Hot work safety program

Microsoft establishes the Hot Work Safety program to comply with applicable regulations such as OSHA 29 CFR 1910 Subpart Q, Welding, Cutting, and Brazing.  Additional state and local regulations may also apply.  This program details a process to prevent workplace hazards that may be present during welding, and cutting operations performed at Microsoft facilities.  Hazards may include fire, injury from exposure to sparks, heat, fumes, gases, or flames, and/or property loss. 

This program applies to all Microsoft employees and external staff in areas where welding, cutting, or other hot work operations are performed.  The program defines the requirements for proper training of employees and external staff to ensure they have the requisite knowledge and understanding of safe work practices and procedures while performing these operations. 

2.1 Prevention and Control

2.1.1 Written Hot Work Plan

Each Microsoft location included in the scope of this procedure must develop a Site-specific Hot Work document.  This document must be made available to any personnel potentially affected by the procedure, including employees, external staff, or regulatory agency personnel.  Site-specific Hot Work must include the following: 

• Program purpose and scope. 
• Personnel roles and responsibilities.  A Site-specific Hot Work Plan must be designated for each work location to oversee implementation of the Site-specific Hot Work. 
• Definitions of terms critical for understanding the program, or those terms not commonly understood. 
• Description of the Hot Work Permit process and the precautions that must be taken before a permit can be issued. 
• General safety rules. 
• PPE requirements 
• Description of hazards and risk assessments 
• SOPs for hot work, including identification of employees and external staff authorized to weld. 
• Welding safety training. 
• Proper disposal methods for wastes generated from welding activities.  

2.1.2 Designated Hot Work Areas

Each location should set up a designated welding area. The designated area must be: 

• Located inside a fire-resistant building or an area that’s properly separated from other operations by noncombustible partitions. 
• Kept clear of combustibles within 35 feet of the work area. 
• Free of flammable and combustible liquids and materials within 35 feet of the work area. 
• Equipped with adequate ventilation. 
• Equipped with automatic sprinklers and at least one 10-pound dry chemical fire extinguisher within 35 feet of the work area. 
• Set up with protective dividers such as welding curtains or non-combustible walls available to contain sparks and slag to the combustible-free area.  

2.1.3 Fire Watch

Hot work operations, especially welding, often produce sparks, molten metal or hot embers. They can travel up to 35 feet and provide an ignition source for combustible or flammable material hours after hot work activities have finished. To prevent ignition, a Fire Watch must be included in every welding operation that occurs outside of a designated area, according to the following practices:

• During the Fire Watch, the Fire Watchperson (as designated by the PAI) must watch for sparks and have a water hose, extinguishers, or fire pails available to immediately put out any fires.
• The Fire Watchperson must maintain a continuous watch for a minimum of 30 minutes after the job is finished.
• Once the continuous watch is completed, the area must be checked at least once every 30 minutes for the next four hours. This area inspection may be completed by the Fire Watchperson or a designated Monitor.
  • Sparks and embers can fly or fall between cracks. The periodic inspection should encompass one floor above and one floor below the area, as well as all adjoining rooms, unless the PAI designates otherwise.
• Individuals serving as the Fire Watchperson must:
  • Have completed hands on training and know how to use fire extinguishers and other firefighting equipment.
  • Understand notification procedures for a medical or fire emergency. 

2.1.4 Hot Work Permits

A Hot Work Permit must be completed and signed by the PAI prior to performing welding tasks. Hot work permits for soldering may be generated for duration up to one year provided the conditions described in the permits do not change. A designated fire watch is not required for soldering operations.

The following individuals are involved in the Hot Work Permit process:

• The Site Safety and Health Administrator will act as the PAI. The PAI inspects hot work sites prior to the start of hot work operations using the checklist found on the Hot Work Permit Form (Appendix B).
• If not in a designated area, the PAI will appoint an employee or external staff trained in the use of a fire extinguisher to serve as the Fire Watchperson or a Monitor. 
• All completed Hot Work Permits must be submitted to the PAI following completion of the work. 

