Hot Work Safety - Hot Work Requirements and Combustible Dusts - Safety Engineering Network (SAFTENG)

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From SAFTENG the Safety Engineering Network, this blog post brings up some good questions.  This is one area of major concern, as several of the fires that caused massive amounts of damage in facilities that create or process combustible dust were started by contractors welding on a duct, dust collector or vessel, or near these areas where combustible dust had built up.

Hot Work Safety - Hot Work Requirements and Combustible Dusts - Safety Engineering Network (SAFTENG)

OSHA has clearly established that hotwork can not take place in the presence of combustible dusts. 1910.252(a)(2)(vi) Prohibited areas. Cutting or welding shall not be permitted in the following situations:


1910.252(a)(2)(vi)(A) In areas not authorized by management.
1910.252(a)(2)(vi)(B) In sprinklered buildings while such protection is impaired.
1910.252(a)(2)(vi)(C) In the presence of explosive atmospheres (mixtures of flammable gases, vapors, liquids, or dusts with air), or explosive atmospheres that may develop inside uncleaned or improperly prepared tanks or equipment which have previously contained such materials, or that may develop in areas with an accumulation of combustible dusts.

The area of concern that I wish to bring to light is doing hotwork in areas where the combustible dust is either a ways below you or above you. If you are in a large industrial complex that spans many floors, and lets say you are working on the first floor. The area is a combustible dust area, even rated as a Class 2 Div 2 HAZLOC. Your housekeeping program does a good job of cleaning at ground level, but not such a good job on those areas not accessible from the ground. Some of those beams can have 1" layer of combustible dust on them and span 35' across with four beams per floor and 10 floors above you.

Do we make any attempt to clean this dusts?
How high do we clean so as to remove the threat of the dust falling on the hotwork?

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