Posted By Ian Waldram
A good and thoughtful original question by Alan, so far no one seems to have tackled the issue of how to decide when a Permit is appropriate, and when it is 'over the top'. My experience suggests that a Permit is typically required when any of the following applies:
1) The are hazards for the worker that are beyond his/her direct control, or competence to manage. The Permit summarises these, and confirms what controls have been put in place, e.g. electrical isolation, equipment depressured and drained, etc;
2) The task to be carried out can present significant hazards for others. The Permit identifies additional controls required, e.g. to prevent harm to adjacent workers, to prevent ignition from planned hot work, etc.
3) Is it important to have a record that this task is in progress, e.g. it will continue beyond a shift handover?
and 4) The task is not covered by an existing standard operating procedure, carried out by competent persons under appropriate supervision. E.g. driving almost any vehicle would be 'caught' by 1) and 2), but nearly all driving hazards are suitably managed by 'rules of the road' (local or public) and driver competence. An exception would be driving off-road on a site where underground services might be damaged, or live overhead power lines were present. A well-developed shift handover system might cover some aspects of 3), but often a Permit which identifies equipment not available, linked isolations, etc. is the best way to summarise important facts.
Thus, for Alan's original question, a competent electrician or fitter working on 'live' equipment which presents hazards only to them, and where no one else is at additional risk if it is isolated temporarily are good examples of work where adding a Permit achieves nothing. On large sites where Permits are widely used, it is not uncommon to find that the system has degenerated to "if in doubt, issue a Permit", the truly hazardous tasks can be obscured in the resulting mountain of paper and completing even a simple task can require numbers of signatures without adding any controls to those the worker planned to have in place anyway! I also recall one site where issuing Permits was said to be necessary to track individuals in case of emergency - quite ignoring the fact that there are ways to do that without generating so much paper, and for much of the time the workers wouldn't be at the Permit location!
I've simplified things a little here, partly to provoke hard thinking. But I reckon many operation H&S advisors are far too ready to support the issuing of Permits when they should be ensuring they really add value by specifying additional controls. If they don't, has the Permit become just a backside-covering exercise?