Understanding Work Permits in the Factory Act-1948: Seeking Guidance on Types, Uses, and Procedures

Dear Seniors,

Please guide me on the following queries:

1. What is meant by a work permit?
2. As per the Factory Act-1948, where is it mentioned about its types and use?
3. Which parameters need to be included in a work permit? Can you provide a sample format?
4. Is a work permit required to be signed by the safety officer? What should be done if the safety officer is on leave?
5. Is a work permit required for routine maintenance work? Could you share a sample format?
6. Who is the authorized person to sign the permit as per the standard system?

I also seek any other relevant information that would be useful for our organization regarding the work permit system.

Regards,
Abhay

Dear Abhay,

Let me try to answer you.

1. What is meant by a work permit?

A Permit-to-Work System is a formal written system used to control certain types of work that are potentially hazardous. It also serves as a means of communication among site personnel to ensure all necessary safety precautions are taken before commencing such work.

2. As per the Factory Act of 1948, where is it mentioned about the types and use? Unfortunately, I am not sure about it. The types of work permits include:

- General Work Permit, which consists of:
i) Cold work permit
ii) Hot work permit

- Special work permit, including:
i) Confined space entry
ii) Working at height
iii) Excavation and fragile roof
iv) Electrical work Permit (HT/LT)
v) Material lowering and lifting

Cold work permit: This is the first level permit issued for general jobs that do not involve any special activities like confined space entry, working at height, excavation, electrical maintenance on HT/LT, and material lowering and lifting.

Hot Work Permit: This permit is issued for jobs involving activities that generate sparks and flames. Welding, gas cutting, grinding, and chipping are a few activities that require a Hot Work Permit.

3. Which parameters need to be included in a work permit? Do you need a sample format?

Please specify which one you are looking for, and I will assist you in creating one.

4. Is a work permit required to be signed by the safety officer? If there is only one safety officer in the organization and they are on leave, what should be done? No, there is no need for the Safety Officer's sign.

5. Is a work permit required for routine maintenance work? Could you provide a sample format?

Yes, a General Work Permit is necessary for all jobs. Please find a sample format attached.

6. Who is the authorized person to sign the permit as per the standard system?

A minimum of three persons need to sign the work permit:
1. Job Executor
2. Concerned Engineer
3. Permit Issuer (Reporting Boss)

Looking forward to more participation in the post.

Regards,

Dipil Kumar V

Dear Abhay,

I am posting a PowerPoint presentation on the work permit system that we use in our plant (CLZS). I hope it will be useful.

Regards, Hansa Vyas

Re: Permits

I have written a Permit To Work procedure for an upstream oil & gas company in Sudan. It may be of interest.

Dear Friends,

I am watching the deliberations eagerly. Mr. Abhay posed a few questions. Mr. Dipil tried to answer them one by one. Many others are providing useful information. Ms. Hansa presented an easy-to-understand and informative PowerPoint presentation. Mr. Gopinathan Pillai presented a permit system in its entirety, which includes sample formats. However, I still feel that Mr. Abhay's questions have not been convincingly answered.

Could any of my friends please make an attempt to directly answer these questions?

Regards,
Kesava Pillai

Dear Abhay,

Some jobs in a factory are dangerous to life and therefore well advanced precautions are necessary before their commencement and till the completion. Hot work like welding and cutting, entering any confined vessel, working at height or on fragile roof, opening of dangerous pipelines, electric work and handling of chemicals. For the safety from such works a work permit system is highly essential.

A work permit system should cover the following points:

- Who requires a work permit i.e., contractors, Engineering, maintenance worker, etc.
- What jobs require a work permit i.e., All maintenance jobs, tank cleaning, etc.
- What types of permits are available:
- General Work Permit which includes:
i) Cold work permit
ii) Hot work permit
- Special work permit
i) Confined space entry,
ii) Working at height,
iii) Excavation & fragile roof,
iv) Electrical work Permit (HT/LT)
v) Material lowering & lifting.

Who is responsible for issuing work permits and arrangements for recording the issue, revalidation, and retention of permits.

If there is only one safety officer in the organization, then only critical work like confined space entry, HOT WORK safety officer should sign. The rest of the permits should be signed by safety coordinators. Section/Department wise safety coordinators help to implement the permit system.

