PERMIT TO WORK - Wild Apricot · Work •A permit-to-work system is an integral component of a safe system of work. HSE HSG 250 An all OSH risks cure – •A PTW is not simply permission

AMCHAM T&T 22nd ANNUAL HSSE CONFERENCE AND EXHIBITION : TECHNOLOGY . CULTURE . RESULTS

DISCLAIMER

The views expressed are those of the Presenter

They in no way represent the views of the National Gas Company or the

AmCham.

The position and opinions expressed are based on my individual experiences in

industry for close to 40 years.

CAUTION

You may disagree with the views expressed! …..


PERMIT TO WORKThe most used term in safety (in

most industries) – have we over-used

or misused it


Several types

of Permits are

used in

Industry

Hot Work Permits

Confined Space Entry

Permits

Ground Disturbance

Permits

Lifting Permits

General (cold work)

Permits to Work


What is a PTW

UK HSE – HSG 250: A permit-to-work system is a formal recorded process used to control work which is identified as potentially hazardous.

Trevor Kletz – What Went Wrong: A Permit System is necessary for the safe conduct of maintenance operations

HC Howlett – The Industrial Operators Handbook: When conducting work on hazardous systems a standard industrial practice is to employ Safe Work Permits

OGP:A PTW system is a formal written system used to control certain types of work which are identified as potentially hazardous

NEBOSH: A PTW is a formal written document of authority to undertake a specific task and is designed to protect personnel working in specially hazardous areas or activities.


Our Legal Obligations

TT OSH Act – Part II, Section 6. (1) It shall be the duty of every employer to ensure, so far as is reasonably practicable, the SH&W at work of all his employees

Sub section (2) (a) the provision and maintenance of plant and systems of workthat are so far as is reasonably practicable, safe and without risks to health.

Note: There is no specific mention of the term Permit to Work


What it is NOT………

A Safe System of

Work

• A permit-to-work system is an integral component of a safe system of work. HSE HSG 250

An all OSH risks cure –

• A PTW is not simply permission to carry out a dangerous job.

• The issue of a permit does not, by itself, make a job safe. HSE HSG 250

A Legal Document

• It may be used as evidence in litigation to demonstrate a robust or weak system of controls


What then is a

Safe System of

Work (SSW)

A SSW is devised from a thorough

(suitable & sufficient) risk

assessment of the activity/task;

which must consider: People,

Equipment, Materials and the

Environment.

A Management System such as ISO

45001 or STOW in themselves do not

constitute a SSW and provides no

assurance of Accident Prevention


Control of

Work Under

the SSW


Typical Work Flow


Elements of the PTW System A well designed system must include:

Criteria and method of assessment and reassessment of those persons authorised to issue and those authorised to receive (Issuing Authority & Receiving Authority)

Clear definition of the work to be done

Identifies the person responsible for controlling the job

What hazards and hazard elimination or controls have been effected (control of hazardous energy/chemicals/fluids etc.)

Identify remaining hazards

A time period for which the PTW is valid

Controls when more than one work party working on same equipment

Monitoring

Training


Contractors and your PTW System

Contractors must be trained and understand your Permit

to Work system

Issuing of Permits to Work to contractor is not advised

unless….

Contractor receiving permits must be trained and assessed

to the same level as your employees


What a good PTW System looks like Common misapplication areas

Control of Work and Control of Risks – for potentially

hazardous work

Used as a substitute for a proper Job Hazard Analysis

(JHA)

Seeks to address weak conformance with site rules such

as required PPE

It is used as means of communication between site

management, plant supervisors and operators and those

who carry out the hazardous work.

Attempts to provide assurance that functional lines

(operations and maintenance) have done their part - in

other words, used as a document for CYA

Not applied to ALL activities – Potentially hazardous

work -Routine and Non Routine

Issued for all work regardless of risks and many times

identifies no special hazard controls such as energy

isolation.

Issued and Accepted by persons who are trained in and

fully understand the system, its use, controls and are

deemed competent

Used to apportion responsibilities … which turns into to

assigning blame

Used as NOTIFICATION of work


Piper Alpha – the most infamous industrial disaster where the

PTW was a key featureFailure of the PTW contributed in a big

way to the events that unfolded on that

fatal day

Image credit https://www.scotsman.com/news/piper-alpha-

inquiry-author-calls-for-safety-reporting-culture-1-4750022


Indicators of Weaknesses

Design of PTW form/certificate cumbersome and busy

Designed with ‘check’ boxes – discourages free thinking

Not aligned to hazard and controls as identified in the JHA/RA

Attempts to capture all things

No clear identification of the person with ultimate responsibility for work to start authorization


Indicators of Weaknesses

cont’d Vague reference to time work is

authorized to start – many times the start of shift is used or presumed to be the effective time of issuance

Date and time format and inconsistencies

Illegible hand writing & Illegible duplicates -(advent of E-permits)

False Information (intentionally & unintentionally)

Leading to loss of respect for the PTW


Summary

A permit ought not to be used merely for notification of work

Should not be used for low risks jobs that can be managed by other

means

Is not a “legal document” – not required by Law

Must be underpinned by a robust system which establishes criteria,

assessment and reassessment for Issuers and Receivers

Must be monitored to ensure rigour, identify weaknesses, conscious

and unconscious incompetence and wilful neglect.


Summary

A PTW is not simply permission to carry out a hazardous job. It is an

essential part of a system which determines how that job can be

carried out safely, and helps communicate this to those doing the job.

Permit to Work should ideally be used for work which poses significant

risks

It is not intended that the PTW system be applied to all activities as

experience has shown that their overall effectiveness is weakened


Suggested Take-Aways

Change your lens and review how your PTW system is used

If being used for ‘notification’ of work, consider an alternative mechanism

Reserve its use for potentially hazardous work

Issuer & Receiver scheme for assurance of competence

Monitor for full conformance – adopt a zero tolerance approach for less

than full conformance

Simplify, Simplify, Simplify


Thank you kindly.I’m pleased to address any questions/concerns at this time.

Documents

PERMIT TO WORK - Wild Apricot · Work •A permit-to-work system is an integral component of a safe system of work. HSE HSG 250 An all OSH risks cure – •A PTW is not simply permission