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Jim Harper  
#1 Posted : 24 September 2013 14:04:42(UTC)
Rank: Forum user
Jim Harper

When should we use a PTW? and when is a comprehensive Risk Assessment and Method Statement suffice?

I ask this question because I have noticed a tendency for more and more companies to issue PTW's for all work being conducted on site by external Contractors regardless of the level of risk involved. At the same time they are reluctant to adopt this higher level of control for their own internal projects.
andrewcl  
#2 Posted : 24 September 2013 14:39:37(UTC)
Rank: Forum user
andrewcl

I can only give you info based on what we do here (nuclear site). We have ten categories of job that require a PTW.

Asbestos, Work at height, Electrical (isolation required), Mechanical (isolation required), Airline suit work, Lifting ops, Confined Space entry, Excavation work, Hot works and additional hazard (usually radiological)

Most of these tasks would be non-routine to have a Permit. Most routine tasks, even hazardous ones would usually have a risk assessment and method statement, or operating instruction.

If a sub-permit is required relating to one of those topics, a PTW is used.
Jim Harper  
#3 Posted : 24 September 2013 15:18:33(UTC)
Rank: Forum user
Jim Harper

Thank you Andrew. I believe that issuing PTW's willy nilly detracts from the serious nature of the document, it becomes under valued and the control measures will not be given the correct level of monitoring they require
David Borland  
#4 Posted : 24 September 2013 15:21:50(UTC)
Rank: Forum user
David Borland

For what it's worth I think I used this definition in a TBT some time ago when I worked for a manufacturing plant and would also include any mechanical LOTO....it's there to be shot down in flames. I think it devalues the permit system if it is used for all works carried out by contractors. PTW should also in my opinion apply to own employees but this is another bugbear I no longer have to deal with. I would imagine on COMAH or similar sites a blanket system might be a consideration?

"The formal issue of a PTW should be considered when authorising any non-routine work which may adversely affect the safety of personnel, plant or the environment. It is essential that PTW’s are not issued for controlling routine, low hazard, tasks as this will tend to devalue the system.

The general rule is that a PTW should be issued when:

• non-routine work can only be carried out if normal safeguards are dropped; or;
• new hazards are introduced by the work.

Specific examples of where a PTW should be issued are:

• hot work, welding and cutting operations, use of open flames;
• entry into a confined space;
• “break-ins” to systems or pipe-work which contain flammable or hazardous substances;
• work with hazardous substances including radioactive materials;
• work which may affect other safety systems i.e. disconnection of the fire alarm system;
• electrical - when working on electrical equipment to ensure isolation and lock off;
• access to roofs;
• excavations to avoid contact with buried services and prevention of excavation collapse;
• ANY OTHER potentially high risk operation."
redken  
#5 Posted : 24 September 2013 15:29:05(UTC)
Rank: Super forum user
redken

On our COMAH site the HSE have criticised us for having an almost blanket approach to issuing permits. They would like it retained for the big stuff.
SW  
#6 Posted : 24 September 2013 16:17:07(UTC)
Rank: Super forum user
SW

I think you are right Jim when you say that it detracts or could detract from the PTW importance.
I know of a Company that complete a "standard Contractors" Permit for most tasks and then a specialist PTW for Heights, Electrical, Hot Works etc.
I think the basic one is just to provide a set of rules and control who is on Site - perhaps they could do this by other ways.
Clairel  
#7 Posted : 24 September 2013 17:53:23(UTC)
Rank: Super forum user
Clairel

I also agree that PTW's are issued for everything and anything nowadays without just cause. Only need for high risk jobs that are not part of everyday work. So just because others are issuing them willy nilly (love that phrase) have the courage to follow your own path and only issue them when needed (if at all).
Jim Harper  
#8 Posted : 24 September 2013 19:29:11(UTC)
Rank: Forum user
Jim Harper

Thanks for the comments, I have compiled a list very similar to your's David. When dealing with contractors I forward them a comprehensive check list to follow when compiling their 'RAMS' so I feel confident in reducing the number of occasions we issue Permits. It's nice to see so far we are all thinking along similar lines
Cheers Jim
patrim  
#9 Posted : 24 September 2013 21:22:01(UTC)
Rank: New forum user
patrim

As the owner of the permit system at a busy food factory and having been audited in the past by various parties I would like to share some of the practices we have

1. All contractors are on permit to work mainly to control where they are on site and what they do.
2. Our permit system allows for low risk permits that may not require the full RAMS.
3. Many of the task that historically were not on permit have had near misses raised against individuals due to standards of work.
4. Our permit system is national so I am unable to reduce when we issue them but can influence how.
5. I see reports from all over Europe about incidents that were apparently low risk and yet the interaction with our equipment and processes has caused an injury

In mitigation of our system the issuing of a permit is the last opportunity to have a face to face discussion with a contractor or employee engaged in non standard activity and whilst the task they are carrying out may be low risk the site may not.