Parameters that need to be included in the work permit:

- Hazards of the plant, chemicals, and work are fully explained.
- Instructions are in detail and fully understood.
- The work area should be clearly identified or hazards highlighted.
- The in-charge of the area who issues the permit should be competent and responsible.
- Any monitoring including gas testing required before and after the work should be clearly specified.
- When the work is completed, the area in-charge signs off the permit, stating that the specified work is completed and the plant is suitable to return to operation.
- The closed permit should be returned to the concerned Safety coordinator/Safety officer.

Attached is the work permit format of our plant that may help you.

Regards,

Sanjay Sabalpara

Dear All,

Thanks a lot for the great participation in the thread. It will surely benefit everyone.

@ Hansa,

Your presentation is very nice. Thank you for sharing.

@ Gopinadahn Pillai,

Thank you for sharing the procedure on the topic.

@ Sanjay Sabalpara,

Thanks for the great explanations and for sharing the sample of permits used in your plant. I disagree with your following statement:

"If there is only one safety officer in the organization, then only critical work like confined space entry and HOT WORK require the signature of the safety officer. The rest of the permits should be signed by safety coordinators. Sections/Department-wise safety coordinators help to implement the permit system. There is no requirement for a Safety Professional's signature on any permit. Is there any law in India that states the need for a Safety Professional's signature on a work permit? The individual executing the job (a qualified engineer) is competent enough to assess the job and take necessary precautionary actions. It is primarily their responsibility to ensure the safe execution of the job rather than the Safety Professional. You can include a clause for cross-checking by the safety department in the permit as follows: This means that work can commence even without the Safety Professional's signature.

Cross-Checking by Concerned Safety Officer:

The above measures have been cross-checked, and work can proceed.

Additional measures required, if any:

If the Safety Professional identifies any violations during this cross-check, they are fully authorized to cancel the permit and stop the work.

@ Keshav Pillai,

Looking forward to your inputs, especially on questions 2, 4, and 5, sir.

Regards,

Dipil Kumar V

Dear All,

Thank you for the valuable inputs. All are good, and the presentation of Hansa is excellent.

For Abhay's questions - (which are not answered)

Q 2. Kindly regret, I'm unable to find the answer & I want Kesava to share his knowledge. I'm too eager in knowing the answer since we are following this as a system.

Q 3. The parameters to be included - removal of all possible hazards like draining the line, purging the line, venting the vapours, etc.

Q 4. For the critical jobs, where additional supervision by the safety persons is needed, it needs to be counter-signed by the Safety Officer. These jobs are Hot/Cold works, Radiation works, Vessel entries. For these jobs, the safety officer should visit the area, find whether the permit fulfills the working condition & get the results of the area inspection (e.g., explosive limit reports, oxygen reports) and then permit the work by counter-signing. In the absence of the safety officer, the Plant Head has to sign the permit. These executions have to be taken care of by the safety persons. In the absence of safety persons, safety coordinators have to take the responsibility.

For other works - a safety officer will not sign the permit, whereas the information about the job has to be communicated to him. He, during the execution of the jobs, visits and inspects whether the jobs are carried out according to the permit & also whether anything needs to be added in the permit.

Q 5. For routine maintenance work - a permit is needed. This question has complex answers. If you are following a permit system, then yes, you have to raise a permit that is for routine maintenance jobs. Some companies follow the work order systems, where you will not require a permit. Why is it so required? Every job needs proper communication with the local operating teams, who are responsible for that area. So, a permit/work order will solve that. In your routine maintenance, you either require a system to be shut down or you will be doing minor adjustments online. So proper communication is required that you are doing a maintenance activity in that.

Q 6. The area in charge (normally for shifts - shift leaders & in big plants the area engineer) will raise the permit. He has to coordinate with his associates & the other related departments to execute the job. He takes full responsibility for the release of a job by following the work permit system. The job performer (if it is the employee, then the employee & if it is the contractor, his supervisor) will receive the permit by counter-signing the permit. By counter-signing, he ensures that he has gone through the permit & understands how a work is to be carried out safely (in case of any special instructions).

Also, I want to tell some more about the work orders.

The work order is an information request & a communication medium that will be issued in normal conditions for performing a work. A work order will be accompanied by the permits (Class I & II or Hot/Cold work permits) if the work requires a permit, based on the criticality of the job.

Not all companies are following this work order system. According to me, a work order will be much easier for handling the jobs.

Regards

Dear All,

Very interesting discussions. Good to see. I always am of the opinion that a Work Permit is a tool used to manage the risks involved in any activity considered hazardous, i.e., where there is potential for the hazard to be released resulting in incidents that affect life, health, property, and/or the environment.

