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OVERVIEW

This procedure establishes the requirements for completing hot work safely and the prevention of harm to persons or property.

Contents

1. INTRODUCTION ..................................................................................................................................................... 2

2. TRAINING AND COMPETENCY ............................................................................................................................ 4

3. HOT WORK PERMIT .............................................................................................................................................. 5

4. TOTAL FIRE BANS ................................................................................................................................................ 5

5. RISK ASSESSMENT .............................................................................................................................................. 7

6. HAZARDOUS AREAS ............................................................................................................................................ 8

7. EQUIPMENT ......................................................................................................................................................... 10

8. FIREFIGHTING EQUIPMENT AND EMERGENCY RESPONSE ........................................................................ 10

9. FIRE WATCH ........................................................................................................................................................ 10

10. DOCUMENT CONTROL ....................................................................................................................................... 12

APPENDIX 1.................................................................................................................................................................... 13

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1. INTRODUCTION

This document outlines the formal processes for performing Hot Work and applies to employees and contractors working for CBH. All contractors engaged to operate under their own HSE Management System are required to comply with the requirements stipulated in the Contractor Management Standard

Objective

This document outlines specific precautions to be taken prior to, during and after hot work to prevent the possibility of fire or explosion, which may result in harm to persons or property.

References

Table 1: External References

Reference

AS 1674.1:1997 Safety in Welding and Allied Processes: Fire precautions

AS 2865:2009 Safe working in confined spaces

AS 4745-2012_A1-2013 Code of Practice for Handling Combustible Dusts

AS 60079.0:2012 Explosive Atmospheres- Equipment – General Requirements

Table 2: CBH References

Reference STORE ID

Permit to Work Group Procedure STORE-1473931053-244096

Hot Work Permit Hard Copy / CBH117A

Critical Safety System Out of Service Permit STORE-1473931053-1527

SOP Barricading and Physical Separation STORE-1473931053-244104

Roles & Responsibilities

Role Responsibilities

Head of Health and Safety ▪ Assuming prime accountability for maintaining currency and validity of this SOP.

Area / Terminal Managers and Maintenance Superintendents

▪ Implementation and compliance with the requirements of this SOP document.

▪ Ensuring sufficient PTW hardware is available.

▪ Identifying and upon successful completion of training, authorising personnel to hold positions of Permit Issuers, Permit Holders and Fire Watch

Hot work Permit Issuer ▪ Reviews the risk assessment and Hot Work Permit for the task

▪ Considers the hazards associated with work in accordance with the Hot Work Permit

▪ Ensures appropriate controls are in place before issuing Hot Work Permit

▪ Authorises hot work to proceed and ensures that the conditions of the permit and JSA are adhered to

Hot work Permit Holder ▪ Adheres to the conditions of the hot work permit and any directives from the Permit Issuer

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Role Responsibilities

▪ When hot work is completed ensuring the area is made safe in consultation with the Fire Watch before closing the permit with the Permit Issuer

Fire Watch ▪ Ensure they are aware of the permit conditions and risk assessment for the task

▪ Sign on to the permit

▪ Ensure safety of people, plant and environment by from risk of fire by attending to duties diligently and in accordance with permit conditions

Definitions

JSA Job Safety Analysis

HOC Hierarchy of Controls

Hot Work Examples of Hot Work include but are not limited to:

▪ Welding, cutting, brazing, or burning with a torch, electric arc or soldering iron

▪ Using a propane torch;

▪ Using open flames; ▪ Grinding; and

▪ Drilling or cutting combustible insulated sandwich panelling.

PH Permit Holder

PI Permit Issuer

PTW Permit to Work

HLRA High level risk assessment

HRW High Risk Work

Designated Hot Work Area

A designated hot work area is an enclosed area, with doors and windows sealed specifically designed for performing hot work. It must as a minimum be free of combustibles (or when working outdoors, in a specially cleared area), have all required fire extinguishers and be adequately ventilated to remove fumes. E.g. A welding bay in a workshop complete with welding screens

Communication

The document owner is responsible for communicating and making available this document to all stakeholders. The document is available to all staff on the company intranet.

