Hot Work and Torch Safety
29 CFR 1926.352 · 29 CFR 1926.354 · This talk in Spanish
Why it matters
Torch-down roofing, brazing, and cutting all leave something behind you cannot see: heat soaked into the deck, smoldering insulation, a spark in the wall cavity. A fire can start after the torch is off. The fire watch is not a formality; it is the job.
Hazards
- ⚠ Fires starting in hidden spaces: wall cavities, insulation, under membranes
- ⚠ Combustibles within the spark and slag radius
- ⚠ Cylinders stored or moved wrong: valves unprotected, oxygen next to fuel gas
- ⚠ Fires discovered after the crew has packed up and left
- ⚠ Torching over coatings that release toxic fumes when heated
Controls and safe practices
- ✓ Clear or protect combustibles around the work; our rule is at least 35 feet, the radius industry practice takes from NFPA 51B (1926.352 requires fire hazards moved or protected, without a fixed radius). Cover what cannot move with fire blankets.
- ✓ Charged extinguisher within reach at the work point, not in the truck.
- ✓ Post a fire watch during work and after the last flame; our adopted NFPA 51B practice is at least 30 minutes (1926.352(e) requires the watch continue for a sufficient period to ensure no possibility of fire).
- ✓ Check hidden sides: the other side of the wall or deck you are heating.
- ✓ Store cylinders upright, capped, and secured. Oxygen separated from fuel gas by at least 20 feet, or by a noncombustible barrier at least 5 feet high with a fire-resistance rating of at least one-half hour (1926.350(a)(10)).
- ✓ Test hoses and fittings for leaks before lighting. Light with a striker, never a lighter.
What the OSHA standard says
Exact words from the official text, with a link to each paragraph.
“When practical, objects to be welded, cut, or heated shall be moved to a designated safe location or, if the objects to be welded, cut, or heated cannot be readily moved, all movable fire hazards in the vicinity shall be taken to a safe place, or otherwise protected.”
“Suitable fire extinguishing equipment shall be immediately available in the work area and shall be maintained in a state of readiness for instant use.”
“When the welding, cutting, or heating operation is such that normal fire prevention precautions are not sufficient, additional personnel shall be assigned to guard against fire while the actual welding, cutting, or heating operation is being performed, and for a sufficient period of time after completion of the work to ensure that no possibility of fire exists.”
“Before welding, cutting, or heating is commenced on any surface covered by a preservative coating whose flammability is not known, a test shall be made by a competent person to determine its flammability.”
Site check before the talk
Walk the site and tick each line. Each line comes from the text quoted above.
- ☐Move the object to a safe spot for hot work when you can. (29 CFR 1926.352(a))
- ☐If it cannot move, take nearby things that can burn to a safe place or cover them. (29 CFR 1926.352(a))
- ☐Keep a ready to use fire extinguisher right in the work area. (29 CFR 1926.352(d))
- ☐Post a fire watch during the work and for a while after, when normal steps are not enough. (29 CFR 1926.352(e))
- ☐Have a competent person test any unknown coating for how easily it burns before heating it. (29 CFR 1926.354(a))
Quotes checked word for word against the official eCFR text on October 5, 2026. This is a summary for a crew talk, not legal advice; the full official text governs. How we check
Crew discussion questions
- Where is today’s hot work happening and what is on the other side of that surface?
- Who is the fire watch and do they know the 30-minute rule?
- Where are the extinguishers at the work point?
- How are the cylinders being stored and moved today?
Applicable OSHA standards
29 CFR 1926.352, 29 CFR 1926.354
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