Permit to Work - Confined Space

What Is a Permit to Work - Confined Space?

A Permit to Work for a Confined Space is a formal written document used in Australian workplaces to control high-risk activities. It is not just a piece of paper. It is a checklist and a legal record that confirms a specific workspace is safe to enter. The permit ensures that all hazards have been identified, safety controls are active, and the people doing the work understand the risks.

Under Australian work health and safety laws, a confined space is an enclosed or partially enclosed space that is not intended or designed primarily for human occupancy. It also means a space where there is a risk of a person being trapped, engulfed, or asphyxiated due to atmospheric conditions like unsafe oxygen levels or contaminants. Common examples include storage tanks, silos, vats, sewers, pipes, pits, and shafts.

The permit acts as a contract between the site supervisor and the workers. It states that the supervisor has checked the environment and says work can proceed. It also states that the workers accept the conditions and will follow the safety rules. This document is essential because conditions in a confined space can change quickly. A permit system helps manage those changes and prevents fatalities.

When to Use This Document

You must use a Confined Space Entry Permit whenever a worker needs to enter a space that meets the definition of a confined space. The law is strict on this. You should not rely on judgement alone. The Work Health and Safety Regulation 2011 (Cth) and equivalent state regulations require a permit unless a risk assessment shows there is no risk to health and safety.

In practice, it is safer to assume a permit is needed. You should use this document if the work involves entering a tank, vessel, pit, or pipe. You also need it if the space has limited means of entry or exit. This applies regardless of how long the job takes. Even a quick ten-minute inspection requires a permit if the space meets the criteria.

There are no thresholds for business size regarding this requirement. Whether you are a sole trader, a small startup, or a large corporation, the duty of care applies. If you employ people or engage contractors to work in confined spaces, you must have a permit system in place.

Key Sections and Required Elements

A robust Permit to Work must contain specific information to be legally compliant and effective. Following the Model Code of Practice and Australian Standard AS 2865:2021, the document should cover several critical areas.

Space Description and Identification The permit must clearly identify the specific confined space. You should use exact names or tags, such as " chemical storage tank 3" or "North Site Effluent Pit." You must also list the exact location of the entry and exit points. This clarity prevents confusion, especially on large sites with multiple tanks or pipes.

Isolation Details This section confirms that all energy sources have been isolated. This is known as Lock Out Tag Out (LOTO). The permit must list every hazard source, such as electrical supply, mechanical moving parts, steam, or gas. It should verify that these sources are locked in the "off" position and tagged to prevent someone from accidentally turning them on while work is happening.

Risk Assessment and Hazards The permit must reference the specific hazards found in the space. This includes atmospheric hazards like low oxygen or toxic gases. It also includes physical hazards like engulfment in liquids or free-flowing solids. The document must list the control measures put in place to manage these risks. For example, if the risk is a toxic gas, the control might be forced air ventilation.

Atmospheric Monitoring Results If the atmosphere is a risk, you must record gas test results. The permit needs a table for these readings. You must record the oxygen percentage, the Lower Explosive Limit (LEL), and levels of toxic gases like Carbon Monoxide or Hydrogen Sulfide. These readings must be taken within 30 minutes of entry and recorded in parts per million (ppm) where applicable.

Emergency and Rescue Procedures The permit must outline how a rescue will happen. It is not enough to just call 000. The document needs to list the rescue equipment available at the site. This includes retrieval tripods, winches, harnesses, and lifelines. It must also state how the emergency services will be notified and how they will access the site.

Authorisation and Sign-Off This section creates the legal record of who did what. It requires signatures from the issuer (the supervisor), the entrants (the workers going in), and the standby person. There must also be a section to close the permit. This confirms the work is finished, all workers are out, and the equipment is removed.

How to Write a Permit to Work - Confined Space (Step by Step)

Creating and issuing a permit is a logical process. Skipping steps puts lives at risk and breaches the law.

Step 1: Conduct a Risk Assessment Before you write the permit, you must assess the risks. This is a legal requirement under Regulation 66 of the WHS Regulations. You need to identify what could go wrong. Look at the contents of the space. Check what was stored there previously. Consider the work to be done. For example, welding inside a tank introduces fumes and heat, which changes the risks. Document these findings on a Risk Assessment Form first.

Step 2: Isolate Energy Sources Once the risks are known, you must isolate the space. This involves shutting down machinery, locking valves, and de-energising circuits. You must apply personal locks and danger tags to every isolation point. Record these isolation points on the permit. Do not issue the permit until the LOTO process is complete.

Step 3: Test the Atmosphere If the atmosphere could be unsafe, you must test it. Use a calibrated gas detector. Test at various levels inside the space, not just at the top. Gases stratify, so heavy gases might sit at the bottom while light gases sit at the top. Write the results on the permit. If the readings are not within safe limits, you must ventilate the space and test again. You cannot issue a permit if the air is unsafe.

Step 4: Complete the Permit Details Fill in the header information. This includes the date, the specific time the permit is valid for, and the names of the workers involved. Be specific about the time limits. A permit usually has a shift limit, typically 8 to 12 hours. Once this time expires, the permit is void, and you must issue a new one.

