A permit to work is not a legal requirement
Worth saying plainly, because most sites treat it as though it were. Nothing in UK law says issue a permit. HSE's permit guidance HSG250 is written for the petroleum, chemical and allied industries and carries the standard formula: following it is not compulsory, and you are free to take other action.
Permits are required by contracts, by principal contractors and, for hot works especially, by insurers. Those are real reasons with real consequences. None of them is a regulation, and knowing which is which is useful when somebody tells you the law says something it does not.
What the law does require, and it is not the permit
For confined spaces, the Confined Spaces Regulations 1997 require two things:
- Regulation 4. Nobody may enter or work in a confined space other than in accordance with a system of work that renders the work safe in relation to the specified risks.
- Regulation 5. Suitable and sufficient emergency arrangementsmust be in place before the work starts.
A permit can evidence the first. It is not a substitute for the second, and regulation 5 is the one that gets missed.
Which is why this tool stops
A confined space permit with the rescue arrangements left blank is refused here. Not warned about, refused.
Because that permit looks thorough. It lists the hazards, names the isolations, specifies the gas testing, sets out the PPE, and has two signatures on it. And it says nothing whatsoever about how somebody gets pulled out of a chamber, which is the only part of the document the law is unambiguous about.
Calling 999 is not a rescue plan. A fire crew is not arriving and getting somebody out of a tank before the atmosphere does for them, and the statistics on confined space fatalities are largely a record of people who went in after somebody else.
The window is the whole mechanism
Everything else on a permit is a condition. The expiry is what makes it a permit rather than a permission.
A permit valid "for the duration of the works" has controlled nothing: it has recorded that work is happening. The conditions it was issued against will not be the same tomorrow: the scaffold will have moved, the crew will have changed, somebody will have opened the thing you sealed. So this tool will not produce a permit without a start and a finish time, and it says so if the window runs longer than a shift.
The hand-back, on its own page
A permit that is never handed back is still live. The work is nominally still in progress, the area is still under the control of whoever accepted it, and nobody has confirmed that the isolations came out or the fire watch was kept.
That is how a second crew walks into a job that was never closed out.
So the PDF prints the hand-back as a separate page rather than a box at the bottom of the sheet. A page that has to be physically brought back and signed is harder to forget than a tick box on a document already folded in somebody's pocket. It lists what is being confirmed: everybody out, isolations dealt with, guards and covers reinstated, and for hot works, the watch kept for the full period with nothing smouldering.
The fire watch, and the hour that is not a law
Insurer codes commonly require a fire watch to continue for an hour after hot works stop. That is a policy condition, not a legal minimum, and the tool labels it as such, but it is not a soft requirement, because what you lose is cover.
Hot work fires are usually found an hour or more after the tools went away. Sparks travel, drop through penetrations, and sit in a cavity smouldering while everybody signs off and drives home. Which is why the watch needs both sides of a wall, and above and below a penetration, and needs to be somebody's named job rather than everybody's.
Nobody signs their own permit
If the person issuing and the person accepting are the same, the control has failed. The entire value of a permit is that a second person looked at the conditions before work started, so the tool marks both fields when the names match.
It is a warning rather than a block, because on a small job there genuinely may be nobody else, and in that case the honest thing is to know the control is weaker, not to be told you cannot work.
Six kinds, and the hazard behind each
Hot works, confined space, work at height, electrical isolation, ground disturbance and roof work. Choosing one shows you where that permit's authority actually comes from, right under the picker rather than buried in small print, because on four of the six the answer is that it does not come from law at all.
Alongside: a risk assessment for the task, the construction phase plan for the site, and a lift plan if anything is going on a hook. Nothing is uploaded and nothing survives closing the tab.
Common questions
Is a permit to work legally required?
No. Nothing in UK law says issue a permit. HSE’s permit guidance HSG250 is written for the petroleum, chemical and allied industries and says in terms that following it is not compulsory. Permits are required by contracts, by principal contractors and by insurers, all real reasons, none of them a regulation.
So what does the law actually require for confined spaces?
Two things, and neither is a permit. Regulation 4 of the Confined Spaces Regulations 1997 requires a safe system of work that renders the work safe in relation to the specified risks. Regulation 5 requires suitable and sufficient emergency arrangements to be in place before the work starts. A permit is one way of evidencing the first. It is not a substitute for the second.
Why will it not produce a confined space permit without rescue arrangements?
Because that is the one part of this whole document the law is unambiguous about. A permit that lists the hazards, the isolations and the PPE and says nothing about how somebody gets pulled out looks more thorough than it is, and regulation 5 is not satisfied by intending to call 999. So the tool stops rather than printing a permit with the important half missing.
Why does it insist on start and finish times?
Because the window is the entire mechanism. Everything else on a permit is a condition; the expiry is what makes it a permit rather than a standing permission. A permit valid "for the duration of the works" has not controlled anything: it has just written down that the work is happening.
Why is the hand-back on a separate page?
To make it harder to skip. A single sheet gets signed at the top, carried around all day and lost, and a permit nobody hands back is still live, the area is nominally still under the control of whoever accepted it, which is how a second crew walks into a job that was never closed out. A page that has to be physically brought back and signed is a harder thing to forget than a box at the bottom of a sheet already in a pocket.
Does it do Australian confined space entry permits?
Not yet, and deliberately not. The model WHS Regulations do require an entry permit for confined space work, but we have not read that provision directly and will not build a document on a half-checked one. This tool is UK only until that changes.