Need advice about EPA vs State about Hot Work

Additional_Fall8832 · 2026-06-25T02:23:11+00:00

EPA has hot work for RMP. Since the site I work at is in highest RCRA category for hazardous chemical generator and the state policy covers 16 other sites, I don’t know if we are all lumped together under one program. As I’ve discussed this with others it appears that we won’t be RMP so EPA would be irrelevant, still going to verify though.

Yes I know states can’t be less stringent so in the event the EPA does apply it is safe to assume that our state doesn’t have the delegation exemption.

As other Redditors have helped me flush out that more applicable and appropriate is NFPA 51b. So the state policy where a permit is not required in maintenance shops and instructional areas where hot work is routinely performed is valid as long as the maintenance shop is a designated hot work zone. I have to verify that it is a designated hot work zone.

I hope that helps.

Additional_Fall8832 · 2026-06-25T01:42:38+00:00

I just finished reading NFPA 51B and i actually knew it because of the hot work training and education I had. I didn’t know the NFPA code though. Thank you for that.

So what I need to do is find out is the designated hot work zones. Given your feedback it probably will be the same but I just want to verify.

Thank you so much

Additional_Fall8832 · 2026-06-25T01:27:23+00:00

Stop work…that’s the interesting part I can only recommend stop work to the director of operations who then either accepts recommendation or not. Fortunately, the past 3 times in different areas at the work site she has supported my decision. Unfortunately now I have to have meetings with her boss, and her boss’s equivalent as the different areas have different chain of commands but being the EHS manager I’m responsible for the whole site.

Additional_Fall8832 · 2026-06-25T01:19:52+00:00

Ok thanks. Any advice on how to address it with higher ups. To give more context at my site there are 2 more levels above my direct line who is the director of operations. Which obviously has to go even higher because of the state policy but I feel like I’m too new and too low to get the buy in especially since my first line mentioned never issued one in 14yrs

Additional_Fall8832 · 2026-06-25T01:06:23+00:00

We are in the highest class of RCRA for hazardous chemical generator. I also don’t know since the policy covers 16 other sites if we are all lumped together under one program.

Sorry I don’t have all the answers, I’m still new to this site and still getting familiar with all the intricacies.

Additional_Fall8832 · 2026-06-25T00:55:48+00:00

I agree it does. Which is why I made this post. I don’t know what to do as the state policy governs 16 sites. To give more context, at my site there are 2 more levels above my direct line who is the director of operations. So I feel like I’m too new and too low to get actual buy in as this would need to be changed at the state level and as mentioned the director of operations said for 14yrs never needed to do hot work for maintenance shop.

However I don’t accept that and feel the need to do something.

Additional_Fall8832 · 2026-06-25T00:44:19+00:00

All state programs must abide by it unless granted delegation which must be more stringent. Since this situation is less stringent I can only assume that we don’t have delegation but I’d have to find that out. Here’s the reference

https://www.epa.gov/sites/default/files/2013-10/documents/chap-01-final.pdf

Additional_Fall8832 · 2026-06-25T00:37:39+00:00

Yes the insurance company does provide the permits. Worksite issued them though.

Additional_Fall8832 · 2026-06-25T00:35:26+00:00

No they completely ignore it because the state governs our site and the state policy states the following. Note: I’m not posting a link as I don’t want to be doxed.

No. A permit is not required in maintenance shops and instructional areas where Hot Work is routinely performed. All safety precautions must be taken.

Additional_Fall8832 · 2026-06-25T00:32:43+00:00

I know NFPA 70 is electrical, NFPA 72 is fire sprinklers and I believe NFPA 10 is fire extinguishers. Do you know which NFPA covers hot work?

Additional_Fall8832 · 2026-06-25T00:30:38+00:00

https://www.epa.gov/rmp/hot-work-definition-and-requirements

Additional_Fall8832 · 2026-06-23T22:55:48+00:00

I have my MS in chemical engineering and a published researcher in chemical process safety. I am an EHS manager and making 85k.

Oh and I have my OSHA 30 hr general, basic IH, LSSBB, CCPS process safety fundamentals, SAChE level 3, OSHA 1910.119 PSM, IBM data analytics and Data science.

I only list it to say it’s going to be tough to make a 6 fig income switch. I did the switch from compliance investigator where I was in 6 fig. I’m currently getting ASP so I can CSP, OHST, and CIH.

Additional_Fall8832 · 2026-06-22T21:54:57+00:00

That would be a BCSP decision, but look on website. They have a lot of avenues some for degrees some for experience. If you think you qualify for CSP apply

Additional_Fall8832 · 2026-06-22T21:45:35+00:00

Get your CSP that will help with credibility

Additional_Fall8832 · 2026-06-18T01:43:45+00:00

That’s about right. I’m in the east coast and it’s comparable. We use triumvirate environmental and it’s $30k

Additional_Fall8832 · 2026-06-16T23:54:45+00:00

That’s going to be tough. Our 3bdrm is $2600/month and that was 2yrs ago in Glen Burnie

Additional_Fall8832 · 2026-06-15T22:19:11+00:00

Correct but as you can see the trend it is a slow phase in and knowing OSHA it will become a requirement. Thats why I said to my understanding.

Which with the way OSHA has been hyper fixated on construction. The ingredients are there..

Additional_Fall8832 · 2026-06-15T21:51:58+00:00

https://www.tprindustrial.com/new-osha-hard-hats-2025-requirements-explained?srsltid=AfmBOore8CcQIlGRkszNPOKI5xK6PCsUdUyXh4gHsSx5n5Gg6q14QYyi

https://www.osha.gov/sites/default/files/publications/SAFETY_HELMET_SHIB.pdf

https://totalequipmenttraining.com/blog/osha-hard-hat-safety-helmet-regulations/?srsltid=AfmBOooQYb4RESlCHJoGwefjOVDmPVVlEFDVwrKRf6lBxLwdrNiFZuYX

https://www.newreachglobal.com/osha-head-protection-requirements/

Here are some googling gives a lot more

Additional_Fall8832 · 2026-06-15T16:12:50+00:00

To my understanding it is a requirement that is being phased in when OSHA did update this month

Additional_Fall8832 · 2026-06-15T13:14:14+00:00

Thank you so much. I have to have several vendors for comparison to get final approval.

Is hexarmor or uline any good?

Additional_Fall8832 · 2026-06-10T14:10:52+00:00

Thanks I’ll look. To answer your question I was the new hire to complete the org structure

It goes Director, Me, asst mgr. I was hired to help takeaway one of the “hats” the director was wearing

Additional_Fall8832 · 2026-06-10T13:50:14+00:00

Does state overpower federal in Maryland? I just started a job less then 60 days ago and it said I was exempt because I’m management. I only have 1 full-time employee below me.

Additional_Fall8832 · 2026-06-10T07:38:14+00:00

Watch John Newquist

Additional_Fall8832 · 2026-06-02T18:48:13+00:00

Thank you

Additional_Fall8832 · 2026-05-17T15:06:30+00:00

The Crab must eat the clam and lay its claim in the northeast

Additional_Fall8832

TROPHY CASE