Risk Mitigation in the Oil & Gas Sector with a Better Permit to Work (PTW) System: A CQ Guide with 9 Best Practices

Safety Control Measures in Oil & Gas Industry

The flammable and toxic nature of materials in the oil and gas industry necessitates extreme caution and safety control measures across all key processes including exploration, extraction, refinement, transportation and storage of materials. According to the International Association of Oil & Gas Producers (IOGP) Safety Performance Indicators report, 14 fatalities occurred in 12 separate incidents in 2020 alone.

Safety experts believe that an efficiently managed permit to work system could have considerably reduced the number of fatalities. Overall, a well-defined Permit to Work (PTW) system is critical to inculcate a safety culture across the organization, with a specific focus on worker and contractor safety.

Ideally, the PTW process must be automated with a next-generation PTW solution that enables effective on-ground implementation along with helping workers and contractors to adopt a data-driven approach to proactively mitigating risks arising from hazards or incidents.

In the US, Occupational Safety & Health Administration (OSHA) regulation 29 CFR establishes several sub-clauses related to high-risk tasks and how permits must be issued to perform those tasks. Some of the sub-clauses are:

1910.146 - Permit Required for Work in Confined Spaces
1910.252 – Permit Required for Welding, Cutting, and Brazing (and other kinds of Hot Work)
1910.147 - Lockout/ Tagout: The Control of Hazardous Energy
1910.333 - Subpart S - Live Electrical Work Permit

ClearStream, Energy Services Inc - a pioneer in providing solutions for the energy and Industrial markets including oil and gas, petrochemical, power, infrastructure and others – aimed at implementing a digital solution that could transform its legacy systems to a simplified, mobile-friendly, and electronic process as this would allow site inspectors to submit safety data from any location, saving valuable time and resources. Seamless integration with Salesforce was an essential requirement too.

Over the last decade, oil and gas operators have been channelizing considerable efforts into ensuring safe operations, by focusing on implementing a digital solution that will help regulate personnel entering hazardous environments. Simply put, a secure work permit creates the requisite executive work power. To that end, the permit to work system has been a key tool to manage work safety in high-hazard industries like Oil & Gas.

Due to the substantial risk and complexity, leading companies use an enterprise ePTW (electronic permit to work) system to meet the regulatory requirements and best practices for protecting workers from these hazards.

It can be intimidating to manage a permit system, so, if you are creating, revitalizing, or auditing best practices, you should start by asking the following questions:

1. What are the different permits that are applicable to my operations ?

2. Who are the different personnel responsible to manage the PTW System?

3. How do I implement and use the PTW System effectively?

Permits Needed for Better Risk Control

Performing a hazard assessment is crucial and often requires a list of all permits that may be needed for each job and its specific environment. Electronic permit to work, or ePTW, refers to a digital management system that ensures that work is done safely and efficiently. ePTWs provide the procedures for requests, review, authorization, documentation, and hazard mitigation, all of which are necessary to protect the front-line workers. Some of the commonly used permits in the Oil and Gas industry are mentioned below

Cold Work Permit – For potentially hazardous work not covered by other types of work permits.
Hot Work Permit – For work involving the use of a flame or other source of ignition.
Confined Space Permit – Allows personnel entry into a confined space such as a blade, trench, tank, vessel, etc. Additional permits may be needed when other work shall be done in the confined space, such as hot work.
Excavation or Ground Disturbance Permit – Authorizes any excavation or ground disturbance activity that involves digging, trenching, excavating, or removing soil or ground.
Hazardous Materials Safety Permit – Permits any material considered hazardous by FMCSA (Federal Motor Carrier Safety Administration) for transport. General chemical safety can be covered under a Cold Work Permit.
Electrical Isolation Permit – For work on electrical systems where there is a possibility of contracting energized electrical conductors.
Drilling Permit – Required when drilling a new well or completing an existing producing well.

ePTW System in the Oil & Gas Sector

To assess the effectiveness of a permit system, there are a few key elements that must be predefined for each job, like a checklist. This checklist ensures that the right permits and processes are used for each unique situation.

The key elements of an ePTW System should be provided in a documented Permit to Work procedure. They are —

1. The location of work – A specific area of work identified through environmental conditions and potential hazards. Examples of location hazards include traffic, weather, heights, topography, adjacent work plans, etc.

Best Practice: Identify a notification system for work plans that are in adjacent areas. This can be effectively implemented with an online system that updates with new and closed permits.

2. Work scope – Work that will be needed or carried out during the completion of the job. Examples of work activities include welding/cutting/brazing, ground disturbance, electrical work, any confined space entry, etc. ePTWs are usually required for non-routine and maintenance work.

Best Practice: Create a documented work request process that supplies work scope and other items covered like location and hazard assessments. This will allow the ePTW System owners to notify all affected personnel, highlight any concerns or needs, and prepare for potential permits.

3. ePTW Life Cycle – Permits must be approved and posted at the work location for the entire duration of the work process. The ePTW System owner should also be notified of the completion of work for permits retention and ensure that the workplace is restored to its safe, original state. A new permit will need to be issued for each shift if the work carries over or has any changes in conditions.

Best Practice: Many organizations have adopted the practice of requiring all individuals working during the process to sign an ePTW form before performing work to confirm that they understand all the processes and guidelines documented in the ePTW System.

4. Hazard assessment – Permits that require hazard assessment in one form or another by listing the hazards and controls for that job. However, they should not be mistaken as a replacement for a detailed risk assessment.

Best Practice: Implement a Quick Risk Prediction (QRP), or the like, for each shift change or change in conditions during the lifetime of the job. This will promote safer behaviors by having employees slow down before completing work and identify any changes in hazards with the work tasks.

5. Personnel responsibilities – Responsibilities must be defined for separate roles in the permit process and can be specific to certain permit needs. Examples of distinct roles in the system include work supervisors, permitting/issuing authority, gas tester, fire watch, operators, etc.

Best Practice: Certain permits will have roles where the personnel need to be named, and when personnel change, a new permit should be issued through the ePTW procedure. Listing a backup is recommended to prevent delays if the primary is unavailable.

6. Training and competency logs – Only qualified employees can perform specific tasks for regulatory and safety reasons. All personnel assigned to roles and responsibilities must be in conformance with currently applicable certifications and any necessary PPE (Personal Protective Equipment) training.

Best Practice: Maintain a database of qualified employees with their training expiration dates. This will help adhere to training requirements and ensure that the required tasks are completed by experts or authorized personnel.

7. Safe Work Plan – A Safe Work Plan should be created for each job that falls under the hazard assessment's identified risks and emergency response procedures. The Safe Work Plan acts as a checklist to ensure adherence to the safety controls at the start of each activity.

Best Practice: Ensure the inclusion of the surrounding public and community in the plan.

8. Permit Retention – As mentioned in the ePTW Life Cycle, depending on your regulating agency, it may be required to maintain all documents related to a permit and also ensure these permits are renewed periodically. This is critical from an audit standpoint.

Best Practice: Maintaining all documents related to project work allows for proof of diligence, easier auditing, and gap analysis of the system.

9. Auditing – The ePTW System should be audited annually and must include both documentation examinations and personnel interviews.

Best Practice:Preserving the audit results for at least three years can allow internal auditors to recognize repeat issues. Make sure to include evidence of conformity or findings to ensure accountability.