Compliance Management

CBH are required to comply with international and national legislated requirements, accreditations and standards. To achieve this staff are required to comply with all Policies, Procedures and Work Instructions provided to them. Regular reviews and audits will be performed by internal and external parties as required to ensure compliance is being achieved. If a non-compliance or breach is identified the Responsible Line Manager must be notified as soon as practically possible.

Change Management

Changes to this document shall be managed, reviewed and updated as described in the Document Control Content and Records Management Group Procedure.

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Designated Hot Work Area Requirements

A designated hot work area may be established and authorised at a site by the relevant manager. For an area to be designated a hot work area, a risk assessment must be conducted, and the outcomes of the risk assessment documented to confirm a hot work area has been designated.

For an area to be designated a hot work area, the following risk control measures must be implemented:

• Fire suppression equipment must be available i.e. water hose and supply, fire blanket, appropriate fire extinguishers or sprinklers.

• Fit for purpose furnishings e.g. no wooden / flammable furniture or benches

• Appropriate screens (AS 3957)/barriers in place.

• No flammable liquids or substances stored within the hot work area.

• No combustible materials stored within the hot work area.

• No build-up of dust on structures, equipment or surfaces.

• No open drains or other openings within the hot work area.

• Signage that indicates the area is a designated hot work area.

• Safe access and egress from the designated hot work area.

• Area is well ventilated (ducted, extraction or forced if required).

• In use gas cylinders are secured in an upright position.

• No storage of spare gas cylinders in designated hot work area.

• Wall and roof joints between walls and ceilings are sealed to prevent ignition sources escaping.

Alternative cold work methods

Alternative cold work methods should be explored whenever hot work is considered.

Cold work is an inherently safer method from a fire or explosion risk standpoint because the operation does not create an ignition source.

Examples include:

• Hydraulic shear cutting (metalworking) instead of torch cutting

• Reciprocating saw cutting (metalworking) instead of radial saw cutting (metalworking)

• Mechanical bolting instead of welding (metalworking)

• Threaded, flanged, coupling, or mechanical pipe joints instead of soldering metal pipe joints

• Approved reduced spark or pneumatic tooling

2. TRAINING AND COMPETENCY

▪ Trade qualified Personnel performing hot work shall be trained and competent in the use of equipment relevant to the task.

▪ Personnel performing Authorised Fire Watcher duties for hot work to be trained in hot work and use of firefighting equipment.

▪ HW Permit Issuer and HW Permit Holders must be deemed competent in relevant CBH Hot Work training.

Note: Hot work permits are not required in areas that are designated hot work areas.

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▪ Persons required to perform atmospheric testing as part of a Hot Work Permit must be trained in the use of the gas testing equipment and deemed competent in its use.

3. HOT WORK PERMIT

This Permit is a formal documented process applied to hot work that occurs outside of designated hot work areas. The Permit requires the following information:

• Details of the preparer, location, date, time of the proposed activity and equipment to be used.

• Precautions and controls to be established and maintained during the activity.

• Authorisation and acceptance details.

• Gas testing requirements.

• Completion details including fire watch and monitoring requirements.

Hot work performed in a confined space, at heights or requires isolation shall be performed in accordance with the Confined Space Entry SOP, Work at Heights SOP and Isolation of Plant and Equipment SOP accordingly.

Permit Validity

Each Hot Work Permit shall be valid for a maximum of one shift. If the permit expires before the hot work being performed is completed, a new permit shall be applied for.

4. TOTAL FIRE BANS

Hot work shall not be performed on total fire ban days in non-designated areas.

