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Pulse Point Newsletter for January 31, 2001
Published by Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
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PROPOSED STANDARD ON WELDING AND CUTTING SAFETY & HEALTH

By Enrique Medina, MS, CIH

Mexico's Ministry of Labor and Social Security (STPS in Spanish) issued a number of proposed Official Mexican Standards (NOMs) towards the end of the Zedillo administration, including safety rules for welding and cutting, agricultural activities, lumber production and saw mill, and railroad operations. Over the next few months we will review these standards pending their revisions and final publication as final rules.

This month we present an overview of the proposed standard for welding and cutting health and safety, PROY-NOM-027-STPS-2000. Its purpose is to establish minimum health and safety conditions that will prevent injury to workers and damage to the work place.

The proposed standard or NOM references the American National Standard Institute's voluntary standard ANSI/ASC Z49.1-1988: Safety in Welding and Cutting, as well as the U.S. National Institute for Occupational Safety and Health's (NIOSH) Criteria for Recommended Standard for Welding Brazing and Thermal Cutting. The health and safety conditions to be followed for welding and cutting are:

There must be adequate natural or artificial ventilation
Proper personal protection equipment must be provided for the hazards identified
A hot work permit must be completed and authorized
Tools, equipment, materials and protection devices must be in good working order
Follow established safety procedures during welding or cutting operations

One of the main provisions of the new standard is the employer's responsibility to conduct a hazard assessment of welding and cutting operations, which will serve as a basis for establishing preventative measures for protection of workers, other exposed individuals, and the work place. As part of its obligations, the employer must:

Notify workers of the risks related to welding and cutting activities,
Develop a site-specific health and safety plan for welding and cutting operations
Establish and maintain adequate health and safety conditions in the areas, equipment and accessories involved in welding and cutting.
Provide workers with personal protection equipment according to NOM-017-STPS-1993, and train them on the proper use and maintenance of such equipment.
Use trained workers for welding and cutting activities based on established procedures from the site-specific health and safety program.
Provide at a minimum annual training for workers engaged in welding and cutting.

The employer must also develop forms and procedures for authorizing welding and cutting activities in hazardous areas, such as confined spaces, elevated surfaces, underground spaces, and other areas not specifically designed for welding.

Trained workers must be available to repair, inspect and maintain safety devices in compressed gas cylinders, equipment and machinery used in welding and cutting. Welders will also be required to undergo specific medical evaluations in accordance to the Health Ministry's (SSA) requirements, or based on recommendations from their private physician. In the absence of regulatory guidance from SSA, the company's doctor shall determine the scope of the annual medical exams and any follow-up activities. All medical information shall be recorded and filed in the worker's permanent record.

The employer must provide a first aid kit in the welding or cutting areas based on the risks identified in the job hazard assessment. A life rescue system is required when welding and cutting in confined spaces. Workers must be trained at least annually on providing first aid and in life rescue for those involved in confined spaces. In addition, at least one fire extinguisher must be available in the welding and cutting area. Welding and cutting areas must have permanent natural or artificial ventilation when active. Welding booths or screens must be used to delineate welding and cutting areas.

The job hazard assessment must include, at a minimum:

The type of equipment or welding and cutting machinery used.
A list of materials, elements, and alloys used as base material or additives, as well as the chemical reactions that are produced and the contaminants generated.
A list of all hazard factors, agents and conditions, which may affect the worker's health during welding and cutting, such as fumes and gases from arc and torch welding; infrared, ultraviolet radiation and high intensity light; noise; electric shock; splashes and sparks, and explosive, corrosive, toxic or oxygen-deficient atmospheres.
The control strategy to minimize or eliminate the hazard and the mandatory personal protection equipment to be used for each activity.
A list of contents of the first aid kit

The employer must develop a written, site-specific health and safety program. It shall include the following:

A hot work permit with the procedures and forms for authorizing welding and cutting operations in hazardous locations.
Procedures for ensuring that the work area has constant make up air through natural or artificial ventilation.
Welding and cutting equipment handling and storage practices.
Standard operating procedures for each type of welding, according to the equipment used.
Monitoring for explosive, flammable, irritant or oxygen-deficient atmospheres.
Training program elements, including first aid manual, confined space rescue, welding and cutting safety procedures.
Training roster with training due dates and documentation of training provided.

The proposed NOM requires that the site-specific health and safety program include procedures for handling, operation and maintenance of cylinders, valves, regulators, hoses and connections, electrical power supply, and confined space operations. The standard provides specific guidance for each of these elements.

According to the standard, compressed gas cylinders may be stored outside the work area in a specially designated, dry and well ventilated area. Inside storage areas must have a minimum of 6-meter separation from other cylinders with flammable gases or highly combustible materials, unless separated by fire-resistant barriers. Empty cylinders must be identified and stored separately. Oxygen tanks, regulators and hoses must be painted green, while those for acetylene must be red.

The standard describes procedures to be followed during confined space welding and cutting, including: completing a hot work permit, implementing a lockout-tagout procedure, monitoring for hazardous atmospheres, providing a rescue apparatus and attendant system, and conducting a close-out inspection.

There is also a non-mandatory reference guide for personal protection equipment to be used in welding and cutting operations. It contains specific recommendations for protective clothing and gloves; respiratory protection against fumes, gases and vapor emissions; and eye protection against ultraviolet, infrared radiation, sparks and projectiles. The guidance references NOM-S-40-1987 for selection of filters for eye protection.

The proposed NOM provides employers the option to contract with an accredited Verification Unit to verify or evaluate compliance with the standard. The proposed standard was published on August 2, 2000 and was subject to a 60-day review for receiving comments. Following the normal rule-making process, a revised proposed standard will be published after the comments received have been reviewed, and would become a final standard after a 60 to 120-day period following its publication.

If you have questions about how the new environmental impact regulations may affect your current or future projects, please contact us at (619) 297-1469 or send us an email at emedina@pulse-point.com.

Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
3361 28th St.
San Diego, California 92104
(619)297-1469
(fax (619)297-1023
emedina@pulse-point.com
www.pulse-point.com/alliance

For articles in previous issues of Pulse Point visit our web site's "archive" section at: www.pulse-point.com/
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Pulse Point is written for the benefit of our readers with the sole intent to provide general information. The articles are not intended as specific opinions or as a substitute for professional advice in individual cases.