The best people to know the hazards of an activity are the line people, especially the supervisors. They should ensure that all precautions are in place to prevent the release of any hazard. Their managers should undertake the responsibility for any activity carried out. So they should be the approving authority for any permits issued.

The safety professional should not take away the line's responsibility and therefore not really sign the permit. They should check the permits at the work site to see whether the precautions specified in the permit are adhered to at all times while the activity is being conducted.

Now comments, please.

Dear Friends,

The discussion is heading in the right direction, and the level of participation is quite encouraging. Let me address one question at a time. The answer to Mr. Abhay's first question, "What is meant by a work permit?" is as follows:

A work permit is a document that includes:
1. Task
2. Equipment involved
3. Location
4. Personnel involved
5. Time limitations
6. Likely hazards to encounter
7. Precautionary measures

It serves specific purposes, such as:
1. Avoiding verbal instructions
2. Providing written information on hazards
3. Outlining remedial measures
4. Indicating necessary personal protective equipment (PPE)
5. Providing a checklist
6. Serving as a medium of information
7. Ensuring the best possible safety measures for working in hazardous operations
8. Offering a sense of security for employees
9. Serving as a written document/record that establishes authority, responsibility, and accountability for safety in the specific task.

Regards,
Kesava Pillai

Dear Abhay

Nice thread. As mentioned your point no 1 is cleared.

For point no 2 - It is mentioned in Factory Rules of the state. In Gujarat Factory Rules it is mentioned in schedule XIX para 20. Further it is also mentioned in each provision. Eg. in clause 15 (Testing examination and repair of plant and equipment.—) it is mentioned in the end - "Wherever, the responsible person shall regulate the aforesaid work through a permit to work system." Similarly it is mentioned under "work in COnfined spaces" etc.

Please check YOUR state factory rules.

Other questions are well answered by the members.

Requirement of the signature will also depend on your Safety procedures.

For further information on Safety PTW reference may also be taken from OISD-105 on Work Permit System, OSHA and NFPA (NFC).

Types of permit will largely depend upon the nature of business you are into. The PTW system in small unit will differ from that of Mega units / Refineries etc.

Authorization is well explained by Dilip. We have Issuer, Receiver and Area Incharge signatures on all permits during normal work hours. During off-hours / sundays / holidays permit has to be signed by RSM (Highest officiating incharge of complex) and the permit needs to be registered with fire station prior starting of work.

Work permit IS REQUIRED for all type of work including road closure and working at height above 1.5 mts.

Standard system is the one YOU are preparing for your complex and getting the procedure approved. You may take deviation if certain thing is not applicable to you. But preparing of the SOP is required as per Factory's act.

Being the safety professional you need to keep constant vigil on all the permits and even conduct PTW audits. Even if you are not signing the permit, a copy of the permit MUST be with the HSE department, as this will be very helpful during investigation of any incident.

You will further find the answers in detail from NEBOSH study material Unit A4, which I hope Keshav can help.

For further queries you may please get in touch on 09925153646.

Best Regards

Neeraj4all

@Neeraj4all,

Thanks for the nice explanations and the participation in the thread. Your answer to question number 2 is that it's mentioned under state factory rules. Is it clearly mentioned together anywhere - like for the following jobs under certain conditions, a work permit is required? I have not found it together. For example, in the case of Confined space, it's written that a permit for work is required, working on a fragile roof, etc.

"Work permit IS REQUIRED for all types of work including road closure and working at a height above 1.5 meters." - Is this sentence from the Factory Rules?

Hope you will guide.

Regards, Dipil Kumar V

Dear Friends,

Mr. Abhay's second question is answered as below:

As per the Factories Act of 1948, where are its types and uses mentioned? Work permit is not mentioned anywhere in the Indian Factories Act. If it is deemed necessary, it will only be included in the Factory Rules. Post the Bhopal incident, a few states have already implemented the work permit system, mainly focusing on chemical accidents.

The Safety Work Permit system serves as a tool to ensure safe performance in potentially hazardous jobs. Not all tools necessary for carrying out work safely need to be explicitly stated in statutory requirements. If you can ensure the safety of workers through other means, you do not necessarily need to implement a permit system. Section 7A of the Factories Act, the General Duty Clause, indirectly states that you must ensure provisions, arrangements, instructions, training, supervision, monitoring, and all other foreseeable safety elements. Understanding the spirit of this clause will reveal that a permit system is not only the best way to ensure safety but also to provide indemnity.

