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johncraig  
#1 Posted : 17 April 2019 15:43:09(UTC)
Rank: New forum user
johncraig

In my workplace we use a PTW system which includes a Risk Assessment section. The section is split into Hazard Identification and Controls. The HazId section prompts the Issuer to identify last chemical present, flammability hazards, contact hazards, utility hazards and other named hazards. There is a total of 24 named hazards so choose from plus blank boxes for others.  My question is this: to meet the legal requirement for a suitable and sufficient risk assessment it is necessary to have a supporting risk assessment for each PTW or is it legitimate to take credit for the risk assessment elements of the PTW form and only require a supporting risk assessment for high hazard/complex work?

Ian Bell2  
#2 Posted : 17 April 2019 16:23:58(UTC)
Rank: Super forum user
Ian Bell2

SOunds like your are mixing 2 douments together.

Your risk assessment should come first - identifying the hazards and risks of a particular activity etc.

As part of your risk assessment, if you identify one of your control measures is to operate a PtW system - then your PtW should specifiy the specific controls you have identified for the particular task.

thanks 3 users thanked Ian Bell2 for this useful post.
A Kurdziel on 18/04/2019(UTC), jdc1975@hotmail.co.uk on 18/04/2019(UTC), johncraig on 24/04/2019(UTC)
Roundtuit  
#3 Posted : 17 April 2019 18:38:10(UTC)
Rank: Super forum user
Roundtuit

Originally Posted by: johncraig Go to Quoted Post
My question is this: to meet the legal requirement for a suitable and sufficient risk assessment it is necessary to have a supporting risk assessment for each PTW or is it legitimate to take credit for the risk assessment elements of the PTW form and only require a supporting risk assessment for high hazard/complex work?

As many in the dock have found out only a court determines what has been "suitable and sufficient" - for those who avoid court it is a case of assumption that what we have documented will not be found wanting under law - so any opinions expressed in response to your post can merely be those of the respondents rather than a case judgement.

thanks 1 user thanked Roundtuit for this useful post.
johncraig on 24/04/2019(UTC)
A Kurdziel  
#4 Posted : 18 April 2019 08:31:07(UTC)
Rank: Super forum user
A Kurdziel

You need to be careful and I think Ian is right these re two different documents. The risk assessment is the contractor’s document and he/she produces it to show you that they know how to work safely. The PTW is YOUR document telling the contractor that they can do the job and what the limits are: tools they can use, where they can work and what timeframe they can work in. It could, I suppose be on one piece of paper but the whole point of the PTW is that someone other than the person doing the job is permitting the work. If people are allowed to self-permit then there is not really any point having the PTW system.

 

thanks 2 users thanked A Kurdziel for this useful post.
JohnW on 23/04/2019(UTC), johncraig on 24/04/2019(UTC)
David Hicks  
#5 Posted : 18 April 2019 09:29:08(UTC)
Rank: New forum user
David Hicks

This sounds more like a "dynamic" or "quick" risk assessment and authorisation which many places have for in-house fixes & repairs, but for planned work I'd be nervous about this.

My worry is over time it's no longer clear who filled in which bit. Host/manager may be tacitly assuming liability for someone else's  risk assessment  or contractor/worker for the restrictions (or lack) on the Permit which should be ther manager's part.

Also, for higher risk work it's usual to do a daily permit. For longer works you'd have to do the damn risk assessment every day.

thanks 3 users thanked David Hicks for this useful post.
jdc1975@hotmail.co.uk on 18/04/2019(UTC), A Kurdziel on 18/04/2019(UTC), johncraig on 24/04/2019(UTC)
andybz  
#6 Posted : 18 April 2019 11:07:02(UTC)
Rank: Forum user
andybz

The misunderstanding here is that Risk Assessment is not a thing, it is a process. You will have followed that process to decide if a PTW was required. You could argue that the permit is a means of documenting the significant findings, which is what you are required to do as as result of following the risk assessment process.

What you probably have attached to your permit is a hazard check or prompt sheet. It is intended to assist the person generating the permit. I would say it is not a risk assessment (mis-titled).

Not sure if that answers your question directly, but I hope it will help you evaluate what you have and determine if you need to be doing more/different.

thanks 2 users thanked andybz for this useful post.
johncraig on 24/04/2019(UTC), A Kurdziel on 24/04/2019(UTC)
johncraig  
#7 Posted : 24 April 2019 06:54:17(UTC)
Rank: New forum user
johncraig

Thank you for all the replies and sorry I've not responded until now.

It is clear to me that the PTW in use tries to be both a permit and a risk assessment with the cavaet that a separate risk assessment document is required for 'high hazard work'.

Thank you again for your valued advice.

thanks 1 user thanked johncraig for this useful post.
A Kurdziel on 24/04/2019(UTC)
Clark34486  
#8 Posted : 24 April 2019 10:06:37(UTC)
Rank: Super forum user
Clark34486

A PTW is an 'enhanced control measure', that's how I have always percieved them. A risk assessment should identify and review existing or required controls measures. Therefore it would tend to suggest that the RA comes first?

maybe just a matter of interpretation I suppose

thanks 1 user thanked Clark34486 for this useful post.
A Kurdziel on 25/04/2019(UTC)
PIKEMAN  
#9 Posted : 24 April 2019 15:13:18(UTC)
Rank: Super forum user
PIKEMAN

In my considerable experience of managing PTW systems in the chemical industry a PTW is in itself a type of risk assessment. It can be backed up by a specific or generic risk assessment. If you consider the criteria for a suitable and sufficient RA, a PTW can do this. Also remember that a RA is a process, not a bit of paper! As I recall the criteria are

•It identifies significant risks
•Enables the employer to identify and prioritise control measures
•Is appropriate to the nature of the work:
‐Proportionate to the risks
•Valid for a reasonable time
•Done by a competent person

Edited by user 24 April 2019 15:14:04(UTC)  | Reason: Typo

johncraig  
#10 Posted : 25 April 2019 06:49:54(UTC)
Rank: New forum user
johncraig

Thank you Pikeman for your reply. We adopt the same approach backing up the PTW with a separate risk assessment when considered necessary. I'd be interested to understand your criteria for when a separate risk assessment is required.

(Nice picture of a pike by the way - not landed one in a while!)

PIKEMAN  
#11 Posted : 25 April 2019 15:51:04(UTC)
Rank: Super forum user
PIKEMAN

In fact, this is a big issue. Either you need to write into the PTW system rules for when a formal additional RA is required. In theory this is easy eg Hot Work, Confined space entry etc. However it can be more complex than this - you end up depending on competent people who either at the work planning stage, or the PTW issue stage, realise that more management input is required. I have seen a PTW which asks a question like "is further management input rqeuired?". If yes, then the PTW is not issued. This is why many organisations insist on a belt and braces approach eg RS, Written Job method and PTW.

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