SAFETY REPORTS

Reg 4 Every operator shall take all measures

necessary to prevent major accidents and limit their consequences to persons and the environment

SAFETY REPORTS

Reg 7(7) The operator shall send to the CA a report

containing information which is sufficient for the purposes specified in Part 1 Schedule 4 and comprising at least the information specified in part 2 of that Schedule

Schedule 4-Purpose and Contents of Safety Report

Part1-The purposes referred to in Reg7 are as follows:

2. Demonstrating that major accidents hazards have been identified and that the necessary measures have been taken to prevent such accidents and to limit their consequencesfor persons and the environment.

Schedule 4 -Part 2Minimum Information to be included in a Safety Report

Identification and accidental risk analysis and prevention methods:

detailed description of the possible major accident scenarios

and their probability ----------- Bang!

Schedule 4 -Part 2Minimum Information to be included in a Safety Report

Identification and accidental risk analysis and prevention methods: 4(b)assessment of the extent and severity

of the consequences of identified major accidents

(R2P2 p76)

PopulationTankABC Chem

ALARP in COMAH

For practical purposes: All Measures Necessary

(AMN)=SFAIRP=ALARP

Existing Guidance

HSE has produced a suite of guidance documents concerning ALARP. These are designed to give high level principles which D/Ds can then use to promulgate sector specific advice.

The documents are: Reducing Risk, Protecting People

(R2P2);

Existing Guidance (continued)

Principles and guidelines to assist HSE in its judgments that duty-holders have reduced risk as low as reasonably practicable;

Assessing compliance with the law in individual cases and the use of good practice; and

ALARP in Design - Policy and Guidance.

Relationship between R2P2 and the ALARP Suite

* Annex 3 of R2P2 reflects the ALARP guidance

** e.g. the concept of 'hypothetical person' set out in R2P2 is adopted in the ALARP guidance

Informationto Stakeholders

legal commentary+ policy'R2P2'

'ALARPPrinciples and

Guidelines'

'GoodPractice' 'Design'

D/Ds'Guidance

HSE's expectation/enforcement policy

HSE's expectatione.g. TOR framework, primacy of Good Practice, tolerability criteria

informs*

informs**

Guidance to Staff

HSE framework for the tolerability HSE framework for the tolerability of riskof risk

Unacceptable Region

Tolerable Region

Broadly Acceptable Region

ALARP DemonstrationALARP Demonstration

"Reducing Risks, Protecting People""Reducing Risks, Protecting People"

".... ".... suitable controls must be in place to suitable controls must be in place to address all significant hazards .... and address all significant hazards .... and those controls, at a minimum, must those controls, at a minimum, must implement authoritative good practice implement authoritative good practice irrespective of situation-based risk irrespective of situation-based risk estimates ...."estimates ...."

"authoritative good practice" = "authoritative good practice" = prescriptive legislation, ACOPs, prescriptive legislation, ACOPs, guidance produced by government. guidance produced by government.

ALARP DemonstrationALARP Demonstration

"Reducing Risks, Protecting People""Reducing Risks, Protecting People"

".... both individual risks and ".... both individual risks and societal societal concerns concerns .... must be taken into account in .... must be taken into account in deciding whether a risk is unacceptable, deciding whether a risk is unacceptable, tolerable or broadly acceptable ...." tolerable or broadly acceptable ...."

"individual risks also give rise to societal "individual risks also give rise to societal concernsconcerns and the latter often play a far and the latter often play a far greater role in deciding whether risk is greater role in deciding whether risk is unacceptable or not."unacceptable or not."

ALARP PrincipleALARP Principle

Measures to reduce risk Measures to reduce risk must be taken until the risk is must be taken until the risk is broadly acceptable broadly acceptable (BA) or (BA) or until the cost of further risk until the cost of further risk reduction would be reduction would be grossly grossly disproportionatedisproportionate (GD) to the (GD) to the reduction in risk that would reduction in risk that would be achieved.be achieved.

Solicitor`s guidanceSolicitor`s guidance

"We believe it is right that, in all "We believe it is right that, in all cases, the judgment as to cases, the judgment as to whether measures are grossly whether measures are grossly disproportionate should reflect disproportionate should reflect societal risksocietal risk, that is to say, large , that is to say, large numbers of people (employees numbers of people (employees or the public) being killed at one or the public) being killed at one go. " go. "

ALARP Diagram

Unacceptable region Level of risk cannot be justified except in extraordinary circumstances.

