SAFETY REPORTS
of Safety Report
n Reg 4
n Every operator shall take all measures
necessary to prevent major accidents
and limit their consequences to persons
and the environment
SAFETY REPORTS
n Reg 7(7)
n 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
n Part1-The purposes referred to in Reg7
are as follows:
n 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 2
Minimum Information to be included in a
Safety Report
Identification and accidental risk analysis
and prevention methods:
n detailed description of the possible
major accident scenarios
n and their probability ----------- Bang!
1
 Schedule 4 -Part 2
Minimum Information to be included in Existing Guidance
a Safety Report

n Identification and accidental risk n HSE has produced a suite of guidance

analysis and prevention methods: documents concerning ALARP. These
n 4(b)assessment of the extent and severity are designed to give high level
of the consequences of identified major principles which D/Ds can then use to
accidents promulgate sector specific advice.
n (R2P2 p76) n The documents are:
n Reducing Risk, Protecting People
(R2P2);
Population
ABC Chem Tank

ALARP in COMAH Existing Guidance (continued)

n Principles and guidelines to assist HSE in its

judgments that duty-holders have reduced
nFor practical purposes: risk as low as reasonably practicable;
n All Measures Necessary
n Assessing compliance with the law in
individual cases and the use of good practice;
(AMN)=SFAIRP=ALARP and
n ALARP in Design - Policy and Guidance.

2
 Relationship between R2P2 and the ALARP Demonstration
ALARP Suite
"Reducing Risks, Protecting People"

informs * ".... suitable controls must be in place

place to
to
'ALARP legal commentary
'R2P2' Principles and + policy address all significant
significant hazards
hazards ....
.... and
and
informs ** Guidelines'
those controls, at a minimum, must
HSE's implement authoritative good practice
practice
Information expectation Guidance
e.g. TOR
to Staff irrespective of situation-based risk
to Stakeholders framework,
primacy of
'Good
'Design'
D/Ds' estimates ...."
...."
Good Practice' Guidance
Practice,
tolerability
criteria
"authoritative
"authoritative good
good practice"
practice" =
HSE's expectation/enforcement policy prescriptive legislation, ACOPs,
* Annex 3 of R2P2 reflects the ALARP guidance
guidance
guidance produced
produced by
by government.
government.
** 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
Unacceptable Region deciding whether a risk is unacceptable,
and societal concerns
Increasing Individual

tolerable or broadly acceptable

acceptable ...."
...."
Tolerable Region "individual risks also give rise to societal
concerns and the latter
latter often
often play
play aa far
far
greater role in deciding whether risk is
Broadly Acceptable Region unacceptable or not."

3
 ALARP Diagram

A L A R P P rin c iple Unacceptable region

Level of risk cannot be justified except in extraordinary circumstances.

M e aa ssuurreess ttoo rreed ___________________________________________________

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
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
____________________________________________________

reduction wou u lld

d b e g r o s s ly Broadly acceptable region
Level of residual risk is regarded as insignificant and further effort
d i s p r o p o r t i o n a t e ( G D ) t o tth
hee to reduce risk not likely to be required. ALARP demonstration based upon
reduction in risk that w o u ld adherence to codes, standards and established good practice. These must
be shown to be up to date and relevant to the operations in question.
be achieved.

Case Specific ALARP

Solicitor`s guidance demonstration
"We believe it is right that, in all Operator has to answer the
cases, the judgment as to following fundamental
whether measures are grossly question:
disproportionate should reflect
societal risk, that is to say, large
numbers of people (employees "What more can I do
or the public) being killed at one to reduce the risks "?
go. "

4
Case Specific ALARP Proportionate Risk Assessment
demonstration
The depth of the analysis in the
Also: operators report should be
proportionate to
"Why have I not done a) the nature and scale of the
it"? MAHs
b) the risks posed to
neighbouring populations

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

5
 ALARP Demonstration
Risk estimation
Selection of a representative n But the higher the installation lies on the
societal concerns scale the greater the need
set of events to look for additional measures, over and
above the normal standards.
Estimation of consequences and frequency How to approach?
n 1. Identify risk reduction measures.
for each event n 2. Assess using Lines Of Defence analysis with
cost estimates
n 3. Possibly, in extreme cases, add a Cost Benefit
Ranking & screening (e.g risk matrix, fn Analysis.
curves)

Risk Matrix (Illustrative)

Proportionality: Type of ALARP Demo.
Risk reduction
regardless of cost Intolerable
Likely >10-2
Intolerable Intolerable Intolerable Intolerable Intolerable

Relevant Good Practice

Plus
TIFALARP(Int TIFALARP(Int
Unlikely olerable if
Fatality >10-3)
olerable if
Fatality >10-3)
Intolerable Intolerable Intolerable Risk reduction
10-4-10-2 Measures
Plus Tolerable if ALARP
Gross
Very Unlikely
TIFALARP TIFALARP TIFALARP/Int TIFALARP/Int Intolerable Disproportion
olerable olerable
10-6-10-4

Remote Broadly Broadly

TIFALARP/Br
oadly
TIFALARP TIFALARP Relevant Good
Acceptable Acceptable
10-6-10-8 Acceptable? Practice
Broadly Acceptable
Single Fatality 2-10 Fatalities 11-50 Fatalities 50-100 Fatalities 100+ Fatalities

6
 `So what`
Sensitivity and uncertainty
analysis If all the risks are BA then
compliance with good practice
Would being more thorough be demonstrates ALARP
worthwhile?
Otherwise the events that
Uncertainties in models, data, contribute significantly to the
methodology.
risks need to be identified, risk
Cautious best-estimate basis.
basis. reduction options compiled,and
appropriate decision aids used
Adopt Precautionary Approach
p89
(eg LOPA for simple cases
p89 91R2P2
91R2P2
CBA for more difficult ones)

Purpose of SR is to demonstrate
ANMs (ALARP) from an activity
(`risk from what`) If AMNs are in place for each
major accident scenario then
Four combinations (`risk of what`
and `risk to what`):
there is nothing more that can be
done and professional judgement
1 IR to those on-site will suffice.
2 IR to those off-site
3 SR to those on-site
4 SR to those off-site
`Explicit` detailed quantification of
risks is not necessary unless the
proportionality is high