Developing an Effective Permit to Work System

Permit to work: the fundamentals

Involved in hazardous operations and other forms of non-routine work? Then you understand the need to implement stringent, work risk controls that go above and beyond safe work protocols for routine jobs. Indeed, statutory requirements in your work jurisdiction are probably pushing you toward taking formalized steps to mitigate the manifold work health and safety risks associated with dangerous jobs.

An essential (and often legally mandated) feature of control of work, the permit to work process represents one of those concrete steps stakeholders can (and should) take to control work deemed potentially hazardous, specifically high-risk operations that fall under the following categories:

• Work within confined spaces
• Work at height
• Work involving the use of hazardous/dangerous substances
• Work where heat may be used or generated
• Work which may generate sparks or other sources of ignition
• Work which may involve breaking containment of a flammable, toxic, or other dangerous substance and/or pressure system
• Work on high voltage electrical equipment
• Well work
• Diving
• Pressure testing
• Any operation requiring additional precautions or personal protective equipmentⁱ

Now, the actual permit to work system, integral to maintaining robust safe work standards where all manner of hazardous operation, non-routine, and non-production work are involved, is just a set of documented processes that ensure dangerous work is done safelyⁱⁱ. The permit in question merely licenses continuous risk control measures (through the duration of the job) and puts approved contours around the hazardous work, defining the exact work to be done, when, where, and for how long it will be done, as well as specific precautions to address associated hazards and risks.

Of course, this arguably simple framework couldn’t be more important in high-risk sectors. As practitioners well understand, the permit to work offers crucial, lifesaving benefits. For one, it establishes a formal communication chain between the most important hazardous work stakeholders, i.e. site/installation management, plant supervisors, operators, and employees who actually carry out the hazardous work (depicted below). In essence, the system is a means of guaranteeing that the right people have duly considered foreseeable risk and are taking suitable precautions.

Sure, these parties are usually already in communication on work health and safety matters, but rarely, if ever, do they coordinate with the same level of detailed focus on hazardous work risk mitigation efforts as that demanded by the permit to work process; just look at the essential features of a best-practice permit to work system that form the basis of the latter: 

• Clear listing of the work to be done on the site, as well as the personnel who will be undertaking the work and the equipment they will be using 
• Types of work considered hazardous, as well as associated tasks, risk assessments, and permitted task durations
• Identification of who can authorize permit-to-work jobs as well as clear delimitation of limits to their authority
• Identification of who is responsible for specifying necessary precautions
• Authorization for the work to commence
• Duration of permit validity, as well as listing of sanctioned methods to extend permit validity
• All-personnel training and instruction in the issue, use, and closure of permits
• Concise listing of actions to be taken in the case of an emergency
• Comprehensive (covering all aspects of permit-to-work procedure) monitoring and auditing measures to ensure that the system works as intended 

Numerous case studies of incidents in high-risk sectors also confirm the correlation between multi-party coordination (through the permit to work process) and better safety outcomes. For instance, in fatal incidents where permit to work procedures were largely absent – cases like the 1988 destruction of the North Sea oil installation Piper Alphaⁱⁱⁱ – post-mortems point to a crucial breakdown in coordination of hazardous activities among stakeholders. 

Figure 1. Hazardous work stakeholders in communication via permit to work. 

It should be said, though, that the permit to work system alone won’t make a dangerous job safe for crews in high-risk sectors. After all, permit to work is only one aspect (albeit an important one) of the larger control of (hazardous) work framework. And the definition of that risk framework, including laying out specific safety precautions to take, only comes after hazardous work is first identified, not unlike in the risk lifecycle of routine work. 

Triggering a permit to work

What, then, are the variables involved in developing a permit to work system that works for your organization’s safety needs? Well, human error is often at fault when safety incidents do occur. A very typical human error in high-risk operations is the failure to implement procedures properly. In and of itself, the permit to work system won’t necessarily address this error; in fact, permit to work systems are often incorrectly designed with the presumption that the humans operating them are infallible^iv. Instead, system operators must communicate the aims and objectives of their permit to work implementation, so that everyone clearly understands the purpose and practical application of the permit to work.

