RAMS and Permit to Work: Which Document Does What

What is the difference between a RAMS and a permit to work?

A RAMS plans the work before it starts; a permit authorises one specific task, in one specific place, for a stated period, and is closed when that task ends. The RAMS is written once for the job. The permit is issued and cancelled repeatedly while the job runs.

HSE puts the discipline plainly in HSG168, Fire safety in construction: a permit "should be issued for clearly defined pieces of work with a specified time period and should end once the activity at that location is complete and/or the time period has ended", and permit documents "should not give blanket authorisations to carry out hot works anywhere on site at any time".

That sentence is the whole boundary. A RAMS that says hot works will be controlled by permit has described an arrangement. A permit says that this cut, on this beam, in this bay, between these hours, has been authorised by a named person who checked the conditions this morning. Neither substitutes for the other, and the failure that shows up most often in review is a RAMS that has quietly been written as though it were the permit.

Does UK law require a permit to work?

There is no general legal duty to operate a permit to work system on a construction site. What the law requires is a safe system of work, and for certain classes of work a permit is how HSE guidance says that system is normally delivered.

The specific instruments are worth knowing by name, because each one bites differently.

Electrical work. Regulation 14 of the Electricity at Work Regulations 1989 prohibits work on or near a live conductor where danger may arise unless it is unreasonable for it to be dead, it is reasonable to work on or near it live, and suitable precautions are taken. HSE's HSG85, Electricity at work: safe working practices, sets the dead working sequence and places the permit at step seven, after isolation, proving dead and earthing. HSG85 is emphatic about what an electrical permit is not: "You must never issue an electrical permit-to-work for work on equipment that is still live or to authorise live work."

Confined spaces. Regulation 4(1) of the Confined Spaces Regulations 1997 prohibits entry "unless it is not reasonably practicable to achieve that purpose without such entry", and regulation 4(2) requires that where entry does occur it is in accordance with a system of work which renders the work safe. HSE's HSG150, Health and safety in construction, states the position for construction: "There should be a safe system of work for operations inside confined spaces. Everyone should know and follow the system. A permit-to-work system may be required." L101, the Approved Code of Practice for confined spaces, ties the permit to specific acts, including securing isolation: locking off the switch and formally securing the key in accordance with a permit-to-work until access no longer needs controlling.

Hot works. HSG168 states it directly: "Where you cannot avoid hot works use formal systems of management, such as a permit-to-work (PTW) system." It adds the control that actually prevents fires, which is not the paperwork: a continuous fire watch of the hot work area for at least an hour after the end of hot work, followed by at least one more check two hours after the end.

Underground services. HSG47, Avoiding danger from underground services, deals with cables that must be made dead before work proceeds and notes that when work can proceed safely only after a cable has been made dead, "A permit-to-work system may assist in managing this process", with the parties continuing to liaise until workers are clear and before the circuit is re-energised.

General permit systems. For a full permit system covering many activities and hazards, the reference HSE names is HSG250, Guidance on permit-to-work systems: A guide for the petroleum, chemical and allied industries. HSG85 draws the distinction explicitly: an electrical permit differs from those broader systems, and "it is common for the requirement for an electrical permit-to-work to be identified through the application of a general permit-to-work system".

Note what that last point means for a construction site. The general permit system is usually the principal contractor's, established by the construction phase plan under regulation 12(2) of CDM 2015 as part of the site rules. The trade-specific permit is issued inside it. A subcontractor's RAMS that invents its own permit regime, parallel to the site's, has created two systems where one is needed.

Which jobs need a permit?

The honest answer is that the site rules decide, and the site rules should be built from the categories where HSE guidance points to one. The table below is the set our review checks treat as permit-bearing, with the source for each.

Work	Why a permit	Source
Work on or near live conductors, and dead working on electrical systems	Live work prohibited unless three conditions met; permit is step seven of the dead working sequence	EAWR 1989 regulation 14; HSG85
Entry into a confined space	Entry prohibited unless unavoidable, then only under a safe system of work	Confined Spaces Regulations 1997 regulation 4; L101; HSG150
Hot works: welding, cutting, grinding, torch-applied roofing	Formal management system where hot work cannot be designed out, plus the fire watch	HSG168
Work requiring a cable to be made dead	Managing the interval between making dead and re-energising	HSG47
Excavation near buried services	Prevention of risk from underground services is a duty in its own right	CDM 2015 regulation 25(4); HSG47
Work near overhead power lines	Passage under a line controlled through defined crossing points	CDM 2015 regulation 25(2); GS6
Access to a fragile roof	Access prohibited except under controlled conditions	HSG33