If works are still to proceed by prior approval by line management and the relevant Area Manager/Terminal Manager in control of the asset, A formal DFES exemption is not required for CBH to conduct Hot Work during these periods, however CBH employees must undertake the following process :

1. Follow the CBH risk assessment and Hot Work Permitting process, taking into consideration DFES prescribed controls listed:

• https://www.dfes.wa.gov.au/totalfirebans/Pages/recenttfbchanges.aspx

• https://www.dfes.wa.gov.au/totalfirebans/Documents/TFBHotWorkFactSheets.pdf

2. Notify DFES and the relevant local government between 24 hours and 30 minutes prior to the activity commencing. Note: If the activity is occurring within 3 kms from land managed by the Parks and Wildlife Service, you must notify the respective local District or Regional Duty Officer from Parks and Wildlife prior to the activity commencing within the same timeframe.

DFES online notification form located here:

https://www.dfes.wa.gov.au/totalfirebans/#tfb-notification-form

3. Work in accordance with all controls prescribed by DFES

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4. If conditions/controls cannot be met, work is not to proceed.

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5. RISK ASSESSMENT

Hot work specific hazards and controls

The risk assessment shall take into consideration the following hazards and controls:

Hazards Controls

Hazardous area zones ▪ Prior to performing any hot work in hazardous area zones, the area must be cleaned down to remove dust residues and any airborne dust allowed to settle.

▪ Any dust that settles on the floor must also be cleaned up.

Hot work affecting other workers in the area

▪ It is important to make sure that the hot work activity does not create a danger for another activity onsite. There shall be means to ensure that clear communication and coordination of work is ongoing to address possible permit/job conflicts.

Sparks falling on other below ▪ Sparks can fall from one level to another level via floor openings or grid mesh. These floor openings may need to be blocked to prevent hot material falling through. Floors and equipment may need to be wet down.

Fire inside ducting or trunking from hot work

▪ Before welding, heating or cutting of ducting and trunking, the interiors must be washed out until they are free of dust and grain both above and below the point of work.

Fire from hot work on rubber lined equipment

▪ Rubber, plastic or polyurethane lined equipment can catch alight – equipment must be thoroughly inspected for the presence of this material

Fire from hot work adjacent to combustible material

▪ Any presence of oxidizing materials and any flammable or combustible material within 7 metres of the worksite should be removed whenever possible. Combustible dust, oil and chemical spills or deposits must be cleaned. Where material cannot be removed it should be securely covered to prevent ignition.

▪ Where potentially flammable/combustible sources are within 7 meters (such as wooden scaffolding boards or grass) additional controls must be implemented such as keeping the flammable material wet, using screens or covering with fire resistant material for the duration of the hot work.

▪ Conveyor belts must be protected from hot materials.

▪ Drain covers within 7 meters of the hot work should be covered with fire resistant material to form a seal across the whole opening to prevent the escape of flammable vapours from the drainage system and the entry of sparks into the drain.

▪ Any potential sources of flammable vapour, gas, dust and grain situated within 7 meters of the hot work site should be rendered safe by isolation.

Fumes generated by hot work activities

▪ The carrying out of hot work activities and cause toxic fumes to be developed. The appropriate respiratory protection shall be considered when planning hot work.

EPS Sandwich Panelling ▪ If expandable polystyrene sandwich panel (EPS) are identified then they shall not be cut or drilled – only cold, low speed cutting apparatus shall be used and documented on the permit

▪

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Hot Work interaction with other high risk activities

Should hot work be performed in accordance with other high risk activities, associated permits shall also be issued or for non-permitted activities, the Permit Issuer shall give consideration to simultaneous operations that may be affected by or introduce fire or explosion risk to hot work activities.

The JSA shall cross reference all related permits, the associated hazards and controls of these activities before permits can be issued.

These include:

▪ Isolation of plant and equipment- Where hot work is undertaken on a system that may introduce hazardous energies, isolation must be undertaken in accordance with Isolation of Plant and Equipment SOP. Consideration shall be given to grain handling, gases or flammable liquids that may potentially be introduced whilst undertaken work and also be isolated and cleaned accordingly i.e. batch weighers that may potentially have grain hang ups.