2.1.5 Hot Work Permit Process

The following steps outline a sample permit process:

1. The work area is made safe for hot work.
2. A request is made to the PAI for a hot work permit by the individual slated to perform the hot work.
3. The requestor and the PAI inspect the work area. The PAI may specify additional safety precautions.
4. The requestor implements required precautions, and then notify the PAI.
5. After verifying the adequacy of completed precautions, the PAI signs and issues the permit.
6. The requestor posts the permit at the site during all hot work operations. The PAI will determine if a fire watch is necessary. If required, the Fire Watchperson will be designated and will stay during operations and monitor the work area.
7. Once the hot work operations are completed, the Fire Watchperson stays in the work area and continues to observe for a minimum of 30 minutes, watching for hot spots. If no hot spots develop, the Fire Watchperson signs off under the Fire Watch section of the permit.
8. The Fire Watchperson, or a designated Monitor, returns every 30 minutes for a minimum of four hours, to continue monitoring for hot spots. The Fire Watchperson continues to initial the permit for the duration of the monitoring under the Fire Watch section of the permit.
9. The Fire Watchperson returns the completed permit to the PAI.

An example of a Hot Work Permit is included in (Appendix B.) 

2.1.6 Cylinder Storage and Handling

Proper handling and storage of cylinders is critical for the safe usage of compressed gases. Safe use of cylinders requires:

• Ensuring each compressed gas cylinder is legibly marked with either the chemical or the trade name of the gas. Empty cylinders must be labeled as such and have their valves closed.
• Regularly checking cylinders for leaks.
• Ensuring cylinders are capped when not in use, and properly secured when moved or stored.
• Posting signs at cylinder storage areas with hazard information regarding the gases stored. 
• Storing cylinders upright in separate, dry, fire-proof areas.
• Refer to the Microsoft's Chemical Hygiene Plan for additional information. 

2.2 Safe Work Practices

2.2.1 Hot Work Safety

2.2.1.1 Before Hot Work Begins

The operator must implement the following precautions:

• Check that all welding or cutting equipment is in good condition.
• Make sure all work pieces and equipment are free of chemical buildup, oily dirt, dust, lubricants and other combustibles.
• Check that the sprinkler systems are operational.
• Check that combustible objects have been removed from the working area.
  • Move all combustible objects at least 35 feet from the work area.
  • Cover or shield any combustibles that cannot be moved, using fire-resistant shielding, sheet metal, flame-retardant tarpaulins or a combination of these.
  • Sweep up any debris on the floor within a radius of 35 feet of the work area.
• Inspect or protect floors, walls, or ceilings, by the following methods:
  • Wet down combustible floors or cover with damp sand or fire-resistant shielding.
  • Use fire-resistant shields to protect combustible ceilings, walls, partitions or roofs within 35 feet of the work area.
  • Move combustibles away from the opposite side of a metal wall, partition, ceiling, or roof if there is a chance of conduction or heat radiation that could cause a fire.
  • Tightly cover any openings or cracks in the floor, walls, or ducts within 35 feet of the work area.
  • If combustibles cannot be moved, a fire watch must be used.
  • For suspended hot work, fire-resistant tarpaulins should be suspended below work.
• Be sure employees using arc welding or cutting equipment are protected from shock.
• When working outside, cover nearby open doors and windows so sparks cannot enter.
• Inspect locations for flammable liquids and gases near work area.    
  • Discontinue operations involving the handling or transport of flammable liquids near the work area.\
  • Remove all compressed gas cylinders not essential to the welding or cutting work.
  • Do not use cutting and welding equipment near flammable liquids or on closed tanks that have held flammable liquids or other combustibles.
  • Cover all openings on operating equipment containing flammable liquids to prevent sparks from entering or vapors from escaping.
  • Clean up any liquids leaked from pumps,
  • If vapors may be present, use a combustible gas indicator to check for flammable atmospheres.
• Use proper personal protection equipment, including eye protection, respiratory protection, and protective clothing as necessary.
  • Screen off areas where other employees or passersby could be exposed to seeing the arc.
• When working at more than six feet above the ground or floor, use a platform with railings, safety harness and lifeline. 
• Make sure the ventilation is adequate to remove fumes and gases from the operator’s breathing zone.
• Ensure that flying embers and sparks are controlled. 

2.2.1.2 During Hot Work

• Follow prescribed procedures:
  • Make sure the fire watch is in place before starting.
  • Use all equipment according to the manufacturer's instructions and follow safe work practices.
  • When using electric welding equipment, ensure sufficient metal contact with the work piece.
  • Use a power cable no more than six feet long, plugged into a Ground Fault Circuit Interrupter.
  • If possible, place the cylinders on carts outdoors.
  • Turn off gas at the bottles when oxyacetylene equipment is not in use.
  • Protect the hose from damage.
• Safe operating conditions:
  • If an unsafe condition is observed, stop all work until the situation is corrected.
  • Stop work if a chemical spill occurs in the area.
    • The spill must be cleaned up and the permit supervisor must inspect the area before work can resume.
  • When cutting or welding outdoors, stop work if the wind increases or changes direction. 