One of those is not a permit in the strict sense and deserves the distinction. Overhead lines are controlled by physical arrangements rather than by a piece of paper: GS6 says you should manage the risks if you intend to work within 10 metres measured at ground level horizontally from below the nearest wire, that a safety zone should extend 6 metres horizontally from the nearest wire on either side, and that where plant must pass beneath the line you define a passageway and "erect goalposts at each end to act as gateways using a rigid, non-conducting material". The Energy Networks Association exclusion zones GS6 cites are 1 metre for a low voltage line, 3 metres for 11 kV and 33 kV, 6 metres for 132 kV, and 7 metres for 275 kV and 400 kV. A permit that authorises a crane into a zone those numbers exclude is a permit issued against the guidance rather than in accordance with it.

The fragile roof row is worth quoting because the guidance names the regime rather than merely implying it. HSG33, Health and safety in roof work, says a risk assessment made under the Management of Health and Safety at Work Regulations 1999 "is likely to require signs warning of the hazard and prohibiting access except under controlled conditions (eg governed by a permit-to-work regime)", and separately that where material has been applied that may disguise fragile parts, the fragile parts should be marked and the information recorded in the health and safety file and in any permit-to-work system for the roof.

What must a RAMS say about the permit?

Four things, and a RAMS that names a permit without them has named an intention rather than a control.

Who issues it. HSG85 is precise about the electrical case, and the principle generalises. A permit should be issued only by a designated competent person "who has been assessed to be so by means of technical knowledge and/or experience and who is familiar with the system and equipment", and that person should be "authorised, in writing, by the employer to issue safety documents". If your RAMS does not name the role that issues the permit, nobody on site knows who to ask, and the default is that the work starts anyway.

What triggers it. Which step in the method cannot begin until the permit is in hand. A permit referenced in the introduction and nowhere in the sequence is not connected to the work.

What it covers. HSG85 lists what an electrical permit should record: the points of isolation, where conductors are earthed, where warning notices are posted and special safety locks fitted, the nature of the work to be carried out, "the presence of any other source of hazard, with cross-reference to other relevant permits", and further precautions to be taken during the course of the work. Cross-reference to other permits is the item most often missing, and it is the one that matters on a site where three trades are working on the same system.

How it is closed. Who cancels it, what has to be true before they do, and who confirms the crew is clear. HSG47's point about re-energising a cable is the general case: the parties involved should continue to liaise to ensure work is completed and workers are clear before the circuit is re-energised. A permit with no closure step leaves an isolation that nobody has taken responsibility for restoring.

HSG85 adds one more control that is worth importing into any permit regime, because it addresses the situation small firms are actually in. If the person issuing the permit will also be doing the work, "it is strongly recommended that someone else makes an independent check of the precautions taken", and the person doing the work should then issue a permit to themselves. That is not bureaucracy. It is the recognition that the check and the work should not be the same act of attention.

What does a permit assert, and what does it not?

An electrical permit is, in HSG85's words, "primarily a statement that a circuit or item of equipment is safe to work on: it has been isolated and, where appropriate, earthed". It is a statement of fact about a physical condition at a moment in time, made by somebody who verified it.

That is why HSG85 recommends the permit is issued at the place where the work is being done, with the issuer explaining the work and agreeing the accuracy and completeness of the details with the person doing it before both sign, and why "as a general rule, a personal inspection should be made". A permit issued from the site office describes a condition the issuer has not seen.

What a permit does not assert is that the method is sound, that the crew is competent, or that the risk assessment covered the work. Those are the RAMS's job. The permit only says: at this hour, this thing is in this state, and you may proceed on that basis.

The corollary catches people out. HSG85 requires that if a programme of work must change, the existing permit is cancelled and a new one issued before any variation is made, and the only person who can do that is the issuer or a nominated successor. A permit is not adjustable in the field. If the work changes, the authorisation is void.

Why do reviewers reject the permit section of a RAMS?

Because it is written as a hedge rather than as an act. The most common wording in a submitted RAMS is some version of "a permit to work will be in place where required", and it fails on both halves of the sentence.

"Will be in place" names no issuer. "Where required" names no trigger. Together they describe a control that nobody is assigned and nothing initiates, and the residual risk score in the register beside it is resting on that sentence.