___________________________________________________ Tolerable region

If the risks fall in this region then a CASE SPECIFIC ALARP demonstration is required. The extent of the demonstration should be proportionate to the level of risk

____________________________________________________

Broadly acceptable region Level of residual risk is regarded as insignificant and further effort

to reduce risk not likely to be required. ALARP demonstration based upon adherence to codes, standards and established good practice. These must

be shown to be up to date and relevant to the operations in question.

Case Specific ALARP Case Specific ALARP demonstrationdemonstration

Operator has to answer the Operator has to answer the following fundamental following fundamental question:question:

"What more can I do "What more can I do to reduce the risks "?to reduce the risks "?

Case Specific ALARP Case Specific ALARP demonstrationdemonstration

Also:Also:

"Why have I not done "Why have I not done it"?it"?

if the measure appears if the measure appears reasonable and it cannot be reasonable and it cannot be shown that the cost of the shown that the cost of the measure is measure is grossly grossly disproportionate disproportionate to the benefit to to the benefit to be gained, then the Operator is be gained, then the Operator is duty bound to implement that duty bound to implement that measuremeasure

Proportionate Risk Assessment Proportionate Risk Assessment

The depth of the analysis in the The depth of the analysis in the operators report should be operators report should be proportionate to proportionate to

a) the nature and scale of the a) the nature and scale of the MAHsMAHsb) the risks posed to b) the risks posed to neighbouring populationsneighbouring populations

BLEVEBLEVE

Risk estimationRisk estimation

Selection of a representative Selection of a representative set of eventsset of events

Estimation of consequences and frequency Estimation of consequences and frequency for each eventfor each event

Ranking & screening (e.g risk matrix, fn Ranking & screening (e.g risk matrix, fn curves)curves)

Risk Matrix (Illustrative)

Single Fatality 2-10 Fatalities 11-50 Fatalities 50-100 Fatalities 100+ Fatalities

Remote

10-6-10-8

Very Unlikely

10-6-10-4

Unlikely

10-4-10-2

Likely >10-2

Intolerable Intolerable Intolerable Intolerable

IntolerableIntolerableIntolerable

Broadly Acceptable

Intolerable

Broadly Acceptable

TIFALARP(Intolerable if

Fatality >10-3)

TIFALARP/Intolerable

TIFALARP

TIFALARP/Broadly

Acceptable?

TIFALARP

Intolerable

TIFALARP(Intolerable if

Fatality >10-3)

TIFALARP

TIFALARP

TIFALARP/Intolerable

ALARP Demonstration

But the higher the installation lies on the societal concerns scale the greater the need to look for additional measures, over and above the normal standards.How to approach? 1. Identify risk reduction measures. 2. Assess using Lines Of Defence analysis

with cost estimates 3. Possibly, in extreme cases, add a Cost

Benefit Analysis.

Proportionality: Type of ALARP Demo.

Broadly Acceptable

Intolerable

Risk reduction

regardless of cost

Relevant GoodPractice

Relevant Good Practice

Risk reduction Measures

GrossDisproportion

Plus

Plus

Tolerable if ALARP

Sensitivity and uncertainty Sensitivity and uncertainty analysisanalysis

Would being more thorough be Would being more thorough be worthwhile?worthwhile?

Uncertainties in models, data, Uncertainties in models, data, methodology.methodology.

Cautious best-estimate basis.Cautious best-estimate basis.

Adopt Adopt Precautionary ApproachPrecautionary Approachp89 91R2P2p89 91R2P2

Purpose of SR is to demonstrate Purpose of SR is to demonstrate ANMs (ALARP) from an activity ANMs (ALARP) from an activity (`risk from what`)(`risk from what`)

Four combinations (`risk of what` Four combinations (`risk of what` and `risk to what`):and `risk to what`):

1 IR to those on-site1 IR to those on-site2 IR to those off-site2 IR to those off-site3 SR to those on-site3 SR to those on-site4 SR to those off-site4 SR to those off-site

`So what``So what`

If all the risks are BA then If all the risks are BA then compliance with good practice compliance with good practice demonstrates ALARPdemonstrates ALARP

Otherwise the events that Otherwise the events that contribute significantly to the contribute significantly to the risks need to be identified, risk risks need to be identified, risk reduction options compiled,and reduction options compiled,and appropriate decision aids usedappropriate decision aids used(eg LOPA for simple cases(eg LOPA for simple casesCBA for more difficult ones)CBA for more difficult ones)

If AMNs are in place for each If AMNs are in place for each major accident scenario then major accident scenario then there is nothing more that can be there is nothing more that can be done and professional judgement done and professional judgement will suffice.will suffice.

`Explicit` detailed quantification of `Explicit` detailed quantification of risks is not necessary unless the risks is not necessary unless the proportionality is highproportionality is high