Permit to work systems: hot works, confined space and excavation permits that stand up to audit

Most sites already run a permit to work system of some description; the question an audit actually tests is whether it does the job a permit is for, rather than standing in for one. A permit is not a record that an activity happened. It is the document that stops the activity starting until the specific conditions for doing it safely today, on this site, are checked and signed off by someone other than the person about to do the work. On hot works, confined space entry and excavation, where the regulations are explicit about what has to happen before anyone starts, that distinction is exactly what a reviewer or an HSE inspector is checking for when a permit lands on the desk.

What a permit to work system actually has to cover

CDM 2015 (SI 2015/51) places the general duty on the principal contractor, under regulation 13, to plan, manage, monitor and coordinate construction work for the whole of the construction phase. A permit to work system is one of the mechanisms that duty gets discharged through on the activities where getting it wrong kills people quickly: fire, asphyxiation or collapse. Nothing requires every site activity to carry a permit; a permit earns its place where a missed check or a changed condition turns into a fatality rather than a near miss. Hot works, confined space entry and excavation are the three that appear on almost every site permit register, and each is governed by its own regulations rather than by CDM alone.

What ties the three together is the shape of the control, not the hazard. A permit to work system that is actually working has four things in place regardless of which activity it covers: a named issuer who is not the person doing the work, a defined set of checks completed and recorded before the permit is signed, a stated validity period after which the permit lapses and has to be reissued, and a formal close-out that records the work finished and the area was left safe. A site that has the forms but not those four features has paperwork, not a permit system, and that is usually what a careful review finds first.

Hot work permits: the fire watch is the control, not the form

The Joint Code of Practice for fire prevention on construction sites, now at its 10th edition incorporating Amendments 1 and 2, is the industry document the insurance market and most client fire safety plans are built around, and it is where the detail behind a hot works permit comes from. HSE's own guidance, HSG168 Fire safety in construction, 3rd edition, sits alongside it as the document an inspector is most likely to be working from. Neither is a statutory instrument; the legal hook is CDM 2015's planning duty.

The permit itself exists to force a sequence, not to record one after the fact: combustible material cleared or protected within the working radius, a fire extinguisher at the point of work rather than at the nearest store, and a fire watch kept during the work and for a stated period afterwards, because the material that starts smouldering during a hot work task often does not catch until the operative has moved on. The commonest gap on a hot works register is not a missing permit; it is a permit correctly issued and then nobody owning the post-work watch, because the form treats the watch as a box rather than a named person's job with a time it ends.

Confined space entry permits: what the regulations actually ask for

The Confined Spaces Regulations 1997 (SI 1997/1713) set a narrower and more direct duty than CDM. Regulation 4 requires that entry into a confined space is avoided so far as is reasonably practicable; where entry cannot reasonably be avoided, the work must be carried out under a safe system of work that makes it reasonably practicable to do it without entering. Regulation 5 then requires suitable and sufficient arrangements for the rescue of a person in the confined space to be in place before entry starts, not improvised once something has gone wrong. HSE's L101, Safe work in confined spaces, 3rd edition 2014, is the Approved Code of Practice and guidance that sets out what those arrangements have to look like in practice: atmosphere testing before entry and, where the risk assessment calls for it, continuous monitoring throughout; a means of communication between the entrant and a dedicated attendant; and a rescue plan with the equipment to carry it out on site, checked and ready, rather than described in the method statement and assumed achievable if needed.

The permit's job is to be the point at which someone checks that regulation 5's rescue arrangements actually exist before authorising entry, not a record that a risk assessment was written earlier. A confined space entry permit signed without a rescue team, a tripod and winch or equivalent, and a tested means of raising the alarm already on site has not discharged regulation 5, whatever the risk assessment says is required.

Excavation permits: the permit to dig and the services check

CDM 2015's general requirements for construction sites cover excavations specifically at regulation 22, energy distribution installations, which is where the duty to locate and protect buried and overhead services sits, at regulation 25, and the duty to produce reports of inspection at regulation 24, with Schedule 3 setting out the particulars those reports have to contain. HSE's HSG47, Avoiding danger from underground services, 3rd edition 2014, and HSG150, Health and safety in construction, 3rd edition 2006, are the guidance documents reviewers and inspectors measure a dig against in practice.

A permit to dig earns its place by forcing three checks before the first bucket goes in the ground: the services drawing has been checked against the work, a cable avoidance tool and signal generator scan has actually been carried out and recorded rather than assumed from the drawing alone, and the excavation method has been agreed against the ground conditions found, not those assumed at tender. The inspection duty under regulation 24 and Schedule 3 then continues for as long as the excavation is open: at the start of every shift, and again after any event liable to affect its stability, such as a fall of material, damage to support, or a change in groundwater. A permit signed once at the start and never reissued against a changed condition is not evidence that regulation 24 was met on day four.

The register that proves the system is working, not just that forms exist

A permit register that lists every permit by number, shows which are open and which are closed, and is reviewed on a stated interval rather than only when someone remembers to, is what turns three separate forms into a system an auditor can trust. The review is where a permit left open on a finished job, or a pattern of permits issued without the independent check they should carry, gets caught before an incident investigation asks why nobody noticed.

What we would put in place before the next audit

The fix is rarely a new form. It is making sure the four features of a working permit to work system are present on the ones already in use: an independent issuer, a checklist that cannot be signed off blank, a validity period that expires, and a close-out someone has to complete. The Site Health & Safety Pack carries a full suite of permits, including the hot works permit, a confined space entry permit and a permit register with its own monthly review tab, and the Excavations & Confined Spaces Pack carries the permit to dig with its services drawing and CAT and genny record alongside the confined space entry permit, gas monitoring log and rescue plan it depends on. The free ITP is the lowest-risk way to see how we cite a current-edition standard before looking at either pack in full.