Section 15.3 Permit to Work Systems
A Permit to Work (PTW) system is a formal, documented safety procedure used to control and manage certain types of hazardous work that are not covered by routine operational procedures. It is a cornerstone of effective risk management for non-routine, high-risk tasks. The ISM Code, through its emphasis on identifying risks and establishing safeguards (Section 1.2.2.2) and developing plans for shipboard operations (Section 7), implicitly supports and often explicitly requires PTW systems for specific activities. On a bulk carrier, where tasks like hot work, enclosed space entry, or working aloft are periodically necessary, a robust PTW system is essential for preventing accidents, ensuring all precautions are taken, and that work is conducted under controlled conditions. The Master has overall responsibility for ensuring the PTW system is correctly implemented, and all personnel involved understand and adhere to its requirements.
1. Purpose and Importance of a Permit to Work System:
Formal Authorization: A PTW is a formal written document authorizing specific work to be carried out at a specific time and location, by named individuals, under strictly defined conditions and precautions.
Hazard Identification and Risk Control: It ensures that a systematic risk assessment has been conducted for the hazardous task, that all identified hazards have been considered, and that appropriate control measures and safety precautions are in place before work commences.
Clear Communication and Coordination: It facilitates clear communication and coordination between all parties involved in the hazardous work (e.g., the person authorizing the work, the person supervising, the person(s) carrying out the work, and any other affected personnel or departments like the engine room if services need to be isolated).
Ensuring Competence: It verifies that the personnel assigned to perform the hazardous work are competent and have received appropriate training.
Isolation of Energy Sources: For many tasks, it ensures that machinery or systems are properly isolated (e.g., electrical power locked off, pipelines blanked or spaded, valves secured) before work begins.
Emergency Preparedness: It ensures that emergency procedures and rescue equipment are considered and are readily available.
Record Keeping: The completed permit serves as a record that the hazardous work was formally assessed, authorized, and carried out under controlled conditions.
Preventing Accidents: Ultimately, the primary purpose is to prevent accidents, injuries, damage to equipment, or environmental incidents associated with high-risk tasks.
2. When is a Permit to Work Required?
A PTW is typically required for activities that are:
Non-routine and high-risk.
Not adequately covered by standard operating procedures or generic risk assessments.
Known to have a high potential for serious accidents if not properly controlled.
Common types of work on bulk carriers that almost invariably require a PTW include:
A. Hot Work:
Definition: Any work involving open flames, sparks, or local heating that could ignite flammable materials or atmospheres. This includes welding, flame cutting, grinding, brazing, soldering, and using non-intrinsically safe power tools in potentially flammable areas.
Specific Hazards: Fire, explosion, burns, toxic fumes.
Key Permit Controls:
Thorough inspection of the area for flammable materials (solids, liquids, vapors, dusts) and their removal or protection.
Atmosphere testing for flammable gas (especially if near fuel tanks, cargo holds carrying flammable cargo, or recently painted areas).
Ensuring fire-fighting equipment is laid out and ready (e.g., charged fire hoses, portable extinguishers, fire watch assigned).
Isolation of any pipelines or systems containing flammable substances in the vicinity.
Proper ventilation.
Securing the area.
Duration of permit validity (often limited to a specific shift or day).
B. Enclosed Space Entry:
Definition: Entry into any space that has limited openings for entry and exit, inadequate natural ventilation, and is not designed for continuous worker occupancy. On bulk carriers, this includes cargo holds (even when “empty”), ballast tanks, fuel tanks, void spaces, cofferdams, chain lockers, forecastle stores, CO₂ rooms, battery lockers, some mast houses, and large machinery crankcases.
Specific Hazards: Oxygen deficiency, presence of flammable or toxic gases/vapors, engulfment by free-flowing solids (if cargo residues are present), restricted movement, communication difficulties.
Key Permit Controls:
Thorough ventilation of the space before entry.
