rina alarp feb 2012

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

RINA, 23rd February, Lloyd’s Register, London

Vince Jenkins, Global Marine Risk Advisor, Lloyd’s Register



Introduction

• The genesis of ALARP and it’ssubsequent development to what is

referred to day as the ALARP triangle

• How ALARP should be used, that isdemonstrating 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…



Aberfan Disaster (21st October 1966)

Health & Safety at Work etc. Act, 1974

• Securing the health, safety and welfare of people atwork

• 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 asis reasonably practicable the health, safety andwelfare at work of all employees (Edwards v NCB1949)



HSE Risk Criteria Framework

Individual fatality frequency per year

ALARP Triangle

Unacceptable regionRisk cannot be justified

save in extraordinarycircumstances

The ALARP or Tolerability

region(Risk is undertaken only if a benefit is desired)

Tolerable only if risk reduction isimpracticable or if it cost is grossly

disproportionate to the improvementgained

Tolerable if cost of reduction wouldexceed the improvement

Negligible risk

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

Necessary to maintain assurancethat risk remains at this level



UK Accident Statistics

INDUSTRY EMPLOYEE

FATALITIES

1987-91

EMPLOYEES

1990

INDIVIDUAL

RISK

(per year)

FAR2

(per 108

hours)

Agriculture

Forestry

Sea fishing

Coal mining

Oil and gas production

Energy production

Quarrying

Metal manufacturing

Chemical industryMechanical engineering

Electrical engineering

All manufacturing

Construction

Distribution and catering

Railways

Sea transport

Banking and business services

Education

All services

All industries

81

7

831

63

1953

22

29

34

2755

18

389

400

107

65

211

34

10

423

1606

258,000

12,000

22,400

80,000

47,000

216,000

34,000

154,000

318,000737,000

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

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

4.1

7.6

64.0

10.2

30.92

1.3

11.0

2.9

1.11.0

0.4

1.0

5.0

0.3

6.6

8.62

0.2

0.1

0.4

0.9



HSE Risk Criteria Framework

Unacceptable regionRisk cannot be justified

save in extraordinarycircumstances

The ALARP or Tolerability

region(Risk is undertaken only if a benefit is desired)

Tolerable only if risk reduction isimpracticable or if it cost is grossly

disproportionate to the improvementgained

Tolerable if cost of reduction wouldexceed the improvement

Negligible risk

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

Necessary to maintain assurancethat risk remains at this level

ALARP Triangle

1 x 10-3

1 x 10-6



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 hasbeen evaluated, and those that are not grossly disproportionate have beenadopted.

• The key is then gross disproportion, as demonstrated by a Cost Benefit Assessment.



Cost Benefit Analysis - CBA

Benefits are NOT disproportionate to the cost

Benefit – risk reduction

Safety risk Cost $$

Are wevaluing a life?

Cost of avoiding

a statisticalfatality



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



• Safety

• Value of lives

• Cost of hospital treatment, etc.

• Environmental costs

• Business costs

• Property damage costs

• Business interruption costs

• Reputation

How much should we invest to prevent an incident?

Guidance - Typical £2M

Regulation appearing…

The value to your business…?

The value to your business…?

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



How is the sum done?

ICAF = £ cost of the measure

(implied cost of avoiding a fatality) Change in risk (R1 – R2)

4.5 E-4 X

X

Option 2 1.3 E-4 5 E-5 Option 1X

£100,5000.00045 – 0.00005

= £251,250,000Option 1

£10,0000.00045 – 0.00013

= £31,250,000Option 2



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, materialUse something less hazardous / do it in a different wayReduce the nature of the hazard by using smaller quantities,

lower toxicity material, lower pressure operation

• 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)

