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Purpose: To provide requirements for doing work that has the potential to generate a
source of ignition (sparks or high temperatures) in areas where flammable or
combustible materials may be present.

Scope & These requirements apply to all Hot Work done by all personnel in the facilities
Applicability: owned or operated by EQUATE. Exemptions are listed in Appendix-A.

Definitions:

Term Definitions

Combustible Combustible materials include:

All liquids that can burn with a flash point above 37.8 C.
All solids (wood, polymer, scaffolding boards, coal, charcoal, straw,
leaves, etc.) that can burn.

Exempt Area An area Outside Battery Limits (OSBL) and greater than 10 meters from a
Potential Source of flammable materials and free of Combustible materials.
(For example: maintenance and shop areas and office areas free of
Combustible and flammable materials, road ways and parking lots, marked
smoking areas). Note: These areas fall outside the scope of this policy.

Flammable Area Within 10 meters of a Potential Source of flammable materials. Refer to

Class I, Division 2 locations, Class II, Division 2 locations (US, Canada)
OR, Zone 1. Zone 2, Zone 21 & Zone 22 locations (EU)

Flammable Flammable materials include:

Any gas that will burn in air.
All liquids with a flash point at or below 37.8C.
Any solid dusts that when suspended in air can be ignited.

General Area An area that is not a Restricted or Flammable Area Inside Battery Limits
(ISBL), or within 10 meters of a Potential Source of Combustible materials,
but greater than 10 meters of a Potential Source of flammable
materials. Note: Warehouses and other non-process buildings may be
considered General Areas provided that the only source of flammable
materials are room heaters that use fuels that have good physical warning
properties at levels well below the LEL of the flammable material (example
natural gas used for heating).

High Energy Includes activities that generate open flames and/or sparks and activities
Ignition Source that could provide an ignition source after an immediate removal of the
(High Energy Hot energy supply (for example: welding, flame cutting, grinding metals, fired
Work) heaters, etc).

Hot Work Work that has the potential to generate a source of ignition in areas where
flammable or Combustible materials may be present.

Ignition Source Any Potential Source that could ignite flammable or Combustible materials.
For example: burning, welding, flame cutting, heating with an open flame or
an electrical device, operating internal combustion engines and the use of
any other spark, flame or high temperature producing equipment or tools
such as pneumatic hammers, grinders, electric drills, etc This includes
Low Energy Ignition Sources and High Energy ignition sources.

Low Energy Includes activities that generate heat or have the potential to generate
Ignition Source sparks and activities that generally do not provide an ignition source after a

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(Low Energy Hot removal of the energy supply (for example: electrical/battery operated
Work) tools, non-intrinsically safe portable equipment - including mobile phones
and pagers, cameras, abrasive blasting, air driven tools, soldering irons,
internal combustion engines and motor vehicles, extension cords, or the
use of hand tools that could generate sparks - like chisels and hammer
wrenches, etc)

Potential Source of A valve, flange, sample point, vessel, tank, vent, overflow, drain or relief
Flammable device etc that has a potential to release flammable materials, either to
Materials the atmosphere or into the equipment being worked on.
A source of flammable materials is only a Potential Source if it is within 10
meters of Hot Work and has a direct path to the source of ignition used
during the Hot Work - either through piping or un-restricted atmosphere.
(For example: if a physical barrier - wall, building, etc. is blocking the
atmospheric path between the source of flammable materials and the
source of ignition then it may not be reasonable to consider it a Potential
Source of flammable materials.)

Restricted Area An area in which there is a continuous presence of flammable materials in

the atmosphere. Hot Work shall not be done. (For example: floating roof
tank, directly over sewer drains, etc with flammables present.). Refer to
Class I, Division 1 locations, Class II, Division 1 locations (US, Canada)
OR, Zone 0 & Zone 20 locations (EU).

