Understanding Safety: Safe Systems of Work

There are two elements to this. The first refers to more general controls that are expected to be in place so that activities can take place safely and it is this that is covered in legislation, but there is a second interpretation to this term. In more recent times, we have seen the development of control of work systems that combine the risk assessment component with the permit to work and isolation procedures, but these are focused on high-risk activities only. In effect, the control of work process is a type of safe system of work for the management of high-risk activities.

The legal framework

The legal framework that requires an employer to have in place safety systems of work is based upon the general requirements of the Safety, Health and Welfare at Work Act, 2005, specifically in Section 8 of Part 2, General Duties. Section 8(2)(e) states that one of the general duties of employers is “…providing  systems  of  work  that  are  planned,  organised, performed,  maintained  and  revised  as  appropriate  so  as to be, so far as is reasonably practicable, safe and without risk to health;” 1

Safe systems of work are also mentioned elsewhere in the 2005 Act, importantly in the General Principles of Prevention, firstly in clause 4 which states that “The adaptation of work to the individual, especially as regards the…choice of systems of work, with a view, in particular, to alleviating monotonous work and work at a predetermined work rate and to reducing the effect of this work on health.” and then in clause 6 which references “The replacement of dangerous articles, substances or systems of work by safe or less dangerous articles, substances or systems of work”. 2

Whilst permits to work is not explicitly referenced in the 2005 Act, it is implied as a component of a safe system of work if risk assessed. It is an explicitly required control in several sections of the Safety, Health and Welfare at Work (General Application) Regulations. 2007, as amended such as in clause 173 of Section 8 – Explosive Atmospheres at Places of Work. Isolations are also mentioned in these regulations, specifically in clause 85 in Part 3 – Electricity.

The general requirements

As mentioned in the introduction, the term safe system of work has two meanings:

Safe systems of work – This general requirement would be the development of a safety management system that would include but not be limited to:

• • • Risk assessment techniques and methods suitable to assess its work activities and therefore tailored to the organisation’s risk profile.
    • Training to develop skill sets and competency.
    • Supply and maintenance of safe work equipment.
    • Procedures to provide instructions and guidance as to how activities are to be performed.
    • Communication between management and the workforce.
    • Managing change and recognising when change introduces risk.
    • Arrangement for the use and management of personal protective equipment.

The Control of Work (CoW) process –  This process is focused upon high-risk activities which are controlled using an electronic permit to work system. The most common hazardous work activities are hot work, confined space entry and working at height although there are many industry-specific specialised work activities that can be covered too, such a diver in the water (e.g. when underwater repairs on ships or platforms takes place), non-destructive testing using radioactive sources or work over the side (e.g. over the side of a ship at sea). The CoW process has three components:

• • • Risk assessment often referred to as hazard identification and risk assessment (HIRA).
    • Permit to work often referred to as a Work Control Certificate (WCC) in an Integrated Safe System of Work (iSSoW).
    • Isolation of equipment for the safe isolation and reinstatement of plant often referred to as an Isolation Control Certificate (ICC) in an iSSoW system.

The investment in the iSSoW process can be significant and therefore it is generally used by organisations with multiple sites that have a significant spectrum of hazardous activities, such as refineries, power stations, fuel storage depots etc. For smaller organisations, the ‘standard’ permit to work system will suffice as long as the three-component model is used too.

As a minimum requirement, all businesses need to have a safe system of work that is documented, either within a simple safety statement or in a more elaborate safety management system. The scope and scale of the appropriate safe systems of work will depend upon the identification, evaluation and analysis of risk that is present. The use of iSSoW systems requires significant technology and training investment over the long term and is only suitable for major high hazard industry sectors. Regardless of the approach taken, employees and contractors need to be informed and instructed in the system of work has been adopted.

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