journey to alarp u - asems to... · alarp – hse perspective • using “reasonably...
TRANSCRIPT
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Journey to ALARP
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Hazard Identification
• Hazards not identified are not analysed and therefore not reduced; – Consider the whole life-cycle;
manufacture, commissioning, trials, operation, maintenance, foreseeable modifications and disposal;
– All reasonably foreseeable hazards must be identified, not just those of intelligent layperson, but professional in that field – hence importance of SQEP team.
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HSE Everyday Risk Decision-Making Process
Is a given risk so great or the outcome so unacceptable that it must be refused altogether?
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HSE Everyday Risk Decision-Making Process
Is the risk, or has it been made, so small that no further precaution is necessary?
Is a given risk so great or the outcome so unacceptable that it must be refused altogether?
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HSE Everyday Risk Decision-Making Process
Is the risk, or has it been made, so small that no further precaution is necessary?
Is a given risk so great or the outcome so unacceptable that it must be refused altogether?
Has a risk, which falls between these two states, been reduced to the lowest level practicable, bearing in mind the benefits flowing from its acceptance and taking into account the costs of further reduction?
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Categories of Risk
Uses quantitative (cost or frequency) boundaries to separate the categories of
Unacceptable, Tolerable and Broadly Acceptable levels of risk.
The ‘normal’ MOD Risk to Life (RtL) four-category risk classification scheme:
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As Low As Reasonably Practicable ALARP
• ALARP defined as A risk is ALARP when it has been demonstrated that the cost of any further
Risk Reduction, where the cost includes the loss of defence capability as well as financial or other resource costs, is grossly disproportionate
to the benefit obtained from that Risk Reduction.
• ALARP principle appears ‘relatively simple’ • However hides significant subtleties and difficulties in its
robust and satisfactory application
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So Far As Is “Reasonably Practicable” SFAIRP
• “shall be the duty” is a strict liability which means that if the outcome occurs there will be no defence to a prosecution;
• “so far as is possible” what can be done - that is, what is possible in the circumstances for ensuring safety. The duty holder must then consider whether it is reasonable, in the circumstances to do all that is possible.
• “so far as is reasonably practicable” means it shall be done if the time, trouble and expense is not grossly disproportionate to the benefit gained
• SFAIRP appears 20 times in Health and Safety at Work Act 1974
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ALARP – HSE Perspective
• Using “reasonably practicable” allows us to set goals for duty-holders, rather than being prescriptive. This flexibility is a great
advantage but it has its drawbacks, too. Deciding whether a risk is ALARP can be challenging because it requires duty-holders
and us to exercise judgement. In the great majority of cases, we can decide by referring to existing ‘good practice’ that has been
established by a process of discussion with stakeholders to achieve a consensus about what is ALARP. For high hazards, complex or novel situations, we build on good practice, using
more formal decision making techniques, including cost-benefit analysis, to inform our judgement.
Reference: HSE Web Site http://www.hse.gov.uk/risk/theory/alarpglance.htm
http://www.hse.gov.uk/risk/theory/alarpglance.htm
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ALARP versus SFAIRP
• SFAIRP is – Enshrined in law; – What the courts will judge you against; – A judgement, based in the future, about actions in the past; – Subjective.
• ALARP is – Not part of any law; – A process used by HSE to help demonstrate SFAIRP; – A judgement about today which may not be valid tomorrow; – Subjective.
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Getting to ALARP – A Process?
Risk to be shown to be ALARP when…..
Mandatory or prescribed requirements defined in legislation
are in place.
The Entire scope of the system, equipment, feature or design element
affected have been considered.
Alternative control measures have been considered with the safest option being applied wherever
reasonably practicable.
Relevant good practice has been identified, considered and
implemented.
Is Residual Risk Broadly Acceptable?
(Risk Class D)
Document into ALARP Statement
YES
NO
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Getting to ALARP Application of “legislation”
• Within the United Kingdom (UK) we comply with all applicable HS&EP legislation.
