Which Permit-to-Work Do You Need?
Guide to the Permit-to-Work System

The fine for admitting a crew without a permit-to-work: from RUB 110,000 for the organisation (Part 3, Art. 5.27.1 of the Administrative Code). Repeat violation: up to RUB 200,000 or suspension of operations for 90 days (Part 5, Art. 5.27.1). Meanwhile, Order No. 776n of the Ministry of Labour describes 24 categories of hazardous tasks, each with its own rules, forms, and deadlines. Which permit to issue for a welder on a roof? For an electrician in a 10 kV switchgear room? What if both hot work and gas-hazardous activities are on site at the same time?

1. What is a permit-to-work

A permit-to-work (PTW): a formal written authorisation for high-hazard activities. The document specifies the scope, location, time and conditions of the work, the required safety measures, the composition of the crew, and the persons responsible for safe execution.

Starting hazardous activities without this document is prohibited. This is a direct requirement under Section 36 of Order No. 903n of the Ministry of Labour (17.12.2020). The fine for admitting a crew without a permit is from RUB 110,000 for legal entities under Art. 5.27.1 of the Administrative Code. A repeat violation can cost an HSE engineer disqualification for one to three years (Part 5, Art. 5.27.1 of the Administrative Code).

Based on Federal Labour Inspectorate (GIT) inspection experience, a significant proportion of permits contain errors. Common issues: work performer not identified, safety measures omitted, admitting person's signature missing. Each error is grounds for an order and a fine.

The indicative list of high-hazard work is established in Annex 2 to Order No. 776n of the Ministry of Labour (29.10.2021) on the Model Regulation for Occupational Safety Management (OSMS). This list is not exhaustive. Each organisation is required to approve its own list considering its specifics (Section 55 of the same Order). However, deviating from the baseline 24 categories without justification is not allowed.

Why is all this necessary? Not for bureaucracy. The PTW system forces you to think through risks in advance, rather than after an accident. It is the only document that links a specific person with specific safety measures at a specific workplace. No other document in Russian legislation serves this purpose.

At large enterprises (oil refineries, metallurgical plants) between 20 and 50 permits are issued per shift. At construction sites with multiple contractors the number can reach 100 per week. Each of these documents passes through the hands of several responsible persons, and an error at any stage leads to a fine or, worse, an injury.

2. When is a permit-to-work required

There is no single exhaustive list in the legislation. Order No. 776n contains an indicative list of 24 categories. Organisations approve their own lists, but cutting below the baseline is a violation.

How to determine if authorisation is required? A simple algorithm: open your organisation's list (it must be approved by order of the head). Work is on the list — issue a permit. No list? That is already a violation, and any hazardous work is formally being performed unlawfully.

The full list includes 15 more categories: tasks near power lines, in restricted zones, at operating facilities, with hazardous chemicals, and others. Each category is covered on a dedicated guide page.

3. Types of permits: full classification

Authorisations for different types of hazardous activities differ. Each type is linked to its own regulatory framework, and form templates also vary.

Can you get by with one document when different types of hazards overlap? A common question on sites. For example, a welder works at a height of 6 metres inside a vessel. Three categories intersect here: hot work, working at height, confined spaces. In this situation, as a rule, several permits are needed simultaneously.

In the oil and gas industry, up to 6 permits can be active simultaneously at a single site. Not an exception, but the norm.

4. Who issues the permit-to-work

Persons authorised to issue permits are appointed by order of the organisation's head. Without this order, issuance is unlawful. There are four roles in the PTW system. Each has its own authority and area of responsibility.

• Issuer. Head of structural unit or chief engineer. Determines: whether the work can be organised safely, what measures are needed, who will be in the crew. The issuer's signature is the work authorisation. If the issuer missed a hazard factor and an accident occurred, they are liable up to criminal responsibility under Art. 143, 216, 217 of the Criminal Code.
• Responsible work supervisor. Oversees the implementation of safety measures on site. Checks: barriers are installed, PPE is issued, briefings are conducted. If measures are specified in the permit but not implemented on site — this is their area of responsibility.
• Work performer (admitting person). Directly admits the crew to work at the prepared site. Conducts a targeted safety briefing, checks site readiness, signs the permit. In electrical installations, the admitting person must hold a safety admission group of at least III (up to 1000 V) or IV (above 1000 V).
• Crew members. Have undergone HSE training, received a targeted briefing, and signed the permit. Minimum composition: 2 persons (including the work performer). Solo work is prohibited.