Step 5: Establish Controls and Rescue Set up the control measures listed on the permit. This might involve setting up a tripod at the entry point, turning on ventilation fans, or lighting the area. Ensure the Standby Person is in position. Check that all rescue gear is on site and ready to use. The permit is invalid if these controls are not in place.

Step 6: Sign and Issue The authorised supervisor must sign the permit to issue it. By signing, they declare the space is safe to enter with the stated controls. The workers entering the space must then sign to acknowledge they understand the risks and the controls. The standby person must also sign to accept their duty to monitor the entrants.

Step 7: Display the Permit Post the physical permit at the entrance to the confined space. It must be visible to everyone. If a WorkSafe inspector visits the site, this is the first document they will ask to see. It keeps the rules top of mind for the workers.

Step 8: Close the Permit When the work is done, or the shift ends, the permit must be closed. The supervisor must verify that all workers are out of the space. They must then sign the "closure" section. This formally ends the authority to enter. If work is not finished, you can extend the permit only if the risk assessment allows, or you must start a new permit process.

Common Mistakes to Avoid

Failing to Isolate Correctly One of the biggest mistakes is relying on a switch rather than a physical lock. Just turning a pump off is not isolation. The pump could be turned on remotely or by accident. You must use lock out tag out procedures to physically prevent energy flow.

Signing Blank Permits Never sign a permit and leave it for the supervisor to fill in later. The person issuing the permit must be the one who verifies the safety controls. Signing a blank document bypasses the whole safety check.

Ignoring Atmospheric Changes Testing the air at the start of the shift is not enough. If work involves painting, cleaning, or welding, the atmosphere can change rapidly. You must conduct ongoing monitoring. If the alarm sounds, workers must evacuate immediately.

Not Having a Standby Person It is illegal to work in a confined space without a standby person. This person must remain outside the space at all times. They cannot leave the post to grab tools or coffee. Their sole job is to monitor the workers and raise the alarm if something goes wrong.

Using Expired Permits Time limits exist for a reason. Conditions can change, and fatigue can set in. Do not let workers stay in the space past the expiry time on the permit. If the job runs over, bring them out, reassess, and issue a new permit.

Legal Considerations (AU)

The legal framework for confined spaces in Australia is strict. The primary legislation is the Work Health and Safety Act 2011 (Cth) and the equivalent Acts in states like New South Wales, Queensland, and South Australia. These laws impose a duty on the Person Conducting a Business or Undertaking (PCBU) to ensure safety so far as is reasonably practicable.

The Regulations The specific rules are found in the Work Health and Safety Regulation 2011 (Cth), Part 4.3. Regulation 69 makes it clear that a confined space entry permit is mandatory for all entries unless a risk assessment says otherwise. You must keep these records available for inspection. Safe Work Australia inspectors can issue fines or stop work notices if you cannot produce a valid permit.

State Variations While most states are harmonised under the "Model" WHS laws, there are differences.

• Victoria: Victoria uses the Occupational Health and Safety Act 2004 and the Occupational Health and Safety Regulations 2017. Regulation 214 specifically requires written authority for confined space entry. The process is very similar, but the specific act references are different.
• Western Australia: WA operates under the Occupational Safety and Health Act 1984. While not fully harmonised, the Commission for Occupational Safety and Health Code of Practice: Working in a Confined Space sets the standard. WA inspectors expect a permit system that matches this code.

The Standard Australian Standard AS 2865:2021 is the benchmark for industry best practice. While a standard is not law, courts and regulators look to it to define "reasonably practicable" steps. If an incident occurs and you have not followed AS 2865, you will likely be found negligent. Clause 4.5 of this standard details exactly what should be in your permit system.

Duty to Consult The WHS Act requires you to consult with workers about safety. When developing a permit system, you should talk to the people who actually do the work. They know the practical realities of the space. A Consultation Agreement can help formalise this process.

Disclaimers and Declarations Your permit should include a specific disclaimer. It must state that the permit is invalid unless all risk controls are in place and atmospheric testing confirms the space is safe. It should also state that the permit does not remove the duty to stop work if conditions change. Workers must know they have the right and the obligation to stop work immediately if they feel unsafe, regardless of what the permit says.

Frequently Asked Questions

Who can sign a Permit to Work? Only a competent person who understands the hazards and controls can sign. This is usually a supervisor or a manager with specific training in confined space entry. The worker entering the space cannot sign off on the safety of the space for themselves.

Do I need a permit for routine inspections? Yes. If the space meets the definition of a confined space, you need a permit for every entry. Even if you are just looking inside, you are still at risk from atmospheric hazards or entrapment. Routine does not mean risk-free.

How long does a permit last? The permit usually lasts for one shift. The maximum duration is often set by company policy, but it is rarely longer than 24 hours. You must specify the expiry time on the document.

What happens if the alarm goes off? The permit should trigger an emergency response. The standby person must not enter the space. They must use the retrieval equipment to rescue the entrants or call emergency services if a retrieval is not possible. The permit is immediately voided once the emergency procedure is activated.

Can I use a digital permit? Yes, digital permits are acceptable and are becoming more common. They can enforce data entry fields and time limits effectively. However, you must ensure that the digital system allows for signatures and that the permit is still displayed or accessible at the entry point. You also need a backup plan in case of technology failure.