A permit to work (PTW) system is a formalised process to control work and access to specific areas, designed to eliminate or control risk as far as reasonably practicable. The PTW system is also implemented to ensure compliance with Work Health and Safety (WHS). The written PTW system is used to control certain types of work or work areas that are potentially hazardous by introducing a risk managed approach consisting of assessment, control and monitoring. The PTW system establishes a means of effective communication between all parties involved in the proposed work.
The process provides an authority to proceed with works only after risk associated with the work/s has been assessed, safe procedures defined and all stakeholders are satisfied that risk has been eliminated or risk reduced as far as reasonable practicable. Defence requires all parties, including Defence units and contractors, undertaking potentially hazardous work on the Defence estate to operate their own permit systems that adequately address requirements described in WHS Regulation 2011, approved Codes of Practice, or defined in relevant Defence policy.
Some examples of work/s requiring permit systems, include but are not limited to: excavation, penetration, hot work, confined space entry, electrical switching, high voltage work (access to the network via EMOS as the electrical operating authority [EOA]), sullage, working within Defence fuel installations (DFI), radiation (RADHAZ advice), hazardous work (including asbestos), working at heights and elevated platforms.
A permit provides a means of communication between site management, supervisors and those carrying out the work, to ensure that the person conducting the business or undertaking (PCBU) has checked and authorised the works to be performed. It also ensures all elements of a safe system of work are in place.
The principle of permit systems management is:
The person undertaking the work (i.e. a Defence project) is responsible for operating its own effective permit system that meets the requirements of WHS Regulation 2011, approved Codes of Practice or defined in relevant Defence policy.
The person with direct control over the work (PCBU) is responsible for the assessment and issuing of permits. The responsibility for issuing permits cannot be delegatedto a party not directly managing or undertaking the work.
The EMOSare not expected to issue permits to third parties completing works as EMOS do not have management control of the work. EMOS, however, are required upon request, to provide information to the person issuing the permit. EMOS review any permit to be issued for accuracy and ensure the requestor has consulted with all the authorities (which can include EMOS), DFI operating authority, Chief Information Officer Group (CIOG) and Telstra, master plans for services etc. As the EOA, EMOS are responsible for issuing permits to contractors working for others for electrical works.
The responsibility for signing and issuing permits for projects remains with the project director (PD) or project manager (PM) or requestor of the permit.
PD/PM within SDD who manage contractors or undertake works requiring permit systems must undertake an assurance process that includes the validation of permit systems used by sub-contractors or contractors the project manages on behalf of Defence. The project or contractor undertaking the work is responsible for the issuing of permits unless it is an area where there is an operating authority eg a DFI. The EMOS will issue permits for areas under their control e.g. as the EOA.
EMOS Contractors. Where high risk work activity is managed by the EMOS contractor, or its sub-contractors, it shall be the EMOS responsibility to prepare, assess and issue its own permits to work.
When supporting other parties permit management systems the EMOS contractor is required to provide information and advice to inform the party to enable the development, assessment and issuing of permits. This information includes that specifically asked for by the party and additional advice on other factors known by the EMOS that may influence the conduct of the work e.g. heritage management plans, environmental or operational restrictions.
The EMOS do not issue permits for others undertaking work on the Defence estate unless they are the designated authority or controller of a particular site. The EMOS are required to manage a robust permit system for their own employees and subcontractors.
Requests for information to the EMOS may come from Defence personnel, consultants or contractors undertaking Defence works. Requests should be emailed to the respective EMOS mailbox.
Project Delivery Services (PDS). The PDS are not expected to directly undertake works requiring permits. However, contractors undertaking high-risk work activity will be managed or programmed by the PDS. It shall be the PDS responsibility to ensure contractors under management have effective permit systems and the PDS will ensure appropriate assurance to ensure that permits are issued appropriately.
