2.4 Safe Work Procedures and Permit-to-Work Systems

Where SWP and PTW sit in the hierarchy

HIRARC often leaves a residual risk that cannot be eliminated or engineered out: welding near combustibles, entering a manhole, working on a distribution board. For these, the control is a safe system of work. Section 15(2)(a) of OSHA 1994 requires employers to provide and maintain "systems of work that are, so far as is practicable, safe and without risks to health". The two administrative tools taught in Parts 3(G) and 3(H) of the course are:

• Safe work procedure (SWP): a standing, written, step-by-step instruction for doing a task safely every time
• Permit to work (PTW): a formal, time-limited written authorisation, issued for a specific job at a specific place after specific checks, for work that is too dangerous to rely on routine instructions

They work together: the SWP says how to do the job, and the permit confirms this job, here and now, is ready to start and is controlled until it is closed.

Safe work procedures (HIRARC 2008, section 5.4)

When an SWP is needed

HIRARC 2008 says SWPs are generally prepared for:

1. critical high-risk jobs where accidents have caused, or could cause, severe injury
2. hazardous work where accidents occur frequently
3. new or altered tasks
4. new equipment added to a process
5. jobs requiring many detailed tasks
6. jobs where two or more workers must perform specific tasks at the same time
7. tasks done infrequently

What an SWP must include

Related documents

• Method statement (MS): the contractor's description of how a whole work package will be carried out. It covers resources, sequence, plant, temporary works and controls. On many Malaysian projects it is submitted with a risk assessment, sometimes called a "RAMS" pack.
• Job hazard analysis (JHA) or job safety analysis (JSA): a step-by-step breakdown of one task, listing hazards and controls for each step. It is often the raw material for an SWP.
• Site rules: CDM 2024 regulation 13 requires site rules in the construction phase plan, for example the PPE zones, speed limit and smoking areas.

USECHH regulation 15(2) and (3) make documentation and review a legal duty where chemicals are involved. Safe work systems must be documented and implemented, and reviewed whenever there is a significant change to the process, equipment, materials or controls.

Making SWPs work on site

• Write them with the people who do the job, then test them in a toolbox briefing.
• Use pictures and translations for multinational crews.
• Keep a controlled copy at the work area, not only in the site office.
• Audit compliance. A procedure nobody follows is evidence of a failed system, not a control.

Permit-to-work systems

What a PTW is for

A permit system is used where several controls must all be in place at the same moment, and where a mistake could be fatal. Common construction permits:

The permit cycle

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The legal model: confined space ICOP 2010

The Industry Code of Practice for Safe Working in a Confined Space 2010 is the main Malaysian legal text that sets out a permit system in detail. It is a useful model for other permits.

• The employer must have a written system for preparing, issuing, implementing and cancelling permits (paragraph 4.2.6).
• The permit issuer must be trained as an entry supervisor and authorised gas tester, and must not be the same person who supervises the entry (definitions; paragraph 5.2).
• The entry supervisor signs to accept the permit's conditions and organises the entry (paragraph 5.3).
• The completed permit is posted at the entry portal, so entrants can see that preparations are complete (paragraph 5.4).
• Duration: no longer than the time needed for the task, or eight hours, whichever is shorter. The entry supervisor may extend it once, for up to four hours, if conditions stay the same (paragraph 5.5).
• The entry supervisor must cancel the permit if a prohibited condition arises, such as a significant change in risk (paragraph 5.6). The entry supervisor closes it when the work is finished (paragraph 5.7).
• The confined space permit is the overriding permit where other permits, such as hot work, also apply (paragraph 6.1).

Common permit failures

• Permits signed in the office without anyone visiting the work point
• One permit "covering" a whole day of changing tasks across several areas
• Isolations not physically locked, or locks removed by someone other than the person who fitted them
• Shift handover without re-briefing the incoming crew
• Permits never formally closed, so equipment is re-energised while people are still working
• Gas test results not recorded, or taken only at the manhole opening

The SSS's job is to audit permits in the field: check that the permit at the work point matches the job being done, the isolations are physically in place, and the people named are the people working.

Scenario: hot work in a plant room

Electricians need to cut and weld a steel bracket in a basement plant room that holds stored cable drums and has one exit.

1. HIRARC rates fire and fume risk as High, so a hot work permit is required.
2. Before issuing it, the issuer confirms that:
   • combustible drums are moved out
   • a fire watch with an extinguisher is assigned for the work and for an agreed period afterwards
   • ventilation is adequate
   • the area is a confined space only if its ventilation and access meet the ICOP definition. If so, the confined space permit becomes the overriding permit.
3. The welder's SWP covers screens, earthing and cylinder handling.
4. When the job ends, the area is checked for smouldering material and the permit is closed and filed.