Hot Work Permit Requirements

The issue around hot work permits continues to be something of a concern. There is no doubt that several recent fires caused by hot work activities have resulted in the insurers tightening up on their requirements.

The issue is relatively clear where an inspection is undertaken and the insurer specifically requests a hot work permit. However, more generally, one needs to closely check the different wordings to see if there is specific reference to hot work permits or compliance with the National Building requirements (or similar).

In this regard, it should be noted that SABS 0287 (9.1.1.3 and 9.1.2.2) specifically requires that suitable precautions must be taken when carrying out hot work, including the issuing of a hot work permit, permission from the owner of the building, notification to occupants of communicating buildings or neighbourhood buildings (or both) and notification to the relevant insurer/insurer(s) prior to commencing the work.

Government Notice R: 1031 of 30 May 1986 covering General Safety Regulations, also spells out certain requirements regarding welding, flame cutting, soldering and similar operations. They are:

9. (1) No employer or user of machinery shall require or permit welding or flame cutting operations
to be undertaken, unless –

1. the person operating the equipment has been fully instructed in the safe operation
   and use of such equipment and in the hazards which may arise from its use;
   
2. effective protection is provided and used for the eyes and respiratory system and, where necessary, for the face, hands, feet, legs, body and clothing of persons performing such operations, as well as against heat, incandescent or flying particles
   or dangerous radiation;
   
3. leads and electrode holders are effectively insulated; and
   
4. the workplace is effectively partitioned off where practicable and where not practicable all other persons exposed to the hazards contemplated in paragraph (b) are warned and provided with suitable protective equipment.
   

(2) No employer or user of machinery shall require or permit welding or name cutting operations
to be undertaken in a confined space, unless-

1. effective ventilation is provided and maintained; or
   
2. masks or hoods maintain a supply of safe air for breathing are provided and used by the persons performing such operations.
   

(3) No employer or used of machinery shall require or permit electric welding to be undertaken in
wet or damp places, inside metal vessels or in contact with large masses of metal, unless –

1. the insulation of the electrical leads is in sound condition;
   
2. the electric holder is completely insulated to prevent accidental contact with current-carrying part;
   
3. the welder is completely insulated by means of boots, gloves or rubber mats; and
   
4. at least one other person who has been properly instructed to assist in the case of an emergency is and remains in attendance during operations; Provided that the provisions of this sub-regulation shall not apply to a welding process where the maximum voltage to earth does not exceed 50 volts.
   

(4) No employer or user of machinery shall require or permit welding, flame cutting,
grinding, soldering or similar work to be undertaken in respect of any tube, tank, drum
vessel or similar object or container where such object or container-

1. is completely closed, unless a rise in internal pressure cannot render it dangerous;
   or
2. contains any substance which, under the action of heat, may-
   1. ignite or explode; or
   2. react to form dangerous or poisonous substances, unless a person who is competent to pronounce on the safety thereof has, after examination, certified in writing that any such danger has been removed by opening, ventilating or purging with water or steam, or by any other effective means.

(5) where hot work involving welding, cutting, brazing or soldering operations is carried out at
places, other than workplaces which have been specifically designated and equipped for
such work, the employer shall take steps to ensure that proper and
adequate fire precautions are taken.

Attention is also again drawn to the trend by insurers to apply stricter terms to the “standard” prevention of loss clause included in policies.

In general, the suggestion is that where in doubt clients should be advised to make use of a hot work permit as part of their prudent risk management wherever possible, rather than leaving things to chance. Please contact our offices if you require more information.
March 2018