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Posted By Claire C
Dear All,
I am looking for some advice. The company i work for are the Principal Contractor. We have three subcontractors who require to excavate within our CDM Area. The subcontractors possess the expertise to carry out the excavation work and have the appropriate qualifications (i.e. to use CAT etc).
The procedure for issuing permits is as follows - we, the Principal Contractor, issues the Permit to Excavate to our subcontractor. Once received the subcontractor then issues out their own Permit to Dig to their operatives. Our Permit to Excavate is held in a file within the subcontractors site office.
However whilst carrying out safety inspections on site recently i found a subcontractor digging with two permits in their posession (ours and theirs), on another site i found the subcontractor digging with their own permit to dig on site and on another visit i found the subcontractor digging with our Permit to Excavate on site.
Obviously the procedure in place is not working effectively, and under no circumstances should anyone be working with two permits in their posession as this is not only confusing to the operatives but also dangerous.
We, the Principal Contractor, do not have much experience when it comes to issuing Permits to Excavate, however our subcontractors do. In fact one of our subcontractors must undergo specific training on issuing permits and has been interviewed to assess his competence. We, on the other hand have received no such training.
With respect to the advice i require - in order to best control the work being undertaken, should we, the Principal Contractor, issue the permits and expect only our permit to be on site - or - should would it be deemed acceptable for us to issue our own Permit to Excavate to the subcontractor and then for the subcontractor to issue their own for the site as per their own HS&E management procedures?
Your advice on the above would be greatly appreciated.
Kind regards
Claire C
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Posted By The toecap
The principal contractor (PC) should control all activities on site. Therfore, i would see the PC as the person who issues the permit. If the PC isn't competent then there needs to be some training. I can only assume that the client has failed to conduct checks on the competency of the PC. CAT scan courses are about half day. I would get somebody in to train you. And obviously follow your own procedures closely. i.e get drawings etc, scan the ground, dig trial holes. The client should have information on all known services.
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Posted By Ian Waldram
I suggest there's no fundamental reason for the PC to issue all permits, thouh it can be done that way. Alternatively, if the sub-contractor is the one with all the relevant excavation competences, what they need is: a) permission from the PC to dig in a particular area, confirming the PC has thought about possible clashes with activities by others, closing of site access/egress routes, etc. - i.e. the site-wide things that they as PC are clearly responsible for. For any hazards identified, the PC should clearly state any controls they expect the excavation contractor to put in place during their task, e.g. liaison with others nearby, road barrier details, etc. Or if the PC is planning to implement the controls, again this needs to be stated and they should be in place when the document is handed over; b) relevant data from the client about ground hazards, e.g. buried services, possible contamination, etc, so the 'expert excavator' can plan their own controls.
For item a) there could be a tick list of possible site hazards, with space for detailing the agreed controls. This should be completed jointly, to ensure both the hazards and the controls are agreed by both parties. For item b) there would be a second brief list of possible hazards, with space to acknowledge these are agreed and that suitable controls will be implemented during the excavation.
This document is perhaps best described as a 'blanket permit' for the area, which describes the conditions when responsibility is transferred to the sub-contractor. The SC then generates their own permit for the actual excavation, which is the document used by their employees.
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Posted By Dan dan
the PC is tteh controlling mind,
however,
The sub contractor is the "professional" and is more often than not more experienced in the rudiments of control issues in that particular field.
There is nothing wrong with the subbie formulating a Permit to dig, agreeing the control measures to be adopted with the PC, including the format to be used. The permits can be signed off locally, however are subject to audit by the PC to ensure that protocols are being adhered to i.e opening notice, guarding, cable location and avoidance duties, deep excavation procedures and closing off of permits at end of day or shift.
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Posted By Claire C
Thank you for your comments - they are appreciated.
Although i am still in the same predicament. With one view being that we, the Principal Contractor, are in ultimate control of the site and therefore it should be our permit that is used, and the other view being that although we are the Principal Contractor we are not the experts in this type of work and therefore should leave the issuing of permits to those who are competent and experienced.
Thanks again for your help and any further views on this are welcomed.
Kind regards
Claire
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Posted By Andy Brazier
You need to remember that a permit to work fulfills a number of different purposes. These include assessing work and specifying risk controls. Also, managing handover and handback of responsibility for plant, equipment, areas etc.
It sounds like no one group on the site is able to fulfill all of the purposes. I would suggest the sub-contractor could prepare the permit by describing the work, controls etc. However, given that the PC is in charge of the area, they need to actually sign the permit to allow the work to start by formally handing over responsibility for the area. Then to accept back the area when the work is complete.
One thing I would certainly point out is that going on a training course is definitely not the same as becoming competent. In this case it may still be appropriate for the PC to receive some training, but the subbie will still be more competent in preparing the permit.
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Posted By Ken Taylor
How about an agreed permit with the sub-contractor that requires a signature from both the PC and the SC - and clearly states this on the permit?
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Posted By Martin C
What you should issue is a permit to issue a permit to dig.
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