Field Review of Permits - Need / Call to Action

Incidents Continue to Happen 

The Lloyd’s Market Association Oil, Gas and Petroleum Loss Analysis provided the first three examples of incidents resulting from the failure of the Permit to Work system.    

Maintain a Sense of Vulnerability

A Sense of Vulnerability Is Healthy – Just because it has not happened yet (or here) does not mean it will not happen in the future!

• Is a sense of vulnerability a critical part of the mindset of every employee and contractor?
• Do you require consistency in practice from everyone in the organization?
• Do you have systems in place to determine if inconsistencies exist?
• Do people believe that “yes, it can happen here”?
• Do people believe that “yes, we have similar vulnerabilities”?
• Have you experienced similar incidents but without consequences (i.e., near misses)?
• Do you combat organizational overconfidence that can be stimulated by past good performance?
• Do discussions on potential vulnerabilities take place between operations and senior leadership?
• Do personnel believe that “Field visits before issuing the permits are important and all permits roles are responsible for executing the activities safely “?
• Do systems exist that would provide sufficient time for Permit roles to identify Task and Location specific Hazards, and to consider other ongoing work or simultaneous operations (SIMOPS) ongoing in area?
• Have you experienced incidents that were near misses due to improperly identifying location specific hazards or situational factors?
• Have you experienced major incidents on routine activities due to inadequate identification of specific hazards present on the day of incident?
• Have you experienced major accidents in last day of scheduled maintenance activity?
• Have you experienced permits issued on running/live equipment?
• Have you experienced cutting of wrong pipelines even though the permit was issued?
• Have you experienced tripping of plant due to bypassing of wrong Interlock?
• Have you experienced work initiated on equipment which was not yet supposed start at that time?

Prevent Normalization of Deviation

Normalization of deviation is defined as…..

Signs of Normalization of Deviations – Does this describe your organization?

• If a deviation is absolutely necessary, are there defined steps that should be taken (i.e., a written variance procedure)?
• Do these defined steps (or variance procedure) require a detailed risk assessment and approval from multiple levels within the organization?
• Are your the expectations clear that no one individual alone is permitted to determine whether a deviation is permissible?
• Do you allow operations outside established safe operating limits without a detailed risk assessment?
• Are willful, conscious, violations of established procedures tolerated without investigation or without consequences for the persons involved?
• Can employees be counted on to strictly adhere to safety policies and practices when supervision is not around to monitor compliance?
• Are you tolerating practices, or conditions that would have been deemed unacceptable a year or two ago? 
• Are all employees empowered to stop work for any situation deemed unsafe?
• Do we have PTW policy which mandates field review of permits?
• Do we allow enough time to permit roles to carry out field review?
• Is there a review of staffing/manpower loading (number of permits vs. operators to review jobs)?
• Do competent person inspect work site before the risk assessment is completed?
• Do we have planning process defined and working?
• Do we estimate the time for each permit and the maximum number of permits that should be issued by each issuer?
• Do we have a defined list of competent permit roles authorized for the area they know?
• Do Permit roles sign the permits in control room without field review?
• Do we use generic risk assessments to identify the hazards and controls?
• Do we have a system to audit sample of live and completed permits to assess quality and compliance?

Evaluate Your Program

How is the planning and risk assessment of the job done as a practice?

• How is the field review of permits done as a practice?
• Who are responsible for field review?
• Is it required to carry out field review before issuing the permit?  What about during the work and after the work has been complete?
• Is the local procedure in line with the codes and regulations specifying requirements for the field review of job to be executed? 
• How frequently are the Critical jobs are reviewed and corrections/updating made to local practices?
• How does the PTW process ensure that the field review is completed? Are there any corrective actions prescribed if any discrepancies are found that might result in a hazardous situation?

Continually Improve Your Program

Are you considering improvements to prevent any future incidents due to deficiencies in field review by permit roles?  Here are some ideas you may want to consider:

• How frequently do you review Chemical Safety Board (CSB) reports, Process Safety Beacon and other relevant incident communication having learning potential with all members of the organization?
• Do PTW form includes the requirement of field inspection of the Safe Work Permit requested, before, during and after execution of the job?
• Do you involve work crew representative/s during planning, task risk assessment and field inspection at different stages of work activity?
• How do you make permit roles feel empowered, particularly area operator and work crew members?
• Do you have a system to improve engagement of people, e.g., Safety Observation process or safety walk?
• Do you have a requirement to verify controls for high risk maintenance activities by senior leadership before the permit is issued for execution?
• How often do your senior managers visit the field / plant site/ job location to verify the risk assessments prepared by the team and execution of controls identified in risk assessment?
• Do your workers (those closest to the work), have a method to point out deficiencies in identified controls before or during execution of the job?

Organizational Culture

A successful Permit to Work program depends on the actions of individuals within the organization.  Do the values and behaviors of your organization determine the manner in which your Permit to Work program is managed and executed?

• Does management and supervision reinforce desired behaviors to ensure they become integrated into the group’s values?
• Are high standards of Permit to Work performance clearly established?
• Is open and effective communication encouraged and supported?
• Has management established safety as a core value?
• Does management and supervision provide strong leadership?
• Has management formalized the safety culture emphasis and approach?
• Does management work to ensure employees maintain a sense of vulnerability?
• Are individuals empowered to successfully fulfill their safety responsibilities?
• Does management ensure open and effective communication exists?
• Does management support and foster mutual trust?
• Does management establish and enforce high standards of performance?
• Does management defer to expertise?
• Has management established a questioning/learning environment?
• Does management require timely responses provided to safety issues and concerns?
• Does management provide continuous monitoring of performance?