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ALARP in the Conventional Power Industry
Andy Lidstone, Principal Consultant, Risktec Solutions
A P t ti t IM hE C ti l P B il U G
IMechE - ALARP, Rev. 1, Slide 1
A Presentation to IMechE Conventional Power Boiler User Group16-17 November 2010
www.risktec.co.uk
Risk Management Process
Establish Context
Identify Risks
Establish Context
Identify Risks
Analyse Risks Risk Monitor & Communicate & Consult Analyse Risks
Evaluate Risks
Assessment Review& Consult
a ua e s s
T i t T f T t T l tRisk
T t tTerminate Transfer Treat Tolerate
ALARPRisk assessment should
be an input into a
Treatment
IMechE - ALARP, Rev. 1, Slide 2
ALARPWhen is enough, enough?
be an input into a decision making process NOT a justification for a decision already made
Case Law
Principle of Reasonable Practicability p y“A computation must be made in which the quantum of risk is placed on one scale and the sacrifice, whether in money, time or trouble, involved in the measures necessary to avert the risk is placed in theinvolved in the measures necessary to avert the risk is placed in the other; and that, if it be shown that there is a gross disproportion between them, the risk being insignificant in relation to the sacrifice, the person upon whom the duty is laid discharges the burden ofthe person upon whom the duty is laid discharges the burden of proving that compliance was not reasonably practicable”
Asquith LJ in Edwards v. The National Coal Board (1949) 1 All ER 743C
“It h ll b th d t f l t f i
Health and Safety at Work etc. Act 1974“It shall be the duty of every employer to ensure, so far as is
reasonably practicable, the health, safety and welfare at work of his/her employees.”
IMechE - ALARP, Rev. 1, Slide 3
SFAIRP and ALARP are generally treated as
interchangeable terms
Key Points
‘Reasonably practicable’ is a lesser standard than y p‘practicable’
There is no absolute safety; accepting a risk requires weighing the risk against the sacrifice necessary to reduce it further
Any risk based decision should be weighted in favour of safety i.e. there is a presumption of i l t tiimplementation
The burden of proving that a risk is ALARP lies ith th d t h ld (‘th ’)with the duty-holder (‘the owner’)
Measures should be adopted unless they involve l di i ifi
IMechE - ALARP, Rev. 1, Slide 4
grossly disproportionate sacrifices
Balancing Sacrifice and Risk Reduction
RiskReduction
RiskReduction Implement
RiskReduction
ALARP levelS ifi l di ti t
RiskReduction
Sacrifice grossly disproportionateNo need to implement
IMechE - ALARP, Rev. 1, Slide 5
implement
Gross Disproportion
Not explicitly defined by law or HSE guidancep y y gMultiplier (‘proportion factor’) on the benefit to ensure bias towards safetyyVaries by – IndustryIndustry– Level of risk– Individual and/or societal risks– Numbers of fatalities– “Aversion” and/or “Dread” considerations?
b l f h fResponsibility of the owner to justify (guidance available)
IMechE - ALARP, Rev. 1, Slide 6
In general, the higher the risk, the higher the proportion factor
ALARP Fundamental Questions
Is there anything more we can do?
Is it reasonably practicable?Is it reasonably practicable?
ALARP
Good Practice
Have we done the basics?
