Hot Work Permit Procedures and Date

Stationary sources subject to the Program 3 Prevention Program requirements in 40 CFR Part 68, Subpart D, must include in their Risk Management Plan (RMP) the date of the most recent review or revision of hot work permit procedures in Section 7.13. What are hot work permit procedures and what date should the stationary source enter in Section 7.13?

Hot work permit procedures can be found in the relevant standard operating procedure (SOP), safe work practice manual, or operations or maintenance guide that the stationary source uses to inform personnel when and how to perform hot work. For the stationary source’s first RMP, the owner or operator should enter the date of the last review of these procedures in Section 7.13, ensuring compliance with the hot work permit requirements in §68.85. For subsequent RMPs, the owner or operator should provide the date of the most recent review or revision of the hot work permit procedures. Hot work permit procedures may be reviewed or revised as a result of, among other things, a periodic audit of the prevention program (§68.79(a)). If the procedures were not reviewed or revised since the previous RMP was submitted, the owner or operator may retain the date provided in the previous RMP.

Additional information on hot work permit procedures can be found in Chapter 7 of the General Risk Management Guidance at:

https://www.epa.gov/rmp/guidance-facilities-risk-management-programs-rmp