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HSG250 Compliance: What the HSE Says About Electronic Permits

Peter Henderson

11/02/2026

This article is part of a series on  Permit to Work systems . Read  'What is a PTW system and why is it important?  to learn more

 

Electronic permit-to-work (ePTW) systems can genuinely improve control of work, but only if they preserve (and strengthen) the safety-critical behaviours that paper systems are meant to enforce. The UK HSE’s core guidance on this is 'HSG250: Guidance on permit-to-work systems (first published 2005). It mentions both paper and electronic-based permit-to-work systems and provides some very clear examples of what the UK Government expect from a permit to work system.

Below is what HSG250 (and the HSE PTW Human factors website) effectively expect from an HSG250-compliant electronic permit system.

Permits are control-of-work, not admin

HSG250 is clear on a point that ePTW buyers sometimes miss: a permit is not simply permission to undertake a hazardous task. It’s part of a wider safe system of work and a communication tool. Safety comes from preparation, supervision and execution.

HSG250’s requirements for electronic permit systems

HSG250’s Electronic permits section is short, but it’s very specific about the failure modes you must design out. Before introducing an electronic permit system, HSG250 says operators must be sure that:

  • Unauthorised issue/acceptance is prevented (e.g. access control and secure e-signatures).
  • Permits cannot be issued remotely without a site visit
  • Issued permits can’t be altered without controlled communication to everyone affected.
  • Paper copies can be produced for display at the job site
  • Training is provided to ensure that workers the specific job and do not rely on cut-and-paste from existing permits
  • Resilience/back-up exists for software failure or power outage.

Don't just digitise the PTW form - design it carefully

On its permit-to-work human factors page, the HSE adds an especially relevant ePTW warning: if you’re moving from paper to electronic, assess the risks from the changeover, use good interface design, and train people in the PTW process, not just the software interface.

This is an acknowledgement of the fact that he UI can create new human error pathways (rushing, mis-selection, false confidence, autopopulated hazards, etc.) unless it is designed and implement carefully.

A practical HSG250 ePTW compliance checklist

Use this as a quick internal audit frame (and as evidence for stakeholders, external audits etc.)

1) Authorisation and identity

  • Role-based controls; secure authentication and signatures
  • Clear limits on who can authorise which permit types
    (Aligns with preventing unauthorised issue/acceptance.)

2) Site visit / remote issuing controls

  • Workflow forces site verification steps (and makes them auditable)
  • Rules that prevent “desk-issued” permits without verification
    (Aligns with “cannot be issued remotely without a site visit.”)

3) Change control on live permits

  • Versioning + audit trail
  • Mandatory re-brief / acknowledgement if anything changes after issue
    (Aligns with preventing alteration without communication.)

4) Job-site visibility

  • Simple, reliable display at point of work (print, kiosk, board, tablet view with offline mode)
  • People can easily see what permits are active in an area
    (HSG250 explicitly calls out producing paper permits for display.)

5) Competence and “copy/paste” risk

  • Training that focuses on hazard thinking and task specificity
  • System design that discourages lazy reuse (e.g, prompts that force reviewing controls)
    (HSG250 warns against relying on “cutting and pasting”.)

6) Business continuity

  • Defined fallback process for outages
  • Regular testing of backup arrangements
    (HSG250 requires suitable back-up systems for failure/power loss.)

The most common compliance gaps

A common reason organisations struggle to justify “HSG250-compliant” ePTW in practice is that the system is configured or used in ways that conflict with the specific safeguards which HSG250 says must be assured before introducing electronic permits.

One clear gap is permits being issued without the required on-site verification. HSG250 is explicit that permits cannot be issued remotely without a site visit, so any workflow or behaviour that allows desk-based issue without that visit is contrary to what HSG250 requires for electronic permits.

Another gap is uncontrolled changes to an issued permit. HSG250 requires systems to be in place to prevent issued permits being altered without the alterations being communicated to all concerned, so any ability to edit a live permit without a controlled communication step undermines the expectation HSG250 sets.

A further gap is generic, non-job-specific permits created through reuse. HSG250 requires training to ensure operators assess the specific job and do not rely on “cutting and pasting” sections from other permits, so heavy reliance on cloning or reusing standard text without re-assessment is directly at odds with that requirement.

Visibility at the point of work is another recurring weakness. HSG250 requires that the facility exists for paper permits to be produced for display at the job site, so an ePTW setup that cannot reliably produce and display the live permit information at the worksite fails to meet that stated expectation

Finally, resilience is frequently overlooked. HSG250 requires suitable back-up systems to be available in the event of software failure or a power outage, so an ePTW deployment without a defined, usable fallback arrangement does not align with what HSG250 says must be assured (HSG250 p24/40).Each of those maps back to an explicit HSE expectation: site visit discipline, good interface design + process training, job-specific assessment, effective communication/display, and resilience.

Closing thought

HSG250 doesn’t come out in favour of either paper or digital PTW. It says that a digital permit to work system is fine if you can prove it preserves the controls that matter: authorised people making job-specific decisions, verified at the worksite, clearly communicated to everyone affected, with strong change control and robust backup.

References

[1]: https://books.hse.gov.uk/gempdf/hsg250.pdf "Guidance on permit-to work systems - A guide for the petroleum, chemical and allied industries"
[2]: https://www.hse.gov.uk/humanfactors//topics/ptw.htm "Permit to work systems - HSE"

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