2.2.1.3 After Hot Work is completed,

• Handle and disassemble equipment safely:
  • Handle, store, and maintain all equipment according to the manufacturer's instructions.
  • When using gas equipment, close the cylinder valves and relieve gas pressure through the regulator.
    • Always shut off the acetylene first.
  • Disconnect electrical equipment from the power source.
  • Take care to prevent arcing. Remove and position the electrode holders so they cannot make inadvertent contact.
• Ensure proper housekeeping and labeling have been restored:
  • Dispose of rod stubs and electrodes properly.
  • Keep tools and other tripping items off the floor.
  • Label all hot work and post warning signs to warn others about hot surfaces. 

2.2.4 Confined Spaces

Performing hot work within confined space presents additional hazards such as entrapment, explosion, oxygen deficient atmosphere, and concentration of hazardous chemicals and may require additional safety procedures. For more information, refer to the Microsoft's Confined Space Program. 

2.2.5 Ventilation

A number of potentially hazardous materials contained in fluxes, coatings, coverings, and filler metals may be released to the work area when soldering.

In general, workers must use local exhaust or general ventilating systems when operations may generate hazardous fumes, gases, or dust. These systems assist with diluting can help keep the amount of airborne hazardous materials below the material’s permissible exposure limit (PEL). Microsoft's Exposure Assessment Program and Microsoft's Chemical Hygiene Plan.

2.2.6 Risk Assessment

Risk Assessment is an evaluation of health and safety hazards in a work task and determining the likelihood of personnel injury or property damage resulting from those hazards. These analyses will usually include:
 

• Interviewing supervisors, employees, and external staff.
• Observing work practices.
• Reviewing supporting documents that may include applicable regulations and guidelines and SOPs.
• Conducting air and/or surface sampling, where occupational exposure limits are in question or as otherwise necessary.
• Engaging process experts to review the tasks and develop safe work practices for operation and maintenance.

The Site Safety and Health Administrator will provide recommendations of appropriate engineering controls, administrative controls, work practices, PPE, or corrective action items. Supervisors must notify the Site Safety and Health Administrator when: 

• Changes are made to job processes that present additional hazards.
• Audit corrective action items have been completed.

For more information on the risk assessment process, consult the Microsoft's Exposure Assessment Program.

2.3 Personal Protective Equipment (PPE)

Before determining the appropriate PPE for the specific task, refer to the Microsoft's Personal Protective Equipment Program and Puget Sound Respiratory Protection Program. The Site Safety and Health Administrator must work with managers to complete a Risk Assessment for each hot work process, which will identify the hazards and select the most appropriate type of hazard controls. The Risk Assessment should include hazards from fire, hot surfaces, exposure to hazardous materials, and other hazards for the specific work task.

The following table contains suggested PPE that may be used in hot work operations:

2.4 Training

Each location must train employees and external staff authorized to perform hot work. Training must be provided for:

• Authorized personnel at initial assignment.
• Retraining for employees and external staff when changes in procedures or work assignments occur.
• Retraining for employees and external staff if there is reason to believe they do not possess the required skills, or as a corrective action item following an incident. 

Microsoft OHS has defined training to meet regulatory requirements for hot work. To obtain training, contact Global OHS. Any training program must include the following information:

• An overview of hot work requirements and hands-on instruction of the applicable Site-specific Hot Work Plan.
• Applicable federal, state, or local regulations.
• A review of the hazards associated with hot work.
• Summary of the hot work program and how to access the written program.
• Hands-on instruction in the use of site-specific equipment, including appropriate fire protection equipment.
• A review of the manufacturer's operating instructions.
• Details of the PPE requirements for hot work.
• Requirements for maintaining records of all training, including the name of the instructor, the trainees (names and signatures), the material covered, and the date.
• Procedures for responding to and reporting an incident.

2.5 Audits

Site-specific Hot Work Plan must be audited annually and updated as needed to correct identified deficiencies. Site Safety and Health Administrator must also review any past incidents related to hot work that occurred since the previous audit.

Managers and supervisors should be consulted about program improvement opportunities and involved in implementation of needed compliance improvements. Site-specific Hot Work Plan should be updated as needed to reflect regulatory changes and improvements resulting from the annual audit.

