Policy

RESPONSIBILITIES

DEPARTMENTS

Each department is responsible for compliance with the criteria set forth in this program. They must ensure that all elements of this program and related procedures are implemented and followed.

SR. BENEFITS AND SAFETY SPECIALIST

• Provide guidance to employees and supervisors in the implementation of this program.
• Ensure all work areas and equipment used for welding/cutting operations are being inspected for compliance with the requirements of these procedures.
• Evaluate the hazard assessment for this program and to annually review the effectiveness of this program.
• Provide prompt assistance to managers, supervisors or others as applicable on any matter concerning this program.
• Assist in developing or securing required training.

• Ensure welding supplies, related equipment and appropriate personal protective equipment (PPE) is purchased to be worn during welding operations.
• Will be responsible for the safe handling of the cutting or welding equipment and the safe use of this equipment during the cutting or welding process.
• Responsible for ensuring all welding equipment, including cables, lines and any accessories, are in good working condition.  If any indication of damaged equipment is present, such as broken or cut insulation on cables, the supervisor will have that equipment removed from service and have it repaired.
• Responsible for identifying employees affected by this safety policy and procedures. 
• Ensure that welding/cutting operations are performed in designated areas by trained and authorized personnel.
• Determine the combustible materials and hazardous areas present or likely to be present in the work location.
• Protect combustibles from ignition by ensuring the following;
  • Have the work moved to a location free from dangerous combustibles.
  • If the work cannot be moved, have the combustibles properly shielded against ignition.
  • See that cutting and welding are so scheduled that operations that might expose combustibles to ignition are not started during cutting or welding.
• Verify that the cutter or welder ensures that conditions are safe before proceeding.
• Verify that fire protection and extinguishing equipment are functional and located in the immediate vicinity of the site.
• Ensure fire watches are present at the site when required.
• Verify that Hot work permits are completed as required and that copies are maintained in departmental files for a period of one year.  The retention of these permits allows for audits by the Sr. Benefits and Safety Specialist and may be required during an OSHA inspection.
• Maintain hot work permit records on site (See Hot Work Program).
• Ensure any contractor performing welding or cutting is informed of the program’s requirements.
• Coordinate welding and cutting operations with the contractor(s) when both St. Norbert College employees and contractors will be working on or near the same equipment, machinery or systems.
• Evaluate the compliance of contractors with this program.
• Debrief the contractor at the conclusion of welding and cutting operations to determine if any hazards were encountered or created in the work area.
• Ensure the proper transfer of risk is in place from contractor to Department Manager.
• Report immediately any unsafe act or condition to Human Resources within 1 hour, if possible.  Injury reports must be forwarded within 24 hours.
  

• Adhere to posted Hot work permits and avoid areas unless proper PPE is donned.
• Report any injury, including suspected flash burns, to their supervisor.
• Report immediately any unsafe act or condition to the Department Manager and to the Sr. Benefits and Safety Specialist within 1 hour, if possible.  Injury reports must be forwarded within 3 days (preferably within 24 hours).
• Perform welding and cutting operations in designated areas.
• Obtain an approved hot work permit prior to performing welding or cutting operations in non-designated areas.
• Report any injury, including suspected flash burns, to their supervisor.
• Responsible for ensuring that all fire prevention and fire protection measures have been taken before any torch cutting or welding begins.
• Responsible for ensuring all PPE is worn properly for the specific hazard involved and that all equipment is in good working condition.  Each employee is responsible for bringing hazards to the attention of his or her supervisor for correction as soon as the hazard is recognized.

CONTRACT WELDERS:

• Each contractor is expected to follow this program when performing welding and cutting operations.
• Coordinate welding and cutting actions with the Department Manager when both St. Norbert College employees and contractor(s) will be working on or near the same equipment, machinery or systems.
• Inform the Department Manager or designee of any hazard encountered or created in the work area.

FIRE WATCHES:

• Be trained in the use of fire extinguishing equipment.
• Be familiar with alarm locations in the event of a fire.
• Watch for fires in all exposed areas and extinguish them within the capacity of equipment available.
• Maintain a fire watch for at least 30 minutes after the completion of welding or cutting operations.
• Report any injury, including suspected flash burns, to their supervisor.

