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Health and Safety - Permit to Work Procedure

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Section 1 - Summary

(1) This Procedure details the operational requirements of the Victoria University (VU) Permit to Work system to ensure that hazardous/high risk work carried out at VU sites is done in such a way as to effectively control all risks and eliminate / reduce the potential harm to people and facilities.

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Section 2 - HESF/ASQA/ESOS Alignment

(2) HESF: 2.3 Wellbeing and Safety

(3) Standards for Registered Training Organisations (RTOs) 2015 (Cth): Standard 8

(4) This Procedure also aligns with ISO 45001:2018 Clause 6.1,8.1.2,9.

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Section 3 - Scope

(5) This Procedure applies to all VU facilities, staff, students, contractors and others who undertake high risk work.

Exemptions:

(6) Construction works activities where the construction company responsible for the works is deemed the 'principal contractor' (as defined by the OHS Regulations 2017) and the construction company's health and safety coordination plan includes adequate controls for the high-risk activity.

(7) High risk activities such as asbestos removal and confined space entry are not covered in this Procedure. These activities require permits in accordance with the Health and Safety - Confined Spaces Procedure, and/or Health and Safety - Asbestos Management Procedure.

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Section 4 - Definitions

(8) Authorised Person: A person(s) with appropriate competency, technical skill and authority to issue Permits to Work.

(9) Fire Indicator Panel/Detector and Alarm Signalling Equipment (ASE) Isolation Request: the form that needs to be completed and submitted to VU Facilities for authorisation when isolation is required. This completed and signed form needs to be presented to VU Security who will undertake isolation.

(10) Hazardous/High Risk Work: is work that involves hazards, which must be either eliminated or effectively controlled to ensure all risks are reduced so far as is reasonably practicable.

(11) General Contractor Tier 1: Services provided by contractors who work with or on the university's services (e.g. electricity, gas, plumbing etc.), processes, equipment or buildings and/or they complete work involving the use of chemicals or machinery. Examples include but are not limited to:

  1. servicing/maintenance/installation of equipment,
  2. minor construction work;
  3. monitoring of equipment;
  4. cleaners and gardeners;
  5. technicians servicing equipment;
  6. delivery activities which are consistent with the above definition;
  7. catering services when their work is consistent with the above definition.

(12) Job Safety Analysis (JSA): A method of evaluating the health and safety aspects of a job or activity. The job/activity is broken down into steps or tasks and the health and safety hazards/risks are identified, assessed and control measures determined.  A JSA provides a written record of the process that is going to be used to carry out a task. JSA's compliment and inform the permit to work system.  JSAs may also be called a Safe Work Method Statement (SWMS), Work Safety Plan or Job Safety Assessment (See HSW-2.15-F-02-1.0 - Job Safety Analysis).

(13) Permit to Work: A formal process that authorises work considered hazardous and/or high risk. Permits to work are written documents which authorise certain people to undertake specific work, at the stated times and dates.  The permit to work system requires the intended work methods and risk control measures to be established, documented and agreed to prior to the high risk activity commencing (See HSW-2.15-F-01-1.0 - Permit to Work).  The permit to work system also establishes communication and understanding between VU personnel and those who are undertaking the high-risk work.

(14) SWMS (Safe Work Method Statement): A SWMS is a document that sets out the high risk construction work (HRCW) to be carried out at a workplace, the hazards arising from these activities, and the measures to be put in place to control the risks. SWMS must be prepared before HRCW commences. (See WorkSafe Victoria SWMS Guidance).

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Section 5 - Policy/Regulation

(15) Health and Safety Policy

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Section 6 - Procedures

Part A - Summary of Roles and Responsibilities

Roles

Responsibilities
Manager responsible for engaging contractors
Management of the permit to work system.
Appointment of authorised persons who have appropriate level competency, skill and authority to issue permits.

