In my experience this is a fairly common approach. There are three interlinked issues. 1. Potentially conflicting activities are one reason for having a PTW system on the operating site. So can events/activities on the operating plant significantly affect the fenced off construction site? If not, then that is one reason not to require the formality of a PTW system within the construction fence. If the only forseeable events are major emergencies, then you need an agreed construction area emergency alarm response (depending on what hazards from the operating site may affect the construction site, i.e. response to flammable and toxic releases have important differences!), but no more than that. 2. Can activities on the construction site affect the operating area? (Hopefully not, or the fence is in the wrong place!). 3. Are there any 'residual hazards' in the construction site as a result of its previous operations? Typical hazards include: over- and underground services; contaminated ground. If there are, then maybe a PTW system is needed for construction tasks in some specific areas, where these residual 'operating hazards' are present? If the responses to all three questions are negative and the PC can demonstrate to the client's satisfaction that their proposed workplace controls are suitable for managing the full range of construction risks, then I suggest there is no reason to require additional paperwork as if the full range of operating risks were present.

Do you really need all the paper required for a daily handover? If conditions really are likely to change overnight, then surely something is wrong with the set up being proposed. If that's just a remote possibility, the normal system is to hand over the area once to the PC, who then becomes responsible for controlling all the activities inside the fence. If the operating plant can seriously affect these, then there needs to be an emergency communications prrocess to alert the PC (and any other 'neighbours') as it happens - including overnight, as the operating plant won't know what tasks may be in hand there (e.g. radiography as an example, or shift working when the schedule gets tight near then end!). If there's no one there, they could notify a construction 'duty manager' by phone.