Incident investigations are initiatied upon receiving reports. To foster a culture of health and safety at Microsoft, employees, interns, and external staff are required to report all work-related accidents, injuries, and illnesses via SafetyHub Report. Learn more on the Global OHS reporting page. 

At Microsoft, data and documents are retained in compliance with the retention times set out in our Corporate Retention Schedule.

Stakeholders for each Microsoft Facility or Business Group are responsible for implementing the requirements established by the Global OHS Program that are necessary for Microsoft to meet its regulatory requirements. 

The following terms are used in this document. The definitions below are used in the scope of this document but local regulatory definitions override if there is a conflict.

Brazing: The use of molten metal to join two pieces of metal together. The metal added during the process has a melting point lower than that of the work piece; only the added metal is melted, not the work piece. Brazing is often used to join metals other than steel, such as brass. Brazing can also be used to apply coatings to parts to reduce wear and protect against corrosion.

Combustible Liquid: Liquids with a flash point of 100°F or above, which are capable of ignition and require a higher degree of heat to produce a fire compared to flammable liquids.

Combustible Material: This term applies to solid materials that are capable of igniting and burning, usually with a flash point at or above 37.8°C (100°F) but below 93.3°C (200°F).

Designated Area: A work area where hot work activities may occur. These areas must be free from combustibles and have certain fire prevention and extinguishing equipment in place.

Engineering controls: The elimination or reduction of a hazard by means of engineered machinery or equipment. Examples include process change, isolation, ventilation, and source modification.

Exposure Assessment: Determination or estimation (qualitative or quantitative) of magnitude, frequency, duration, and route of exposure.

Fire Watchperson: A person or persons assigned to an area for the express purpose of notifying the fire department and/or building occupants of an emergency, preventing a fire from occurring, extinguishing small fires, or protecting the public from fire and life safety dangers.

Fire Watch: The act of watching for the occurrence of fire during and after performing hot work. This is performed by a Fire Watchperson with the intent of detecting fires early so they can be extinguished quickly and damage to land and/or property can be prevented or minimalized.

Flammable Liquid: A liquid with a flash point below 100°F.

Flammable Material: This term applies to solid materials that are capable of igniting and burning, usually with a flash point below 100°F.  

Ground Fault Circuit Interrupter (GFCI): Provides additional protection from shocks by shutting off current to equipment when a change in electricity is sensed. GFCI's are designed to shut off electrical power within as little as 1/40 of a second.

Hot Work: Any work involving burning, open flame, heat, or spark generation capable of initiating fires or explosions. This includes welding (arc welding and oxy-fuel gas), open-flame soldering, brazing, thermal spraying, cutting, grinding, soldering, torch-applied roofing, heat treating, and all similar applications producing a spark, flame, or heat sufficient to ignite combustibles.

Hot Work Operator: An employee or external staff who performs hot work operations.

Hot Work Permit: A regulatory required document that provides a step-by-step checklist for welding, soldering, cutting or brazing work and serves as a reminder of fire prevention responsibilities before, during, and after any hot work is conducted.

National Fire Protection Association (NFPA): An international nonprofit organization focused on reducing the worldwide burden of fire and other hazards on the quality of life by providing and advocating consensus codes and standards, research, training, and education.

Occupational Safety and Health Administration (OSHA): The federal agency responsible for developing and enforcing regulations related to health and safety in the workplace, establishing enforceable chemical exposure limits, and setting minimum standards for workplace health and safety. OSHA is part of the United States Department of Labor.

Oxygen Deficient Atmosphere: An atmosphere with oxygen content below 19.5% by volume.

Permit Authorizing Individual (PAI): The individual designated by management to authorize hot work. The PAI cannot be the hot work operator.

Personal Protective Equipment (PPE): Clothing and other work accessories worn by an individual to create a barrier against workplace hazards. Examples include safety glasses or goggles, respirators, hard hats, hearing protection, gloves, impermeable or fire-retardant clothing, and protective boots.

Shielding: Non-combustible welding drapes used in hot work areas. Visible signs should be displayed on shielding while hot work is being performed.

Standard Operating Procedures (SOPs): A written document or instruction detailing all steps and activities of a process or procedure.

