As Low As Reasonably Practicable (ALARP) Understanding what it means and its applications

RINA, 23rd February, Lloyds Register, London Vince Jenkins, Global Marine Risk Advisor, Lloyds Register

Introduction

The genesis of ALARP and its subsequent development to what is referred to day as the ALARP triangle How ALARP should be used, that is demonstrating ALARP, and the benefits of doing this

How much do we spend on safety? 1 100 1,000,000..

How do we prioritise any spending? 1 2 3

HSE and ALARP What is it? Where has it come from?

Edwards v National Coal Board [1949] All ER 743 (CA)
Reasonably practicable definition, the quantum of risk risk test Facts travelling elling road Mr Edwards was killed when an unsupported section of a trav in a mine gave way. Only about half the whole length of the road was shored up. The company argued that the cost of shoring up all roads roads in every mine was prohibitive when compared to the risk. The Decision The question at issue was not the cost of shoring up all roads roads in every mine operated by the company. The issue was the cost of making safe safe the section of road that fell. Some roads are secure and show no signs signs of failing. Others may already have fallen and have already been repaired. repaired. The section in question was already supported by timber along half half its length. The cost of making it safe was not great compared to the risk of injury and loss of life

Aberfan Disaster (21st October 1966)

Health & Safety at Work etc. Act, 1974

Securing the health, safety and welfare of people at work Protecting other people against risks arising out of other work Controlling the release of noxious/offensive substances to the atmosphere A fundamental requirement of Health and Safety legislation is that the employer must assure, so far as is reasonably practicable the health, safety and welfare at work of all employees (Edwards v NCB 1949)

HSE Risk Criteria Framework

ALARP Triangle

Unacceptable region

Risk cannot be justified save in extraordinary circumstances

The ALARP or Tolerability region

(Risk is undertaken only if a benefit is desired)

Tolerable only if risk reduction is impracticable or if it cost is grossly disproportionate to the improvement gained Tolerable if cost of reduction would exceed the improvement

Broadly acceptable region (No need for detailed working to demonstrate ALARP)

Necessary to maintain assurance that risk remains at this level

Negligible risk

Individual fatality frequency per year

UK Accident Statistics
INDUSTRY EMPLOYEE FATALITIES 1987-91 81 7 831 63 1953 22 29 34 27 55 18 389 400 107 65 211 34 10 423 1606 EMPLOYEES 1990 258,000 12,000 22,400 80,000 47,000 216,000 34,000 154,000 318,000 737,000 551,000 4,991,000 1,033,000 4,700,000 127,000 24,100 2,668,000 1,719,000 15,393,000 22,134,000 INDIVIDUAL RISK (per year) 7.9 x 10-5 1.5 x 10-4 1.2 x 10-3 2.0 x 10-4 1.0 x 10-3 2.5 x 10-5 2.1 x 10-4 5.5 x 10-5 2.1 x 10-5 1.9 x 10-5 8.2 x 10-6 1.9 x 10-5 9.7 x 10-5 5.7 x 10-6 1.3 x 10-4 2.9 x 10-4 3.2 x 10-6 1.5 x 10-6 6.9 x 10-6 1.8 x 10-5 FAR2 (per 108 hours) 4.1 7.6 64.0 10.2 30.92 1.3 11.0 2.9 1.1 1.0 0.4 1.0 5.0 0.3 6.6 8.62 0.2 0.1 0.4 0.9

Agriculture Forestry Sea fishing Coal mining Oil and gas production Energy production Quarrying Metal manufacturing Chemical industry Mechanical engineering Electrical engineering All manufacturing Construction Distribution and catering Railways Sea transport Banking and business services Education All services All industries

HSE Risk Criteria Framework

ALARP Triangle

Unacceptable region

Risk cannot be justified save in extraordinary circumstances

1 x 10-3
The ALARP or Tolerability region
Tolerable only if risk reduction is impracticable or if it cost is grossly disproportionate to the improvement gained Tolerable if cost of reduction would exceed the improvement

(Risk is undertaken only if a benefit is desired)

1x

10-6
Broadly acceptable region (No need for detailed working to demonstrate ALARP)

Necessary to maintain assurance that risk remains at this level

Negligible risk

ALARP

If on initial evaluation risk falls in the tolerable zone, it does NOT mean it is ALARP A risk is only ALARP when it is demonstrated that every risk reduction option has been evaluated, and those that are not grossly disproportionate have been adopted. The key is then gross disproportion, as demonstrated by a Cost Benefit Assessment.

Cost Benefit Analysis - CBA

Cost of avoiding a statistical fatality

Are we valuing a life?

Benefit risk reduction Safety risk Cost $$

Benefits are NOT disproportionate to the cost

Ways of Valuing the Cost of Avoiding a Statistical Fatality

Human Capital - how much you earn in your life Willingness to Pay - how much are you prepared to pay Implied Value e.g. cost of traffic calming measures Court Awards - how much has been paid out in the past

How much should we invest to prevent an incident?

Safety

Value of lives

Guidance - Typical 2M

Cost of hospital treatment, etc. Regulation appearing The value to your business?

Environmental costs Business costs

Property damage costs Business interruption costs Reputation The value to your business?

IMO Formal Safety Assessment uses a figure of USD $3m

How is the sum done?