I. General Requirements:
A. Hot Work area classification:
1. Hot Work areas are classified as Restricted, Flammable, General or Exempt. (See
definitions).
2. Department Leaders shall document the Hot Work classification of each specific area
of their facility according to LPP 3.1. Department Leader shall review this list annually.
3. The drawing showing Hot Work classifications shall be made available for the facility
personnel.
Note: Flammable materials brought into the area to do Hot Work do not affect the area
classification. Example: cylinders that feed welding / cutting torches.
B. Restrictions on Hot Work:
1. Hot Work shall not be done in a Restricted Area.
2. Hot Work shall be done in Flammable or General Areas only if there is no other
practical means to do the job or if the equipment to be worked on cannot be removed
to an Exempt Area.
C. Re-classification of Hot Work Areas: Appendix-B shall be completed for reclassification of
areas.
1. Department Leader may temporarily re-classify a Restricted Area as a Flammable
Area only when:
a) The potential sources of flammable materials have been removed from the
area, or,
b) The process is currently not operating, all flammable materials have been
isolated and flammable materials are not detectable in the Hot Work area.
2. A Restricted Area that has been temporarily re-classified as a Flammable Area shall
not be further re-classified as a General or Exempt Area.

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3. Department Leader may temporarily re-classify a Flammable or General Area as an

exempt area only when:
a) There are currently no potential sources of flammable materials within 10
meters, and
b) The area is Inside Battery Limits (ISBL) but the process is currently not
operating or the area is Outside Battery Limits (OSBL).
4. Approval from VP-Operations is required for permanent reclassification of hot work
areas.
D. Flammable Area Preparation: Prior to any High Energy Hot Work, and when Combustible
or flammable materials are potentially present in, below or above the Hot Work in a
Flammable Area then:
1. Those combustible or flammable materials that can be moved shall be removed to a
distance of 10 meters, or
2. The equipment to be worked on that can be moved shall be removed to an Exempt
Area, or
3. Guards shall be used to minimize contact with the source of ignition. For example, the
following in order of preferred method:
a) A 5 sided (4 walls plus floor) spark containment structure utilizing fire resistant
tarp material, or
b) A 4-sided containment (walls only) spark containment structure when the floor
is concrete, gravel or other non-Combustible material and it is free of
Combustible hazards, or
c) Water sprays on the Potential Source of flammable materials, or
d) Wetted fire tarps on the Potential Source of flammable materials.
E. General Area Preparation: Prior to any High Energy Hot Work, and when Combustible
materials are present in, below or above the Hot Work in a General Area then the
following shall be considered:
1. Combustible materials that can be moved are removed to a distance of 10 meters, or
2. The equipment to be worked on that can be moved is removed to an Exempt Area, or
3. Guards are used to minimize contact with the source of ignition. See procedure D3
above.
F. Clearing the Area:
1. During Hot Work in a Flammable or General Area, the area around the Hot Work shall
be clear of all persons not directly involved.
2. Barricades shall be used when there is a potential for the people who are not directly
involved in the high energy Hot Work to enter the area.
G. Fire extinguishing equipment (for example: fire extinguishers) shall be identified,
continuously available and easily accessible in the area where High Energy Hot Work is to
be performed.
H. Use of Enclosures: Requirements of policy 5.4 (CSE) shall be followed when enclosures,
fireboxes, tarps or any other guard is used that has:
1. The potential for limited ventilation, or
2. The potential for an oxygen enriched or oxygen deficient atmosphere, or
3. The potential for vapor, liquid or solid engulfment,
I. Safe Work Permitting for Hot Work:
1. Refer to Policy 5.3 for SWP requirements for Hot Work.