7.1 Microsoft Internal

• MS Policy 37019-2, Regulatory Compliance
• MS Policy 37019-5, Regulatory Investigations, Inspections, and Inquiries
• Microsoft Medical Surveillance Procedure
• Microsoft Vendor Code of Conduct
• Employee Safety Incident Reporting and Investigation Procedure
• Microsoft Exposure Assessment Program
• Microsoft Personal Protective Equipment Program
• Microsoft Respiratory Protection Program
• Microsoft Confined Space Program 
• Microsoft Chemical Hygiene Plan 

7.2 Microsoft External 

• OSHA, 29 CFR 1910.251-.255 Subpart Q, Welding, Cutting, and Brazing
• OSHA, 29 CFR 1910.1000 Table Z-1, Limits for Air Contaminants
• OSHA, 29 CFR 1910.132, Personal Protective Equipment
• OSHA, 29 CFR 1910.133, Eye and Face Protection
• OSHA Chemical Sampling Guide, Chemicals
• NIOSH Publication No. 88-110: Criteria for a Recommended Standard: Welding, Brazing, and Thermal Cutting
• NIOSH Publication No. 2005-151: NIOSH Pocket Guide to Chemical Hazards – Welding Fumes
• NIOSH Approval of Respiratory Protective Devices, 42 CFR Part 84
• NFPA, Standard for Fire Prevention in Use of Cutting and Welding Processes, NFPA Standard 51B,1962
• Washington, WAC 296-24-680, Welding, Cutting and Brazing
  
• California, CCR, Title 8, Section 4794, Gas Systems for Welding and Cutting
• California, CCR, Title 8, Section 4850, Electric Welding

The Site Safety and Health Administrator may use this outline to produce a written hot work plan for establishing safe work practices and communicating the hazards associated with hot work activities to employees and external staff working in their areas. this document must be tailored to identify or comply with the following:

• Federal, state, or local regulations governing hot work at the facility location.
• Machines, equipment, or processes covered under their program.
• Employees or external staff covered under their program.

Managers must make this document available to employees, external staff, and corporate or regulatory compliance officers.  

Purpose  

State the purpose of the program (establishes consistent management practices, minimize safety and health risks, and communicate workplace hazards). 

Scope

Describe the area or facility-specific operations that fall under this program (areas that perform hot work operations). 

Regulations  

A list of any applicable federal, state, and local regulations must be included here. For example, in the United States, federal regulations for hot work safety fall under OSHA 29 CFR 1910.251 -.255, Subpart Q, Welding, Cutting, and Brazing. Individual states or local municipalities may have additional requirements. 

Roles and Responsibilities  

Personnel with responsibility for oversight or implementation of Welding, Cutting, and Brazing safe work practices must be identified here. This document’s list should include those roles and responsibilities listed in this document. 

Definitions  

The written hot work plan must include definitions. However, additional definitions may be required based on applicable regulations or activities that take place at the site. 

Workplace Survey and Risk Assessment  

Summarize the workplace survey and risk assessment results at the workplace. This summary can be presented as a table for easy reference. Be sure that the summary allows the reader to easily identify the referenced machine, equipment, or process on the workplace floor. This can be done by including photographs or floor maps in the document. 

Hot Work Procedures

Establish SOPs and safe work practices for hot work. Include specifics on controls and PPE that employees and external staff must use during that procedure. Include a list of employees and external staff authorized to conduct hot work. Each workplace should consider what additional rules should be added to this list, based on site-specific conditions. 

Training  

Information on training frequency and site-specific training content must be incorporated in this section.  

Inspections  

Annual audits of each established Site-specific Hot Work Plan must be performed. Audit documentation must be retained onsite. Following the audits, training and other corrective actions must be taken as necessary. 

Incident Investigations  

Incident investigations should be performed for all accidents, incidents, and near-miss incidents that were 

THIS HOT WORK PERMIT IS REQUIRED FOR ANY OPERATION INVOLVING OPEN FLAMES OR PRODUCING HEAT AND/OR SPARKS. THIS INCLUDES, BUT IS NOT LIMITED TO: BRAZING, CUTTING, GRINDING, SOLDERING, THAWING PIPES, TORCH APPLIED ROOFING, AND WELDING.

 

QUALIFICATIONS OF EMPLOYEES INVOLVED IN WORK

(ATTACH ADDITIONAL SHEET IF NECESSARY)

Are employees involved in the process trained for the task?

No _____  Hot Work cannot be performed by inadequately trained workers

Yes _____  Document related experience, training and/or certifications below 

WORK PLAN  
THIS PERMIT IS ONLY GOOD FOR THE DATE AND TIMES SHOWN BELOW. 

FOLLOW THE INDICATED REQUIREMENTS CAREFULLY.  ANY VIOLATION OF THESE RULES WILL NULLIFY THIS PERMIT AND WORK WILL BE STOPPED.