Working on energised plant

Eliminating the risk is the most effective level of protection and the primary duty for an employer is to eliminate any risk associated with the plant, so far as reasonably practicable.

One way to eliminate the risks from working on energised plant is to replace plant with models that do not require maintenance or repair work while the plant is energised.

If it is not reasonably practicable to eliminate the risks associated with the plant, employers and self-employed persons must reduce the risks, so far as is reasonably practicable, by using one or more of the following:

Substitute the plant with plant that has a lower level of risk.

Isolate the plant from persons by locating it in an interlocked guarded or barricaded area and operate the plant from outside the guard or barricade.

Guarding and barriers are examples of engineering controls which can reduce risks. Such guards or barriers should also be interlocked where reasonably practicable to do so.

If a risk still remains you must reduce the risk, so far as is reasonably practicable, using administrative controls such as lockout and tagout systems. If you have complied with all of the listed risk controls and the risk associated with plant still remains, you must reduce the risk so far as is reasonably practicable by providing appropriate personal protective equipment to those at risk.

Identify all hazards that exist or may arise from working on energised plant

Find out what could cause harm, such as electric shocks, burns, cuts, crushing or impalement, while maintenance or repair work is underway on energised plant. There are many factors to consider when identifying hazards, including, for example:

• the task
• how the work will be done
• tools and equipment being used
• location to other work processes and other plant
• production processes
• walkways and pedestrian access
• employee and contractor interactions
• individual factors such as the background, knowledge and experience of those working on the plant
• the levels of instruction, training and supervision that might be required

Identify all hazards, including the 'not so obvious' hazards associated with working on energised plant, taking into account the current state of knowledge. Consult with employees and contractors who use the plant or will undertake the maintenance or repairs. They can provide vital information about the hazards associated with the plant.

Ensure hazardous zones are identified

Hazardous zones are areas where energy causes the plant or its parts to move, creating a potential for a cutting or crushing injury while a person is in the hazardous zone, or causes the release of energy into the zone that may result in an electric shock, burn or cut. These hazardous zones must be clearly marked on the plant or the area around the plant.

Avoid work in a plant's hazardous zone. If employees and contractors are not exposed to a plant’s hazardous zone, they will not be exposed to hazards associated with the energised plant.

Remember: Work on energised plant can only take place when it is not reasonably practicable for the task to be done on de-energised plant and only when it is safe for employees or contractors to do the work.

Break work into tasks and sub-tasks

Complete a detailed written assessment of each task involved in the work to confirm it cannot take place on de-energised plant.

Define each task, break the task down into sub-tasks and then assess each sub-task to identify all hazards posed by the task and the appropriate risk controls – see step 3. Use an assessment and risk control process to confirm that each sub-task cannot take place on de-energised plant.

If specific tasks such as testing and diagnostics must take place on energised plant, all hazards must be identified and appropriate risk controls put in place to ensure employees and contractors can undertake this work from outside the hazardous zones.

Ensure employees and contractors can work safely

If work must take place on energised plant, you must ensure it is safe for employees or contractors to do the work.

Make sure persons undertaking the task are aware of what the task requires, are competent to safely perform the work and are correctly supervised.

If the work must take place while the plant is energised, you must assess the available risk controls and consult with employees, contractors and HSRs during the assessment. Your assessment should include the degree to which the controls eliminate or reduce hazards to employees and contractors and whether the controls introduce new hazards which must then also be controlled.

A risk assessment should identify:

• the type of harm or injury that could occur because of the tasks
• the likelihood of harm or injury occurring
• the frequency that employees and contractors are exposed to the hazard
• the circumstances that could increase the severity of an injury or incident
• employee and contractor competencies to undertake the task on energised plant
• risk controls to be implemented that will enable the work to be undertaken safely

Work must not proceed on energised plant until you, the employer, confirm the task can be done safely and have issued a permit to work.

Work on energised plant should not proceed if the risk assessment has identified that it is reasonably practicable to work on the plant while it is de-energised.

Due to the hazards and higher levels of risk employees and contractors are exposed to when carrying out repair and maintenance work on energised plant, you should take a systematic approach to controlling the risks.

You must confirm it is safe for employees or contractors to do the work, that the persons undertaking the task are aware of what the task requires, are competent to safely perform the work and are correctly supervised.

You should also introduce a formal risk assessment process. Completing a formal risk assessment, keeping records of hazards and risk controls and reviewing operational and repair logs and maintenance schedules can help show your compliance with the Occupational Health and Safety Act 2004 (OHS Act) and Occupational Health and Safety Regulations 2017 (OHS Regulations).

You can eliminate or reduce hazards in the following ways:

• modify or replace the plant to eliminate the hazard
• interlock barriers and guards so access is only possible when the plant is de-energised and it is safe to enter
• ensure access areas do not take employees or contractors into hazardous zones
• redesign the task so the work can take place while the plant is isolated and de-energised

Engineering controls can help control risks when the employee or contractor is able to access the hazardous zone. Examples of engineering controls include:

• interlocked guarding to prevent access to moving parts that can crush or trap employees or contractors
• ensuring operational controls are used only by the person undertaking the task, while all other operational controls on the plant are disabled and locked out and tagged out
• interlocked de-activation of automatic sensors so that plant operation cannot be triggered while hazardous zones are being accessed
• control devices and systems designed so they cannot be bypassed

Work should only take place on energised plant when:

• a risk assessment has confirmed there is no other way to perform the  task and it is safe to do so
• the hazards have been identified and appropriate risk controls put in place
• employees and contractors with the necessary skills, knowledge and competencies have been identified, trained and assessed as competent to safely carry out the work
• the employer has confirmed the person authorised to supervise and enforce the safe work practice has the necessary skills and authorisation to enforce the safe work practice

Remember: Employers must control any risk associated with the use of plant in the workplace, so far as reasonably practicable. If the work can be done on de-energised plant, it must be done on de-energised plant.

The employer must ensure risk controls are reviewed, tested where possible and revised if necessary to ensure plant cannot injure employees and contractors.

If employees and/or contractors are injured while working on energised plant, the employer’s control measures are not appropriate. The employer must, so far as is reasonably practicable, ensure all hazards a person may be exposed to while working on plant have been identified.

Maintenance and repair work on energised plant can proceed only after the employer has confirmed all risks have been controlled and a permit to work has been issued.  Before issuing a permit to work, the authorised person must reconfirm it is safe for persons to do the work. Persons undertaking the task must be aware of what the task requires, must be competent to safely perform the work and must be correctly supervised.

The permit to work should be issued in writing and detail the:

• description of the task
• names of employees or contractors involved in carrying out the task
• equipment needed to carry out the task
• hazards and their risk control measures

WorkSafe's checklist for working on an item of energised plant has more information about permits to work and is available on the WorkSafe website.