Using Permits to work

When would you use permits to work?

The Health and Safety at Work, etc Act 1974 requires employers to provide safe systems of work as part of their duties to ensure, so far as is reasonably practicable, the health, safety and welfare of their employees at work. Although there are a variety of safe systems of work, the permit to work is designed to be used to manage activities where the risk is highest and where the consequences of failing to control the risk are likely to be serious injuries or fatalities.

For permit systems to be effective, organisations need to implement a procedure which clearly identifies:

• the type of job that requires a permit
• how the system works
• the different responsibilities within the system.

What type of job requires a permit?

The main high-risk jobs that require the use of a permit are:

• hot work — introducing an ignition source (eg welding, grinding)
• confined spaces — working in an enclosed space where there is potential for chemical or heat exposure, or asphyxiation
• electrical equipment— whether working with certain electrical equipment or testing and maintenance
• working at height — tasks carried out where there is a risk of falls or falling objects.
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Unfortunately, because the basic legal requirement is to have a safe system of work, permits are often overused if organisations do not have other methods of controlling the work, such as a safe working procedure (eg standard operating procedure (SOP) or work instructions) or method statements. Although using a permit under these circumstances allows the organisation to comply with the law, it devalues permits so they are seen as just another piece of paper, delaying the start of work, rather than a document that might save lives in a high-risk situation.

Another common problem with permit procedures occurs when organisations insist they are mandatory for every contractor visiting a site, without assessing whether a permit is actually required, based on the risk associated with their proposed activities. So, a permit is issued for someone carrying out a service of the office photocopier on the same day as one is issued to workers carrying out maintenance on a fragile roof.

Using permits in this way does not emphasise the fact that, if the roof work activity is not controlled effectively, someone might suffer a serious accident. It does not encourage those involved to focus on developing and implementing adequate controls.

How does the permit system work?

A permit to work is a risk management tool, and should therefore encourage users to identify hazards and precautions applicable to the task and the conditions in which the activity is to be carried out. The first step in the procedure, therefore, should be to ensure the scope of the activity and its location are clearly understood.

This will then allow the permit issuer and receiver to follow the normal risk assessment procedure to identify:

• the hazards
• who might be harmed and how
• whether the risk is adequately controlled under current conditions (ie evaluate the risk).

If additional risk reductions are required, these should follow the “principles of prevention” (in practice implemented through the hierarchy of control), so consideration is given to eliminating hazards before applying controls that can only reduce risk (eg simple mechanical or electrical isolation, or the use of personal protective equipment). Due to the potential consequences if high-risk work is inadequately controlled (eg hot work can result in fire), mitigation controls (those that limit the consequences if there is an incident) should also be developed at this stage.

Responsibilities in the permit procedure

Most permit procedures also designate specific roles in the permit procedure. The permit issuer is the individual who has final control over whether the permitted work goes ahead — and is normally the area controller. However, the permit issuer cannot produce a comprehensive risk assessment without the support of the permit receiver — the person who is going to be in charge of the permitted work. This is the Supervisor or Manager who is responsible for the operative carrying out the works. Both bring different competences to the permit system: the issuer, their knowledge of the workplace environment and the other activities that occur there; the receiver, their knowledge and experience of the high-risk activity for which the permit is issued.

A recent case highlighted how important the permit issuer’s co-ordinating role can be. Whirlpool was fined ￡300,000 (reduced from the original ￡700,000 fine following an appeal) after a contractor, who was standing on a mobile elevating work platform (MEWP) installing fire detection equipment, died after an overhead conveyor was started by the factory maintenance staff. The movement of the conveyor destabilised the MEWP, toppling it, and the contractor fell 5m to the floor.

Users’ responsibilities within the system

Those involved with the permit system must not only be trained, but also assessed as competent to follow the permit procedures. They should be chosen for their knowledge of the operational plant and equipment involved or the health and safety issues associated with the task. Even more important is their awareness of the limit of their competence, to ensure they obtain further advice where necessary.

The roles of permit issuer and permit receiver have been described above, but due to the vital role that the permit system plays in managing high-risk work, organisations should also appoint a permit system manager. This individual is accountable for ensuring the procedure is implemented and followed on a daily basis. They need to regularly review how the permit process is working, whether through formal “live” audits of permits that have been issued, or paperwork audits.

Following an explosion at ESL Fuels at Stanlow in 2015, a Health and Safety Executive’s investigation identified that one of the significant causes was that the permit issued for the hot work had been copied from one issued for the same job the previous week. Unfortunately, the equipment had been modified since the first permit had been issued and the use of a grinder caused an explosion. Luckily nobody was injured, but ESL was prosecuted and fined ￡100,000 with ￡17,000 costs.

Documentation

Permit procedures should also include standard sets of forms that are used to record the outcome of the risk assessment and create the permit to work. Specific permit forms (eg hot work permit, working with electrical equipment permit) can include a list of the common hazards associated with such work, encouraging the users to check they have adequately controlled the hazards. The forms also provide a communication tool, clearly identifying where, how and what equipment can be used, reducing the risk of any misunderstanding/misinterpretation of the permit conditions.

Permit procedures should limit the validity of the permit, depending on how the hazards may change over time — one example might be the loss of daylight towards dusk.

Finally the Conclusion

Permits to work are a vital safe system of work used to control high-risk activities. However, if the permit procedure is poorly designed or enforced, permit issue can easily become a paperwork exercise that adds little value to the process of health and safety risk management.