▪ Hot work performed in a confined space – As per Confined Space Entry SOP should be conducted outside of a Confined Space wherever practical. Caution must be exercised at any time hot work is required in a confined space as the work process itself may render the atmosphere hazardous even though initial tests were satisfactory.

▪ Provision shall be made for exhausting the fumes created by the Hot Work and for introducing a supply of clean air to maintain oxygen concentrations at safe levels. Continuous monitoring shall be conducted for any hot work in a Confined Space

▪ Hot work performed where corresponding plant hygiene activities may create an explosive atmosphere that could be triggered by hot work ignition sources.

6. HAZARDOUS AREAS

Hazardous areas are regions or spaces in which an explosive atmosphere is present, or may be expected to be present, in quantities such as to require special precautions for the construction, installation and use of potential ignition sources. (e.g. flammable liquids, vapours or gases, combustible liquids, dusts or fibres etc).

Grain dust provides the fuel source for most of CBH Group’s hazardous areas. All areas have been evaluated against AS 4745:2012 (Code of practice for handling combustible dusts) to determine the degree of hazard presented by combustible materials and where applicable assigned a zone rating.

Zones for Dusts

Layers, deposits and heaps of combustible dust should be considered as any other source that can form an explosive atmosphere. Zones for dusts are (as per AS/NZS 60079.10.2) classified and designated as follows:

Zone 20 — A place in which an explosive dust atmosphere, in the form of a cloud of dust in air, is present continuously, or for long periods or frequently.

This can be the case inside dust containment areas where dust can form explosive mixtures frequently or for long periods of time. This occurs typically inside equipment.

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Zone 21 — A place in which an explosive dust atmosphere, in the form of a cloud of dust in air, is likely to occur in normal operation occasionally.

This zone can include, among others, areas in the immediate vicinity of powder filling or emptying points and areas where dust layers occur and are likely in normal operation to give rise to an explosive concentration of combustible dust mixed with air.

Zone 22 — A place in which an explosive dust atmosphere, in the form of a cloud of dust in air, is not likely to occur in normal operation but, if it does occur, will persist for a short period only.

Flammable Gas Testing

Hot work in hazardous areas must be managed to minimise the risks involved. When undertaking hot work in hazardous areas it is important to understand the terminology around ‘flammable range’. This relates to the range of flammable gas or vapour (% by volume) in air in which an explosion can occur upon ignition. This is expressed by Lower Explosive Limit (LEL) and Upper Explosive Limit (UEL).

The explosive (flammable) range is the range of mixtures of air and flammable dust, vapour or gas, between the Lower Explosive Limit (LEL) and the Upper Explosive Limit (UEL) where:

• The lower explosive limit is defined as: “In relation to a flammable contaminant, the concentration of the contaminant in air below which the propagation of a flame does not occur on contact with an ignition source.”

• The Upper Explosive Limit is defined as: “In relation to a flammable contaminant, the concentration of the contaminant in air above which the propagation of a flame does not occur on contact with an ignition source.”

If hot work is planned on any equipment that has held or may still hold flammable or explosive substances, a gas test shall be performed.

The person performing the gas test shall be trained in the use of the gas detection equipment to be used and results must be documented on the Hot Work Permit.

Gas testing results for hot work must be within the following limits for work to proceed:

• Oxygen less than 23.5%

• Lower Explosive Limit less than 5.0% LEL

In the event that the concentration of oxygen or flammable gas or flammable vapour in the test area exceeds the above limits, the Permit Issuer must be notified immediately to ensure the permit is not approved and corrective actions can be taken to reduce the concentrations of oxygen or flammable gases or vapours.

Equipment must be drained, flushed, purged or washed as necessary to provide an atmosphere which is gas free before commencement of hot work.

Fire system impairment

Depending on the location of planned hot work, fire systems may need to be impaired to prevent false alarms. In these instances, the Safety Critical Equipment “Out of service” permit shall be utilised and approved before commencing works.

