Permits & RA: what SIRE 2.0 inspectors ask and find
Permits to work and risk assessments are checked for routine jobs as well as big ones, and the names on the permit must match who did the work.
Do this before the inspector arrives: Check permits and risk assessments exist for routine jobs too.
What the inspector wants to see
- Permit-to-work and risk assessment for routine jobs too: gangway rigging, work aloft, small jobs
- Names on the permit match who did the job
- Toolbox meeting records
Questions inspectors ask about Permits & RA
What controls are needed before taking SIRE 2.0 photos from height?
Photos taken from height (e.g. crane winch limit switch, windlass from the forward mast) need a work-aloft permit, risk assessment and LOTO in place.
What is needed for personnel transfer by basket?
A contingency plan for basket transfers, and training certificates that specifically say 'personnel transfer'.
What are the company's risk assessment requirements?
Be ready to show the list of tasks/scenarios for which a risk assessment is required.
What do inspectors look for in permit-to-work records?
Hot work, enclosed space and work aloft permits fully completed. Repeat gas readings must be recorded, and the person approving an enclosed space permit must not enter the space.
Which lists should be decided on the basis of a risk assessment?
The list of enclosed spaces, the mooring zone marking and the list of critical spares.
How does the new COSWP define working at height (aloft)?
Anyone working where there is a risk of falling may be regarded as working at height (COSWP 17.1.1).
There are 17 Permits & RA questions in NilObs, with spaced repetition so the ones you miss come back. Practise them free.
Real Permits & RA observations, and how to avoid them
No working-aloft permits were raised for the quarterly water mist nozzle test, which needed collection baskets rigged 4-6 m above deck.
Avoid it: Raise a working-aloft permit for any test or maintenance job above the company's height threshold.
Interviewee was not aware of the term SIMOPS (simultaneous operations).
Avoid it: Know what SIMOPS means and how the company controls simultaneous operations such as bunkering during cargo.
Interviewee could not state the height at which work-at-height controls apply and was unfamiliar with the precautions in the work aloft risk assessment.
Avoid it: Know the company's working-aloft height threshold and the key controls in the RA before starting the job.
Lock-out/tag-out records used generic terms such as 'hydraulic lock out' instead of naming the actual equipment isolated.
Avoid it: Name the specific equipment and isolation points on every LOTO record.
Procedures did not require a working overside/aloft checklist for routine rescue boat launches, and launch records showed none was used.
Avoid it: Use the working overside checklist for every rescue boat launch, including routine drills.
Interviewee could not explain hazardous energy types, the isolation steps or how to prove zero energy, despite recent training.
Avoid it: Know your LOTO steps: identify energy sources, isolate, lock, tag and prove zero energy.
Repairs to the incinerator refractory and an engine room damper valve were done without the cold work permit or LOTO; one engine rating on the job was not named on the permit.
Avoid it: Raise the cold work permit and LOTO for every repair and list every person working under it.
The SMS described lockout/tagout, but LOTO equipment had not been supplied; the crew were using placards and permits instead.
Avoid it: Make sure the LOTO equipment the SMS calls for is on board, and raise a requisition if it is not.
Who answers for Permits & RA
Master, Chief Officer, Chief Engineer, Second Engineer, Bosun, Pumpman, Fitter, Port Captain, HSEQ Manager, Designated Person Ashore, Other role. NilObs picks the questions and the daily drill for your role.
Rehearse Permits & RA before your next inspection.
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Other topics
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