CQ Guide: Automation of Permit to Work (PTW) in the Life Sciences Industry

CQ Checklist: 3 Steps to Better PTW workflows

To ensure the automation of PTW processes is successful, we recommend the following 3-step approach.

Step #1: Identify all high-risk tasks and decide which ones need a PTW

The first step towards improving safety standards is to put together an exhaustive list of all high-risk processes and tasks. Some risks are common across all sectors. One needs to plan for exposure to chemicals, hot work, electrical work, working with inflammable material, tripping and falling, etc.

In addition to these, companies in the life sciences sector need to plan for safety precautions due to:

• Exposure to biological agents
• Usage of laboratory chemicals
• Working with cytotoxic drugs and pharmaceutical substances
• Precautions to be taken with anesthetic gases (nitrous oxide, halothane, isoflurane, desflurane, sevoflurane)

These substances can cause respiratory problems, cause allergic reactions, skin irritation, etc. Therefore, it is important to work with subject matter experts to document precautionary measures, and then create a process (or a system) for people to follow them. 

Often times, laboratory processes are outsourced to a CRO by sponsor organizations, and even then it important for both the sponsor and the research organization to “know the risks” of using these substances and plan for the same.

Step #2 - Risk assessment, scheduling and de-conflicting

Once an exhaustive list of “high-risk” tasks are identified, its time to implement a PTW workflow. The key here is to ensure that a proper risk assessment is integrated into the PTW management system. Additionally, the system must be aware of scheduling rules, including precautions to be taken for de-conflicting two risky tasks.

The Factories Act makes certain precautions and safety measures mandatory when carrying out hazardous operations. This includes the following steps:

• Identify and assess the hazards involved in each task
• For highly hazardous tasks, safer alternatives must be considered - such as using robots or using a different approach
• Only if such an alternative does not exist should a worker be deployed to undertake the task
• The worker, an employee or someone on contract, must be evaluated for his/her skills and proficiency in handling the task and the associated risks
• The workplace environment must be prepared to minimize the risks and mitigative measures established to handle any events. We must ensure that tasks are scheduled to avoid any conflicts, where it is risky to perform two hazardous tasks simultaneously
• A permit should be issued for the work that clearly enunciates:

• The date when the task is to be undertaken
• The exact location where it is to be carried out
• The nature of job to be performed
• Any precautions to be taken
• Specific instructions, if required
• The duration of the work, as covered in an issued permit

• The final issued permit should be made available at the job-site at the time of starting work
• The permit should be specific to one worker or a set of workers clearly mentioned in the permit
• The work should not continue after the end time mentioned in the permit
• No other unauthorized person should be allowed in the work site
• All those who are assigned the permit should review the instructions and precautions properly before undertaking the task

A next-generation PTW solution, like the one we offer at ComplianceQuest is designed to streamline your process from initiation through to permit closure. The system automatically deactivates permits based on work completion while manually supporting extensions and exceptions.

Based on the hazard, permits can be one of the following types:

• 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, let us say a lab or a particular location within a factory. 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.
• Electrical Isolation Permit – For work on electrical systems where there is a possibility of working with energized electrical conductors.
• Drilling Permit – Required when drilling is involved.
• Cold Work Permit – This refers to work to be done at lower temperatures, or during extremely cold weather conditions.

Step #3 - PTW workflow with integrated risk management

The lifecycle of Permit to Work automation involves steps - right from assessing risk to finding alternative approaches, to identifying the right personnel, to issuing and managing the permit itself. All these processes can be automated and managed using a cloud-based software solution, like the one we offer at ComplianceQuest.

CQ’s PTW solution is part of our EHS product suite and it adopts a risk-based approach to the management of workplace safety improvement efforts. Built on the Salesforce platform, the solution is flexible, scalable and easy to use. 

It helps to formalize PTW procedures on a case-by-case basis, keeping in mind personnel workloads, budgeting, and other specific conditions. It can automate the entire PTW process - from the time of requesting a work form till its expiration, while providing complete data visibility to all stakeholders involved.

The system is highly customizable and can be used to identify tasks that require a permit(s), develop permit forms, define roles, train and maintain the competency of personnel, create a work order, fill out permit forms and identify associated hazards and mitigation needed.

It is also used to track the completion of a task within the duration listed on the permit.

Broadly, the PTW process can be divided into:

• Work Request Form – A Work Request Form must be completed and submitted to the ePTW System owner, with the following information:

• Work Location
• Work Scope
• Hazard Assessment
• List of personnel for tasks and roles
• Current training certificates
• List of permits needed for work
• Safe Work Plan

• Authorization – All individuals affected by work scope must approve the work request before continuing the ePTW System procedure. Examples of potentially necessary approvals include:

• ePTW System owner
• Work Scope
• Facilities Manager
• Safety officer
• Contract manager
• Operations Manager
• Safe Work Plan

• Granting a Permit – Once the work request is authorized, the necessary permits must be authorized before commencing work. Permits must be turned in at the end of the shift and reissued for each shift where one is needed.
• Notifications – When the work request is authorized and permitting requirements are confirmed, the involved individuals will need to be notified of the upcoming work. Notifications of the work scope must be defined. An ePTW form duly signed by the the authorized person must remain posted for the duration of the work at the area/location of work.
• Posting – Each completed permit must be posted at the work site for the entire duration of the project.
• Quick Risk Predictions – A QRP must be completed before each shift, change of activities, and changes in conditions. QRPs (Quick Risk Prediction) must be turned in with the permit to the owner at the start of work, and all individuals involved in the project work must review.
• Closure of Work and Retention – All documents as part of the ePTW System must be submitted to the ePTW System owner once the work duration is completed and maintained for at least one year. The worksite must be cleaned and returned to normal working conditions.
• Training – Integrate the permit generation with training where required to fill any gaps.

Our risk-based ePTW solution ensures data visibility & transparency, facilitates analysis of risk trends and helps companies remain compliant with OSHA requirements.

Find out more about ComplianceQuest Permit to Work System here: https://www.compliancequest.com/permit-to-work/

Request a demo here: https://www.compliancequest.com/online-demo/