Regards,

Kesava Pillai

Normally, a Work Permit is used to ensure that all safety precautions have been taken to ensure that potentially hazardous or non-routine jobs are carried out safely. For extremely hazardous work such as confined spaces, heavy lifts, etc., a Job Safety Analysis is carried out, and the precautions listed are either included in the Work Permit or the JSA is attached to the work permit.

The other key point to remember in Work Permits is that approval signatures are not the end-all, but it is important that supervisors brief the workers on the job after the signatures have been obtained. This becomes a reminder to the workers on the precautions to be taken. Supervisors then have to monitor that the precautions are applied throughout the work process.

In my experience regarding routine jobs, I have found that Standard Operating Procedures (SOP) are used, but these are written by people in the office. Some of these cover routine hazardous work, but no permit is used. To overcome this, I normally tell participants in my training sessions that I recommend they do a JSA on the critical routine activities and convert them into SSOP (safe standard operating procedure).

The last point was to share some experiences.

Regards,

Gopi

Dear Dilip,

The sentence is not from Factory Rules. Keshav has correctly said that this is not mentioned in the Factory's act but in Factory rules. Please provide the factory rules applicable to you, and then I can be of little help.

As Gopinadhan has said - yes, it is the responsibility of the employer to ensure the safety of workers/employees and has given an example of best practices followed.

The system that I have maintained here is - Every work permit needs to have a TBRA (Task-based Risk Assessment) sheet attached. We believe that accidents are preventable, and risk is involved in each work. After the permit is issued - TBT (toolbox talk) is given to all the contractor staff as per TBRA, which updates the workers on the possible hazards of the work they are going to perform. After that, our officer essentially goes to all work locations to inspect and fill in SAR (Safe at Risk) checklist to ensure that the behavioral aspect of safety is ensured.

I thank all who are actively participating in this forum, especially Mr. Gopi, who has also started to give inputs for best practices - which can be incorporated into the reader's company too, making this a safer place.

Dear Neeraj,

Thank you for your comments and for sharing the good practices adopted. In our plant, we create a Safe Work Procedure (SWP) for each new job and issue it along with the required work permit to the contractors. Tool Box Talks are held regularly in each section, during which the supervisor/engineer explains the potential hazards and the preventive measures to be taken.

The Rajasthan Factory Rules apply to us. If you have a soft copy of these rules, please share them with me.

Regards,
Dipil Kumar V

Dear Friends,

Answering the 3rd question:

There are no hard and fast rules. You may create your own forms in your own style, color, shape, and as many copies as you want.

As a minimum, it must have the following contents (Parameters):

- Information on hazards
- Instructions to ensure safety
- People responsible for safety
- Proprietor's consent guaranteeing safety at the place/equipment
- Provide instructions/information to that effect
- Executors accepting that responsibility in adhering to instructions and limitations stipulated
- Provide written instructions and documentary evidence
- Making it a document of consent between the proprietor and the executor

BASIC INFORMATION

On top of permit issuer must write basic information such as Date, Duration of work, exact area or plant where work will be conducted, exact work location, work to be done, equipments to be used at the site.

A CHECKLIST SECTION

The checklist section verifies if a joint site inspection was done, how equipment must be prepared for work, what protective equipment is required, and if a fire watch or standby man is required, etc.

ADDITIONAL PRECAUTIONS

The additional precautions section is used to list precautions not included in the checklist section.

GAS TEST

In this section, the certified gas tester records his test readings using a three-in-one gas monitor where required.

SPECIAL CONSIDERATIONS

Issuer's signature Receivers signature

Extending or closing details of the permit...

Regards,

Kesava Pillai

Dear Abhay,

Regret the late reply.

Is a work permit required for the sign-off of a safety officer (if there is only one safety officer in the organization, what should be done if he is on leave)? It is a controversial question.

The permit should only be signed by the competent person. For safety, a Competent Person is one who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees. This person must have absolute authority, responsibility, and accountability to take prompt corrective measures to eliminate these hazards. This individual manages the affairs of the section, typically a supervisor, foreman, department head, engineer, or manager.

The safety officer, poor fellow, does he have absolute control over the affairs of the department? The answer is "NO." Therefore, he cannot issue a permit to work in an area that is not under his absolute control. However, to ensure that the Safety Officer is aware of and monitoring every permit work, he can be made a co-signatory. He can also be made responsible for endorsing any additional safety precautions, but he cannot issue a permit on his own.