Our review checks are built to catch exactly this shape. One asks whether somebody could carry out each stated control as written, and treats it as a failure when the control is a hedge rather than an act: "consideration given to", "where possible", "as required", "wherever practicable". Another sets its severity floor at critical and asks whether every step touching energised, pressurised or stored-energy equipment names isolation, proving dead, or a permit. A step that has none of the three is a stop-the-work defect regardless of what the document says elsewhere about competence and PPE.

The three failures that recur, in the order a reviewer meets them:

The permit is named and never triggered. It appears in a list of controls at the front and no step in the method waits for it. The method reads as though the work proceeds continuously.

The permit is the control. The register lists a serious hazard and the control column says "permit to work". A permit is an authorisation mechanism, not a physical control. What makes the work safe is the isolation, the proving dead, the gas testing, the fire watch. The permit records that those were done. A row that puts the permit in place of the measure has substituted the receipt for the act.

The permit belongs to nobody. No issuer role, no authorisation in writing, no closure step, no cross-reference where two permits touch the same system. On a job with one crew, that is survivable by proximity. On a site where three firms are working on the same distribution board, it is how somebody gets a shock from a circuit that another trade re-energised.

How permits and the construction phase plan fit together

The permit regime belongs to the site, and the construction phase plan is where it is established. Regulation 12(2) of CDM 2015 requires the plan to set out "the health and safety arrangements and site rules", and a permit system is a site rule in the plain sense: it binds everybody, including contractors who arrive later.

Regulation 13(3)(a) then makes the principal contractor responsible for organising cooperation between contractors, including successive contractors on the same construction site. Permits are the sharp end of that duty, because they are where one firm's isolation becomes another firm's hazard.

Practically, that means three things should be settled at the plan rather than in each RAMS: which categories of work require a permit on this site, who holds authorisation to issue each category, and how permits are registered so that a second issuer can see the first one. A subcontractor's RAMS should then reference the site's regime rather than describe a private one. See who writes a RAMS and who approves it for where the duties divide.

Frequently asked questions

Is a permit to work a legal requirement in the UK? Not in general. No statute imposes a blanket permit duty on construction. The duty is a safe system of work, and for confined space entry, electrical work, hot works and work involving cables made dead, HSE guidance points to a permit as the way that system is delivered: HSG150 and L101 for confined spaces, EAWR 1989 regulation 14 with HSG85 for electrical work, HSG168 for hot works, and HSG47 for cables.

Can a RAMS replace a permit to work? No. The RAMS plans the work in advance; the permit records that specified conditions were verified immediately before a specific task, by a named person, for a stated period. HSG168 makes the point that permits should not give blanket authorisation, which is precisely what a RAMS used as a permit would be.

Who can issue a permit to work? A designated competent person authorised in writing by the employer, familiar with the system and equipment. HSG85 sets that standard for electrical permits and requires the issuer to work out in detail and in writing the steps to disconnect, isolate, prove dead, lock off, earth, post warning notices and identify both the equipment being worked on and the adjacent equipment that stays live.

Do I need a permit for every confined space entry? Regulation 4 of the Confined Spaces Regulations 1997 requires that entry only happens where it is not reasonably practicable to do the work without entering, and then only under a safe system of work. HSG150 says a permit system may be required. Whether one is depends on the specified risks present, but where isolation, gas testing and a rescue arrangement are involved, a permit is the normal way of confirming all three were in place at the moment of entry.

Does a permit transfer liability to the person who issued it? No. It records that a named person verified a stated condition. Regulation 15(2) of CDM 2015 keeps the duty to plan, manage and monitor the work with the contractor carrying it out, and section 40 of the Health and Safety at Work etc. Act 1974 puts the burden on the accused to prove that it was not reasonably practicable to do more than was in fact done. A permit is evidence in that argument, not a transfer of it.

How long should a permit last? As long as the defined piece of work and no longer. HSG168 requires a specified time period and closure once the activity at that location is complete or the period has ended. HSG85 requires that a change of programme cancels the permit and a new one is issued before any variation is made.

Where this leaves the two documents

A permit is a record that somebody checked a physical condition and said so. A RAMS is a record that somebody thought about the work before anybody was standing in it. Both are receipts, and a receipt is only worth what the reader can verify.

About the author

Dylan Squires is the founder of Tarian and a former Royal Engineers officer and site manager, SMSTS qualified, with delivery experience across UK civil engineering projects. He writes about the reasoning behind construction safety documents rather than the format of them.