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2. Authorized Operating Procedure Users are not required to have an SWP for Hot
Work (as specified by policy 5.3) provided that the work is covered by a Hot Work
Operating Procedure (for example: a furnace/burner light-off by operations), which
shall address all of the requirements of this document.
J. When an SWP is required for Hot Work:
1. The exact location of the Hot Work shall be identified during the on-site SWP
inspection, and
2. The flammable and/or combustible material(s) within the area and the material(s) last
contained in the equipment shall be identified on the Safe Work Permit.
3. The Person Issuing an SWP for Hot Work shall ensure that the following is
understood by the Person Accepting an SWP and documented:
a) The location of the Hot Work, the classification of the area (Flammable or
General, etc),
b) The potential hazards, and
c) The necessary precautions to eliminate or minimize the potential hazards.
K. Prior to the High Energy Hot Work in a Flammable Area, the person issuing the SWP shall
conduct an on-site inspection of the Hot Work area to verify that all following requirements
have been met:
1. The area where Hot Work is to be done is prepared per the requirements of this
policy.
2. That the area classification is correct.
3. The Hot Work area has been cleared of all persons not directly involved in the Hot
Work.
4. The equipment has been prepared for Hot Work per the requirements of this policy,
including isolation of energy sources and line & equipment opening requirements.
5. The potential hazards have been documented and communicated.
6. The necessary precautions to eliminate or minimize the potential hazards, including
flammable atmospheric monitoring requirements have been documented and
communicated, and
7. The exact location of the Hot Work has been identified during the on-site SWP
inspection.
L. Fire watch:
1. A Fire watch, other than the person performing the Hot Work, shall be present during
all High Energy Hot Work in Flammable or General Areas when:
a) There are combustibles or flammables within 10 meters of the Hot Work, or
b) There are Combustibles or flammables at a distance of greater than 10
meters that could easily be ignited.
2. The Fire watch shall be present for at least 30 minutes after all High Energy Hot Work
is done when there are Combustible or flammable materials:
a) That are contained in walls, partitions, etc.., that could be ignited by radiation
or conduction, or
b) That could smolder and ignite over time.
3. Additional Fire watch shall be present when, but not limited to:
a) There are combustible or flammable materials at elevations above and/or
below the Hot Work that would be difficult for the first Fire watch to meet his
responsibilities.

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b) The area observed by a Fire watch extends beyond a distance that would be
difficult for the first Fire watch to meet his responsibilities.
4. The Fire watch shall:
a) Not be assigned any additional duties or tasks which will in any way conflict
with his responsibility as a Fire watch.
b) Continually observe the actions of the person doing the Hot Work and
surrounding conditions, and
c) In the event of an injury, fire, gas release or other emergency, shut down Hot
Work equipment in the affected zone, alert the person doing the Hot Work
and initiate the proper response for the situation.
M. Designation of Fire watch: Facility shall document the names of their Fire watches. Only
people who have all of the following shall be designated to be Fire watch for Hot Work:
1. Knowledge of his responsibilities, and
2. Knowledge of the work to be done and the specific tasks and the impact that these will
have on the Hot Work and vice versa, and
3. Knowledge of the proper procedures for shutting down the Hot Work equipment in
case of emergency, and
4. Trained on the proper use of flammable atmospheric monitoring equipment that they
will use (if any) and the specific fire extinguishing equipment provided.
N. Purging: When inert purging is used to clear contents to acceptable levels, then the SWP
for Hot Work or the Hot Work Operating Procedure shall:
1. Indicate the purge gas to be used.
2. Describe how the purging will be done.
3. Address considerations for ventilation and personnel protection in a potentially oxygen
deficient atmosphere.
O. Flammable Atmospheric Monitoring:
1. Flammable atmospheric monitoring (LEL) shall be done for all Hot Work in Flammable
Areas.
2. When a Facility has General Areas that border upon Flammable Areas, flammable
atmospheric monitoring (LEL) shall be done for all High Energy Hot Work in those
General Areas.
3. Flammable atmospheric monitoring shall be done:
a) When an SWP for Hot Work is required.
b) At the time of the on-site inspection.
c) When the safe working conditions upon which the SWP for Hot Work are
based are not being maintained and/or have changed.
d) Periodically or continuously as specified on the SWP for Hot Work.
e) If the SWP for Hot Work is suspended and needs to be re-authorized because
of a work stoppage.
f) When a Hot Work Operating Procedure is being used as specified in the Hot
Work Operating Procedure.
4. The date, time, name of the person performing the flammable atmospheric monitoring
and detected level of flammables (LEL) shall be documented.
5. Hot Work shall not be done when the flammable atmospheric monitoring has detected
a flammable material (for example: the meter has detected a reading above zero
LEL).