Ri k L l
Good PracticeCompany Standards
IMechE - ALARP, Rev. 1, Slide 7
Risk LevelsLegislative Requirements
Tolerability of risk framework
Q lit tiQuantitative
(i di id l i k f
Unacceptableregion
Risk cannot be justified save in extraordinary circumstances
Qualitative (individual risk of death per annum)
1E 3 W kcircumstancesTolerable only if risk reduction is impracticable or if its cost is grossly disproportionate to the
1E-3 – Workers1E-4 – Public
Tolerable if ALARP regionRisk is taken only if a benefit is
disproportionate to the improvement gained
if a benefit is required
Tolerable if cost of
Broadly
reduction would exceed the improvement
Necessary to maintain
1E-6 – Workers1E-6 – Public
IMechE - ALARP, Rev. 1, Slide 8
Broadly acceptable region assurance that risk
remains at this level
Role of Good Practice
“those standards for controlling risk that HSE has judged and recognised as satisfying the law when applied to a particular relevant case in an
Includes
satisfying the law, when applied to a particular relevant case, in an appropriate manner”
HSE: Assessing compliance with the law in individual cases and the use of good practice
– ACoPs– HSE and other governmental guidance– Standards e.g. BS, CEN, ISOg , ,– Industry body guidance
Universal practices may not necessarily be good practice
‘Good Practice’ may be less than ‘Best Practice’
May change over time e.g. new legislation, new technology
Deviations should be justified
“Compliance with good practice alone may be sufficient to d h i k h b d d ALARP”
IMechE - ALARP, Rev. 1, Slide 9
demonstrate that risks have been reduced to ALARP”HSE: Assessing compliance with the law in individual cases and the use of good practice
Basic ALARP Process
For each potential risk reduction measure:
Assess the risk reduction
p
Assess the sacrifice (money, time, trouble)trouble)
Compare the twop
Decide on implementation
All practical measures
IMechE - ALARP, Rev. 1, Slide 10
All practical measures should be considered –not just what was done
last time
Risks and Sacrifices
RisksAll reasonably foreseeable risks (on and offsite effects)External events where can mitigate consequencesEffects to most exposed person
Benefitsd h k blReduction in harm to workers, public
Sacrifice
M ti t blMoney, time, trouble e.g.– Cost of installation, operation, maintenance, future
productivity losses– Temporary shutdown costs for installation where required– Offset any costs, benefits that may occur– To duty holder only and no gold-plating
IMechE - ALARP, Rev. 1, Slide 11
To duty holder only and no gold plating
Transfer of risk e.g. new/altered hazards
Approach
O t d id i t h ( idOwner to decide on appropriate approach (guidance available)Rigour will depend on e gRigour will depend on e.g.
– Nature of the hazard– Extent of the risk
Control measures to be adopted– Control measures to be adopted– Societal concerns e.g. numbers, type of persons affected
The more systematic the approach, the more e o e syste at c t e app oac , t e o erigorous and transparent it is to stakeholders e.g. regulator, workforce, publicThree basic approachesThree basic approaches
– Qualitative– Semi-quantitative
IMechE - ALARP, Rev. 1, Slide 12
– Quantitative
Demonstration Proportional to Risk
IntolerableRisk reduction
regardless of cost
QRARelevant Good Practice
plusk d
QRA
Tolerableif ALARP
Risk Reduction Measuresplus
Gross DisproportionSemi-Quantitative
Relevant QualitativeBroadlyAcceptable
Relevant Good Practice
Qualitative
IMechE - ALARP, Rev. 1, Slide 13 HSE: Guidance on ALARP Decisions in COMAH
Approach vs Risk Level
Use in DecisionUse in DecisionUse in DecisionUse in DecisionContext
W ll d d i k
Making Process
Codes & actic
e
ent
Methods Context
Nothing new or unusual
Making Process
Codes & actic
e
ent
Methods
•
Context
W ll d d i k
Making Process
Codes & actic
e
ent
Methods Context
Nothing new or unusual
Making Process
Codes & actic
e
ent
Methods
•Codes & Standards
Verification
A • Well understood risks• Established practice• No major stakeholder implications
Standards
Good P
ra
alysisneerin
g JudgemenCodes & Standards
Verification
A •• Established practice• No major stakeholder implications
Standards
Good P
ra
alysisneerin
g JudgemenCodes & Standards
Verification
A • Well understood risks• Established practice• No major stakeholder implications
Standards
Good P
ra
alysisneerin
g JudgemenCodes & Standards
Verification
A •• Established practice• No major stakeholder implications
Standards
Good P
ra
alysisneerin
g Judgemen
• Lifecycle implications• -• Uncertainty/deviation from standard, best practice• Significant economic implications
Peer Review
BenchmarkingBRisk Based Analy
e.g. QRA, C
BAEngine
• Lifecycle implications• Some risk trade offs/transfers•• Significant economic implications
Peer Review
BenchmarkingBRisk Based Analy
e.g. QRA, C
BAEngine
• Lifecycle implications• -• Uncertainty/deviation from standard, best practice• Significant economic implications
Peer Review
BenchmarkingBRisk Based Analy
e.g. QRA, C
BAEngine
• Lifecycle implications• Some risk trade offs/transfers•• Significant economic implications
Peer Review
BenchmarkingBRisk Based Analy
e.g. QRA, C
BAEngine
g pg
Internal StakeholderConsultation
C• Very novel or challenging• Strong stakeholder views and perceptionsCompany
g pg
Internal StakeholderConsultation
C• Very novel or challenging• Strong stakeholder views and perceptionsCompany
g pg
Internal StakeholderConsultation
C• Very novel or challenging• Strong stakeholder views and perceptionsCompany
g pg
Internal StakeholderConsultation
C• Very novel or challenging• Strong stakeholder views and perceptionsCompany
External StakeholderConsultation
C• Significant risk trade-offs or risk transfers• Large uncertainties• Perceived lowering of safety standards
SocietalValues
ValuesExternal Stakeholder
Consultation
C• Significant risk trade-offs or risk transfers• Large uncertainties• Perceived lowering of safety standards
SocietalValues
ValuesExternal Stakeholder
Consultation
C• Significant risk trade-offs or risk transfers• Large uncertainties• Perceived lowering of safety standards
SocietalValues
ValuesExternal Stakeholder
Consultation
C• Significant risk trade-offs or risk transfers• Large uncertainties• Perceived lowering of safety standards
SocietalValues
Values
IMechE - ALARP, Rev. 1, Slide 14
UKOOA - A Framework For Risk Related Decision Support
Qualitative
Can we think of any risk reduction measures?measures?
