Risktec SolutionsRisktec Solutionsfiles.imeche.org/events/downloads/s1546/Andy Lidstone.pdf · risk management and assessment for businessRisktec SolutionsRisktec Solutions ALARP

Risktec Solutionsrisk management and assessment for businessRisktec Solutions

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


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.”


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


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


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)


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


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


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”


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


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


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


– 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


Verification

A • Well understood risks• Established practice• No major stakeholder implications

Standards

Good P

ra

alysisneerin


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


e.g. QRA, C

BAEngine

• Lifecycle implications• -• Uncertainty/deviation from standard, best practice• Significant economic implications

Peer Review


e.g. QRA, C

BAEngine

• Lifecycle implications• Some risk trade offs/transfers•• Significant economic implications

Peer Review


e.g. QRA, C

BAEngine

g pg

Internal StakeholderConsultation

C• Very novel or challenging• Strong stakeholder views and perceptionsCompany

g pg



g pg



g pg



External StakeholderConsultation

C• Significant risk trade-offs or risk transfers• Large uncertainties• Perceived lowering of safety standards

SocietalValues

ValuesExternal Stakeholder

Consultation


SocietalValues


Consultation


SocietalValues


Consultation


SocietalValues

Values


UKOOA - A Framework For Risk Related Decision Support

Qualitative

Can we think of any risk reduction measures?measures?

Is it cost effective Y/N?/


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


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


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


Power Industry Initiatives

Development of Good Practice GuidesGuides

ALARP Good Practice Guide

Greater awareness throughout i d tindustry


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


Documenting the decision-making process is critical

Documents

Risktec SolutionsRisktec Solutionsfiles.imeche.org/events/downloads/s1546/Andy Lidstone.pdf · risk management and assessment for businessRisktec SolutionsRisktec Solutions ALARP