4.5 E-4 Option 2 1.3 E-4
X X X

5 E-5 Option 1

ICAF
(implied cost of avoiding a fatality)

cost of the measure Change in risk (R1 R2)

Option 1

100,500 0.00045 0.00005

= 251,250,000

Option 2

10,000 0.00045 0.00013

= 31,250,000

Risk Elimination / Mitigation Priorities

Eliminate / remove the hazard inherent safety

At the design stage, typically the most cost and risk effective solution

Substitute the hazard (reduce the likelihood and consequences)

Use an alternative design, process, method, material Use something less hazardous / do it in a different way Reduce the nature of the hazard by using smaller quantities, lower toxicity material, lower pressure operation

Ozone depleting CFCs substituted with HFCs

Mitigate the hazard (reduce the likelihood, then reduce the consequences)

Use fewer connections or operations to reduce likelihood Use physical barriers or increase separation to reduce consequences

Control hazard exposure through engineering systems or working practices Last resort - Personal Protective Clothing (PPE)

ALARP Application to Qualitative Risk Ranking

Consequences
Negligible Marginal Critical Catastrophic

Frequent

Probable

Likelihood

Remote

Incredible

Is ALARP and CBA the last word?

Expectation of society.. Safety is continually improving Best practice, even if the measure involves gross disproportion The: Cost of undertaking a quantitative analysis Data to support it Will people (employees / public etc) believe it? To not meet ALARP criteria is brave e.g. rigor or < 2m To exceed ALARP is a business decision e.g. use a figure > 2m If you are the operator, it is your responsibility to make decisions based on a range of issues. ALARP is an input to the decision making process.

Challenges to the ALARP concept

A 2-year legal battle in the European Court of Justice resulted in the SFAIRP principle being upheld on 14 June 2007. (Case C127-05 European Commission v United Kingdom) The European Commission had claimed that the SFAIRP wording in the Health & Safety at Work Act did not fully implement the requirements of the Framework Directive. The Directive gives employers an absolute duty "to ensure the safety and health of workers in every aspect related to the work", whereas the Act qualifies the duty "So Far As is Reasonably Practicable". The court dismissed the action and ordered the Commission to pay the UK's costs. Had the case been upheld, it would have called into question the proportionate approach to safety risk management embodied in the ALARP principle. I am pleased by this outcome outcome. We continue to believe that the right way forward is a proportionate and riskwhilst st risk-based approach protecting employees and others effectively, whil allowing commonsense to be applied when deciding on what protective protective measures to adopt. adopt. Bill Callaghan, Chair of the Health and Safety Commission (HSC)

Risk Criteria

Individual Risk

The risk of some specified event harming a statistical or hypothetical person assumed to have representative characteristics (HSE, 1995)
Can be calculated for a specific location or a specific job

Societal Risk

The risk of widespread or large scale detriment from the realisation of a defined hazard (HSE, 1995) We refer to the chance of accidents that could harm a number of people in one go as societal risk. It is in effect a measure of several combined issues - what things could go wrong, how likely they are to happen and how many people could be affected as a result? (HSE,
2007) Can be expressed in terms of F-N curves & Potential Loss of Life (PLL)

Hong Kong FN Criterion Lines

1.E-02

1.E-03

Frequency of N or more Fatalities (per year)

UNACCEPTABLE 1.E-04

1.E-05 ALARP

1.E-06

1.E-07 ACCEPTABLE 1.E-08

1.E-09 1 10 100 1,000 10,000

Number of Fatalities

Netherlands FN Criterion Lines

1.E-02

1.E-03

Frequency of N or more Fatalities (per year)

1.E-04 UNACCEPTABLE 1.E-05

1.E-06

ACCEPTABLE 1.E-07

1.E-08

1.E-09 1 10 100 1,000 10,000

Number of Fatalities

Denmark FN Criterion Lines

1.E-02

1.E-03

Frequency of N or more Fatalities (per year)

1.E-04 UNACCEPTABLE

1.E-05

1.E-06 ACCEPTABLE

1.E-07

1.E-08

1.E-09 1 10 100 1,000 10,000

Number of Fatalities

UK FN Criterion Lines
1.E-02

1.E-03

SERIOUS CONCERN

Frequency of N or more Fatalities (per year)

1.E-04 SIGNIFICANT MODERATE

1.E-05

1.E-06

BROADLY ACCEPTABLE

1.E-07

1.E-08

1.E-09 1 10 100 1,000 10,000

Number of Fatalities

Dutch Criteria

UK Criteria

Hong Kong FN Criterion Lines

1.E-02

Danish Criteria

1.E-03

Frequency of N or more Fatalities (per year)

UNACCEPTABLE 1.E-04
SERIOUS CONCERN

1.E-05 ALARP
SIGNIFICANT MODERATE

1.E-06

1.E-07 ACCEPTABLE 1.E-08

BROADLY ACCEPTABLE

1.E-09 1 10 100 1,000 10,000

Number of Fatalities

Further information

http://www.hse.gov.uk/risk/theor y/alarpglance.htm http://www.hse.gov.uk/risk/theor y/alarp.htm http://www.hse.gov.uk/foi/intern alops/nsd/tech_asst_guides/tast0 05.htm

Nuclear Directorate Guidance on the demonstration of ALARP

Goggle search - HSE ALARP

Conclusions

ALARP concept:

Rational for safety investment Has to be demonstrated Is used outside of QRA

Guidance

Land based & UK - ALARP! Land based global ALARP Marine industry ALARP is useful

For more information, please contact: Vince Jenkins Global Marine Risk Advisor

Lloyds Register Marine 71 Fenchurch Street London, EC3M 4BS +44 (0)20 7423 2018 vince.jenkins@lr.org www.lr.org/marine