Working on energised plant
Maintenance and repair workers are involved in 60% of Victoria's plant-related injuries and fatalities. This page has guidance which can help employers eliminate or control risks to persons performing maintenance or repair work on energised plant.
What is energised plant
Energised plant is plant that functions through the use of energy. Energy can remain in an item of plant after the isolation of energy sources. Energy that remains in plant following isolation is known as stored energy and includes:
- electricity, including mains, solar and generator
- heat
- steam
- fluids under pressure, such as water, air or hydraulic oil
- stored energy such as batteries, accumulators, capacitors, springs and flywheels
- gravity
- radiation
- static, kinetic, rotational and potential energy
Performing maintenance or repair work on energised plant has significant risks. Employees and contractors will be exposed to health and safety hazards such as electric shock, burns, cuts and crush injuries if stored energy in an item of plant has not been properly isolated or otherwise controlled.
Plant should be isolated, locked out, tagged out and, where reasonably practicable, de-energised before work starts. WorkSafe has guidance on its website about isolating, de-energising, locking out and tagging out plant.
If a hazard assessment has confirmed plant must have energy during maintenance or repair work, employers should have systems in place to ensure the work can proceed safely. The guidance on this page can help employers put those systems in place and reduce risks from working on energised plant. This information may also benefit managers and supervisors, employees, health and safety representatives (HSRs) and maintenance and repair workers.
Note: Guidance on this page does not cover work on electrical systems such as high-voltage power lines and generators. Guidelines for those tasks are available on Energy Safe Victoria's website.
Employer duties for work on energised plant
Employers have a duty to provide and maintain a safe working environment. As an employer, you should thoroughly assess whether the plant must be energised while work takes place. Wherever reasonably practicable, work on energised plant should be avoided. A series of steps later in this guidance can help you ensure that only essential repair and maintenance tasks take place on energised plant.
Information, training, instruction and supervision
As an employer, you must provide information, instruction, training and supervision to persons undertaking maintenance and repair work on energised plant so they can perform the work safely and without risks to their health. Workers must receive training in order to maintain competency in safe systems of work and be able to competently identify the plant's energy sources, range of movement and energy controls. Workers should also have the skills and knowledge to assess hazards, control associated risks and perform their work safely.
Consultation with employees
You must consult with employees, any HSRs for the designated area and contractors when:
- identifying or assessing hazards or risks to health and safety at your workplace
- making decisions about the measures to control identified risks to health and safety
- making decisions about procedures for resolving health and safety issues
- proposing changes to the workplace, the types of plant, substances or safe work practices performed at the workplace
Identifying hazards and controlling risks
As an employer or self-employed person, you have a duty to identify and eliminate hazards and risks, so far as is reasonably practicable. If you cannot eliminate risks you must control risks, so far as is reasonably practicable, to ensure work on energised plant can take place safely.
The hierarchy of control
The hierarchy of control can help you control risks associated with working on energised plant. The hierarchy of control ranks methods of controlling risks, from the highest and most effective level of protection to the lowest and least effective.
The following steps show how to use the hierarchy of control to eliminate or control risks from 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.
Permit to work
Employers must provide appropriate permit to work systems for plant exposed to an electrical hazard. Permit to work systems help avoid accidental energising of plant that has been isolated and locked out and tagged out but not physically disconnected from the electrical supply and de-energised.
Before issuing a permit to work you should have developed an effective safe system of work and put in place appropriate risk controls to control the identified hazards.
You should issue a permit to work once all risk management steps have been confirmed as complete and it has been determined that the work can be undertaken safely. A permit to work should include details about the type of work to be done, the hazards that have been identified and the risk controls put in place so the work can take place safely.
WorkSafe's checklist for working on an item of energised plant includes a permit to work procedure and is available on the WorkSafe website.
Steps to follow before performing any work on energised plant
If it is necessary to work on energised plant, all energy sources must be properly controlled before maintenance and repair tasks are carried out. You must perform an assessment to determine that the necessary risk controls are in place and that the work can proceed safely.
As an employer, you should apply the following risk management steps before allowing any maintenance or repair work on energised plant:
Assess that work can be done safely
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.
Review regularly
It is important to regularly review and update hazard and risk controls for work on energised plant. Employers must review and, if necessary, revise the hazard and risk controls:
- before any alteration to the plant
- before any change to the way the plant is used or its associated systems of work, including a change in the item of plant's location
- if new or additional information about hazards or risks relating to the plant or its systems of work becomes available
- after a notifiable incident involving the plant or its associated system of work
- if, for any other reason, the risk controls do not adequately control the risks
- after an appropriate request from an HSR
You should also review your hazard and risk controls and make sure they are appropriate before using an item of plant for the first time.
Standards Australia
Standards Australia provides Australian Standards information relating to the safety and reliability of a range of products. The following Australian Standards may be of benefit when identifying and controlling risks from working on energised plant:
- AS/NZS 40204.1204:2019: Safety of machinery – Electrical equipment of machines – General requirements (IEC 60204-1:2016 (ED. 6.0) MOD)
- AS 4024.1-2014 Series - Safety of Machinery
- ISO 12100:2010 Safety of machinery - General principles for design - Risk assessment and risk reduction