A reader of Sheqafrica.com recently requested: “Please could you advise us who issues hot work permits? What qualifications must the responsible or competent person have.” In a search for the correct advice, Sheqafrica.com asked Shane Lishman to shed some light on this problem, which many readers may also experience. He addresses this below.
Over the years I have encountered numerous Permit to Work Systems and numerous types of permits e.g. cold, hot, radiation (both ionising and non-ionising), electrical trenching, working at heights, working on electrically alive equipment, “hot tapping”, excavation, confined spaces, switching and commissioning permits to name a few. The key question to each of them is “Who is the competent person to issue them?”
In South Africa there is no standard that prescribes or recommends who can issue what permit and the word “competence” is not meaningfull unless a description and qualification goes along with it. Many companies have in-house standards developed or acquired from their holding companies in other parts of the world.
Interpretation is therefore left up to each company’s operations director/manager to determine if the person issuing the permit is competent. (Remember that PTW systems lie with operations and not HR or H&S).
The issuing of permits is industry specific or procedural, situational and in many instances time specific. In other cases the issuing of a permit may require more than one signature before being issued, e.g. a confined space (CS) permit needs an AGT – approved gas tester signature plus the issuers signature (person from operations who controls the CS), or an ionising radiation permit signed by a Health Physicist and the issuer. So, it can require two different sets of skills and knowledge.
Determining who can issue a permit can become quite a conundrum. I have personally experienced permit receivers who knew nothing about the work to be done, and when questioned many times I received the answer “my manager told me to come and get the permit”. This leads to the question “should the responsible issuer issue a permit to a person who does not know why he/she is receiving the permit or what it means”, but that is for another discussion.
In answering the competency question, the discussion should be around:
- What is the qualifications of the issuer
- Are the qualifications appropriate
- What experience is required to issue the permit
- What language and communication skills are required to issue a permit
- What emergency response skills does the issuer have
- What specific training does the person have e.g. Authorised Gas Tester level 2
- Does the issuer have skills related to other issue permit, to be able to identify clashes e.g. SIMOPS, SIMCON?
- Does the issuer know his/her legal accountability and is willing to accept it
- Is the operations manager happy with his/her choice of permit issuer and trust the decision made on his/her behalf?
- What does the Risk Assessment divulge in terms of issuing permits?
How would I determine who was to issue permits if I was the Operations Director/ Manager?
The starting point for me would be a Risk Assessment of all the processes, machinery and physical constraints of my operation in which I was in-charge and accountable. Valuable input could be obtained from the HSE Department at this stage.
Secondly, I would get the necessary information from my HR department regarding the education, training and experience of each of my key employees, those who are in charge of processes and equipment, (Please note: energy is required to injure people).
I would then identify all the major tasks that are required to be maintained, run and operate my operation, from start to final product.
I could then match these three basic areas together to get a basis from which I could work. Include a verbal interview in the language of issue and get the candidate to write a permit in the language of issue, and we have a great starting point.
The next step is to research international best practice and legislation from developed countries.
A simple matrix could then be developed that would identify the above and more importantly the gaps, the identified gaps would be a proactive step to getting confidence in the competent persons. Perhaps more experience is required, or only certain types of permits may be issued by a certain person or, only on certain processes or equipment. Perhaps further training and education is required.
The “Permit to Work” competent person is not your average tick-box person. He or she is an experienced, skilled and educated person in this field.
We forget that his/her decisions determine how safe YOU or your EMPLOYEES are going to be whilst doing work. In the last two months we have had explosions in sewers that have taken life, failure of structures, engulfment and others. Relying on a non-competent person to issue permits amounts to a crime, that the employer would be implicit in.