Project Delivery Contractors (Including Consultants). Where high risk work activity is managed by contractors, or their sub-contractors engaged by Defence to deliver projects, it shall be the prime/head contractor’s responsibility to ensure appropriate permit systems are in place and used. Unless the EMOS is the authority or controller of a site, the EMOS is not obliged to issue permits on behalf of a project delivery contractor.
Contractors delivering projects may need to engage the EMOS for information when issuing a permit. In these cases, the contractor is to lodge a "Request for Information" service request with the EMOS Base Services Support Centre (BSSC), as outlined at Annex A.
The EMOS undertakes responsibilities as the manager of the Defence estate on behalf of SDD. In the interests of maintaining base operations and security, the EMOS is authorised to seek further details from contractors prior to providing estate information to confirm the purpose and scope of work and the contractor’s authority to obtain the information. The project may incur a cost for the provision of information depending on the requirement and effort required by the EMOS to service the request.
National Program Service (NPS). The NPS is not expected to directly undertake works requiring permits and contractors undertaking high-risk work activity, this will be managed or programmed by the PDS. It shall be the NPS responsibility to undertake appropriate assurance to ensure contractors under PDS management have effective permit systems and that permits are issued appropriately.
Defence. Where high risk work activity is being managed by a Defence unit, it shall be the unit’s responsibility to prepare the permit to work. The unit may need to engage the EMOS for information when issuing a permit. In these cases, the unit is to lodge a "Request for Information" service request with the EMOS BSSC.
In the interests of maintaining base operations, the EMOS are authorised to seek further details from a unit proposing to undertake work to confirm the scope of work and determine what information may be necessary to inform the development of the permit to work. In the interests of ensuring a safe estate, the EMOS may also undertake an assessment of the permit authorities competency to issue the permit prior to providing information and provide advice to the Defence point of contact for the project as appropriate.
A permit must be obtained for the following works:
Hot Works Permit. A hot works permit (authorised copy) is to be forwarded to the base fire station or local state or territory fire services before work commences. This can be either hand delivered or emailed to the duty station officer. Persons conducting the work are to call the fire station 15 minutes before hot works are commencing for the day. Alarm de-activations should be discussed at this time, if applicable. When hot works are complete for the day, the base fire station or local state or territory fire service is to be advised by telephone.
Confined Space Entry. Confined spaces pose dangers because they are usually not designed to be areas where people work. Working in, or even entering a confined space can present serious hazards which differ from those in regular workspaces. Confined spaces often have poor ventilation which allows hazardous atmospheres to quickly develop, especially if the space is small. The hazards are not always obvious and may change from one entry into the confined space to the next. When undertaking work in or around confined spaces, the PCBU must ensure that the contractors conducting the works have completed confined space training with a reliable registered training organisation and maintained that competency.
A Confined Space Risk Assessment (Web Form AC 869) must be conducted for each confined space in preparation for entry into, and/or work within, a confined space. No person is to enter a confined space unless granted an Entry Permit for Confined Spaces (Web Form AC 818). Also refer to the Australian Standard AS 2865-2009 Confined spaces, and the WHS (Confined Spaces) Code of Practice 2015.
Working at Heights. When conducting work at heights requiring using of fall-arrest systems, the person conducting the work must have appropriate rescue equipment available and workers competent to use such equipment. Emergency procedures, which provide for immediate rescue, must be established and rehearsed. Technical rescue, if required will be via 0-000. This response should be notated in a pre-activity risk assessment and/or emergency and rescue response plan.
Excavations Work Permits. Excavation work permits (permit to dig) are required for any digging or excavation work carried out on the Defence estate including "driving" star pickets in the ground. Examples of these events would be driving pegs into ground to pitch a marquee for a squadron open day (excavation work permit). If you are unsure if you will be digging in an easement area off Commonwealth land, it is recommended that you lodge an enquiry with Dial Before You Dig (www.1100.com.au) before commencing any excavation work.
Asbestos Removal. For asbestos removal works (including the Asbestos Removal Plan), refer to the Asbestos Management Plan (AMP) Section 10 and Section 11.