As I keep saying In know nothing about construction and stuff but I do know a bit about managing contractors. What is the point of a subbie raising their own PTW? They will simply permit anything and everything they want  to do without looking at what the site as a whole needs. The PTW is not just about the subbie having the right RAMS etc.it  is also  about making sure  that they coordinate their work with everybody else on the site: what services need to be disabled, who else is working in that area, it is about  managing their time: they will be doing this job on that date at that time and no where else.  The subbie is not in position to manage that.

Originally Posted by: Dudz

has only authorised permits by virtue of the fact that he is the most senior on site

Given the lack of knowledge and understanding who would you propose grants "authority" to the contractor.

The "Responsible" person is already playing Russian Roulette with their liberty in the current circumstances, "permitting" a free for all is just inviting trouble.

Dudz, not sure which of the previous respondents I should "thank", but to add to what has already been said...

Usually the sort of work you are talking about is being done over an occupied facility.

Somebody in the client team has to make decisions as to what, if anything, needs to be suspended in terms of work under the roof.

This sort of scenario is at the heart of why the most important duty holder in CDM is the CLIENT.

In my past days as an HSE Inspector - before CDM - I wrote the prosecution report against Client [HSWA Section 4(2)], Main Contractor and subcontractor with the case against the Client being precisely as the PTW they signed was not fit for the purpose. 

Any competent procuring Client should be able to interpret the HSE guidance in HSG33 and decide on whether the roofing contractor's risk assessment documentation is "suitable and sufficient" and such as to enable the Client to set conditions on the work to be done by the Contractor at premises where the Client has control of entry.

So, in the case I refer to, the Client knew that the roof lights were fragile [previous accident on very same roof] and had even had 10 guard-rail frames fabricated for use by Contractors at the site.

However, there were 45 roof lights and with work being done at both ends of the same roof, absolutely no realistic way to deploy 10 frames to provide sufficient protection. Scaffolder fell through rooflight and ended up with a surgical scaffold on his head for 4 months.

But worse, hindsight bias. The Client didn't think about the potential that someone could fall off one of the three edges of the roof [No fourth edge as there was a wall to a roof at higher level]. So Permit did not specify anything to protect against THAT risk.

P