Introduction

Hot work is defined as "an operation that can produce heat from flame, spark or other source of ignition with sufficient energy to ignite flammable vapors, gases, or dust". Hot work includes such things as electric arc and gas welding, chipping, grinding, cutting, abrasive blasting, brazing and soldering. When it becomes necessary to conduct hot work near equipment in service with hydrocarbons present, e.g., oil and gas pipelines or wellbays, then safety professionals will be especially challenged to ensure the health and safety of the workers conducting the hot work. With oil and gas prices at record heights and many offshore production facilities destroyed or offline due to recent hurricane damage, energy companies are understandably reluctant to shut in much-needed production unless absolutely necessary. Because of this, special hot work procedures and equipment have been developed in cooperation with the Minerals Management Service (MMS), a division of the Department of the Interior. These procedures are designed to ensure the safety of personnel and equipment when conducting this type of work. This paper will discuss the use of pressurized welding habitats in high-risk environments on offshore production platforms and pipelines.

Developing a General Welding, Burning and Hot-Tapping Plan

In 30 CFR 250.502 109–113, the requirements for a General Welding, Burning and Hot-Tapping Plan are found. You must submit a Welding Plan to the MMS District Supervisor before you begin drilling or production activities on a lease. You may not begin welding until the District Supervisor has approved your plan and you must keep a copy of the plan and its approval letter; and drawings showing the designated safe-welding areas onsite where the welding will occur.

You must include all of the following in the Welding Plan that you prepare under Sec. 250.109:

  • Standards or requirements for welders;

  • How you will ensure that only qualified personnel weld;

  • Practices and procedures for safe welding that address:

    • Welding in designated safe areas;

    • Welding in undesignated areas, including wellbays;

    • Fire watches;

    • Maintenance of welding equipment, and

    • Plans showing all designated safe-welding areas

  • How you will prevent spark-producing activities (i.e., grinding, abrasive blasting/cutting and arc-welding) in hazardous locations.

A welding supervisor or a designated person-in-charge (PIC) must be thoroughly familiar with your welding plan. This person must ensure that each welder is properly qualified according to the welding plan. This person also must inspect all welding equipment before welding. Your welding equipment must meet the following requirements:
  • All engine-driven welding equipment must be equipped with spark arrestors and drip pans;

  • Welding leads must be completely insulated and in good condition;

  • Hoses must be leak-free and equipped with proper fittings, gauges, and regulators; and

  • Oxygen and fuel gas bottles must be secured in a safe place.

Before you weld, you must move any equipment containing hydrocarbons or other flammable substances at least 35 feet horizontally from the welding area.

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