Hazard identification and risk assessment for permit issuers

So you need to issue a permit. First things first: evaluating the hazards and controls proposed by the permit receiver, and cross-checking those against all other hazards at the work site. Every permit decision depends on your ability to identify hazards and assess risk. If you get this wrong, the controls you put in place will be wrong too, and people may be seriously injured or killed doing work you authorised.

A hazard is anything that has the potential to cause harm. Risk is the likelihood of that harm occurring, combined with how serious it could be.

Identifying hazards

When assessing a task for a permit, you must identify all hazards associated with the task itself, the location, the equipment, the materials, the environment, and any nearby work that could introduce additional risk. You will do this using a combination of physical inspections, task analysis, process analysis, and lessons learned from previous incident investigations.

Hazard identification cannot be done from your desk. Unless you are issuing a remote permit, you need to inspect the worksite. Walk the area. Look at the ground conditions, access routes, overhead structures, and nearby plant. Check for underground services. Find out what substances are stored or processed in the vicinity. Ask the people who work there every day; they will often know things that are not captured in any documentation.

The common hazard categories you will encounter include energy sources (electrical, mechanical, hydraulic, pressure, and thermal), hazardous atmospheres where oxygen levels or flammable gas concentrations may be outside safe limits, physical hazards such as falls from height, falling objects, excavation collapse, and confined space entrapment, and hazards introduced by the work itself (sparks from grinding or welding that could ignite nearby material, for example).

Bear in mind that hazards change. A task you have permitted twenty times before may present different hazards this time because of weather conditions, nearby simultaneous operations, a change in plant status, or a different crew doing the work. The permit process exists to catch those differences, and a risk assessment that does not describe the actual conditions on that day, in that location, is not a risk assessment. It is paperwork.

Assessing risk

Once you have identified the hazards, you assess the risk by considering two factors: the likelihood that harm will occur, and the consequence if it does. Most organisations use a risk matrix to bring these together into a numerical rating. The rating determines what level of control is needed and what type of permit documentation is required.

A low-risk task might proceed under a verbal permit with basic precautions. A high-risk task will require a full written permit, a detailed risk assessment, and potentially specialist certificates for activities such as confined space entry, hot work, or working at height. Some organisations use a Permit Assessment Score (PAS) system, while others use a Hazard Identification and Task Risk Assessment (HITRA) process. The terminology varies. The principle does not: you match the level of control to the level of risk.

The risk assessment must be specific to the task being permitted. A generic risk assessment written for a previous job in a different location is not adequate, even if the task appears identical. Conditions change, and the assessment must reflect what is actually happening on site, not what happened last time.

The hierarchy of controls

Once you have assessed the risk, controls are applied using the hierarchy of controls as required under the Health and Safety at Work Act 2015. This is an order of preference, not a menu you pick from. You work from the top down.

Elimination means removing the hazard entirely. Can the task be done a different way that avoids the hazard altogether? If the answer is yes, that is the preferred control. In practice, elimination is not always possible for the kinds of high-risk work that require permits, but the question must still be asked.

Substitution means replacing a hazardous material, process, or piece of equipment with a less hazardous alternative. Using a less flammable solvent or a less toxic chemical where possible is an example.

Isolation means physically separating people from the hazard. Lockout/tagout of energy sources, barricading excavation zones, and sealing off confined spaces before entry are all forms of isolation. This is where much of the Permit Issuer’s verification work sits, because isolation failures are among the most common causes of serious harm in permitted work.

Engineering controls modify the work environment to reduce risk. Ventilation systems, guardrails, shoring for excavations, and gas detection equipment all fall into this category. They do not remove the hazard, but they reduce the likelihood or consequence of exposure.

Administrative controls include procedures, training, signage, job rotation, and restricted access. Safe work method statements, toolbox talks, and the permit conditions themselves are administrative controls. They rely on people following the rules, which makes them less reliable than engineering or isolation controls.

Personal protective equipment (PPE) sits at the bottom of the hierarchy because it does nothing to reduce the hazard itself. It only reduces the consequence if a person is exposed. PPE is never a substitute for higher-level controls. In practice, most high-risk tasks require controls at several levels working together, and PPE is the last layer, not the only one.

Your role as Permit Issuer

As a Permit Issuer, you are responsible for confirming that the risk assessment has been done properly and that the controls are adequate for the level of risk. If you’ve done the permit issuer course, then this should be clear.

You do not have to carry out the assessment yourself in every case, but you must be able to review it, challenge it, and refuse to issue a permit if the controls are not sufficient.

This means reading the Job Safety Analysis or HITRA that accompanies the permit application and checking whether it actually reflects the work being done, in the location where it is being done, on the day it is being done. A photocopied risk assessment from a previous job with the same boxes ticked is a red flag. If the assessment does not describe the specific hazards and specific controls for this task, it needs to be redone before you sign.

You also need to look for gaps. Are there hazards that the applicant has not identified? Has the hierarchy of controls been applied properly, or has the assessment jumped straight to PPE? Does the risk rating match what you see on site? If a risk assessment says “low risk” but you can see six pallets of shrink-wrapped product stacked two metres from where an angle grinder will be running, the assessment is wrong, regardless of what the form says.

If you are not satisfied, send it back. The delay is always less costly than the consequences of issuing a permit against an inadequate risk assessment.