• Overseas we apply our UK arrangements where reasonably practicable and, in addition, respond to host nations’ relevant HS&EP expectations.
• Where Defence has exemptions, derogations or disapplication's from HS&EP legislation, we maintain Departmental arrangements that produce outcomes that are, So Far As Is “Reasonably Practicable, at least as good as those required by UK legislation.
JSP 815 ANNEX A SAFETY, HEALTH, ENVIRONMENTAL PROTECTION AND SUSTAINABLE DEVELOPMENT IN THE MINISTRY OF DEFENCE - A Policy Statement by the Secretary of State for Defence signed 20/9/2010
PresenterPresentation Notes
Exemption A legislative instrument that specifically identifies that the Secretary of State (or other named authority) may authorise the exemption of some or all legislative requirements under a piece of legislation. The availability of an exemption must be written into the law concerned, which may make provisions as to the circumstances in which an exemption may be granted. An exemption will always require a formal authorisation by a named authority. Derogation A lessening or restriction of the authority, strength, or power of a law, right, or obligation which can have a caveat (e.g. must be solely for a specific purpose and not used for any dual purpose). Once a derogation is in place the use of the derogation does not require further legal authorisation by the relevant authority. However the SofS requires where a derogation exists that internal standards and management arrangements are in place that, so far as is reasonably practicable, produce outcomes at least good as those otherwise required by legislation Disapplication Legislation or a requirement within legislation, which explicitly states that it is not applicable to the MOD or defence activity and where the MOD does not have to officially do anything to use the exemption e.g. MARPOL but where internal processes may require action.
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Getting to ALARP - Good Practice
• ‘Good practice’ refers to measures, actions, procedures or specifications considered appropriate by professionals based on either experience of their application or a consensus view.
• Good practice is likely to ensure that risk is reduced to ALARP. • Applying good practice removes the need to assess safety risks from
first principles, as well as providing quick and effective guidance as to how to proceed in a particular set of circumstances.
• Good practice can include: – HSE – British and EN standards; – Defence or NATO Standards; – SOLAS; – ACOPs; – OEM Company Standards.
PresenterPresentation NotesACOP - Acceptable Code of PracticeSOLAS – Safety Of Life At Sea.
http://www.imo.org/home.asp?topic_id=424
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Getting to ALARP - Good Practice - Problems
• Applicability – examples:- – Defence Standards – infrequent updates; – IEC/EN standards – which, if any, apply.
• Who judges applicable “good practice” ?
– MOD Regulators - Defence Safety Authority (DSA) – SME – Manufacturer / Supplier
• New Technology (or novel application of existing technology)
– New hazards but no standards exist, therefore “good practice” not established.
PresenterPresentation NotesDefence Safety and Environment Authority (DSEA), the Military Aviation Authority (MAA) and Defence Fire Safety Regulator (DFSR)Defence Maritime Regulator (DMR), DOSR Defence Ordinance Munitions and Explosives Safety Regulator
International Electrotechnical Commission
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Getting to ALARP - Good Practice Evolves
Best Practice Good Practice
Good Practice Not
Good Enough Practice!
TOMORROW TODAY Knowledge, Experience, accidents
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Getting to ALARP - Do I need to do more?
PresenterPresentation NotesRIDDOR Reporting of Injuries Diseases and Dangerous Occurrences Regulations 1995 Definitions of injuries
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Getting to ALARP - Do I need to do more?
PresenterPresentation NotesRIDDOR Reporting of Injuries Diseases and Dangerous Occurrences Regulations 1995 Definitions of injuries
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Getting to ALARP - Do I need to do more?
PresenterPresentation NotesRIDDOR Reporting of Injuries Diseases and Dangerous Occurrences Regulations 1995 Definitions of injuries
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Getting to ALARP - Do I need to do more?
Examples
• Remove people from hazard
• PPE
PresenterPresentation NotesRIDDOR Reporting of Injuries Diseases and Dangerous Occurrences Regulations 1995 Definitions of injuries
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Getting to ALARP - Do I need to do more?
