Number 2

2014 MAHB Major Accident Hazards Bureau

Security Technology Assessment Unit

seveso
common INSPECTION series
criteria

The Permit-to-Work System

This publication of the European community on Common Inspection Criteria is intended to
share knowledge about technical measures and enforcement practices related to major hazard
control and implementation of the Seveso II Directive. The criteria were developed by Seveso
inspectors to aid in dissemination of good enforcement and risk management practices for the
control of major industrial hazards in Europe and elsewhere. It is foreseen that these criteria
may not only be useful to inspectors but they may also offer inspiration to industry safety
managers as well.
This particular issue highlights a number of issues that are critical for successfully reducing
risk using permit-to-work systems . Note that this document is not intended as a technical
standard nor as a summary or replacement of any existing standards on the matter.

Definition supervisor and the staff responsible for the

execution of the work.In general, the preventive
The permit-to-work is a documented procedure safety measures to be taken during execution
that authorises certain people to carry out specific and when work is completed can be established
work within a specified time frame. It sets out the and documented either following the completion
precautions required to complete the work safely, of a risk analysis performed by the HSE unit or, in
based on a risk assessment. It describes what work the case of complex works, following a joint on-
will be done and how it will be achieved.1 site examination, conducted by the supervisor
and the staff responsible for execution of work.
Purpose of the Permit to Work
When a permit to work may be
The need for a permit to a work should be assessed
for any work that may be conducted in an area needed
where dangerous substances are present and for
An effective system of permits-to-work cannot
which no existing procedure has been established.
be achieved exclusively with the provision of a
Where proposed work is identified as having a high
JRC93841 Copyright © European Union, 2014

permit for the authorisation to work in

risk, strict controls are required.
dangerous areas, but it is an essential part of the
All company employees or contractors should be SMS which is realized through specific
authorised by a responsible company person procedures, instructions and authorizations.
(normally, the supervisor) for the execution of the
According to this principle the work shall be
work required with the issue of a permit-to-work.
carried out against previously agreed safety
In this document both the functional role and
procedures, a ‘permit-to-work' system.
risks of the installation are described along with
the risks associated with the execution of the work The adoption of a permit-to-work system for
itself. It can be defined and written either authorising, managing and documenting the
following a risk analysis performed by the HSE unit execution of works and modifications, including
or (in the case of complex works) following a joint testing, surveillance, inspection, maintenance,
on-site examination, carried out by the construction and/or assembly and finally
1 Health and Safety Executive (United Kingdom).
http://www.hse.gov.uk/coshh/basics/permits.htm

Joint
Research
Centre
dismantling of parts or components within an • instructions explaining the sequence of
operating plant can minimize the occupational and operations to be followed for re-
process safety risks potentially associated with commissioning of equipment, including pre-
these activities. start-up, inspections and testing, e.g.,
verifying the absence of leaks, alignment of
Works concerning construction, maintenance, rotating parts, removal of trips and locks, etc.;
modification, etc. should be carried out in a
planned and controlled manner through: • procedures for formal delivery of the
equipment to the unit responsible for its
• procedures or instructions including all control under normal operating conditions;
information necessary to prevent a major
accident and to ensure the safety of workers, • written authorisation specifying among other
in particular, preliminary inspection, cleaning responsibilities, the means, timing, interfaces
operations, shutdown procedures, when with other operations, operating limits,
necessary, and testing of associated safety precautions, and signals.
systems. The effectiveness of these
operations should then be fully verified prior Application and types of permits
to proceeding with the activity to ensure that
all foreseeable risk has been removed;
to work
The permit should be applied in all work areas in
• control procedures specifying, at least, the which these activities are carried out by internal
initial job authorization required, the personnel or contractors, except, generally:
preliminary verification of operability, and the
• normal operations already subjected to
final checks necessary before the equipment
or operational unit is placed back into specific procedures;
operation; • works carried out in authorised workshops

• procedures specifying what to do in case that for which it is assumed that all the necessary
an unsafe or abnormal situation arises and precautions have been taken to carry out
who to inform, and also what to do in an maintenance and repair activities at the
emergency including measures to be followed workbench.
as outlined in the internal emergency plan; From a general point of view one can identify
• instructions for cleaning the equipment before the following examples of permits-to-work:
the operation and how to take charge of the • work in which a flame or spark is prohibited;
equipment from the unit responsible for its
control under normal operating conditions; • hot” work, e.g., work involving the use of
flame, heat, gases, flammable liquids or
• a mechanism (e.g., daily observation and materials;
feedback) for verifying that the safety
requirements are being followed and, where • work in confined spaces;
required, ongoing or spotcheck monitoring of • working at heights;
working conditions and the performance of
the employee during the execution of the • construction and modifications, including
activity (i.e., in confined spaces); excavation;

• procedures to be followed to perform the • maintenance works;

non-routine activities (repair, replacement,
inspection, etc.), including any procedure for • work on electrical installations, utilities and
uninstalling/re-installing the component; other equipment (live or dead
environments);
• specific criteria for inspections, tests, or
whatever else is necessary to verify that the
equipment is in perfect order prior to
returning it to service;

Joint
Research
Centre
Fig 1 Example of a flow chart for a structure of a permit-to-work

