Contractor shutdown: permit conflict and simultaneous operations
A specialty chemicals site plans a 10-day shutdown. A mechanical contractor will bring 18 workers to remove and replace a reactor's internal baffles. The contractor has submitted a 40-page risk assessment and method statement and its own permit-to-work form. The site's permit system requires isolation and gas testing by site operations, but the contractor's supervisor says his workers are 'competent and have done this at other plants' and wants to start early on Saturday when site supervisors are thin. Two other contractors will be hot-working nearby. The reactor last contained a flammable solvent; cleaning records are incomplete. The contractor's insurance certificate expired three weeks ago. The site has a single gas detector, currently out for calibration.
1. Allocate health and safety responsibilities between the site and the contractor, and identify the contractor-management failings evident in the setup.
Read the worked answer
Responsibilities are shared but not interchangeable
The site controls the premises, the plant, the isolation and the permit-to-work system. It must provide a safe site, site-specific induction, information on hazards, isolation and gas testing by authorised site personnel, emergency arrangements, and supervision of contractor interfaces. The contractor controls its own work, competence, supervision, method statement, tools and workforce. The contractor cannot simply adopt its own permit form for site plant; the site's permit system governs work on the site's equipment.
Failings evident
- Expired insurance is a pre-qualification failure. The contractor should not start until insurance is verified; this is a commercial and assurance control, not a substitute for safety control.
- A 40-page RAMS is not evidence of quality. It must be reviewed against the actual reactor, the cleaning status and the simultaneous operations.
- The contractor's own permit form is inappropriate for site plant. It may supplement, but the site permit and isolation certificate must control the work.
- The 'we have done this before' argument is not competence evidence for this site. Competence must be verified for the task and the plant.
- Start-up on Saturday with thin supervision is a deliberate weakening of control at the highest-risk moment.
- Incomplete cleaning records mean the reactor must be treated as potentially contaminated until proven otherwise.
- Single out-of-calibration gas detector means gas testing cannot be relied on.
The site manager remains accountable for the interface and must not delegate that accountability to the contractor.
2. Identify the permit-to-work and simultaneous-operations conflicts, and specify the controls that must be in place before work starts.
Read the worked answer
No permit, no entry
Permit conflicts
- The contractor wants to use its own permit form while the site requires isolation and gas testing by site operations. There must be one controlling permit for the reactor entry, issued under the site system, with the contractor's method statement attached as a supporting document.
- The permit must record the isolation boundary, lock-off, drain/vent/purge, gas test results, entrants, standby person and rescue arrangements.
- The permit must not be issued until the gas detector is calibrated or a calibrated replacement is available, and until cleaning status is verified by sampling or other evidence.
Simultaneous-operations conflicts
- Hot work nearby creates ignition risk if the reactor contains, or may contain, flammable solvent residue. The hot-work permit and the reactor-entry permit must be coordinated; one should not proceed if the other creates an unacceptable risk.
- Other contractors nearby create traffic, dropped-object and emergency-response interactions. The site must control the sequence and separation, not leave it to the contractors.
Controls before start
- Verify insurance and competence; complete site induction for all 18 workers.
- Review the RAMS against the actual plant and cleaning records; resolve gaps.
- Issue site isolation and gas-test certificates; use a calibrated detector and record results.
- Issue a site permit for reactor entry with a named authorised person and standby.
- Coordinate hot work: fire watch, area clearance, permit suspension if gas is detected.
- Confirm rescue plan and emergency arrangements for reactor entry.
- Ensure adequate site supervision on Saturday; if not available, do not start.
3. The contractor says delay costs £8,000 a day. Advise the site manager on the decision.
Read the worked answer
Cost is a factor, not a justification
The site manager should not authorise start-up until the controls above are in place. The £8,000 a day is a real commercial pressure, but it cannot justify accepting an uncontrolled flammable-atmosphere or confined-space risk. Under risk-based reasoning, cost may be weighed when deciding whether a control is reasonably practicable, but it does not permit ignoring a known serious hazard. The decision should be recorded with the reasons.
Practical advice
- Authorise only work that can be safely done now, such as site induction, document review, isolation planning and cleaning verification. Do not authorise reactor entry or hot work.
- Obtain a calibrated gas detector or a verified calibration service before entry; if unavailable, the entry work waits.
- Sequence the shutdown so non-hot work and cleaning verification proceed first, reducing the delay without exposing workers.
- Require adequate site supervision; a Saturday start with thin supervision is not acceptable for this task.
- Escalate the insurance expiry and detector issue to the site's management so the commercial and safety decisions are made at the right level.
The site manager should tell the contractor plainly that the delay is caused by unmet controls, not by obstruction, and set a clear date when the missing items will be resolved. That is both a safety decision and a defensible business decision.