Examples
• Redundancy
• Defence in Depth
• Reliability
Examples
• Remove people from hazard
• PPE
PresenterPresentation NotesRIDDOR Reporting of Injuries Diseases and Dangerous Occurrences Regulations 1995 Definitions of injuries
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Getting to ALARP - Can I do more?
• Reasonably foreseeable “Control Measures” need to be considered – This needs SQEP to deduce control measures.
• Determine for each control measure whether it is reasonably practicable to apply. – This needs SQEP to deduce whether
• “practicable” (e.g. technology or process exists and it could be applied)
• “reasonably” (e.g. benefit is worth the trouble, cost benefit analysis, professional judgement or experience)
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Hierarchy of hazard control.
ERICPD Eliminate – the safest control measure is to eliminate the hazard completely.
Reduce or Substitute – Do it less often, reduce the number of people who do it, use something else.
Isolate – physically separate the hazards from people.
Control – A safe system of work, procedures, training, supervision, safety devices and tools.
Personal Protective Equipment – Gloves, eye protection, respirators etc.
Discipline – Ensure that all controls are monitored, enforced and reviewed.
Consider if these introduce new hazards
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Accidents - Example
Electricity
Hazard
Electric Shock
Accident
Degree of Harm
Tingling, Burns, broken bones, Death
Technical Publications
Safe System of Work (Risk Assessed)
Work Permits
Warnings and Cautions
Process Control
Equipment Design Standards
System Design Standards
Material Design Standards
Jigs and Tools
Design
First Aid Training
Medical Officer/Doctor
Medical Equipment
Hospital
Incident response training
MEDEVAC
Contingency
Access control
Electrical Isolation
Physical Isolation
Physical Control
Trained Operators / Maintainers
Qualified Operators / Maintainers
Experienced Operators / Maintainers
SQEP Protection
PPE
Earthing Arrangements
Insulating Arrangements
First Aid Response
Emergency Procedures
Rescue/Evacuation
Emergency
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‘Global’ Versus ‘Local’ Control Measures
• When thinking about systems or platforms it may be appropriate to apply a simple policy of consistent control measures to combat a common risk; some examples include Fire fighting methods, electrocution prevention, lighting, etc.
• Cost Benefit Analysis may show further control measures when applied globally across a platform/fleet would be grossly disproportionate. However, consideration of applying further control measures in specific, individual areas may not be grossly disproportionate.
• Global policies can be useful but may mask local hazard issues and therefore undermine ALARP.
• Zonal risk assessment should be considered and used to check that all reasonably practicable control measures are in place.
PresenterPresentation NotesEquipping a fire suppression sprinkler system in every compartment in a ship may be grossly disproportionateEquipping storage areas containing expensive equipment or explosive/inflammable goods may not.
Consider if these introduce new hazards
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Getting to ALARP - Guilty till proven innocent!
*Health and Safety at Work etc Act 1974
The onus of proving the limits of what is practicable
In any proceedings for an offence under any of the relevant statutory provisions consisting of a failure to comply with a duty or requirement to do something so far as is practicable or so far as is reasonably practicable, or to use the best means to do something, it shall be for the accused to prove (as the case may be) that it was not practicable or not reasonably practicable to do more than was in fact done to satisfy the duty or requirement, or that there was no better
http://cui6-uk.diif.r.mil.uk/r/929/SEP/0412/Local Settings/group/EUNDESShipsFWE/NATeam/04-RECDel/153-CME/Archived-CME/L_Presentation/ALARP/riding the shaft.wmv
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Getting to ALARP - Many ways to go to jail…..
• Not taking action to protect people (workers or public) from avoidable danger is a criminal offence.
• An accident does not need to happen for action to be taken against an employer (directors or managers, in our case Duty Holders or HoE).
• If action is taken it is up to the defendant to prove everything reasonably practicable was done to comply with the relevant H&S legislation.
