The HSE defines a permit-to-work system as “a formal recorded process used to control work which is identified as potentially hazardous. It is also a means of communication between site/installation management, plant supervisors and operators and those who carry out hazardous work.”
A Permit to Work should document and communicate the precautions that need to be taken to control the risks. Examples of Permits to Work include include working in confined spaces, working at height, lone working and hot work. Having a Permit-to-work system in place ensures that work only goes ahead after safe procedures have been defined, put in place and it provides a clear record that all foreseeable hazards have been considered.
What is the legal background?
Permits to Work are not legally required documents. However they are widely acknowledged as being best practice for workplace safety and supporting the requirements of the relevant umbrella safety legislation:
- The Health and Safety at Work Act specifies that employers have a general duty to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all employees. They must also provide and maintain systems of work that are, as far as reasonably practicable, safe and without risks to health.
- Under the Management of Health and Safety at Work Regulations 1999 (MHSWR) employers must make an assessment of the risks to the health and safety of their employees while at work, and a similar assessment of the risks to the health and safety of persons not in their employment that may arise as a result of their work activities.
- Employers must ensure specific procedures are set in place for each type of work that is covered by specific legislation (eg Work at Height Regulations 2005).
- Employers must consult with their workforce over health and safety issues under the Safety Representatives and Safety Committee Regulations 1977 and Health and Safety (Consultation with Employees) Regulations 1996.
- The Health and Safety at Work Act requires employees to have a duty to take reasonable care of their own health and safety and that of other people who may be affected by their work. They also have a duty to co-operate with their employer when implementing health and safety statutory requirements.
- Under the MHSWR employees must use workplace equipment in accordance with any instruction and training given by the employer and inform their employer of any danger to health and safety posed by a work activity.
- Employees must also inform their employer of any shortcomings in the employer’s protection arrangements, such as systems of work and suitable training under the MHSWR.
The main HSE guidance on Permits to Work is the HSG250 ACOP Guidance on permit-to-work systems. The guide describes good practice in the use of permit-to-work systems, ensuring risks have been reduced to a level as low as reasonably practicable.
Why and when to use a Permit to Work
When a job has the potential of causing serious injuries or death, it is necessary to formalise agreed work procedures. This prevents instructions from being missed, forgotten or misinterpreted.
A Permit to Work works as a checklist to ensure that all the hazards, protective measures, work procedures and the general requirements are reviewed and understood by the workers undertaking the job. The permit also serves as a record of the authorisation and the completion of the specific work.
When is a permit-to-work required?
Permit-to-work systems need to be introduced for all activities where the potential risk is high and where there is no suitable existing safe system of work or where changes in the conditions (such as weather) may create risks that a generic safe system of work may not recognise. Permits-to-work are particularly important where failure to implement all necessary safety measures could create potentially serious and immediate risks to health and safety.
However, permit-to-work systems should not be applied to all activities, as experience has shown that their overall effectiveness may be weakened. Permits-to-work are not normally required for controlling general visitors to site or routine maintenance tasks in non-hazardous areas. Permit to work systems are normally considered most appropriate to non-production work e.g. maintenance, repair and non-routine operations. They are also recommended for jobs where two or more individuals or groups need to co-ordinate activities to complete the job safely or where there is transfer of work and responsibilities from one group to another.
Examples of activities where permit-to-work systems are useful include:
- working at height such as work on roofs
- pressure testing
- hot work such as cutting and welding in premises under refurbishment
- working on low or high-voltage electrical equipment, such as in electrical plant rooms and substations
- well intervention
- excavation work, such as digging trenches
- work involving temporary equipment such as generators or welding equipment
- work affecting evacuation, escape, or rescue systems
- work which may involve breaking containment of a flammable, toxic or other dangerous sub-stance
- any operation which required additional precautions or personal protective equipment (PPE) to be in place
- diving including onshore operations near water
- work involving the use of hazardous substances, including explosives and radioactive materials
- work in confined spaces, such as tunnels, vessels or sewers
- maintenance and use of certain machinery or machinery on production lines, such as power presses
- lone working in isolated areas, such as lift motor rooms
- work with asbestos such as removal of insulation from hot water systems
- work on lifts, such as routine maintenance
What are essential deliverables of a Permit to Work?