The Fire System Impairment/Restoration notice shall also be lodged with the CBH Insurance Manager

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Barricading and Physical Separation

Wherever practicable, physical separation should be user to separate hot work from other activities. Refer to SOP Barricading and Physical separation

7. EQUIPMENT

Only approved equipment shall be used for hot work tasks. All equipment shall be used in accordance with the manufacturer’s instructions or relevant standard and as a minimum meet the following requirements:

▪ All portable electrical equipment and electrical equipment that is used in an environment that could damage the equipment (through moisture, heat, vibration, mechanical damage, corrosive chemicals or dust) must be protected by earth leakage current by means of a residual current device (RCD).

▪ The output of electrical welder should be protected by a voltage reduction device (VRD) to reduce the risk of electrocution.

▪ The earthing clamp must be as close to the welding point as possible and connected directly to the welding piece.

▪ Oxygen and acetylene cylinders and the associated hoses must be placed in a location where they are protected from the effects of hot work (I.e. hot slag or sparks).

▪ Oxygen and fuel gas bottles must be turned off and bled down when not in use or when unattended.

▪ Oxygen gas must be protected from oil, grease and fuel. Cylinders, hoses, regulators, and torches must be clean and oil-free.

▪ The correct type of grinding/cutting wheel or disc must be used for the correct application (e.g. size and speed requirements).

▪ Grinding equipment must NOT be used unless the correct guards are in place.

▪ Employees must wear the appropriate PPE for the hot work activity being done.

8. FIREFIGHTING EQUIPMENT AND EMERGENCY RESPONSE

Fire-fighting Equipment must be available at the location and readily accessible should an emergency develop during undertaking of hot work. They shall be:

▪ Immediately accessible and ready to operate.

▪ Appropriate type / class to suit the potential emergency

▪ May include any or all the following as deemed appropriate in the risk assessment: fire extinguishers, water hoses (to be charged with water at the nozzle), and fire blankets.

▪ If work is performed under a total fire ban, emergency provisions in line with Appendix 1

▪ Fire extinguishers shall not be removed from a standing location provided for emergency purposes.

9. FIRE WATCH

A Firewatch shall be present to oversee works in the event of a fire outbreak or hazard and conduct continuous and thorough inspection of the area where Hot Work is performed.

A Designated Fire Watch must be ready to take immediate action to combat any outbreak of fire that may occur and must not leave the job unless properly relieved by another Firewatch and must monitor the work area for at least 60 minutes after cessation of work.

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Designated Fire Watch persons shall:

• Be trained and deemed competent

• be alert for any fire outbreak or hazard

• inspect adjoining compartments, if heat transfer is possible

• take immediate action to combat any outbreak of fire that may occur.

• not allow hot work to proceed outside the area specified on the hot-work permit.

• immediately stop the work and withdraw the hot-work permit, if a hazardous

• condition is observed.

• monitor changes in wind direction (e.g. by means of a windsock).

• be aware of the need to use eye protection, to protect eyes against flashes where hot

• work involves arc welding, cutting or arc gouging.

• obtain fire extinguishers or fire hose or both.

• not leave the job unless properly relieved by an authorized person.

Note: fire watching is a continuous and thorough inspection and presence in the area and its vicinity by the assigned personnel, with special attention being given to any new developments that might affect the safe condition of operations.

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10. DOCUMENT CONTROL

Authorities

Approved By Head of Safety and Environment Approval Date 26/10/2020

Review Frequency Annual Next Review Date 26/10/2021

Owner Head of Safety and Environment Custodian HSE Advisor – Systems

Division Operations Department Safety and Environment

Review History

Version Date Author Description of Revision

0.1 18/10/2020 HSE Advisor – Systems New document creation

0.2 20/10/2020 HSE Advisor – Systems Draft, issued for review, not published

0.3 22/10/2020 Head of Safety and Environment

Approved and issued for publish

1.0 26/10/2020 IMS Team Final, issued for use, published

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APPENDIX 1

Total Fire Ban Control Requirements as per:

https://www.dfes.wa.gov.au/totalfirebans/Documents/TFBHotWorkFactSheets.pdf

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