Coordinating with Facilities and seeking their guidance in identifying all requirements of permit to work (PTW) and to complete the job safely.
Ensure all nominated authorised persons have been trained in this procedure.
Authorised Person(s)
Be familiar with the intended task(s).
Assess the Job Safety Analysis (or similar documentation eg: SWMS) to ensure it has been completed and is based on the actual work/task that is to be done and that it is specific to the VU environment.
Inspect the work area as required to ensure the appropriate details are recorded on the Job Safety Analysis (or similar documentation eg: SWMS) and the Permit to Work Form.
Ensure that the person(s) undertaking the work are appropriately qualified or competent to do the work.
Ensure the area and equipment is safe before work commences.
Ensure the permit to work is provided to the person undertaking the work. The authorised person retains the permit when the work has been completed.
Sign the permit to work before work commences and when work has been completed and the area has been inspected.
Periodically check that the work is being undertaken in accordance with the specifications on the Permit to Work and Job Safety Analysis (or similar documentation eg: SWMS).
Ensure that the completed permit to work records (including associated JSAs/SWMS) are retained for 2 years.
Manager /Supervisor of the area where high risk activity is being conducted
Where appropriate, countersign the permit to work in order to confirm that they have been informed about the work taking place within their area of responsibility.
Ensure appropriate persons are informed of the work being undertaken within their areas prior to the work commencing and when the work is completed.
Person(s) completing high risk activity
Complete a Job Safety Analysis (or similar documentation eg: SWMS) for the intended high risk task so that hazards are identified and appropriate controls are determined.
Have current licenses (where applicable) and be skilled, qualified, trained and competent to perform the work required. This includes the use of any PPE or rescue equipment that may be necessary.
Ensure that the requirements on the Permit to Work form are understood.
Sign the permit to work before work commences.
Make the permit available when requested.
Ensure all necessary locks, tags and signs are prominently displayed so that personnel are aware that the equipment etc. is isolated/not in operation.
Adhere to the Job Safety Analysis (or similar documentation eg: SWMS) and permit to work requirements.
Ensure the work area is safe prior to commencing work; seek advice if in doubt or if the circumstances change.
Ensure equipment and the area is safe when the task/activity is completed.
Ensure the area manager / supervisor is advised when the work is completed.
HSW Team
Provide health and safety advice as required.
Audit compliance to procedure as part of audit plan.

Part B - When a permit to work is required:

(16) A permit to work is required when the following hazardous or high risk work is to be carried out:

Height work

(17) All work performed at heights greater than 2 metres above ground level or when somebody may fall more than 2 metres (e.g. open penetrations). Examples include when work:

  1. Requires a safety harness to be used.
  2. Is on a roof and a safety railing is not provided.
  3. Involves contractor/maintenance repair work.
  4. Is done from an attached forklift cage or scissor lift.
  5. Where any employee or contractor is required to access heights to complete any specific task e.g. painting, erecting banners, replacing light fittings, hanging decorations or conducting inspections etc.

Hot work

(18) Any activity where there is a risk of fire or smoke e.g. the activity produces flames, sparks or heat. Examples include welding, grinding, use of heat guns. Note: Fire Indicator Panel (FIP) /Detector Alarm Signalling Equipment (ASE) isolation may be required.

Exemptions:

(19) Hot work undertaken in recognised welding bays.

Dangerous goods vessel and/or store, pressure vessels

(20) Works on any dangerous goods storage area or on any vessel that contains dangerous goods e.g. gas cylinder and chemical stores.

Trenching and excavation

(21) When the depth of the trenching or excavation works are going to exceed 450mm.

Exemptions:

(22) Trenching Shoring Training at TAFE.

Electrical

(23) Prescribed electrical installation work as defined by Victorian Electrical Safety (Installations) Regulations 2009.

Amusement Structures

(24) Any activity (i.e. set up, operation, dismantling) of an amusement structure e.g. jumping castle.

Power lines, electricity or gas lines

(25) Working near power lines, electricity or gas lines.

Powered mobile plant

(26) Where Forklifts, cranes, scissor boom lifts etc. are used in or required to enter pedestrian only areas.

Drilling or Cutting

(27) If work involves drilling or cutting into buildings or facilities, VU Facilities Managers need to be consulted as a permit to work may be required. For this type of work, the asbestos registers need to be checked and the Permit to Work must be issued by an authorised person from the VU Facilities Department.