A permit to work system must address a number of basic elements, it must:
- result in the production of a clear and accurate safe system of work
- encourage those involved in preparing the permit to identify all potential hazards and steps needed in the work
- specify all necessary isolation of plant and electrical equipment and checks of the environment
- clearly specify any particular personal protective equipment (PPE) and other safety equipment that will be necessary
- clearly identify responsible and competent persons
- adequately deal with the handover of plant and equipment to local supervision after work.
- Unique asset code
- Date purchased/received
- Estimated value of item
- Building and room location
- Make and model number
- Order number
- Purchase Price
- Asset Status (e.g. on Loan)
- Serial Number
- Order Number
Who is responsible for managing a Permit to Work system?
Defining who is responsible for the provision, authorisation and acceptance of a Permit to Work is an essential part of the whole process.
Who designs the permit to work?
Responsibilities for the development, maintenance and supervision of all safe systems of work should be documented in the organisation’s health and safety policy. The risk assessment process will identify activities where a more formalised and controlled safe system of working will be needed to reduce risk i.e. a permit to work.
People associated with the assessment of risk levels will normally have the main input into the site-specific permit to work because of their specialised knowledge. However, the staff and support personnel of the work area should be involved as they have a detailed practical knowledge of the work requirements and the operation of the equipment.
Who issues the permit to work?
Typically, there is one designated approved person who is responsible for the permit-to-work system for the organisation. Usually, one copy remains with the permit issuer in the log book and one copy is completed and given to the competent person to be displayed at the work location.
The permit system owner receives the completed permit-to-work forms that should come back after work completion and places the forms into a central record keeping log book.
Who puts the precautions in place?
The person who puts in place the precautions needs to be an experienced competent person, working under the direction of the authorised person issuing the permit (if this is not the same person). However, in each different type of work to be completed (eg working at height or in a confined space), for each different type of organisation (eg university or chemical plant) and for different system of work culture, there will be quite different named positions for those who have a responsibility within this formal process.
For tasks that have to be carried out from more than one location, or if there are a number of tasks that require different skills, a second person will put in place some of the necessary precautions e.g. the person issuing a permit to work for a confined space may not have the necessary instrumentation to declare that the atmosphere is safe, hence a second competent person or organisation may be employed.
What about arrangements for contractors?
Contractors working on site are the employer’s responsibility and any contractors arriving on the premises should be given information about the organisation’s safe working practices.
The contractor may not know the working area in sufficient detail, so, where possible the contractor should be shown the place where the task is to be carried out or, if that is not convenient, suitable plans of the equipment involved and its location. There should be a confirmation that the person sent by the contractor’s firm is competent in all matters associated with the work that is to be performed. Even if the contractor’s employee has been to the site before, they must again be given the necessary details as this person may have been to many other similar jobs since that time with slightly different work methods.
Even if a contractor has their own permit to work, it is important to make sure that issues at the location do not impact on the work that is planned. Barriers and signs may be needed. There might be other contract work being performed in the vicinity or a company driver using a fork lift truck passing near the planned work.
Monitoring a Permit to Work
As with any health and safety process, there will be a need for monitoring. Permits-to-work, certificates and risk assessments should be retained at the site by the issuing authority for at least 30 days after completion, and then archived for a specified period to enable an effective monitoring and audit process.
In addition to checks carried out by issuers, permit-to-work monitoring checks should be undertaken by site management and supervisors to validate compliance with detailed work instructions and control measures. Information gained from permit monitoring should be used to reinforce safe working practices on site. Monitoring records should be archived on site and reviewed during periodic permit-to-work audits. Monitoring should be reactive and proactive:
Those using the permit-to-work systems should be encouraged to report any near misses. It could be that pre-planning had not identified a potential safety issue which could be reviewed and modified.
Active monitoring should include workplace inspections while the activity is being carried out, checking things such as:
- Is the permit document copy displayed prominently at the actual place of the work?
- Has the document been completed according to company policy on permits to work?
- Are the agreed safety procedures in place and are they in use?
- Are all necessary items of emergency equipment available and is personal protective equipment being worn?
- Are arrangements in place to prevent crossover with other work such as the suitable placement of notices, signs and barriers?
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