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6. When conducting flammable atmospheric monitoring of flammable materials in an

inert atmosphere a meter specifically designed for such measurement shall be used.
P. A Hot Work Operating Procedure can be used in place of an SWP for authorizing Hot
Work only when:
a) The Hot Work Operating Procedure is used by Authorized Operating
Procedure Users only.
b) The Hot Work Operating Procedure is specific to the Hot Work job.
Q. The Hot Work Operating Procedure shall document and communicate.
1. The location of the Hot Work.
2. The flammable and/or combustible material(s) within the area and the material(s) last
contained in the equipment.
3. The classification of the area (Flammable or General, etc).
4. The status of the line or equipment to be worked on.
5. Flammable atmospheric monitoring requirements to include:
a) The specific needs for flammable atmospheric monitoring, to include periodic
or continuous monitoring needs.
b) The location of all points where flammable atmospheric monitoring checks are
to be made.
c) The frequency of flammable atmospheric monitoring checks when periodic
monitoring is to be done.
d) The specific needs for subsequent flammable atmospheric monitoring when:
i. There is a work interruption due to an emergency or plant operating
problem.
ii. The safe working conditions upon which the Hot Work Operating
Procedure is based are not being maintained and/or have changed.
e) The potential hazards and the necessary precautions to eliminate or minimize
the potential hazards.
R. Vehicle Entry: :
1. Vehicle entry into the process area shall be granted only when absolutely necessary.
2. LEL monitoring shall be done for general or flammable areas:
before each entry, and
before restarting the vehicle while moving from one location to another area,
and
before restarting for leaving the process area
Additionally, for flammable areas following shall be done:
While the vehicle is running, it must be lead into and out of process areas and
conditions must be monitored at all times.
Exception: Continuous LEL monitoring is not required under any of the
following conditions:
1. The equipment used is zone-compliant. Can be known from the
manufacturer documents.
2. A provision exists with the vehicles or IC engines that prevents sparks
coming out. Example: Having spark (or flame) arrestors in the
exhaust.
3. Placing the IC engines outside the boundary of flammable area. Just
at the border between general and flammable areas.

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LEL shall be monitored at a distance of 8ft or greater in front of the vehicle.

3. If the vehicle would pass within 5 feet of any process piping, this specific area shall be
closely monitored to allow the vehicle to continue moving. Stopping of the vehicle
Engine: Engine of the vehicle must be stopped:
i. If you notice a flange, valve or equipment leak
ii. If the gas release alarm sounds
iii. If any unusual smell that is detected
iv. If the LEL detection monitor alarms
v. If you have reason to believe the gas detector is not functioning
properly.
vi. Any other unit specific requirement for vehicle stoppage.
II. Documentation requirements: The following documentation shall be available.
1. Safe Work Permits and Hot Work Operating Procedures
2. Hot Work Area Classifications for the Facility.
3. Documented list of personnel authorized to be fire-watch.
III. Record keeping requirements: There are no record-keeping requirements specific to the Hot
Work procedure.
IV. Audit and Self-assessment: Annual internal audits shall be carried out to determine if the Facility
complies with the requirements of this policy.
V. Training Requirements:
A. Following personnel shall receive training on this policy:
1. Fire Watch
2. Person Issuing an SWP
3. The Person Accepting an SWP
B. Additional Training requirements for Fire Watch:
1. When needed, the proper operation and use of any flammable atmospheric monitoring
equipment that he/she will use.
2. The proper operation of fire extinguishing equipment that he/she will use.
3. Re-training whenever these tools, equipment, methods, techniques, or procedures are
modified or changed.
4. Additionally, the personnel conducting flammable atmospheric monitoring for Hot Work
shall be trained on the use of flammable gas monitoring meters.
C. Re-training on requirement every 3 years or when new or modified procedures or methods are
introduced or when an audit or event indicates a need for re-training.
VI. Roles and Responsibilities:

Role Responsibilities

Department Leader 1. Document and maintain the list of Hot Work Area Classifications for
the Facility.
2. Document and maintain a list of all personnel designated as fire
watches.
3. Ensure that either an SWP is issued or a Hot Work Operating
Procedure is being used for all Hot Work within the Facility.