Is it cost effective Y/N?/
IMechE - ALARP, Rev. 1, Slide 15
Problems with auditability and arbitrary decisions
Semi-Quantitative - MatricesHigh Impact / Low Cost High Impact / High Cost
Implement Immediately Implement if Practicable*
High Impact / Low Cost High Impact / High Cost
Implement Immediately Implement if Practicable* L M di Hi h
Sacrifice (time, cost, effort)
k C
ontr
ol Im
pact
Implement Immediately Implement if Practicable
k C
ontr
ol Im
pact
Implement Immediately Implement if Practicable Low Medium High
Low ConsiderConsider, if
risk highDo not
implement
Medium Implement ConsiderConsider, if
i k hi hBenefit (risk
d ti )
Ris
k
Implement as part ofContinuous Improvement Don't Implement
Low Impact / Low Cost Low Impact / High Cost
Cost of Risk Control
Ris
k
Implement as part ofContinuous Improvement Don't Implement
Low Impact / Low Cost Low Impact / High Cost
Cost of Risk Control Allows for consistent and
prisk high
High Implement Implement Consider
reduction)
Cost of Risk ControlCost of Risk Control Allows for consistent and transparent decision making
Ho to calib ate the a es?Risk Reduction Level Value Risk Matrix Value
HIGH 1 Risk reduction from High to Low MEDIUM 2 Risk reduction from High to Medium LOW 3 Risk reduction from Medium to Low
How to calibrate the axes?
Cost Level Value
$ Cost of implementation
LOW 1 <50k MEDIUM 2 50k – 500k HIGH 3 >500k
Effort Eff t
IMechE - ALARP, Rev. 1, Slide 16
EffortLevel Value
Effort
LOW 1 Quick Fix, simple to achieve, e.g. install new valve or conduct training
MEDIUM 2 Simple fix, relatively easy to achieve, e.g. replace item of equipment or revise simple layouts
HIGH 3 Complex fix, technically feasible but not easy to achieve, e.g. major equipment or layout changes
Quantitative Cost Benefit Analysis
Must meet minimum standards (irrespective of cost) CBA cannot be used to argue against implementation of relevant good practiceimplementation of relevant good practice
Depth of analysis should be fit for purpose i.e. greater rigour required for higher risks or largergreater rigour required for higher risks or larger consequences
Sensitivity analysis generally requiredSensitivity analysis generally required
A CBA on its own– Does not constitute an ALARP caseDoes not constitute an ALARP case– Cannot be used to argue against statutory duties– Cannot justify intolerable risks or justify evidently
poor engineering
IMechE - ALARP, Rev. 1, Slide 17
poor engineering
ALARP Misconceptions
If risks are Tolerable, they are ALARP
Ensuring that risks are reduced to ALARP means graising standards continually
If some companies have adopted a high standard of risk control, that standard is ALARP
Ensuring risks are reduced to ALARP means we i i t ll ibl i k t lcan insist on all possible risk controls
Ensuring that risks are reduced to ALARP means there will be no accidents or ill healththere will be no accidents or ill-health
IMechE - ALARP, Rev. 1, Slide 18
Power Industry Initiatives
Development of Good Practice GuidesGuides
ALARP Good Practice Guide
Greater awareness throughout i d tindustry
IMechE - ALARP, Rev. 1, Slide 19
Summary
Always desirable to reduce risk, but not always y , ywarrantedALARP regime gives greater flexibility than prescriptive legislative approaches but also entailsprescriptive legislative approaches, but also entails greater responsibilityPracticality and cost considerations may bePracticality and cost considerations may be justifications for not implementing measuresALARP demonstration can be qualitative or
tit ti ( b b i )quantitative (case-by-case basis)Minimum legal standards and company expectations must be metmust be metOptions must be considered, and reasonable ones implemented
IMechE - ALARP, Rev. 1, Slide 20
Documenting the decision-making process is critical