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ALARP Statement – the case for the defence
• The ALARP statement outlines the basis of your defence of how you:- – Assessed the risk appropriately; – Complied with all relevant legislation; – Implemented relevant “good practice”; – Considered other reasonably foreseeable control
measures and implemented any which were reasonable practicable and showed that the rest were grossly disproportionate;
– Showed that the risk and associated risk reduction control measures were regularly reviewed.
• In hindsight, it should show how you proved that it was not practicable or not reasonably practicable to do more than was in fact done to satisfy the duty or requirement, or that there was no better.
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ALARP Statement - Pitfalls
• Are ALARP assessments suitably sufficient to demonstrate that we have managed the risk So Far As Is Reasonably Practicable? – Asserted ALARP; – Tweeted ALARP; – Unjustified Assumptions; – Difficult to judge if legislative compliance achieved; – Are we applying “good practice”? – Lack of demonstration of gross disproportion (i.e. sacrifice versus
benefit); – Open ended actions; (no such thing as Temporal ALARP) – No evidence of regular review of control measures; – Lack of diversity in the argument made;
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ALARP Statement - Example of Class B Risk
Twitter approach, fit statement into
Excel box
Tasks involving access to equipment at height are rare: Work at height subject to case-by-case risk assessment . This risk category has been classified as Tolerable with the managemnets endorsement (Class B risk) and is currently considered as ALARP. The risk only applies when personnel are working on top of the platform. Actions have been raised to obtain further detail on the exact hazard and existing safety measures and local risk assessments. No further mitigation is considered practicable.
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ALARP Statement - Example of Class B Risk
Twitter approach, fit statement into
Excel box Important actions still outstanding Tasks involving access to equipment at height are rare: Work at
height subject to case-by-case risk assessment . This risk category has been classified as Tolerable with the managemnets endorsement (Class B risk) and is currently considered as ALARP. The risk only applies when personnel are working on top of the platform. Actions have been raised to obtain further detail on the exact hazard and existing safety measures and local risk assessments. No further mitigation is considered practicable.
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ALARP Statement - Example of Class B Risk
Twitter approach, fit statement into
Excel box Important actions still outstanding
No demonstration that other control measures
were grossly disproportionate
Tasks involving access to equipment at height are rare: Work at height subject to case-by-case risk assessment . This risk category has been classified as Tolerable with the managemnets endorsement (Class B risk) and is currently considered as ALARP. The risk only applies when personnel are working on top of the platform. Actions have been raised to obtain further detail on the exact hazard and existing safety measures and local risk assessments. No further mitigation is considered practicable.
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ALARP Statement - Example of Class B Risk
Twitter approach, fit statement into
Excel box Important actions still outstanding
No demonstration that other control measures
were grossly disproportionate
No check of meeting legislative requirements
Tasks involving access to equipment at height are rare: Work at height subject to case-by-case risk assessment . This risk category has been classified as Tolerable with the managemnets endorsement (Class B risk) and is currently considered as ALARP. The risk only applies when personnel are working on top of the platform. Actions have been raised to obtain further detail on the exact hazard and existing safety measures and local risk assessments. No further mitigation is considered practicable.
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ALARP Statement - Example of Class B Risk
Twitter approach, fit statement into
Excel box Important actions still outstanding
No demonstration that other control measures
were grossly disproportionate
No check of meeting legislative requirements
No discussion of appropriate “good practice”
Tasks involving access to equipment at height are rare: Work at height subject to case-by-case risk assessment . This risk category has been classified as Tolerable with the managemnets endorsement (Class B risk) and is currently considered as ALARP. The risk only applies when personnel are working on top of the platform. Actions have been raised to obtain further detail on the exact hazard and existing safety measures and local risk assessments. No further mitigation is considered practicable.
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How to Show ALARP
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ALARP Statements - Proportionate to Risk
Its important to tell a story of “what we didn’t do” and why not, as much as it is to state “what we
decided to do”.
