Benefits of using a control of work system in a manufacturing facility

Many plant managers and environmental, health and safety (EHS) professionals can manage regulatory requirements for dangerous environments more easily as part of a larger control of work system.

By Phil Molé April 4, 2023
Courtesy: VelocityEHS


Learning Objectives

  • How control of work helps companies meet major regulatory requirements and safety management goals.
  • The ways control of work reduces risks related to management of temporary workers and contractors.
  • How companies can use control of work to help build environmental, social and governance (ESG) maturity and operational excellence.

Control of work insights

  • By incorporating a control of work software system, facility workers and their managers can meet regulatory and safety requirements.
  • Companies can incorporate control of work systems to building and enhance an environmental, social and governance (ESG) program.

Many facility managers, plant engineers and environmental, health and safety (EHS) professionals know there are regulatory requirements for safe work practices and procedures for permit-required confined space entry or “hot work.” This includes welding, cutting, grinding, torching, brazing or other slag or spark producing activities. However, workers may not understand how these requirements fit into and are more easily managed as part of a larger control of work system. They may not realize the wider benefits of control of work for safety management which builds the foundation for environmental, social and governance (ESG) maturity.

What is control of work?

Control of work is an essential element of a comprehensive EHS management program that ensures hazardous work only occurs when safety preconditions are met. It also helps with management of multiemployer worksites by ensuring all temporary workers and contractors (as well as the staffing agencies and contractor providers who employ them) meet the organization’s qualifications and safety standards, support safe facility operations and align them with safety performance goals.

Companies with robust control of work programs can reduce risk and improve relationships with key stakeholders such as employees and contracted workers. It also provides an important building block for ESG maturity.

How control of work improves EHS management and regulatory compliance

An element of a control of work program is especially useful for managing the risks associated with high hazard activities is a permit to work (PTW) system. This formal documentation system establishes safe work practices and procedures to control when certain hazardous work tasks are performed, who can perform them, and the conditions and controls that need to be in place before work can proceed.

Systems involving spreadsheets and paper documents are often cumbersome and tedious; modern EHS software can simplify the process, improving efficiency and minimizing management time. The right software gives organizations all the benefits of an effective system without the headaches.

A PTW system can improve key areas of regulatory compliance and EHS management.

Permit-required confined spaces

Many workplaces have “confined spaces,” which are spaces big enough for a person to enter and work in but have limited means of entry and exit. Some confined spaces pose significant risks to the safety and health of employees who would work in them. In the U.S., the Occupational Safety and Health Administration (OSHA) requires employers to use a permit system for confined spaces that have one or more of the following characteristics:

  • It contains or has a potential to contain a hazardous atmosphere.

  • It contains a material with potential for engulfing an entrant.

  • It has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section.

  • It contains any other recognized serious safety or health hazard.

OSHA sets requirements for “permit-required” confined spaces at 29 CFR 1910.146 for general industry, and a similar standard at 1926.1206 for construction. These regulations define which confined spaces are “permit required” confined spaces and define the information that needs to be included in the permit. This includes the permit space to be entered, the date, the length of time the permit is valid, name of entry supervisor, methods of assessing air contamination hazards and more.

There is no specific European Union requirement for confined spaces, although Directive 89/391/EEC from June 12, 1989, covers all aspects of safety and health at a workplace and places a duty on employers to consider the specific characteristics of every workplace. A formal PTW system, even when not specifically required in a regulatory jurisdiction, is an effective way to limit and monitor access to hazardous confined spaces.

Controlling hazardous energy

The term “control of hazardous energy” refers to a process of protecting workers from unexpected startup of equipment that could release any form of energy such as electricity, heat, hydraulic energy or stored energy such as gravity, and other energy sources The system for managing control of hazardous energy is often known as lockout/tagout (LOTO), which involves both physical prevention of activating equipment as well as visual identifications, aka “tags,” indicating employees should not activate the equipment until the tags are removed.

In the U.S., OSHA has a regulatory standard addressing LOTO at 29 CFR 1910.147.

In Canada, there’s no specific regulatory framework for enforcing control of hazardous energy, although it’s considered an employer obligation and CSA Z460-13, which is based on ANSI/ASSP standard Z244.1-20 which establishes specific characteristics and requirements for lockout programs. In the United Kingdom, British Standard BS 7671 “Requirements for Electrical Installations” covers electrical installation and the safety of electrical wiring in domestic, commercial, industrial and other buildings, and in special installations and locations. It states “every employer shall ensure that, where appropriate, work equipment is provided with a suitable means to isolate it from all its sources of energy. Every employer shall take appropriate measures to ensure that reconnection of any energy source to work equipment does not expose any person using the equipment to any risk to their health or safety.”

None of these standards explicitly state employers should use a PTW system, but in practice, many employers do use one because it provides better assurance employees don’t activate dangerous equipment by accident.

