What’s wrong with ‘verifying’ a work precaution during the writing out of the Permit, rather than after it has been implemented at the work site?
The WPTW (Permit) Form is designed to support the development of documentation for the authorisation of work in situations where the activity may involve an elevated risk to the health and safety of workers, the environment, or plant and equipment.
The intent of the WPTW Process is to establish a safe working environment for Work Party Members before the Permit is issued and before work can start.
Work Precautions listed in Section B of the Permit Form are risk controls that must be in place to ensure the safety of the working environment. They are pre-conditions of the Permit that are specified by the WPA, and that are required to be verified by a competent person before the Permit is Issued. They are different to Ongoing Controls, which can be implemented after Permit Issue, if required.
This means that, according to the WPTW System, a work precaution that has been verified on the Permit Form is confirmed to already be in place as a risk control for the Work Party when the Permit is Issued.
We have identified two reasons that ‘pre-verification’ occurs:
- The WPH, or other person developing the Permit Form, thinks they are verifying that the documented risk controls will be a suitable; or
- It’s just easier to get all of the paperwork done and the Permit Issued before workers go out on site and actually start work.
The Problem with ‘verifying the suitability of a control’.
With all due respect, it’s not relevant whether people other than the WPA think a particular risk control would be suitable, because it’s the WPA that is ultimately responsible for establishing a safe working environment, and for nominating the work precautions that will be pre-conditions for the issuing of the Permit. The WPTW System is clear that the ‘Initial by Verifier’ column on the Permit is not for people to express an opinion about the suitability of that control.
The WPA is held to be responsible for identifying and documenting the required risk controls, and then verifying that they are in place before they issue the Permit.
Misuse of the ‘Initial by Verifier’ column might lead to a critical risk control being overlooked by the WPA. This, in turn, creates a problem for the WPA if an incident occurs, because they have failed in their duty of care to create a safe work environment.
The Problem with ‘just getting the paperwork done’.
Completing all of the paperwork and issuing the Permit, before work precautions are fully implemented, creates an even greater problem because it constitutes a series of false statements being made by the ‘verifier’, and by the WPA in the issuing of the Permit.
Each time a person initials the ‘Initial by Verifier’ column, the WPTW System says that they are making a statement that the nominated work precaution has been implemented (WPTW Handbook, s5.4 – Wellsite Permit to Work Life Cycle, Element 8). That is the intention of the verification process. If that control has not been implemented, they are making a false and misleading statement.
If the WPA knowingly or otherwise issues a Permit that has specified work precautions that must be in place as a condition of Issue, and those controls have not been implemented, they are failing in their duty of care to create a safe working environment for the Work Party.
WPTW has been carefully designed to maximise protection for all role holders using the Permit System. It includes a series of checks and balances to support each role holder to complete work in a safe and efficient manner, and this includes the proper verification of work precautions, prior to the authorisation of work.
More information
For information about verification, contact our support centre on 1800 078 939, or email [email protected].
FAQ Notes
“What if the Permit has to be issued before the work precautions can be implemented and verified, for example work on a remote site?”
Where the WPA knows that implementation and verification can only occur after the Permit is issued, they should document an Ongoing Control in Section C that states: “All listed work precautions to be implemented and verified prior to the commencement of work”
This provides an acknowledgement by the WPA that a variation to normal process is required, and makes post-Issue implementation and verification of work precautions a condition of the work authorisation, maintaining compliance with the Wellsite system.
“What if a control can only be implemented after work starts, so it can’t be verified until then?”
According to the Wellsite system, that would be an Ongoing Control, not a Work Precaution.