Comprehensive atmosphere testing by a competent person for oxygen content, flammable gases, and relevant toxic gases (e.g., H₂S, CO, SO₂, fumigants if applicable). Readings must be within safe limits.
Isolation of any pipelines or systems that could release hazardous substances into the space.
Assignment of a trained standby person at the entrance, maintaining communication with those inside.
Availability of rescue equipment (SCBAs, harnesses, lifelines, resuscitation equipment).
Procedures for continuous or frequent re-testing of the atmosphere if work is prolonged.
Emergency rescue plan.
C. Working Aloft or Overside:
Definition: Any work performed at a height where there is a risk of falling (e.g., on masts, funnels, crane jibs, ship’s side for painting or repairs).
Specific Hazards: Falling from height, dropping tools/equipment, electrocution if near radio antennae.
Key Permit Controls:
Use of appropriate fall protection equipment (safety harnesses, lifelines, inertia reel devices).
Inspection of access equipment (ladders, staging, bosun’s chair, man-lifts).
Securing the area below to prevent injury from falling objects.
Weather conditions (avoid in strong winds, heavy rolling, or lightning).
Isolation of radar/radio antennae if working nearby.
Standby person if appropriate.
D. Electrical Work (High Voltage or Complex Systems):
Definition: Work on electrical systems carrying high voltage, or complex repair/modification work on lower voltage systems where there is a significant risk of electric shock, short circuit, or fire.
Specific Hazards: Electric shock, burns, arc flash, fire.
Key Permit Controls:
Isolation of electrical power (lock-out/tag-out procedures).
Confirmation that circuits are dead using appropriate test equipment.
Use of insulated tools and appropriate PPE (e.g., insulating gloves, face shields).
Work performed only by competent electrical personnel.
Fire-fighting equipment ready.
E. Breaking into Pipelines or Machinery Containing Hazardous Substances or Under Pressure:
Definition: Opening up pipelines, valves, pumps, or machinery that contain or have contained fuel oil, lube oil, hydraulic oil, steam, compressed air, refrigerants, or hazardous chemicals.
Specific Hazards: Burns (hot surfaces/liquids), chemical exposure, pressure release, fire.
Key Permit Controls:
Depressurization of the system.
Draining and purging of hazardous contents.
Isolation of the section (e.g., closing and securing valves, blanking/spading lines).
Appropriate PPE for the substance involved.
Containment for potential spills.
F. Other High-Risk Tasks:
The company’s SMS may identify other specific tasks requiring a PTW, such as critical lifts, diving operations (rarely by ship’s crew), or entry into battery rooms when charging.
3. Structure and Content of a Permit to Work Form:
While the exact format varies, a typical PTW form should include sections for:
Permit Identification: Unique number, date, validity period (start and end time).
Description of Work: Clear and precise details of the task to be performed.
Location of Work: Specific compartment, deck area, or equipment.
Personnel Involved: Names and signatures of:
Authorizing Person: A responsible officer (e.g., Master, Chief Engineer, Chief Officer) who has assessed the risks and authorizes the work.
Competent Person(s) Performing Work: Those who will actually do the job.
Supervising Person (if different from authorizing person).
Hazard Identification and Risk Assessment: A summary of the key hazards identified and the risk level (often referencing a more detailed JSA/TRA if one was done).
Precautions and Control Measures Required: A checklist or detailed list of all safety precautions that must be in place before, during, and after the work. This is the core of the permit. Examples:
Isolation of energy (electrical, mechanical, pressure) – with lock-out/tag-out details.
Atmosphere tests (O₂, LFL, Toxics) – with acceptable readings and who performed them.
Ventilation requirements.
PPE required.
Fire precautions (fire watch, extinguishers ready).
Communication arrangements.
Emergency/rescue arrangements.
Securing of area.
Signatures for Confirmation: Sections for relevant personnel (e.g., gas tester, person isolating equipment) to sign confirming that specific precautions have been implemented.
Permit Acceptance: Signature of the person in charge of the work party, confirming they understand the conditions and precautions.