Who can combine roles? It depends on the regulations. Under POTEU (electrical installations), the issuer can simultaneously be the responsible work supervisor. The work performer combines the admitting person's functions. But the issuer cannot be the work performer. For working at height (Order No. 782n), combining is restricted more strictly.

More detail on each responsible person's authority is available in the "Who issues the permit" section.

5. Permit issuance procedure

Issuing a permit is not just filling out a form. It is a 9-step process, each step documented in the regulations.

1. Determine the need. Cross-reference the task with the organisation's list.
2. Assign responsible persons. Issuer, responsible work supervisor, work performer — by organisational order.
3. Develop safety measures. Specific measures: barriers, signs, lockouts, PPE, air testing (for gas-hazardous and confined spaces), equipment isolation.
4. Fill out the form. Two copies. Pencil is prohibited. Corrections are not allowed — only a new form.
5. Conduct a targeted safety briefing. Each crew member signs. The briefing is conducted by the work performer or admitting person.
6. Prepare the workplace. Install barriers, post safety signs, check protective equipment, earthing (for electrical installations), gas levels (for gas-hazardous work).
7. Admit the crew. The work performer inspects the site and signs off. Only then does the crew start work.
8. Daily oversight. If the work continues the next day — repeat admission with an entry in the permit.
9. Close the permit. Inspect the workplace, collect signatures, return to the issuer. Retention: 30 days for general permits, 30 days for height permits. Specific periods depend on the type.

An error made at every third site: filling out the form after work has started, "backdating" it. During a GIT inspection this is easily detected (briefing time is later than the work start time). A fine is inevitable.

Another common problem: safety measures are recorded in generic terms. "Ensure safety" or "use PPE" — instead of specifics: "put on a safety harness with two lanyards, attach the carabiner to a support at 1.5 m height". Vague wording protects neither the worker nor the HSE engineer.

A third typical mistake: the crew signs the permit but cannot recount the content of the targeted briefing. A GIT inspector has the right to interview crew members right on site. If a worker does not know what hazard factors are listed in their permit, the briefing is considered not conducted.

How to check yourself before admission? Five control questions: (1) is a specific work performer named? (2) are all hazard factors in the work zone listed? (3) are specific PPE items recorded with types and sizes? (4) have all crew members signed? (5) does the briefing time match the start time? If even one answer is "no" — the permit is not ready.

Step-by-step instructions with sample forms are available in the "Permit issuance" section.

6. Permit validity period

Validity periods depend on the type of hazard. This is a direct regulatory requirement, not a recommendation. Violating a validity period is treated the same as working without a permit: a fine under Art. 5.27.1 of the Administrative Code.

Pay attention to the difference: for working at height, working days are counted; for electrical installations, calendar days. Confusion here is costly.

Hot work and gas-hazardous — the strictest. One permit per shift, no extension. At oil refineries, a welder may receive a new permit every 8 hours. Normal practice, not excessive bureaucracy: conditions on site change quickly, and air composition needs to be rechecked.

Who extends a permit? The person who issued it. Or a person with equivalent authority under the organisational order. Extension is recorded with the date and signature.

A detailed table of validity periods for all types of work is available in the "Permit validity" section.

7. Work without a permit-to-work

Not everything requires full documentation. By verbal or written instruction (simplified form), tasks can be performed that simultaneously: are not in the organisation's list of high-hazard work and do not require special workplace preparation.

• Working at height from inventory scaffolding with protective barriers (handrails, toe boards). Scaffolding is serviceable and accepted by certificate — full documentation is not needed.
• Routine operation of electrical installations: operational maintenance as part of day-to-day operations. The list of such tasks is approved by the unit head.
• Minor current repairs without decommissioning equipment, without opening, and without operations near moving parts.

At one facility in 2024, an electrician suffered a severe electrical injury during "maintenance as part of day-to-day operations". The investigation showed: the work had been incorrectly included in the routine operations list; in fact, it required equipment isolation and a permit-to-work. The HSE engineer received a prison sentence under Art. 143 of the Criminal Code.

The rule is simple. Not sure if full documentation is needed? Issue it. Fine for unnecessary documentation: zero roubles. Fine for a missing permit: from RUB 110,000. The choice is obvious.

Another common question: what to do with urgent tasks when there is no time for full documentation? If the situation is not an emergency — there is always time. 15–20 minutes to fill out the form and conduct the briefing. If it is an emergency — Section 37 of Order No. 903n allows starting without a permit, but after the emergency is contained, the permit must be issued.

