraduate and graduate level safety sciences courses as well as various OSHA outreach training courses through the Keystone Occupational Safety and Health Training Center. He holds a B.S. in safety sciences and an M.A. in industrial and labor relations.