Hot work analysis
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Recently, the **Work Safety Administration came to our company for an inspection. After the inspection team left, the way in which hot work is carried out in our company has changed: high-risk hot work is now virtually non-existent. The person in charge of safety listed various potential safety hazards, and the conclusion was that high-risk hot work cannot be performed; it must wait until the system is shut down, the system is thoroughly cleaned, and all safety hazards are eliminated before such work can be carried out. For level 2 hot work, a hot work analysis must be conducted even if it is 500 meters away from the production equipment. Their reasoning is that since a fire permit is required, there are fire hazards present, and therefore a fire hazard analysis must be conducted. A task that requires welding can be completed in 30 minutes, but obtaining the welding permit takes over 2 hours. Especially at the construction sites of new projects, where there are no flammable or explosive materials to begin with, it is still required to obtain a hot work permit twice a day and to conduct hot work analyses every 2 hours – it’s absolutely exhausting. I don’t know if it was a wrong path or the monk mispronounced it. Dear sea friends, has your company encountered similar situations? Seeking discussion.
All of these are specified in GB30871-2014. It is understandable for safety managers to implement this policy, but its implementation must be based on reality. Safety is important, but it must be aligned with production. In principle, level 1 hot work should not be carried out when working on flammable and explosive pipelines while they are in use; if it must be done, it definitely shouldn’t happen. Accidents of this kind usually result in death or serious injury. Secondary hot work depends on the circumstances. The length of time taken by safety and environmental personnel for conducting a hot work analysis is closely related to the level of preparation at the site where the hot work is to be carried out; good preparation leads to a faster analysis process. It also depends greatly on the competence of the safety and environmental personnel – it’s not acceptable to be too afraid of taking responsibility.
Level 1 hot work should, in principle, be avoided if possible; Level 2 hot work can be carried out except during holidays. The speed of firework analysis depends on the preparation at the production site; with thorough preparation, the firework permit can be issued in just a few minutes.
Danger is relative! Conduct a proper analysis of risk factors; if everything is controllable, then it can be carried out
It feels like moving from one extreme to another； Working with fire near operating equipment requires extreme caution. According to GB30871-2014, such work is classified as a high-risk activity; not only must standard preventive measures be strengthened, but a work plan for carrying out the task as well as emergency response plans must also be developed. This includes isolating pipeline equipment, testing the area where work will be carried out, conducting environmental assessments, and establishing emergency rescue procedures. However, in non-explosion-proof areas, far from production facilities, and during the construction of new projects, approval at the level 2 for hot work can be fully applied, as clearly stated in GB30871-2014. GB30871 specifies that the approver for level 2 hot work is the person in charge of the construction project or the person in charge of the facility; the safety management department must be informed, and on-site supervision is required ； The maximum validity period for level 2 hot work is 72 hours ； The safety management department has shortened the validity period for level 2 hot work and strengthened the hot work analysis procedures, which indicates that the inspection by the **State Administration of Work Safety had a significant impact on the company’s decision-makers and management team. This shows that these stakeholders lack confidence in the safety awareness and management practices of those at the grassroots level.
If level 1 can’t be operated, then can the company only operate at level 2? Top-grade ones must not be used! Flame hazard analysis is necessary. As for what you mentioned about a new project, that seems a bit unrealistic; it makes no sense. Not to mention 72 hours, giving them at least one day should definitely be fine.
It seems your company still isn’t inspected often enough. I can understand the approach adopted by the company’s management. In fact, the compliance of your company’s relevant systems should be fine; it’s just that there might be some issues in their implementation at the grassroots level, and perhaps there is a lack of proper management in day-to-day operations. It’s a bit extreme for your company’s management to demand this; safety management isn’t about adding more measures, but rather about controlling risks. If you try to control welding projects merely by regulating their execution and tightening approval procedures and steps, that only addresses the symptoms rather than the root cause. In terms of welding, what’s most important are risk identification and the implementation of on-site safety measures – these two steps are the key. If you are able to offer suggestions to your company, I recommend that you do so: hot work at level 1 can be carried out, with the relevant department heads and company supervisors issuing work permits on-site and ensuring that safety measures are implemented there. By making this a regular practice, it is possible to **reduce the risks associated with hot work within production facilities. For other new projects under construction, fire hazard analysis is still required. Conducting it twice a day for 2 hours each time is indeed an overreaction; it’s complicated and unnecessary. It would be sufficient to manage things according to the requirements for level 2 fire hazards. But then why is fire hazard analysis still necessary? To give a simple example, if you need to perform welding work in a confined space using this device, is it necessary to conduct gas analysis and oxygen level testing? The answer is that it is necessary. Sometimes, a measure is implemented not only for safety reasons; some measures are also aimed at maintaining the seriousness and continuity of the management system, and of course, the influence of corporate culture plays a role as well.
According to the GB30871-2014 standard, this requirement applies mainly to the fire and explosion prevention areas of Category A and B in chemical manufacturing enterprises. For new installations that are not yet in operation, the level of fire and explosion prevention on site does not meet the requirements for Category A or B; in such cases, measures should be taken based on the actual conditions on site. Additionally, portable combustible gas detectors can be used for on-site testing during Class II welding operations, allowing for continuous monitoring – with analyses to be conducted every 2 hours. This is somewhat cumbersome. Safety managers should not be too rigid in their approaches; moreover, the standard states that the readings from portable combustible gas detectors can be used as data for welding safety assessments.
This is completely irresponsible behavior. Safety during hot work is indeed very important, but it doesn’t mean that hot work of level 1 cannot be carried out. If production demands it, such work can still be done, but the risks are high; therefore we must take adequate precautions and implement proper countermeasures；
The key is to master the hazards of combustion and explosion, as well as the skills of the operators. Pressure substitution and hot work can both be carried out. Conversely, as long as the regulations are met, any method of welding is legal; of course, it is preferable to avoid welding in the plant area or in workshops where production is taking place. Reference.