Hot work fire safety requirements

A designated area is a workplace the employer sets aside for hot work because it is free of fire hazards. Employers may designate areas for hot work in places like vessels, vessel sections, fabricating shops, and subassembly areas that they have inspected and found free of fire hazards. See 1915.503(a)(1).

Before authorizing hot work in a non-designated area, you must visually inspect the work area and adjacent spaces to ensure they are free of fire hazards unless you use a Marine Chemist's certificate or a Shipyard Competent Person's log for authorization. This inspection requirement is stated in 1915.503(a)(2)(i).

You may only authorize hot work in non-designated areas that are free of fire hazards or where hazards have been controlled by physical isolation, fire watches, or other positive means. That is the requirement in 1915.503(a)(2)(ii).

• Physical isolation can include removing or shielding combustibles and closing openings to adjacent spaces.
• Fire watches mean trained personnel assigned to detect and extinguish smoldering fires or to stop work if a hazard appears.

See 1915.503(a)(2)(ii).

Yes — a Marine Chemist's certificate or a Shipyard Competent Person's log may be used instead of performing the visual inspection described in 1915.503(a)(2)(i). The certificate or log documents that the space has been evaluated and found free of fire hazards for the intended hot work.

For guidance on the duties and authority of a competent person in shipyards, see OSHA’s interpretation on competent persons in shipyards at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

Employers must keep all hot work areas free of new hazards that may cause or contribute to the spread of fire while hot work is in progress. That is the obligation in 1915.503(b)(1).

• This includes monitoring for unexpected energizing or energy release hazards covered by 1915.181.
• It also includes controlling exposures to toxic or hazardous substances covered by 1915.1000 through 1915.1450 when those hazards are present.

No. Fuel gas and oxygen hose lines or torches may not be left unattended in confined spaces. This prohibition is explicit in 1915.503(b)(2)(i).

Charged fuel gas and oxygen hose lines or torches may not be left unattended in enclosed spaces for more than 15 minutes. That is the rule in 1915.503(b)(2)(ii).

If workers must leave the area for longer than 15 minutes, the equipment should be secured or disconnected so it is not left charged and unattended in the enclosed space.

Yes. Employers must disconnect all fuel gas and oxygen hose lines at the supply manifold at the end of each shift, per 1915.503(b)(2)(iii).

After disconnection, fuel gas and oxygen hose lines must be rolled back to the supply manifold or rolled back to open air to disconnect the torch; extended hose lines must not be reconnected at the supply manifold unless they were given positive identification when first connected and then tested (for example, by a drop test) to ensure system integrity. This requirement is in 1915.503(b)(2)(iv).

• Positive identification and testing (such as a drop test) prevent incorrect reconnection and help ensure safe fuel gas/oxygen systems.

The employer is responsible for authorizing employees to perform hot work only after confirming the area is free of fire hazards or that hazards have been controlled; this authorization requirement is set out in 1915.503(a)(2).

Employers commonly delegate this authorization to a qualified supervisor, a Marine Chemist when appropriate, or a Shipyard Competent Person as described in OSHA’s interpretation on competent persons in shipyards at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

Yes, the requirements in 1915.503(a)(2) apply to all hot work operations in shipyard employment except those covered by 1915.14. The note at the end of paragraph (a)(2) makes that clear.

If hot work could expose employees to toxic or hazardous substances, the employer must follow the shipyard toxic substances rules in 1915.1000 through 1915.1450 and 1915.1450. 1915.503(b)(1) specifically points employers to those provisions when exposures to toxic substances are possible.

1915.503 requires that hot work be done only in areas free of fire hazards or where hazards are controlled by fire watches or other positive means; see 1915.503(a)(2)(ii). A fire watch means an assigned person watches for and responds to smoldering or open fires during and for a specified time after hot work, stopping work and alerting others if a hazard develops. While 1915.503 does not spell out exact fire-watch procedures, employers should ensure fire-watch personnel are trained and equipped to detect and extinguish fires promptly.

No. Ordinary sunglasses are not suitable for protection from the intense radiant energy produced by arc welding and gas torch cutting. OSHA’s interpretation explains that "potentially injurious light radiation" in welding and cutting means intense radiation and that affected employees must use appropriate welding eye/face protection. See OSHA’s letter of interpretation on shipyard eye and face protection at https://www.osha.gov/laws-regs/standardinterpretations/2019-12-30 and the general eye-protection requirements in the shipyard standards. The LOI explains welding-specific protection (e.g., welder’s hoods, shaded lenses) is required for welding and cutting operations.

A competent person in shipyards may evaluate hazardous atmospheres and specify the necessary protection and precautions for employee safety; their determinations can be used to authorize hot work when documented in a log. OSHA explains the competent person must be capable of recognizing and evaluating hazardous conditions and specifying protection, and for many shipyard subparts must meet the additional requirements of 29 CFR 1915.7; see OSHA’s interpretation on competent persons in shipyards at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18. Also see the hot work authorization provisions at 1915.503(a)(2)(i).

Yes. Employers must keep hot work areas free of new hazards that could cause or spread a fire, so if a new hazard appears the employer must control it, which may include stopping hot work until the hazard is corrected. This duty is stated in 1915.503(b)(1).

Extended fuel gas and oxygen hose lines may not be reconnected at the supply manifold unless the lines were given a positive means of identification when first connected and the lines are tested by a drop test or other positive means to ensure the integrity of the fuel gas and oxygen burning system. That requirement appears in 1915.503(b)(2)(iv).

Yes — 1915.503(b)(1) directs employers to control unexpected energizing and energy release under 1915.181. Employers doing hot work should consult 1915.181 for specific procedures to prevent accidental energizing or energy release.

1915.503(b)(1) points employers to the shipyard toxic and hazardous substances standards in 1915.1000 through 1915.1450 for exposure limits and controls when hot work may create airborne toxic contaminants. Employers must follow those rules for monitoring, limits, and protective measures.

No — for non-designated areas the employer must visually inspect the area and adjacent spaces to ensure they are free of fire hazards before authorizing hot work unless a Marine Chemist's certificate or Shipyard Competent Person's log is used, per 1915.503(a)(2)(i). Written procedures do not replace the visual inspection unless one of the specified authorizations is used.