When directed to by the person responsible for the work area or job

(28) Examples may include non-routine lifting/moving of heavy awkward objects where specific lifting equipment is not provided, working in high traffic areas (e.g. painting new lines on a road surface) or working in hazardous laboratories.

Part C - Issuing Permits to Work

(29) A permit can only be issued by an authorised person.

(30) Authorised persons must have the appropriate level of competency and authority to safely issue permits. They must undertake training in the permit to work procedure. This will be recorded in The VU Learning Management System.

(31) A Job Safety Analysis (or similar documentation eg: SWMS) must be completed by either the contractor or the employee who is undertaking the work prior to a permit to work being issued (see HSW-2.15-F-02-1.0 - Job Safety Analysis).

(32) The completion of the Job Safety Analysis (or similar documentation eg: SWMS) may also be done in consultation with the person who is engaging the contractor and the contractor.

(33) The authorised person must review the Job Safety Analysis (or similar documentation eg: SWMS) with the person(s) undertaking the work to ensure that hazards are identified appropriately and adequate controls measures are identified and implemented. This may require both parties to inspect the site.  See page 2 of the Permit to Work form for guidance on hazard / risk control measures for high risk activities.

(34) The authorised person and the person(s) undertaking the work will both sign the permit.

(35) Where relevant the supervisor / manager responsible for the area where the works are being conducted (e.g. laboratories) may also be required to sign the permit. This is required in order to ensure there is adequate communication of the planned high risk activity and associated risk controls.

(36) When required, the person(s) undertaking the high risk works will need to be able to produce the permit.

(37) The authorised person may check that work is performed according to the permit.

(38) The person(s) completing the works must inspect the work area when works are completed to ensure that the work area is left in a safe manner.

(39) The authorised person may inspect the work area, or otherwise consult with the persons completing the works to ensure that the work area is left in a safe manner.

(40) The permit must be signed off (i.e. date/time) and retained by the authorised person at the completion of works.

(41) The authorised person must retain the permit for a period of 2 years for the purpose of auditing the system. If an injury or dangerous occurrence is experienced during the completion of the work then a copy of the permit is to be included in the incident report on the VU incident reporting system.

Part D - Permit to Work Form

Validity of permit

(42) When the authorised person and person(s) completing the high risk activity have both signed the permit, it becomes valid and authorises the commencement of work within the period and time specified on the permit.

(43) Permits are valid for a maximum of a twelve-hour period i.e. working day or shift but may be extended by the authorised person.

(44) If the permit is required for longer than twelve hours, the authorised person must re-inspect the area where the high risk activity is being undertaken and re-approve the permit at the commencement of each shift or working day.  The authorised person must endorse the extensions on the permit form.

Possible Exemption for a Permit to be issued:

(45) If a contractor is engaged to complete the same task on a regular ongoing basis, a permit may not be required if

  1. an agreed documented Safe Operating Procedure (SOP) is developed by the contractor and the manager of the area where the task is performed; and,
  2. this SOP is followed. This must be jointly approved on each new occasion by the Authorised Person.

(46) The SOP must be submitted in order to support this exemption and appropriate conditions will be identified and implemented to ensure that there is ongoing compliance with the provisions of the SOP.

(47) The contractor must agree to perform the work in accordance with the SOP and compliance must be monitored by the Authorised Person.  

(48) If the conditions or situation to which the SOP alter, then a new Permit to Work will need to be issued.

Cancelling a work permit

(49) If a permit is cancelled and further work is required, a new permit will need to be issued to cover the remaining work. The cancellation of a permit can be done by writing cancelled on the permit and by signing, dating and recording the time and reason for the cancellation on the permit.

Lost permit

(50) Work in progress must cease until a replacement permit has been authorised.

(51) The Authorised Person shall, in conjunction with the permit holder and supervisor (where relevant):

  1. Identify all lock out /tag out devices (e.g. energy isolating devices, danger - do not operate tags) associated with the lost permit,
  2. Thoroughly inspect the isolated plant/area,
  3. Issue a new permit,
  4. Arrange where possible, to have all of the personnel who had previously signed the lost permit, sign the new permit. A notation must be recorded on the new permit to indicate that the above steps have been undertaken.