The aims themselves are largely contingent on factors like job, company, sector, etc. As an aside: note that your system should only be set up after consultation with site management and other personnel; if not, violations become more likely, as procedures don’t accurately reflect the needs of staff. But an objective common to all permit to work implementations is ensuring proper consideration is given to all risks associated with a particular job or simultaneous activities on the site.

What this means practically is that the permit to work system should convey the exact identity, nature, and extent of the job and the hazards involved in undertaking it, as well as any limitations on the extent of the work and the time during which the job may be carried out. Designated work, whether of a given type or undertaken within certain areas, must also be authorized. The person in charge of a given unit should be made aware of all of the hazardous work being done on the site.

So, then, what does the process for triggering a permit to work look like? In most cases, the permit to work process gets triggered by a request from a permit receiver (see a list of permit to work roles below). 

The request, then, goes to a permit issuer for review. The issuer is looking to see whether the permit identifies all potential hazards as well as suitable controls to manage those hazards. Also, the issuer must ensure that there are no potential conflicts between the activities of different groups carrying out work in the area or on the same set of machines or systems. To meet all of these conditions, the permit issuer can also ask for additional review and signoff from engineers, maintenance team leaders, technicians, and Health and Safety officials onsite. Isolations to machinery or system may be required to complete work safely, so lockouts must also be identified and recorded as part of this process. 

Source: Health and Safety Executive: Guidance on permit-to-work systems

Maintaining permit to work best practices

The installation owner or operator usually acts as the duty holder, the person in charge of developing, then maintaining permit to work best practices throughout the duration of the permit. This person delegates some day to-day responsibilities to senior managers; for instance, a senior manager may be responsible for introducing the permit to work system. But core permit to work responsibilities rest with the duty holder, including auditing the system and training staff on its operations.

Finally, these two tasks are vital. For one, revising the permit to work system ensures it continues to remain relevant to concerns on the ground. Audits also unearth instance of lower-level non-compliance. Those instances often go ignored but usually foreshadow major incidents down the road^v. The same logic applies to operational training; for the system to be effective, all users need to be trained to a level commensurate with their role in the system^vi.

In recapitulation: hazardous and other forms of nonroutine work demand a set of stringent, work risk controls, so that the operation remains safe for workers and the job gets done. By necessity, those controls go above and beyond what’s required for routine work. Developing a permit to work system is just one of those control of work measures that operators can (and should) undertake, but it’s a best-practice process that yields surefire safety results. 

Appendix: Sample permit to work system regulations

Australia, Offshore Petroleum and Greenhouse Gas Storage (Safety) Regulations, 2009^vii.

Permit to work system for safe performance of various activities

1. The safety case for a facility must provide for the operator of the facility to establish and maintain a documented system of coordinating and controlling the safe performance of all work activities of members of the workforce at the facility, including in particular:
   a. Welding and other hot work;
   b. Cold work (including physical isolation)
   c. Electrical work (including electrical isolation)
   d. Entry into, and working in a confined space
   e. Procedures for working over water
   f. Diving operations
2. The system must:
   a. Form part of the Safety Management System described in the safety case in force for the facility
   b. Identify the persons having responsibility to authorize and supervise work
   c. Ensure that members of the workforce are competent in the application of the permit to work system

Citations

i     Health and Safety Executive: Guidance on permit-to-work systems: A guide for the petroleum, chemical and allied industries. Available at  http://www.hse.gov.uk/pUbns/priced/hsg250.pdf.

ii     Research finds that applying a permit to work framework to all work dilutes its core effectiveness in controlling non-routine work risk.

iii     Indeed, the incident precipitated a radical overhaul of permit to work procedures at Shell U.K. More available at Michael Booth and John D. Butler, Safety Science: A new approach to permit to work systems offshore. Available at https://www.sciencedirect.com/science/article/pii/092575359290022R.

iv     Ronny Lardner, The Keil Centre: Human Failure In Control Of Work: Plugging Holes In The Swiss Cheese? Available at http://www.keilcentre.co.uk/media/1432/human failure-in-control-of-work-hazards-australasia-lardner-2013.pdf.

v     Ibid.

vi     Health and Safety Executive: HID Inspection Guide Offshore: Inspection of Control of Work arrangements. Available at http://www.hse.gov.uk/offshore/ed-control-of work.pdf.

vii     Supplemental regulation to Offshore Petroleum and Greenhouse Gas Storage Act 2006.