Most safety professionals attribute “safe work permitting” to process safety, Line Breaks/Process Openings, LOTO, Hotwork, and PRCS. But my first exposure to work permits was because of OSHA’s Hazardous Communications standard…
1910.1200(e)(1)(ii) The methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas.
For the life of me (all pun intended) I can not understand the fear of Safe Work Permits, but many safety professionals outside of the process industries and even some within that industry sector hate the idea of using these work permits. But the advantages of using a safe work permitting system far outweighs the effort to implement and manage such a system. Here are the biggest advantages outside of complying with the standards mentioned above:
1) 1910.1200(e)(1)(ii) – As I said, using a SWP to meet the HAZ COMM requirement is a perfect fit. The permit acts much like a JSA/Hazard Review document with appropriate approvals. Of course in a PSM/RMP-covered process, cleaning out a reactor vessel will involve many SWPs such as LOTO, Equipment Opening, and PRCS permit if entry is made into the vessel.
2) 1910.132(d)(2) – Every task done that needs some level of PPE must have a “certified PPE HAZ Assessment”. This is darn near impossible to fully comply with, as so many “out of the ordinary” jobs pop up and we have no control mechanisms in place for them all. So the SWP process will walk us through the hazard identification and the necessary safeguards, including the PPE, needed to perform the job safely. The “approved” SWP is how we “certify” the PPE HAZ Assessment for the task. A lot of folks will use a JSA/JHA for this exercise but remember – the HAZ Assessment MUST BE “certified”.