Ozone depleting CFCssubstituted with HFCs



ALARP Application to Qualitative Risk Ranking

Negligible Marginal Critical Catastrophic

Frequent

Probable

Remote

Incredible

ConsequencesConsequences

L i k

e l i h o o d

L i k

e l i h o o d



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 basedon 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 beingupheld 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. TheDirective gives employers an absolute duty "to ensure the safety and health of workers inevery aspect related to the work", whereas the Act qualifies the duty "So Far As isReasonably Practicable". The court dismissed the action and ordered the Commission topay 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 outcomeI am pleased by this outcomeI am pleased by this outcomeI am pleased by this outcome…………. We continue to believe that the right way forward is a. We continue to believe that the right way forward is a. We continue to believe that the right way forward is a. We continue to believe that the right way forward is aproportionate and riskproportionate and riskproportionate and riskproportionate and risk----based approach protecting employees and others effectively, whilbased approach protecting employees and others effectively, whilbased approach protecting employees and others effectively, whilbased approach protecting employees and others effectively, whilststststallowing commonsense to be applied when deciding on what protectallowing commonsense to be applied when deciding on what protectallowing commonsense to be applied when deciding on what protectallowing commonsense to be applied when deciding on what protective measures toive measures toive measures toive measures to

adopt.adopt.adopt.adopt.““““ Bill Callaghan, Chair of the Health and Safety Commission (HSC) Bill Callaghan, Chair of the Health and Safety Commission (HSC) Bill Callaghan, Chair of the Health and Safety Commission (HSC) 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 realisationof a defined hazard (HSE, 1995)

• We refer to the chance of accidents that could harm a number ofpeople in one go as ‘societal risk’. It is in effect a measure of several

combined issues - what things could go wrong…, how likely they areto 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-09

1.E-08

1.E-07

1.E-06

1.E-05

1.E-04

1.E-03

1.E-02

1 10 100 1,000 10,000

Number of Fatalities

F r e

q u e n c y o f N o r m o r e F a t a l i t i e s ( p e r y e a

r )

UNACCEPTABLE

ALARP

ACCEPTABLE



Netherlands FN Criterion Lines

1.E-09

1.E-08

1.E-07

1.E-06

1.E-05

1.E-04

1.E-03

1.E-02

1 10 100 1,000 10,000


F r e

q u e n c y o f N o r m o r e F a t a l i t i e s ( p e r y e a r

)

UNACCEPTABLE

ACCEPTABLE



Denmark FN Criterion Lines

1.E-09

1.E-08

1.E-07

1.E-06

1.E-05

1.E-04

1.E-03

1.E-02

1 10 100 1,000 10,000


F r e q u e n c y o f N o r m o r e F a t a l i t i e s ( p e r y e a r

)

UNACCEPTABLE

ACCEPTABLE



UK FN Criterion Lines

1.E-09

1.E-08

1.E-07

1.E-06

1.E-05

1.E-04

1.E-03

1.E-02

1 10 100 1,000 10,000


F r e q u e n c y o f N o r m o r

e F a t a l i t i e s ( p e r y e a r

)SERIOUS CONCERN

SIGNIFICANT

MODERATE

BROADLY ACCEPTABLE



Hong Kong FN Criterion Lines

1.E-09

1.E-08

1.E-07

1.E-06

1.E-05

1.E-04

1.E-03

1.E-02

1 10 100 1,000 10,000


F r e q u e n c y o f N o r m o r e F a t a l i t i e s ( p e r y e a

r )

UNACCEPTABLE

ALARP

ACCEPTABLE

Dutch Criteria

Danish Criteria

UK Criteria

SERIOUS CONCERN

SIGNIFICANT

MODERATE

BROADLY ACCEPTABLE



Further information

• http://www.hse.gov.uk/risk/theory/alarpglance.htm

• http://www.hse.gov.uk/risk/theory/alarp.htm

• http://www.hse.gov.uk/foi/internalops/nsd/tech_asst_guides/tast005.htm

Nuclear Directorate Guidanceon 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

Lloyd’s Register Marine71 Fenchurch Street

London, EC3M 4BS

+44 (0)20 7423 [email protected]

www.lr.org/marine

rina alarp feb 2012

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