29 CFR 1910.119(k) requires the employer to issue a hot work permit for hot work operations conducted on or near a covered process. The permit must document that the fire prevention and protection requirements of 1910.252(a) have been implemented before work begins, show the dates authorized and the object of the work, and be kept on file until the hot work is completed. The standard defines hot work in 1910.119(b) as "work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations." OSHA reads "similar" broadly.

What OSHA Has Said

Apr 30, 2024
Sulfur sticks for ammonia leak checks are hot work
A trainer asked whether lighting a failsafe lighter and burning a sulfur stick to find ammonia leaks needs a hot work permit when the company already has a written procedure for it. OSHA said yes: hot work is defined as welding, cutting, brazing, "or similar flame or spark-producing operations," so lighting the lighter and burning the stick is hot work and requires a permit under 1910.119(k). Having a procedure does not substitute for the permit.
Read OSHA Letter ↗
Jul 12, 2006
How long to keep hot work permits
In a letter on ammonia refrigeration PSM records, OSHA said hot work permits do not have to be retained after the hot work is completed. The permit must be kept on file until completion of the hot work operations, as the standard itself says in (k)(2).
Read OSHA Letter ↗

⚡ Key Compliance Takeaway

If it makes a flame or a spark on or near a covered process, treat it as hot work and issue a permit, even for routine tasks like leak checks that already have a procedure. Build the permit around the 1910.252(a) fire prevention requirements, keep it on file until the work is done, and audit your practice so the shortcuts don't become habits.