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Getting to ALARP - High Consequence
• If the hazard consequences are high then the analysis needs to be thorough: – Should we be doing the
risky activity? – Can the consequences be
reduced? – Am I certain of the analysis
which claims that the frequency is low.
• Can all this withstand detailed scrutiny.
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Cost Benefit Analysis (1) Consequences
• A hazard exists that an amphibious platform’s davit could have a structural failure whilst lifting a landing craft could result in the consequence of 2 deaths.
• From D Ships RCM this means the consequence is “Critical”.
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Cost Benefit Analysis (2) Frequency
• The annual frequency of occurrence of this accident is qualitative assessed as being no better than 1 in 10000 years but no worse than 1 in 1000 years (Probability of 0.001).
• From D Ships RCM this is “Remote”
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Cost Benefit Analysis (3) Risk Assessment
• Therefore the risk class is “B”
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Cost Benefit Analysis (4) Value to Prevent Fatality or Injury
• Values of VPI have been scaled from DfT published figures for 2007 in TAG unit 3.4: The Safety Objective, Table 4a: Average value of prevention per road accident by severity and class of road: all hours. The scaling factor used is D Ships VPF/DfT VPF = £2,000,000 / £1,876,830 = 1.065627, Serious injury is set at £215,170 (assumed equivalent to permanent RIDDOR), slight injury is set at £22,230 (assumed equivalent to Recoverable RIDDOR) and damage only is set at £ 1,970 (assumed equivalent to Non-RIDDOR injury).
• The value to prevent 2 fatalities is determined to be – 2 x £2,000,000 = £4,000,000
Level of Harm VPF /VPI
Individual Death from Industrial Disease e.g. Cancer (2 x VPF) £4,000,000
Individual Death Resulting from Accident (VPF) £2,000,000
Individual Permanent RIDDOR Injury (VPI) £229,291
Individual Recoverable RIDDOR Injury (VPI) £23,689
Individual Non-RIDDOR Injury (VPI) £2,099
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Cost Benefit Analysis (5) Safety Benefit
• The host platform is assumed to have 20 more years of service left before disposal.
• The benefits of preventing this accident occurring can be assessed as follows:- – Annual cost
• ‘Frequency’ x ‘value of preventing a fatality’ • 0.001 x £4,000,000 = £4,000 per year of platform life
– Or Lifetime cost • ‘Frequency’ x ‘value of preventing a fatality’ x lifetime • 0.001 x £4,000,000 x 20 years = £80,000
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Cost Benefit Analysis (6) Gross Disproportion
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A • Risk Class A = 10 x Cost
B • Risk Class B = 6 x Cost
C • Risk Class Cu = 4 x Cost
C • Risk Class Cl = 2 x Cost
D • Risk Class D = Cost
10 6 4 2 1
From MAA/HSE consultation
From MAA/HSE consultation
Tapered cost between A & D Risks
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Cost Benefit Analysis (7) Reasonable Practicable Test
• To rule out a control measure on the grounds that it is grossly disproportionate requires
Costs >= Disproportion Factor (DF) Safety Benefits
• which can also be written as
Costs => Disproportion Factor (DF) x Safety Benefits
• For our class B risk the Gross Disproportion Factor to be used in any CBA is x6
• Costs >= DF >= £4000 x 6 = £24,0000 per annum • Benefits
• OR >= DF >= £80,000 x 6 = £480,000 one off cost
• Therefore, any control measure that costs less than £24,000 per annum or less than
£480,000 as a one off cost would be deemed to be “reasonably practicable”.
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Getting to ALARP - Professional Judgement
• When Sacrifice or Benefit cannot be reasonably quantified, then a quantitative comparisons becomes impractical.
