Safe Communities & a Sustainable Hazaedous Industry : Present and Future Discussion

1. Safe Communities & a Sustainable Hazaedous Industry : Present and Future Discussion

2. Purpose and Contents of Safety Report Demonstrating that major accidents hazardshave beenidentified and that the necessary measures have been taken to prevent such accidents and to limit their consequences for persons and the environment.

3. Minimum 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 -----------

4. Minimum 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)

5. ALARP in COMAH_____ All Measures Necessary (AMN) = SFAIRP = ALARP

6. Existing Guidance____________ HSE has produced a suite of guidance documents concerning ALARP. These are designed to give high level principles.

7. 'R2P2' 'ALARP Principles and Guidelines' 'Good Practice' D/Ds' Guidance 'Design' Relationship between R2P2 and the ALARP Suite informs* legal commentary + policy informs** HSE's expectation e.g. TOR framework, primacy of Good Practice, tolerability criteria Guidance to Staff Information to Stakeholders 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

9. ALARP Demonstration____ “Reducing Risks, Protecting People” “…. suitable controls must be in place to address all significant hazards …. and those controls, at a minimum, must implement authoritative good practice irrespective of situation-based risk estimates ….” “authoritative good practice” = prescriptive legislation, ACOPs, guidance produced by government

10. ALARP Demonstration_______ “Reducing Risks, Protecting People” “… both individual risks and societal concerns …. must be taken into account in deciding whether a risk is unacceptable, tolerable or broadly acceptable …” “individual risks also give rise to societal concerns and the latter often play a far greater role in deciding whether risk is unacceptable or not.”

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

12. Principles 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.”

13. 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.

14. Case Specific ALARP demonstration____________ Operator has to answer the following fundamental question: What more can I do to reduce the risks”?

15. Case Specific ALARP demonstration____________ Also: “Why have I not done it?”

16. If the measure appears reasonable and it cannot be shown that the cost of the measure is grossly disproportionateto the benefit to be gained, then the Operator is duty bound to implement that measure

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

19. Risk estimation____________ • Selection of a representative set of events • Estimation of consequences and frequency for each event • Ranking and screening (eg risk matrix, fn curves)

20. Risk Matrix (Illustrative) Intolerable Intolerable Intolerable Intolerable Intolerable Likely >10-2 TIFALARP (Intolerable if Fatality >10-3) TIFALARP( (Intolerable if Fatality >10-3) Unlikely 10-4-10-2 Intolerable Intolerable Intolerable Very Unlikely 10-6-10-4 TIFALARP TIFALARP TIFALARP/ Intolerable TIFALARP/ Intolerable Intolerable TIFALARP/ Broadly Acceptable? TIFALARP TIFALARP Remote 10-6-10-8 Broadly Acceptable BroadlyAcceptable Single Fatality 2-10 Fatalities 11-50 Fatalities 50-100 Fatalities 100+ Fatalities

21. 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.

22. Proportionality: Type of ALARP Demo

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

24. Purpose of SR is to demonstrate AMNs (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

25. `So what` 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)

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

27. Questions?