For routine maintenance work, is a work permit required? Is there a sample format available? Imagine electrical workers performing routine maintenance on power lines or someone working on a conveyor in a remote corner far from controls! If absolute safety cannot be assured with normal work procedures, then "YES," even routine maintenance work requires a permit.

Who is the authorized person to sign the permit according to the standard system? Only the competent authority who has absolute authority, responsibility, and accountability at the location.

Hope this provides you with the desired clarification.

Regards,

Kesava Pillai

Kindly find the attached OISD-105.

Regards

Hi Kesav Sir,

I was just waiting to read your answer regarding question No. 4. Thanks for the same. Now, I can also refer to your words to anyone who is insisting on the safety officer's sign in the work permit.

Hi Neeraj4all,

Thanks a lot for posting the entire standard. I hope that now, if anyone goes through this thread concerning Work Permit, there is no need to refer to anything else. Everything is here - Standard, Procedure, Training Material, FAQ, etc.

Thanks to all for the great participation and making this section lively. I look forward to the same in the future.

Regards,
Dipil Kumar V

Dear Amish,

I think you need a lockout/tagout permit. Please see the attached.

Thanks & be safe,
Raghu

Dear All,

We had a very good discussion on Work Permits so far in the forum. I need to clarify one more thing on this matter. What should be the retention period of any Work Permit? How many days do we have to keep the cancelled permits? Is there any provision in the Factories Act or Rules regarding the same?

Hope to get clarification from the forum members.

Regards,
Dipil Kumar V

Thank you for your nice contribution. This document is really good. As per our new corporate guideline, we are supposed to keep the Work Permits copy for seven days after work. Since there are no specific guidelines in any act, I believe it varies from organization to organization.

Thanks, dear Dipil. That was good. I also found another comprehensive lifting permit to work. It can be useful.

I would like to share the following, which may help solve some existing issues:

Factory Act of 1948: Types and Use

The requirements of the work permit system are mentioned in Rule No. 172 of the Gujarat Factory Rules.

Work Permit and Safety Officer's Role

Is a work permit required to be signed by the safety officer (if there is one safety officer in the organization, what should be done if he is on leave)? The signature of the safety officer is not required on the work permit. The responsibility lies with the person issuing the work permit to ensure safe working conditions. The work permit serves as a checklist and authorization to ensure the work site is free from any potential hazards or accidents, and that safety precautions are being followed. Work permits are typically issued by the area in charge where the work is to be carried out. The safety officer may verify if the work permit guidelines are being followed during his inspection of the area. Different companies define the role of a safety officer differently based on the structure of the safety department and the maturity of the safety management system. If the safety officer has specific responsibilities for this task, then another competent individual can fulfill this role.

Work Permit for Routine Maintenance Work

Is a work permit required for routine maintenance work? Is there a sample format available? A general work permit may be used for routine maintenance work (cold work only), ensuring that general safety provisions are adhered to during the work.

I hope this information adds value to what has been discussed by all.

Thanks and regards,

Lokesh Khandelwal

In the organization, the Permit Issuing Authority is a separate section. Only the safety officer will cross-check the permit system.

For daily routine (normal work), no permit is required to perform the job. However, if departments wish to obtain a permit for a job, there are no restrictions.

Regards,
B.K. Mishra

I missed discussions in this thread. I have read the complete conversation. I have seen that most of the industries have permit systems to ensure compliance. I fully agree with Mr. Pillai that this has to be followed in spirit. This is to be followed in the true sense for communicating hazards, ensuring proper equipment, and PPEs.

While investigating an accident at one of our vendor's workplaces, the permits were issued, but none of the conditions in the permit were followed. There is no use of such systems. The work permit system should be viewed as a "proactive means to identify hazards and to mitigate adverse consequences of these hazards."

Very good discussions on this thread.

Thanks & Regards,
Sudhir

I am interested in the safety field and I want to know some basic things related to safety.

1) How many types of work permits are there as per the Factory Act?
2) What is the limit of noise in an industry as per the Factory Act?
3) What is the limit of illumination in an industry as per the Factory Act?
4) What topics are covered in toolbox talks?
5) Various types of safety training topics.
6) How to improve or gain knowledge of the Factory Act.

Dear all,

Kindly share the general Permit to Work (PTW) Excel format for all general activities.

Dear All,

Could you please send me a common work permit format that includes all activities such as height work, hot work, confined space entry, excavation, and chemical handling jobs?

Please send me this format if you have it.