• How do you show that a risk is As Low As Reasonably Practicable? – Often such “first principles” comparisons can be done qualitatively,
i.e. by applying common sense and/or exercising professional judgment, or experience.[1]
[1] - http://www.hse.gov.uk/risk/theory/alarpglance.htm - sighted 5th May 2010
Professional Judgement!
http://www.hse.gov.uk/risk/theory/alarpglance.htmhttp://cui6-uk.diif.r.mil.uk/r/929/SEP/0412/Local Settings/group/EUNDESShipsFWE/NATeam/04-RECDel/153-CME/Archived-CME/L_Presentation/ALARP/BrickiesLabourerinBangladesh.wmv
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Getting to ALARP - “Ah, ha, ha, ha, Stayin’ ALARP.”
• ALARP is judgement about a risk today. • Tomorrow the risk may not be ALARP • Eventually, over a longer period of time,
the risk will not be ALARP (evolving best practice, new standards, laws, technology, material state degrades, etc.)
• Regular review of risks is required to remain or return to ALARP – Risk assessment – Legislation changes – Good practice – Control measure effectiveness – Failure data and accidents/incidents
ALARP
http://en.wikipedia.org/wiki/File:Bee_Gees_Stayin_Alive.jpg
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Operation
Maintenance
Documentation
System Design
Accident
Hazard
Hazard
‘Swiss cheese’ end to end safety model
• Consult & communicate • Treat the holes, watch creep • Look for trends & address • Increase barrier thickness • Share problems
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Getting to ALARP - “Ah, ha, ha, ha, Stayin’ ALARP.” Good Practice Evolves
Best Practice Good Practice
Good Practice Not
Good Practice Enough???
TOMORROW TODAY Knowledge, Experience, accidents
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Warning - Risk Compensation!
Propensity to take risks
Rewards
Perceived Danger Accidents
Balancing Behaviour
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But be warned - Idiots are getting smarter
JCB Gazebo
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Safety Ambition
Continually panicking
about safety
Perpetually uneasy about safety
Everything is
alright
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Safety Ambition
Continually panicking
about safety
Perpetually uneasy about safety
Everything is
alright
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Slide Number 1Hazard IdentificationHSE Everyday Risk Decision-Making ProcessHSE Everyday Risk Decision-Making ProcessHSE Everyday Risk Decision-Making ProcessSlide Number 6As Low As Reasonably Practicable�ALARPSo Far As Is “Reasonably Practicable”�SFAIRPALARP – HSE PerspectiveALARP versus SFAIRPGetting to ALARP �– A Process?Getting to ALARP�Application of “legislation”Getting to ALARP - Good PracticeGetting to ALARP - Good Practice - ProblemsGetting to ALARP - Good Practice�EvolvesGetting to ALARP - Do I need to do more?Getting to ALARP - Do I need to do more?Getting to ALARP - Do I need to do more?Getting to ALARP - Do I need to do more?Getting to ALARP - Do I need to do more?Getting to ALARP - Can I do more?Slide Number 22Accidents - Example‘Global’ Versus ‘Local’ Control MeasuresGetting to ALARP - Guilty till proven innocent!Getting to ALARP - Many ways to go to jail…..ALARP Statement – the case for the defenceALARP Statement - PitfallsALARP Statement - Example of Class B RiskALARP Statement - Example of Class B RiskALARP Statement - Example of Class B RiskALARP Statement - Example of Class B RiskALARP Statement - Example of Class B RiskHow to Show ALARPALARP Statements - Proportionate to RiskGetting to ALARP - High ConsequenceCost Benefit Analysis (1)�ConsequencesCost Benefit Analysis (2)�FrequencyCost Benefit Analysis (3)�Risk AssessmentCost Benefit Analysis (4)�Value to Prevent Fatality or InjuryCost Benefit Analysis (5)�Safety BenefitCost Benefit Analysis (6)�Gross DisproportionCost Benefit Analysis (7)�Reasonable Practicable TestGetting to ALARP - Professional JudgementGetting to ALARP - “Ah, ha, ha, ha, Stayin’ ALARP.”Slide Number 46Getting to ALARP - “Ah, ha, ha, ha, Stayin’ ALARP.” Good Practice EvolvesWarning - Risk Compensation!Slide Number 49Safety AmbitionSafety AmbitionSlide Number 52