SAFETY REPORTS SAFETY REPORTS. Schedule 4-Purpose and Contents of Safety Report

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Trevor French
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1 SAFETY REPORTS Reg 4 Every operator shall take all measures necessary to prevent major accidents and limit their consequences to persons and the environment Schedule 4-Purpose and Contents of Safety Report 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 Schedule 4 -Part 2 Minimum Information to be included in a Safety Report Reg 7(7) 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: detailed description of the possible major accident scenarios and their probability Bang! 1

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

2 Schedule 4 -Part 2 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) ABC Chem Tank Population Existing Guidance 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) For practical purposes: All Measures Necessary (AMN)=SFAIRP=ALARP 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. 2

These are designed to give high level principles which D/Ds can then use to promulgate sector specific advice.

3 Relationship between R2P2 and the ALARP Suite Information to Stakeholders 'R2P2' informs** HSE's expectation e.g. TOR framework, primacy of Good Practice, tolerability criteria informs* 'Good Practice' 'ALARP Principles and Guidelines' 'Design' legal commentary + policy D/Ds' Guidance 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 Guidance to Staff 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. HSE framework for the tolerability of risk Unacceptable Region Tolerable Region Broadly Acceptable Region 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." Increasing Individual and societal concerns 3

expectation/enforcement policy * Annex 3 of R2P2 reflects the ALARP gu

4 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. 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. 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 "? 4

Tolerable region If the risks fall in this region then a CASE SPECIFIC ALARP demonstration is required.

5 Case Specific ALARP demonstration Also: "Why have I not done it"? 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 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 that measure 5

nature and scale of the MAHs b) the risks posed to neighbouring populations BLEVE if the measure appears reasonable

6 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) 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. Risk Matrix (Illustrative) Likely >10-2 Proportionality: Type of ALARP Demo. Risk reduction regardless of cost Relevant Good Practice Unlikely Very Unlikely (Int olerable if Fatality >10-3) (Int olerable if Fatality >10-3) /Int olerable /Int olerable Plus Risk reduction Measures Plus Gross Disproportion Tolerable if ALARP Remote Broadly Acceptable Broadly Acceptable /Br oadly Acceptable? Single Fatality 2-10 Fatalities Fatalities Fatalities 100+ Fatalities Relevant Good Practice Broadly Acceptable 6

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.

7 Sensitivity and uncertainty analysis Would being more thorough be worthwhile? Uncertainties in models, data, methodology. Cautious best-estimate basis. Adopt Precautionary Approach p89 91R2P2 `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) 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 7

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

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