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Role Responsibilities

Fire Watch 1. Not be assigned any additional duties or tasks which will in any way
conflict with his responsibility as a Fire watch
2. Continually observe the actions of the person doing the Hot Work
and surrounding conditions, and
3. In the event of an injury, fire, gas release or other emergency, shut
down Hot Work equipment in the affected zone, alert the person
doing the Hot Work and initiate the proper response for the situation.
Person Issuing SWP Refer to procedure K.

Person Accepting Refer to procedure J-3.

SWP

VII. Implementation Guide: N/A

VIII. Reference Documents:
a. LPP 3.1 Hazardous Locations.
b. Dow Global Hot Work Standard.
IX. Practice & Guidance: Refer to the FAQ document linked here.

Document History
Approved by: EH&S department leader. Date: 03-Sep-2014
The following information documents at least the last 3 changes to this document, with all
changes listed for the last 3 months (most current is first).

Date Activity by Activity

8-Sep-14 Bhanu Added exemption for continuous LEL monitoring in

flammable areas.
MOC# EHS-02Sep2014-24294

29-Oct-13 Bhanu Added more info to the definitions of Restricted and

Flammable Areas for better understanding. Included
vehicle entry requirements.
MOC# EHS-29Oct2013-20563

8-Dec-09 Bhanu Changed to L3E format.

24 Mar-08 Sabir Made minor changes, highlighted in red, to align with

revised emergency procedure requirements.
See II-M3, IVB3, Appendix-A E7.
MOC# EHS2008020001
As per L3E document control requirement.
20 Oct 2005 Sabir 1. Document history block added
2. Header/footer modified.

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APPENDIX A (GENERAL EXEMPTIONS)

General exemptions to the requirements of this policy:
A. Exempt Areas
B. Refueling of motor vehicles at a refueling station.
C. Travelling motor vehicles in General or Flammable Areas on road ways that are Outside
Battery Limits (OSBL).
D. Motor vehicles in General or Flammable Areas that are Inside Battery Limits (ISBL), provided
that a vehicle entry procedure exists that documents the safeguards determined based on the
hazards in those areas. Refer to general requirement Q for elements to be covered in the
procedure.
Shop areas may be exempted from the other requirements of this policy provided that:
1. Any flammable liquids or gases used in the shop area have good physical warning
properties at levels well below the LEL of the flammable material. (Example natural
gas used for heating).
2. All hoses and tanks of fuels used for torches shall be checked for leaks prior to use.
3. The area around the Hot Work shall be clear of all persons not directly involved.
4. When there is the potential that people who are not directly involved in the Hot Work
can enter the area then barricades shall be used.
5. Combustible / flammable materials that can be moved are removed or protected from
ignition.
6. Fire extinguishing equipment (for example: fire extinguishers) shall be identified,
continuously available and easily accessible in the area where High Energy Hot Work
is to be performed.
7. In the event of an injury, fire, gas release or other emergency all Hot Work equipment
(welding machines, flame cutting, drilling, etc.) shall be shut down in the affected zone
and Hot Work shall be suspended until the emergency is cleared.
8. A procedure shall be in place to ensure all equipment and items brought into the area
are cleaned of all flammable material.
9. When the shop area is adjacent to Flammable Areas, or when flammable gases or
vapors are suspected, then flammable atmospheric monitoring shall be performed
prior to High Energy Hot Work and shall be performed prior to re-start if Hot Work is
suspended due to an emergency.

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