SAFETY REPORTS

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Schedule 4-Purpose and Contents of Safety Report

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Reg 4 Every operator shall take all measures necessary to prevent major accidents and limit their consequences to persons and the environment

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.

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

Reg 7(7)
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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

Identification and accidental risk analysis and prevention methods: n detailed description of the possible major accident scenarios n and their probability ----------Bang!

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

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Existing Guidance
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Identification and accidental risk analysis and prevention methods:

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4(b)assessment of the extent and severity of the consequences of identified major accidents
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(R2P2 p76)

Population ABC Chem Tank

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);

ALARP in COMAH

Existing Guidance (continued)

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For practical purposes: n All Measures Necessary (AMN)=SFAIRP=ALARP

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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

ALARP Demonstration
"Reducing Risks, Protecting People"

informs *

'R2P2'
informs ** HSE's expectation e.g. TOR framework, primacy of Good Practice, tolerability criteria

'ALARP
Principles and Guidelines'

legal commentary + policy

Information to Stakeholders

'Good Practice'

'Design'

D/Ds' Guidance

Guidance to Staff

".... suitable controls must be in place place to to address all significant significant hazards hazards .... .... and and those controls, at a minimum, must implement authoritative good practice practice irrespective of situation-based risk estimates ...." ...."
"authoritative "authoritative good good practice" practice" = prescriptive legislation, ACOPs, guidance guidance produced produced by by government. government.

HSE's expectation/enforcement policy

* 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

ALARP Demonstration
HSE framework for the tolerability of risk

"Reducing Risks, Protecting People"

".... both individual risks and societal concerns .... .... must must be be taken taken into into account account in deciding whether a risk is unacceptable, tolerable or broadly acceptable acceptable ...." ...." "individual risks also give rise to societal concerns and the latter latter often often play play a a far far greater role in deciding whether risk is unacceptable or not."

Increasing Individual and societal concerns

Unacceptable Region Tolerable Region Broadly Acceptable Region

ALARP Diagram

A L A R P P rin c iple
Mea as su ur re es s tto or re ed du c e r i s k m u s t b e t a k e n u n t il th e r i s k i s b r o a d ly acceptable (BA) or u n til th e c o s t o f f u r t h e r r i s k reduction wou u lld d b e g r o s s ly disproportionate (GD) to t th he e reduction in risk that w o u ld be achieved.

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 ALARPdemonstration 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.

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

Case Specific ALARP demonstration Operator has to answer the following fundamental question:

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

Case Specific ALARP demonstration Also:

Proportionate Risk Assessment The depth of the analysis in the operators report should be proportionate to a) the nature and scale of the MAHs b) the risks posed to neighbouring populations

"Why have I not done it"?

BLEVE

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

Risk estimation
Selection of a representative set of events Estimation of consequences and frequency for each event Ranking & screening (e.g risk matrix, fn curves)
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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?
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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.

Risk Matrix (Illustrative)

Likely >10-2 Intolerable Intolerable Intolerable Intolerable Intolerable

Proportionality: Type of ALARP Demo.

Risk reduction regardless of cost Relevant Good Practice
Plus

Intolerable

Unlikely 10-4-10-2

TIFALARP(Int olerable if Fatality >10-3)

TIFALARP(Int olerable if Fatality >10-3)

Intolerable

Intolerable

Intolerable

Risk reduction Measures

Plus

Tolerable if ALARP

Very Unlikely 10-6-10-4

TIFALARP

TIFALARP

TIFALARP/Int olerable

TIFALARP/Int olerable

Intolerable

Gross Disproportion

Remote 10-6-10-8

Broadly Acceptable

Broadly Acceptable

TIFALARP/Br oadly Acceptable?

TIFALARP

TIFALARP

Relevant Good Practice Broadly Acceptable

Single Fatality

2-10 Fatalities

11-50 Fatalities

50-100 Fatalities

100+ Fatalities

`So what`

Sensitivity and uncertainty analysis

Would being more thorough be worthwhile? Uncertainties in models, data, methodology. Cautious best-estimate basis. basis. Adopt Precautionary Approach
p89 p89 91R2P2 91R2P2

If all the risks are BA then compliance with good practice demonstrates ALARP Otherwise the events that contribute significantly to the risks need to be identified, risk reduction options compiled,and appropriate decision aids used (eg LOPA for simple cases CBA for more difficult ones)

Purpose of SR is to demonstrate ANMs (ALARP) from an activity (`risk from what`) Four combinations (`risk of what` and `risk to what`): 1 IR to those on-site 2 IR to those off-site 3 SR to those on-site 4 SR to those off-site

If AMNs are in place for each major accident scenario then there is nothing more that can be done and professional judgement will suffice. `Explicit` detailed quantification of risks is not necessary unless the proportionality is high