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When a Permit to Work (PTW) Stops Working!

A permit-to-work system is a formal written system used to control certain types of work that are potentially hazardous. It is a document which specifies the work to be done and certain precautions that are required to be taken.

Permits-to-work are an essential part of a safe system of work and only allow for work to start when safe procedures have been defined. A permit is needed when conducting maintenance work in generally critical areas such as confined spaces, work at heights, excavations and high voltage electrical areas.

The biggest concern when it comes to using safe work programs is when the whole system becomes bureaucratic. This happens when permitting is applied for all activities without giving any consideration to the criticality or the need. It is at this point when the system loses its efficiency and becomes a paper exercise with no direct impact on controlling work risks. Employees issuing the permits start realising this and end up treating every permit the same way, signing off on the documents and getting jobs started without any critical analysis of the risks involved.

Companies generally need to take a more risk-based approach when it comes to issuing permits to work and develop their standards based on those concepts. Permit to work training for the issuers of the permit is key to instilling this approach.

Permit issuers are normally part of the operational teams and in many organizations, other than the occasional auditing of the system, safety professionals do not play a big role in this process. It is therefore important that safety professionals, through coaching and training, instil the basic concepts of risk management, hierarchy of controls and a holistic view of work hazards to be monitored when issuing a these permits.

During my time working in a number of industries, I have had the opportunity to be involved with improving existing systems, developing new ones and supporting the transition of permit systems to electronic permit systems. I have found that a number of the below points, if not adequately managed, can generally contribute to an inefficient permit to work system:

1.      Permits are used to control all activities.

 This is generally not advisable as permits to work should only be used to control activities that are firstly considered non-routine and secondly high risk (or take place in high risk locations)

 Routine activities within an organization should normally be controlled through standard operating procedures with medium to low risk tasks controlled through other forms of risk management methods such as JHA’s, risk assessments or method statements.

2.      Lack of site validation

Companies that are not selective with the type of activities that require permits often find that the permit issuers are overloaded with the number of permits they are required to process. In many cases, this results in the critical tasks not getting the attention it fully deserves. More importantly, this can result in the actual working location not being adequately inspected by the issuing authority before releasing the permit to the workforce. 

3.      Daily work permits

I have worked in organisations that only issue daily work permits. This may work for establishments that do not have too many non-routine or critical activities but for anything larger, can create many issues.

It is normally advised to issue permits until the work is complete or up to a minimum of 7 days. Having permits issued for up to one month is also normal practice in some industries.

It is important to note that re-validating those permits still need to take place at least once every 24 hours and during any shift change. Companies must also instill the importance of reviewing any potential safety documentations such as JSA’s or conducting a pre task safety discussion during each of those re-validation periods. 

4.      Permits used to control work related risks

Issuers of the permit must always understand that a PTW Is NOT about controlling job related risks and is purely to control risks the location of the work presents. This can often be a confusing concept for employees to get their head around.

Let me give you an example, say you are required to perform a painting operation in a confined space. The permit to work is there to ensure the confined space is made safe to allow for the work. Isolations, Gas testing, lighting, access and egress, availability of a whole watch, ventilation, rescue equipment etc. are all considerations the permit issuer will make to ensure the confined space is kept hazard free. This is where the permit to work controls end.

Risks in relation to the painting activity such as the type of chemicals used, Specific PPE respirators, inspection of any spray paint equipment are all job related and should be controlled with a specific risk assessment method fully independent from the permit to work.

Organizations fall into the mistake of combining these elements together, creating much duplication in the documentation which can create confusion and effects the success of the overall system.

I must also mention that many organizations, specifically within the Oil & Gas or chemical industries may also use documents such as certificates to control specific activities in certain areas, providing a stronger control of isolation and an initial site preparation.

5.      Multiple types of permit to work forms used

Red forms for hot work permits, Blue for cold work, yellow for radiography, green for excavation. Many companies apply this approach and may even consider it to be successful

In my experience, the most efficient systems tend to use a single form for the work permit where the issuer will highlight the type of activity at the top of the form and provide a brief description of the work. This approach is also easier from an administrative point of view as each permit will have its own unique and orderly number.

6.      Use of a permit to work (PTW) during turnarounds, shutdowns or projects.

I have seen the use of permits during these periods create so many logistical issues and generally put a lot of pressure on safety and operational departments in a period when time is generally of the essence.

During these periods in a company’s operations, many location hazards are generally non-existent. Processes have been switched off, lock out / tag outs applied on pumps and machinery, Pipelines adequately blinded, scaffolding constructed and many other routine and non-routine operations stopped.

Of course, much critical work that would require a permit such as hot work, confined spaces and working at heights still remain. Many others such as cold works, instrumentation, electrical work, activities which are observational in nature, painting and many others will not require such permits and can be individually controlled by other means of hazard control.

7.      Too many people involved in the permit to work process

I have found that keeping it simple always works best. This means the permit being issued by the Issuing authority directly to the supervisor in charge of the work crew. This may be harder in larger worksites where area authorities may be required to support the site verification. Other sites may involve project managers, safety representatives, authorised gas testers, civil teams and contract supervisors as part of any permits being issued.

Although on occasions this input may be essential, very often it is not, creating a sequence of approvals and signatures which do not add any value in terms of work controls and are often nothing more than a hindrance.

In conclusion, although it is fair to say that the application of permit to work systems in the various industries has improved in recent years, elements such as the above seem to enter the equation from time to time causing inefficiencies in the system. It is hoped that this article provides some guidance on these areas of concern.

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March 28, 2018

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