Understanding permits-to-work
August 1st 2008 Permits-to-work can be an effective tool for controlling potentially hazardous work, but only when they are administered correctly. Kevin Chicken and David Dainty highlight the ways in which permit-to-work systems can fall short, and what can be done to address this.
We are reminded of the importance of permits-to-work by the recently passed 20th anniversary of the Piper Alpha disaster. 167 people lost their lives when a series of explosions ripped through the Piper Alpha platform in the North Sea on 6 July 1988.
The Public Enquiry that followed conducted by Lord Cullen made 106 recommendations. The enquiry found that: There had been insufficient analysis of the hazards There were deficiencies in the permit-to-work system employed on the platform which was described as little more than a 'paperchase' There was a 'superficial' approach to safety on the platform and this was compounded by inadequate training of the personnel in the use of their system and emergency responses Many of the inadequacies identified on Piper Alpha can still be found in some current permit-to-work systems. This seems to indicate that these failings have not been addressed in many sectors of industry and there continues to be insufficient attention applied to safety controls.
A permit-to-work is a document, which sets out the work to be done, and the precautions that need to be taken. It pre-determines a clear procedure and is a formal record that demonstrates that all foreseeable hazards and their associated risks have been considered in advance. It defines the sequence of the appropriate and preventive actions that should be followed.
The system should require the removal of hazards where reasonably practicable. Where this is not possible, effective control of the hazards needs to be maintained.
Unfortunately, some view permits-to-work as permission to do work without the forethought, planning and risk assessments which should underpin the safety controls; particularly the level and security of the isolations.
Where permits-to-work should be applied is largely implicit under UK Health and Safety legislation. There are no mandatory requirements to issue permits-to-work, although there are a number of references within various Health and Safety Executive guidance documents and Approved Codes of Practice that strongly recommend their use. A good example of this is the Confined Spaces Regulations, 1997.
The requirement to manage and issue permits-to-work is mainly dictated by individual organisations under their strategic and operational control requirements. Having said this it is unlikely that higher risk operators would have their safety cases approved without the consideration of a suitable permit-to-work system. Furthermore which the enforcing authorities have the power to issue either an improvement or prohibition notice if they identify that a task is being performed unsafely stipulating that a suitable permit-to-work system needs to be applied to control a higher risk activity.
Each organisation must decide for itself the number of permits-to-work they wish to apply. While for some higher risk operators permits will be applied to all practical work, this may be unnecessary and result in a lack of focus for those organisations that face less complex risks. In this situation, a blanket application of permits-to-work irrespective of the risk potential could mean that the system fails to achieve its objectives, because it does not distinguish between high and low risk tasks.
The template(s) that an organisation chooses to use are a matter of choice. They can be developed internally or bought in and there is a growing tendency for users of permit-to-work systems to move to electronically managed systems.
One of the common failings of permit-to-work systems, whether they are paper based or electronic, simple or complex, results from a lack of communication. If the issuer of the permit fails to talk through the risk assessment with the person who is going to conduct the work they could fail to challenge each others thought processes and the levels of safety control applied.
The comments of Brian Appleton, the technical assessor to the Piper Alpha Public enquiry are noteworthy in this context. He stated: "I do not fault Occidental's policy or organisation in relation to matters of safety. However, I have had to consider a number of shortcomings in what existed or took place on Piper. This calls in question the quality of Occidental's management of safety, and in particular whether the systems they had for implementing the company safety policy were being prepared in an effective manner..... Safety is not an intellectual exercise to keep us in work. It is a matter of life and death. It is the sum of our contributions to safety management that determines whether the people we work with live or die. On Piper Alpha they died".
Training Employees and contractors' personnel, who issue or work under the authority of a permit-to-work system, need to be trained to ensure they fully understand the importance of the system. They must have sufficient knowledge of the hazards and precautions associated with the plant and the proposed work. Their knowledge and experience must enable them to ask the important 'what if?' questions that will ensure that all potential hazards inherent in a particular situation are identified. Above all they must have the mindset to cease work if circumstances change so that the situation can be discussed and control reestablished before continuing with the work. For this training to be effective it should incorporate a competency based analysis of the trainee.
Monitoring For the system to work effectively, everyone involved must abide strictly by the instructions given on the permit. The behaviour of those working under the authority of a permit and the operation of the permit-to-work system itself must be monitored and reviewed regularly. An independent audit may be undertaken to inform the review process from time-to-time.
Some indicators of a good permit-to-work system are: It is recognised by all within the organisation The permits outline the nature and extent of the work to be carried out All documentation is clear and easy to understand.
It has authority Disciplinary action will result if the system is abused The Health and Safety Commission's Oil Industry Guidance document HSG250 was revised in 2005 to consider the use of electronic permit-to-work management systems. Electronic systems are not intended to substitute solid understanding based on dynamic assessment of risks; but they can build in rules for safe application such as levels of authorisation and issue and help to safeguard against inept application of permits to work; together with linkages to those in control of areas on impending or live work with real time status.
It is for these reasons that ITConsillium and Norwich Union Risk Services are working together to deliver a complete permit-towork solution. ITConsillium have developed their electronic Permit to Work Manager which incorporates a user friendly interface providing Total Management of the permit to work application together with contractor control and also incorporating many other commendable features from the front end permit to work inception, through the active life of the permit-to-work to its final closure providing a complete on-line audit facility.
Norwich Union Risk Services provide an Institution of Occupational Safety and Health (IOSH) accredited permit to work training course and the delivery will include the application and understanding of any supporting policies, procedures and guidance to reinforce how the permit to work system is applied in practice and the elements covered will include: Senior management responsibilities and understanding of the permit system Verification of the competence of the authorising and issuing authorities System understanding, including isolation procedures Understanding of the contractor(s) interface Evaluation of and establishing robust safe systems of work for various work disciplines Maintenance, monitoring and auditing of the system Emergency procedures More articles from Norwich Union Risk Services: | 