DEFINITIONS

• Adequate Ventilation – A ventilation flow, which allows fresh air to circulate to replace contaminated air, which is simultaneously removed.
• Combustible Substance – Any substance, which, after ignition, will continue to burn in air.
• Hot Work Permit – An approval form required prior to performing welding or cutting operations in areas not designated for welding.
• Ignitable Material – Any material that is capable of burning.
• Local Exhaust Ventilation – A ventilation system that captures and removes the contaminants at the point they are being produced before they escape into the worksite.
• Welding Lead – A cable that comes from the welding machine that either feeds the wire and shielding gas or provides current to the electrode through the holder.

Procedures

TRAINING

The Department Manager or designee must ensure that those performing welding, cutting and brazing operations and their supervisors/leads (if applicable) are properly trained and competent concerning assigned duties.  Employees who perform welding operations will be trained to:

• Recognize the hazards associated with various welding operations
• Know the safe work practices for welding operations
• Understand the importance and requirements of Hot work permits (if necessary)
• Use the appropriate personal protective equipment (PPE) for the job
• Recognize confined spaces and the requirements associated with them
• Understand the importance of regular inspections of welding equipment, attachments and accessories.

Training shall be made available upon initial employment or job reassignment.  Refresher training shall be provided upon the discretion of the supervisor.

TYPES OF WELDING

Several types of welding operations are used at St. Norbert College.  The most common welding operations include:

• TIG (tungsten inert gas)
• Arc welding and cutting
• MIG (metal inert gas)

The gas welding process bonds metals by heating.  The gasses commonly used as fuel gas are oxygen and acetylene.  The gas cutting process removes metal by a chemical reaction of the base metal with oxygen at an elevated temperature.  

Arc welding and cutting uses electric current.  One lead is connected to the electric power supply while the other is attached to the work surface.

WELDING HAZARDS - The hazards associated with welding include health and safety hazards.  Health hazards are primarily respiratory due to the generation of fumes and gasses.  Safety hazards are generally physical hazards due to the work site and conditions and materials associated with the work site.

• HEALTH HAZARDS associated with the generation of fumes and gasses depend upon the welding process, the base material, the filler material and the shielding gas if any.  Health hazards include exposure to:
  • Toxic gasses
  • Primary pulmonary gasses
  • Non-pulmonary gasses
  • Particulate matter
  • Irritants and toxic inhalants

Air sampling may be required to identify the fumes and gasses emitted from a specific operation.

• SAFETY HAZARDS associated with welding operations include:
  
  • Fire
  • Proximity to combustible materials
  • Hazardous locations (rooms containing flammable or combustible vapors)
  • Closed containers that have held flammable liquids or other combustibles
  • Electric shock (arc welding)
  • Arc Flash burn

• SAFE WORK PRACTICES - Safe work practices for all welding operations include:
  
  • Placing work at an optimal height to avoid back strain or shoulder fatigue
  • Using fall protection equipment for work on elevated surfaces more than 4 feet above the floor or ground surface
  • Wearing PPE as applicable for the work conditions
  • Following special precautions when welding or cutting in a confined space
  • Following safe housekeeping principles
  • Using equipment as directed by the manufacturer instructions or practices
  • Removing any butane lighters, matches or other combustibles from pockets prior to performing work
  • Not performing welding work with oily clothing (protective clothing may need to be worn over clothing).
  • Following fire protection and prevention practices during the welding operation
  • Using proper ventilation techniques during welding operations
  • If hot work activities cannot be performed safely, welding/cutting shall not be performed

• HOT WORK PERMITS - Hot work permits are a useful accountability tool to ensure that all the necessary precautions are taken prior to commencing welding.  They also ensure that employees are aware of and use the appropriate safeguards when performing welding operations (See Hot Work Policy). 

RECORDKEEPING – Records and documentation will be maintained as follows:

• DEPARTMENT MANAGERS (or their designee)
  • Hot Work permits should be kept by manager and a copy sent to Human Resources.
  • Permits should be retained for 3 years.
• SR. BENEFITS AND SAFETY SPECIALIST
  • Copies of training will be retained. These records will be updated as new employees are trained and as existing employees receive refresher training.

VISITORS & OTHER PERSONNEL - Visitors, contractors (personnel not under the direct supervision of the College), and other personnel will be required to comply with all administrative controls specified in this policy. 

PROGRAM EVALUATION - The Sr. Benefits and Safety Specialist will conduct periodic evaluations of the workplace to ensure that the provisions of this program are being implemented. The evaluation will include regular consultations with employees who utilize PPE, their supervisors, site inspections and review of records. Identified problems will be noted and addressed by the Sr. Benefits and Safety Specialist.

PROGRAM REVIEW AND UPDATE - This policy shall be reviewed and updated on an annual basis or sooner if necessary.