• generic work (any work that does not fall • important characteristics of the area in which
within the previous categories of specific risks the work is located interfaces with other
but, however, requires the safe management operations, other works covered by other
of works carried out by internal or external permit-to-work and operating limits necessary
personnel). for safe and efficient execution of the work;
• all those activities that need to be concluded
Contents of the permit-to-work before the start of the work described in the
To carry out non-routine activities, work orders, permit to work;
permits-to-work and other instructions (in • measures in place to control the risks and
agreement with what is described in paragraph alarms or other warning signs that could
“permit-to-work system”) should specify: indicate a potentially unsafe situation;
• the interested parties, the type of permit, the • safety systems and procedures to protect
work area; workers from hazards such as disconnection,
• isolation and the preparation of locks and trips
specifications of the work required and the
time frame for execution. Actions that are (Lockout-Tagout);
specifically NOT authorized should also be • the personal protective equipment to be worn;
specified. This latter measure is particularly
important for avoiding ad hoc changes that •
the confirmation of the supervisor indicating
could increase accident risks during temporary the possibility of starting the work under the
shut down or maintenance work. conditions specified in the permit-to-work;

• risks associated with the activity, including • the acknowledgment and acceptance of the
hazardous substances present and their performing unit (personnel or contractors) of
properties the conditions and requirements specified in
the permit-to-work;

Joint
Research
Centre
• if there is an extension of the validity of the permit, there
should be a special space for renewals. For renewal
Case studies illustrating the
should be foreseen further authorization and acceptance; importance of permit to
formal confirmation that the maintenance work has been Work Systems
•
completed according to specification, including Source: UK Health and Safety
immediate communication to the relevant supervisor Executive (http://www.hse.gov.uk/
and/or shift manager that work has been completed; techmeaspermit.htm) and Wikipedia

• confirmation by the supervisor that the work has been

correctly executed and tested, closed the permit and
authorized the recommissioning.
Hickson Welch Ltd Fire
(22/9/1992) Five persons were killed
The communication of these requirements and the after a severe fire erupted in a batch
effectiveness of the operations stipulated in the permit should processing plant following an attempt
then be fully verified prior to proceeding with the activity to to clean 30 years of sludge from a
ensure that all foreseeable risk has been removed. vessel without a permit to work, or
any prior analysis of the risks and
Information, training and qualification associated safety precautions.
The following principles should also be embedded in the
safety management system: Pasadena - Phillips 66
(23/10/1989) Failure to follow
• All personnel who are in charge of critical operations for isolation procedures during routine
safety, including maintenance activities, (internal workers maintenance of a reactor in the
or contractors and sub-contractor employees, or in general polyethylene plant led to the release
whoever supplies products or services) should receive of a flammable vapour cloud that
adequate training and information about the risks, the eventually ignited, launching a
correct procedures to be followed, and the permit to work devastating series of explosions. The
required to perform them. incident resulted in 23 deaths and
• 314 injured.
In case of special activities, for which the national legislation
requires specific qualifications (e.g., electrical work,
maintenance of ATEX equipment, works in confined spaces), San Francisco Natural Gas
the operator should set up specific procedures to take into Pipeline Puncture (25/8/1981) A
account those instructions both for their employees 16-inch natural gas pipeline was
(through a specific qualification) and contractor employees punctured by an excavation
(verifying the qualifications of the external personnel). contractor who, in violation of permit
conditions, failed to verify the
• dŚŽƐĞ ƌĞƐƉŽŶƐŝďůĞ ĨŽƌ ŝƐƐƵŝŶŐ ǁŽƌŬ ƉĞƌŵŝƚƐ ƐŚŽƵůĚ ďĞ location of underground utilities.
ŝŶǀŽůǀĞĚ ŝŶ ƌŝƐŬ ĂŶĂůLJƐŝƐ ĂŶĚ ĂĐĐŝĚĞŶƚ ŝŶǀĞƐƚŝŐĂƚŝŽŶ ŝŶ ŽƌĚĞƌ The gas did not ignite and was
ƚŽŐĂŝŶƚŚĞĂƉƉƌŽƉƌŝĂƚĞƌŝƐŬĂǁĂƌĞŶĞƐƐĂŶĚŬŶŽǁůĞĚŐĞŽĨƚŚĞ naturally dispersed. The PCB-mist
ƐƉĞĐŝĨŝĐ ŚĂnjĂƌĚƐ ŝŶŚĞƌĞŶƚ ŝŶ ƚŚĞ ĂĐƚŝǀŝƚŝĞƐ ƚŚĂƚ ƚŚĞLJ ĂƌĞ spread over a busydistrict of the city,
ƌĞƋƵŝƌĞĚ ƚŽ ĂƵƚŚŽƌŝnjĞ͘ Ɛ ǁŝƚŚ ŽƚŚĞƌ ŽƉĞƌĂƚŝŽŶĂů ĂƐƉĞĐƚƐ͕ requiring the evacuation of 30,000
ĞŵƉůŽLJĞĞƐƐŚŽƵůĚďĞŝŶǀŽůǀĞĚŝŶĞƐƚĂďůŝƐŚŝŶŐƉƌŽĐĞĚƵƌĞƐĨŽƌ people.
ƐĂĨĞǁŽƌŬŝŶŐ͘
• There should be explicit procedures for supervision,
monitoring and auditing of contractors and suppliers to
verify that the external company performs the work safely
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and in compliance with established requirements including a
Security Technology Assessment Unit
job performance evaluation against specific criteria based on
Major Accident Hazards Bureau
the job requirements. European Commission Joint Research Centre
Institute for the Protection and Security of the
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This bulletin is a product of the EU Technical Working Group on Seveso 21027 Ispra (VA) Italy
Inspections. For more information related to this bulletin or other products
and activities of the Technical Working Group, please contact: http://minerva. jrc.ec.europa.eu