The full list is available in the "Work without a permit" section.

8. Liability and fines

Administrative and criminal liability is provided for violations. Fine amounts are current as of April 2026.

Basis: Art. 5.27.1 of the Administrative Code, Art. 143, 216, 217 of the Criminal Code of Russia.

Typical violations identified during GIT inspections: working without a permit, incorrectly filled forms, expired permits, absence of a targeted briefing. The most common by frequency: admitting a crew without an issued permit.

Criminal liability arises not from the fact of a violation, but from its consequences. Serious harm to a worker's health: Art. 143 Part 1 of the Criminal Code, up to one year of imprisonment. Death of one person: Part 2 Art. 143 (up to 4 years), Art. 216 Part 2, Art. 217 Part 2 (up to 5 years). Death of two or more: Part 3 Art. 143 (up to 5 years), Art. 216 Part 3, Art. 217 Part 3 (up to 7 years).

A separate category of violations: "checkbox" permits. Formally filled out, signatures are in place, but safety measures were not implemented. Barriers not installed, PPE not issued, gas levels not measured. During an accident investigation, this is treated more severely than a missing permit. Courts treat this as an intentional violation.

9. Permit-to-work by industry

The permit-to-work system operates in all industries where high-hazard work is performed. Intensity depends on the specifics.

Oil & Gas. Hot, gas-hazardous, working at height, confined spaces — all simultaneously. Up to 6 permits per shift at a well pad. The widest range of types. Regulated by Federal Rules for HIF, additionally by corporate standards (Gazprom, Rosneft, LUKOIL have their own systems, sometimes stricter than federal ones).

Construction. Up to 70% of construction tasks require a permit. Height, excavation, installation, crane work — the standard set. Specifics: multiple contractors on one site, and permit coordination between them is a separate challenge. Who coordinates? The general contractor, under Art. 214 of the Labour Code.

Power Industry. A separate PTW system under POTEU (Gov. Decree 875). Its own forms, its own procedure, its own admission groups (II–V). The permit for electrical installations is not the general format under Order No. 903n, but a specialised form with its own rules.

Metallurgy. Operations near molten metal, in hot shops, equipment repairs. Hot work and working at height are the main types. The temperature factor adds PPE requirements and work regime rules (shortened shifts, mandatory breaks).

Mining. Mines, quarries, drill-and-blast operations. The strictest requirements. Regulated by Federal Rules for mining. The work order (in mines) is a separate form. Do not confuse them.

Chemical Industry. Operations with hazardous chemical substances, in confined spaces, gas-hazardous work. Enhanced requirements for decontamination, air testing, emergency PPE reserves. Response time in case of a leak — minutes.

Utilities & Heating. Manholes, heating mains, electrical installations in residential buildings. Gas-hazardous work in basements — a frequent task. Specifics: sites are dispersed across the city, oversight is more difficult.

Transport. Railway tracks, roads, ports, airports. Operations in traffic zones — an additional hazard factor. Specific measures in the permit: signal fencing, posting lookouts.

Shipbuilding & Repair. Confined spaces (compartments, tanks), hot work, working at height in dry docks. Plus diving operations with their own permits.

Nuclear Power. The strictest system. Operations in ionising radiation zones, mandatory dosimetric control, admission through the radiation safety service. A violation here is not a fine, but criminal liability. Separate requirements for crew composition, function duplication, and emergency planning.

How to choose the right set? Identify your industry, identify the types of hazards at the site, check industry-specific Federal Rules and regulations. For an oil & gas enterprise, the standard set: general (Order No. 903n) plus hot work (Fire Rules) plus gas-hazardous (Federal Rules). For a construction site: general plus working at height (Order No. 782n). For an electrical grid company: a specialised permit under POTEU (Gov. Decree 875), which replaces the general one.

In practice, errors most often arise at industry intersections. A contractor from a construction company arrives at a petrochemical plant. They are accustomed to a permit under Order No. 903n, but the plant operates under Federal Rules for HIF. Forms differ, the admission procedure is different, briefing requirements are stricter. If the contractor issues "their own" permit by "their own" rules rather than the client's rules — the permit is invalid.

Detailed guides for each industry are available in the "By Industry" section.

Rustem Khusnutdinov

Author of expert materials on occupational health and industrial safety

10. Frequently asked questions