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OSHA 1926.352

Fire prevention for welding

Subpart J

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.352(a), what must I do if the metal piece I need to weld cannot be moved from the work area?

You must either remove all movable fire hazards from the vicinity or protect them if the object cannot be moved. Employers should move objects to a designated safe location when practical, but when the workpiece cannot be readily moved, all movable fire hazards in the area must be taken to a safe place or otherwise protected before welding, cutting, or heating begins (1926.352(a)).

Under 1926.352(b), what does "positive means" to confine heat, sparks, and slag look like when welding near immovable fire hazards?

Positive means include using noncombustible shields, fire blankets, welding curtains, or other physical barriers to prevent sparks, heat, and slag from reaching immovable fire hazards. The rule requires taking steps to confine the hot material and protect nearby fixed combustibles when they cannot be removed (1926.352(b)). Consider using metal shields, welding screens, or erecting temporary noncombustible covers between the hot work and the hazard.

Under 1926.352(c), can I weld in an area where flammable paints or heavy dust are present?

No — welding, cutting, or heating must not be performed where flammable paints, other flammable compounds, or heavy dust concentrations create a hazard. You must eliminate or control those flammable materials before starting hot work (1926.352(c)).

Under 1926.352(d), what firefighting equipment must be on hand during welding and how ready must it be?

Suitable fire-extinguishing equipment must be immediately available and maintained in a state of readiness for instant use. Keep appropriate extinguishers (for example, Class ABC or those suitable for nearby hazards) within easy reach of the hot work area and ensure they are inspected and operable (1926.352(d)).

Under 1926.352(e), when must I assign additional personnel to watch for fires, and what training should they receive?

You must assign additional personnel (fire watchers) whenever normal fire prevention precautions are not sufficient, and they must be assigned during the hot work and for a sufficient time afterward to ensure no fire risk remains. These personnel must be instructed about the specific anticipated fire hazards and on how to use the firefighting equipment provided (1926.352(e)). Employers should perform a hazard assessment and provide training or written certification per OSHA guidance on PPE and hazard assessment when protective equipment or safety assignments are required (PPE hazard assessment guidance).

Under 1926.352(f), what precautions do I need to take when welding on a wall, floor, or ceiling shared with another area?

You must take the same fire-prevention precautions on the opposite side of the surface as you do on the side where welding is performed because heat or sparks can penetrate and ignite adjacent areas. That means inspecting and protecting both sides of walls, floors, and ceilings before beginning hot work (1926.352(f)).

Under 1926.352(g), what must I do with the gas supply to a torch before leaving an enclosed space during hot work breaks or at shift change?

You must positively shut off the gas supply to the torch at some point outside the enclosed space whenever the torch will not be used or is to be left unattended for a substantial period (for example, lunch or shift changes). Additionally, torches and hoses must be removed from confined spaces overnight and at shift changes to prevent gas leaks and potential fires (1926.352(g)).

Under 1926.352(h), what should I do with disconnected open-end fuel gas and oxygen hoses in enclosed spaces?

Open-end fuel gas and oxygen hoses must be immediately removed from enclosed spaces when they are disconnected from the torch or other gas-consuming device. This prevents accumulation of flammable gases in the enclosed space (1926.352(h)).

Under 1926.352(h), how must drums and pails that contain or held flammable liquids be stored during hot work?

Except when contents are being removed or transferred, drums, pails, and other containers that contain or have contained flammable liquids must be kept closed; empty containers must be removed to a safe area away from hot work or open flames. This reduces the risk of vapors igniting during welding or cutting (1926.352(h)).

Under 1926.352(i), what must be done before welding, cutting, or heating on a drum, container, or hollow structure that held flammable or toxic substances?

Before starting hot work, such drums, containers, or hollow structures must be either filled with water or be thoroughly cleaned, ventilated, and tested to ensure they are free of flammable or toxic residues. This prevents hidden vapors or residues from igniting or producing toxic atmospheres during heat application (1926.352(i)).

Under 1926.352(i), do pipeline welding rules differ for steel natural gas pipelines and where can I find the applicable pipeline regulations?

Yes — when welding, cutting, or heating on steel pipelines containing natural gas, the Department of Transportation's pipeline safety regulations in 49 CFR part 192 apply to the pertinent portions of the work. Employers must follow those pipeline safety requirements in addition to OSHA's hot-work provisions (1926.352(i) and 49 CFR part 192).

Under 1926.352(j), what must I provide before applying heat to a drum, container, or hollow structure?

You must provide a vent or opening to release any built-up pressure before applying heat to the container or structure. This prevents sudden pressure releases or explosions as materials heat up during welding or cutting (1926.352(j)).

Under 1926.352, do I have to keep fire extinguishers inspected and ready, and how does that relate to assigning a fire watcher?

Yes — extinguishers and other fire-extinguishing equipment must be immediately available and kept ready for instant use, and when normal precautions are insufficient you must assign trained fire-watch personnel. The standard requires both readiness of equipment and, when needed, additional personnel who are instructed about the specific hazards and how to use the firefighting equipment (1926.352(d) and (e)). Employers should conduct hazard assessments and train those personnel appropriately, consistent with OSHA guidance on workplace hazard assessments and PPE (PPE hazard assessment guidance).

Under 1926.352, how long should a fire watcher remain after the welding or cutting is finished?

A fire watcher must remain for a sufficient period after the work is completed to ensure that no possibility of fire exists. The exact time depends on conditions (for example, smoldering embers or hot metal that could ignite nearby combustibles) — retain the watcher until the work area is inspected and judged safe (1926.352(e)).

Under 1926.352, can compressed oxygen and fuel gas hoses be left in a confined space connected but not in use?

No — open-end fuel gas and oxygen hoses must be removed from enclosed spaces when disconnected; hoses should not be left connected and unattended inside confined spaces to prevent leaks and gas accumulation (1926.352(h)).

Under 1926.352, are there special precautions for hot work in areas with heavy dust concentrations?

Yes — welding, cutting, or heating is prohibited where heavy dust concentrations create a fire or explosion hazard; you must clean or control dust before performing hot work to eliminate ignition sources (1926.352(c)).

Under 1926.352, how should empty containers that held flammable liquids be handled relative to hot work?

Empty containers must be removed to a safe area apart from hot work operations or open flames. Even apparently empty containers can hold flammable vapors and should not remain near welding or cutting (1926.352(h)).

Under 1926.352, what specific actions should I take before welding on a hollow structure that previously held toxic substances?

Before applying heat, you must either fill the structure with water or thoroughly clean, ventilate, and test it to ensure all toxic residues are removed. Testing and ventilation are required to confirm the atmosphere is safe and free of flammable or toxic materials prior to hot work (1926.352(i)).

Under 1926.352, does the standard require removal of torches from confined spaces at shift changes and overnight, and why?

Yes — the standard requires torches and hoses to be removed from confined spaces overnight and at the change of shifts to prevent accidental gas leaks and accumulation of flammable gases while the space is unattended (1926.352(g)).

Under 1926.352, what recordkeeping or written documentation is required when assigning personnel to guard against fires during hot work?

The standard itself does not mandate written records specifically for assigning fire-watch personnel, but it requires that those personnel be instructed on the hazards and the use of firefighting equipment. Employers should document hazard assessments and training as part of their safety program; OSHA guidance on hazard assessment and PPE emphasizes documenting assessments and training when PPE or special protective assignments are required (1926.352(e) and PPE hazard assessment guidance).