Permit to work systems are crucial to general safety management

There are many job tasks, such as working at heights, where using a permit system could help mitigate risks of employees performing tasks without proper training, authorization or personal protective equipment (PPE) such as fall arrest or protection systems. Energized electrical work or troubleshooting may expose employees or contractors to hazardous energy when lockout-tagout is not possible. “Hot work” like cutting, welding and brazing is another slag or spark activities are often managed with hot work permits which are often driven by property insurance companies.

OSHA’s hot work regulations in the U.S. require a prework inspection and authorizations assuring the work is performed by a competent individual.
PTW is part of a proactive, risk-focused approach to safety management. As businesses move from a compliance-focused approach to a more mature approach based on employee engagement and best practices, this is why they tend to expand their use of control of work systems.

Managing temporary worker and contractor safety

Control of work systems are especially important in today’s workplaces, because “traditional workforces” are being supplemented by temporary workers and on-site contractors.

For example, temporary employment in manufacturing is much higher compared to other industries.

With contractors always entering and exiting workplaces, it can be challenging to track them, and even to know which specific individuals are on-site at any given time.

Consider this situation involving a Chicago Fire Department hazardous materials manager, who relayed a story about arriving at a chemical manufacturing facility in response to an emergency call. Upon their arrival, site representatives informed fire department first responders that contractors had been on-site working on some decommissioned chemical processing tanks, and while in the process of working, one of the contractors got trapped inside the tank.

While site representatives knew the person inside the tank was a male contractor — that’s all they knew. They didn’t know his name or what time he’d entered the tank. This real-life example highlights the horror of how badly things can go wrong when organizations lack efficient and effective control of work processes tracking who’s on-site, tightly controlling access to dangerous places and processes and ensuring everyone on-site has the right knowledge, pre-qualifications and competencies before starting work.

Formal control of work and PTW systems provide an effective communication framework that promotes collaboration and coordination between host and temporary employers and between host employers and contractors. This makes it easier to ensure all parties to the employment contract are aware of their obligations for worker safety and verify all necessary training, hazard controls, PPE and other job-specific precautions are in place before work. This understanding and communication are a crucial, yet often overlooked component of contractor and temporary worker safety, the lack of which has been shown to be a significant factor in temporary worker injuries and illnesses.

Modern control of work software is configurable to the specific PTW processes in place at the organization and helps manufacturers and employers across all industries manage complete contractor journeys and electronic permit-to-work processes across locations through a centralized system. Providing greater transparency, strengthening compliance with EHS policies and structuring the PTW system in a way that prompts workers to accurately complete permits helps electronic PTW systems can save significant time and headaches with day-to-day tasks while minimizing EHS risks.

Control of work helps build, sustain ESG maturity

Another major advantage of a control of work system is it helps organizations navigate the journey from EHS management to ESG maturity.

There are a couple of specific ways that control of work helps move the needle on ESG performance. The first pertains to shoring up the essentials of EHS management by giving better oversight of contractors and temporary workers and having a sustainable process for maintaining regulatory compliance. To build and sustain ESG maturity, companies first need to do EHS right. Think of ESG management in terms of a pyramid (see Figure 1). Without a solid foundation in EHS management, the peak of the pyramid, ESG maturity, will remain out of reach.

Another benefit of control of work is it helps build good stakeholder relationships. A stakeholder is anyone affected by, or who perceives themselves to be affected by, the business operations and who affects them in turn. The organization’s employees are stakeholders, but so are temporary workers and contractors.

Control of work improves communications with these stakeholders, which helps organizations maintain ESG programs and policies. Organizations may have great programs to avoid impacts to stormwater and wastewater, reduce wastes sent to landfill and avoid use of chemicals that pose hazards to workers, the community and the value chain. However, if contractors don’t know those policies, those sustainability efforts may be negatively impacted and the organization’s reputation will be damaged.

The stakeholder relationships that control of work helps build can then help organizations advance their ESG initiatives by identifying and focusing on the issues that matter most. The term for such an exercise is a materiality assessment, which is a stakeholder survey designed to assess the relative importance of various areas of ESG, such as greenhouse gas emissions or supply chain stability.

Contractors, for example, may have important insights into aspects of business they’d need to know about. Modern ESG software can then organize the survey results in the form of a materiality matrix, which ranks ESG issues as a function of impact and importance and shows the most significant issues in the top right corner (see Figure 2).

Putting everything together, a control of work system can help proactively reduce risk, help maintain regulatory compliance and protect employees, temporary workers and contractors. In a business environment where stakeholders demand higher levels of ESG accountability and performance, control of work can be an important part of the journey, helping organizations demonstrate proactive safety practices, improve value chain relationships and gain competitive advantages by building ESG maturity.

Author Bio: Phil Molé, MPH, EHS & sustainability expert for VelocityEHS.