Permit systems are an important part of work control at operating facilities where equipment is handed over from the permit issuer to the permit receiver. Auditing them is an important component of driving performance across the workflow, from work execution to risk assessments, isolations, permit/certificate issuing, monitoring of the worksite, and handover back to operations.
Internal Auditing should focus on the quality of the permit to ensure the steps within the process have been followed, documentation is in order and risk assessments have been completed to a sufficient quality. External audits should be structured around the workflow and supporting systems. The IChemE Safety Centre has presented the following Permit model which is a useful framework for external auditing.
A structured audit process against the 8 lifecycle elements and 5 foundational elements can yield meaningful results. Here are some of the findings we have come across during our auditing activities:
Permit Request - simplification opportunities, samples of good permits available to permit issuer, Work approved but contractor training not completed or certificates not checked/available.
Plan and Prepare - last minute permits, poor quality JSAs, overuse of JSA libraries, JSAs are not specific to the job, accuracy of control owners, Toolbox quality.
Implement Isolations and Controls - lack of isolation standards based on service, unclear roles and responsibilities, verification of isolations pre-permit issuing, linkage of single isolation plan to multiple permits, isolation tracking, Isolations documents are processed separately from PtW, cross-referencing between PtW and isolation permits.
Review and Verify - authorisation requirements are based on risk, permits prepared are not completely checked by the permit issuer, and Gas testing done at the start of the shift does not represent conditions at the time of work commencing.
Issue and Accept - permit issuing timing (when resources are limited), toolbox delivery and quality requirements, advance notice of permits, cross referencing requirements.
Perform Work Activity - responsibilities for monitoring permit conditions at the work site.
Suspend/ Issue / Transfer - formally suspending permits for remote work from the permit office.
Surrender/ Cancel - ensuring field operator involvement in end-of-job inspection.
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Work Process & Procedures - work done without a permit, minimum JSA standard, transfer of work requirements, scope of PtW system, clear triggers, simplicity vs complexity, guidance documentation suitable for field personnel. suitability of the system for different environments (e.g. retail vs industrial)
Roles and Responsibilities - limited internal resources available to conduct permit audits, verification of isolations, use of non-operations staff for key PtW roles, permit issuer responsibilities for remote locations (to permit office), Overlapping responsibilities.
Training and Competency -training for permit issuers, receivers, isolating authorities and contractors.
Resource and Tools - no dedicated permit facility with appropriate resources, electronic vs paper-based system, use of visual boards,
Monitoring and Assurance - insufficient internal auditing of permits (e.g. 10%), development of KPIs, use of corporate personnel vs site personnel in the assurance process, sharing of learnings from audits to operations.
These are just a few of the findings we have seen for some of the audits we have worked on. Feel free to contact us if you would like to discuss Permit audits or other types of Safety Management audits.