Work Completion and Permit Closure:
Section to be signed by the work party upon completion, confirming the area has been left safe.
Section for the authorizing person to sign, confirming work is complete and the permit is closed/cancelled. Any isolations removed and equipment returned to service.
Permit Extension/Revalidation (if applicable): Procedures if work extends beyond the initial validity period (often requires re-assessment of conditions).
4. The Permit to Work Process – A Step-by-Step Approach:
Identify Need for Permit: The person planning the work (e.g., department head) recognizes it’s a PTW-controlled task.
Risk Assessment (JSA/TRA): A specific risk assessment for the task is conducted or an existing generic one is reviewed and adapted.
Prepare the Permit Form: The responsible officer (e.g., Chief Officer for deck work, Second Engineer for engine work) initiates the permit, filling in details of the work, location, hazards, and required precautions based on the RA.
Joint Site Inspection (if necessary): The authorizing person and the person who will supervise/perform the work may inspect the worksite together to confirm conditions and agree on precautions.
Implement Precautions: All specified safety precautions and isolations are put in place before the permit is authorized. This is verified and often signed off on the permit.
Authorize the Permit: The designated authorizing person (Master, C/E, C/O) reviews the completed permit, ensures all precautions are satisfactory, and then signs to authorize the work to commence.
Brief the Work Party (Toolbox Talk): The supervisor of the work party conducts a toolbox talk with all individuals involved, explaining the task, hazards, precautions on the permit, and emergency procedures. Everyone should understand their role.
Carry Out the Work: The work is performed strictly in accordance with the conditions and precautions specified on the permit.
Supervision and Monitoring: The work is supervised, and conditions are monitored throughout. If conditions change or new hazards emerge, work must be stopped, and the permit reassessed.
Work Completion: Upon completion, the work party ensures the area is left clean and safe. Any isolations that can be removed are done so under instruction.
Permit Closure: The work party leader signs off the permit. The authorizing person inspects the worksite, confirms completion and safety, and then formally closes/cancels the permit.
Record Keeping: The completed (closed) permit is filed as per SMS procedures.
5. Master’s Role and Responsibilities:
The Master has overall responsibility for the effective implementation and functioning of the PTW system onboard.
Ensuring System is in Place: Verify that the company’s SMS includes a robust PTW system with clear procedures and appropriate permit forms for all relevant hazardous tasks.
Authorizing High-Risk Permits: The Master often personally authorizes permits for the most critical operations (e.g., hot work in or near cargo areas, complex enclosed space entries).
Delegation of Authority: May delegate authority to issue certain permits to competent officers (e.g., Chief Engineer for engine room hot work, Chief Officer for deck hot work or enclosed space entry), but the Master retains overall accountability.
Ensuring Competence and Training: Confirm that all personnel involved in issuing, supervising, or working under PTWs are properly trained in the system and understand their responsibilities. This includes training in risk assessment, hazard identification, and specific precautions for tasks like gas testing or electrical isolation.
Monitoring and Auditing the System: Periodically review completed permits and observe PTW procedures in practice to ensure the system is being used correctly and effectively. This can be part of the Master’s review of the SMS.
Fostering a Culture of Compliance: Emphasize that the PTW system is a vital safety tool, not just a paperwork exercise. Discourage any shortcuts or bypassing of the system.
Stopping Unsafe Work: If the Master observes any work being carried out under a permit where conditions are unsafe or precautions are not being followed, they must intervene and stop the work immediately.
Reviewing Incidents: If an incident occurs during work covered by a PTW, the permit and the associated risk assessment must be reviewed as part of the investigation to identify any failings in the system.
A well-implemented Permit to Work system is a critical defense against accidents during high-risk, non-routine operations on bulk carriers. It formalizes the risk assessment process, ensures that all necessary precautions are considered and implemented, and promotes clear communication and accountability among all involved personnel. The Master’s commitment to upholding the integrity and effectiveness of the PTW system is paramount to creating a safe working environment onboard.