The permit is used to protect us from the contractor and the contractor from us.
I must however agree that it is possible to over permit the answer as ever is risk assessment.
I am currently exploring the idea of a passport / permit to operate for those companies that do low risk repetitive jobs on site.
Jim Harper  
#10 Posted : 24 September 2013 22:46:29(UTC)
Rank: Forum user
Jim Harper

Hi Patrim
Have you considered beefing up your requirements in respect of Contractors Risk Assessment and Method Statement rather than having a two tier PTW.
The check list I issue to all Contractors requires a high level of detail covering qualifications & competence, Plant tools & equipment as well as thorough description of how the job will be conducted.
This is supported by an audit sheet when they come on site which is retained in the work area with a copy of their 'RAMS'.
Thanks for your input
Cheers Jim
stevedm  
#11 Posted : 25 September 2013 07:35:46(UTC)
Rank: Super forum user
stevedm

I agree with everything that has been posted previously on only using the PTW system when necessary for high risk work etc...

That said I have put a blanket system in which was due to procurement selecting a contractor on price rather than safety. That was 7 months ago...we have only just got the contractor to agree to complete risk assessments for all the activities he carries out...so although the criticism of blanket system is fair it is right to use it to ensure you have control and are not putting your contractor or your employees at risk.
Zyggy  
#12 Posted : 25 September 2013 08:44:59(UTC)
Rank: Super forum user
Zyggy

When I worked in the Gas Industry, PTW's were only used in high risk work, but for the less hazardous ones we had a "Job Authorisation".

This was used to check that contractors had considered how they were going to tackle the job in a safe manner, but also be aware of our activities & those of other contractors in the working area.

The latter system was much less detailed & appeared to work, & I fully agree with many of you that there is an overuse of the PTW system which then undervalues it.
imwaldra  
#13 Posted : 25 September 2013 11:04:53(UTC)
Rank: Super forum user
imwaldra

One issue no one seems to have mentioned is for tasks that will continue from one shift to another (where continuous operations are in place) - such 'continuing Permits' should be an essential element in shift handovers.

Also the emphasis in many responses is strongly on contractors, but in fact any work group that assumes responsibility for a work area or equipment where the hazards are normally controlled/ managed by others may need a Permit, or some form of 'handover certificate' to record that transfer of responsibility and any residual hazards they may not be aware of.

In contrast, tasks that nominally might require a Permit may instead be covered by a rigorous procedure implemented by competent people. An example of this is landing a helicopter on an offshore installation. This requires co-ordination between various operating groups (e.g. may include stopping crane operations), plus some key communications to assure safe helideck conditions, etc. For other such safety-critical offshore tasks, a Permit would be seen as mandatory - but they aren't used for helicopter operations!

This approach may be one way to reduce the number of Permits issued for tasks where the risks are low and all under the control of the person(s) doing the task, but a Permit has become 'standard' so as to ensure communication between the work group and the person responsible for the area. As others have said, large numbers of such Permits can detract attention to the paperwork required, and thus away from those tasks where mutually agreed controls are absolutely essential.
gramsay  
#14 Posted : 25 September 2013 11:07:39(UTC)
Rank: Super forum user
gramsay

I've just finished a review of our isolation permit procedures (for mechanical or electrical work) at one of our sites. We used to issue permits for all isolation, but 99% of the jobs are routine and very well understood.

We're now trialing a procedure where permits will only be required if any of 3 conditions are met:

[ol]
[li]Anyone in the risk area hasn't completed our in-house isolation procedures training.[/li]
[li]Two or more teams will be carrying out work involving any of the same isolated circuits.[/li]
[li]In the judgement of the relevant manager, a Permit is required due to the complexity or unfamiliarity of the job, or for any other reason.[/li]
[/ol]

All isolation must be approved by a designated manager, whether under permit or not. Point 1 initially mentioned non-employees (ie subcontractors) but we have a couple of subbies on site who have been here for some considerable time and have gone through our training. This point was changed to emphasise that people unfamiliar with our procedures being in the risk area would be a reason to use a permit (which would include all other subbies).

I'm interested in whether this need to continue permits for work involving subcontractors is borne out by the results of the trial.
gramsay  
#15 Posted : 25 September 2013 11:08:10(UTC)
Rank: Super forum user
gramsay

thought that list would work, sorry about the mess...
Jim Harper  
#16 Posted : 25 September 2013 11:56:46(UTC)
Rank: Forum user
Jim Harper

No need to apologise gramsay, I like the contents.
Good point also raised by Inwaldra re handover.
I see Zyggy the system you describe is where I am at.
I think there is always going to be a grey area between where Contractors 'RAMS' and in house 'Procedures' end and the need for a PTW begins. The information you have supplied has certainly moved me forward in consolidating a plan.
Thank you.
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