This presentation is based on content presented at the Industry Forum on Reducing Approval Times What is Reasonably Practicable held on 14 November 2014 It is made available for noncommercial use eg toolbox meetings safety discussions subject to the condition that the PowerPoint f ID: 775229
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This presentation is based on content presented at the Industry Forum on Reducing Approval Times: What is “Reasonably Practicable”?, held on 14 November 2014It is made available for non-commercial use (e.g. toolbox meetings, safety discussions) subject to the condition that the PowerPoint file is not altered without permission from Resources Safety For resources, information or clarification, please contact:RSDComms@dmp.wa.gov.auor visitwww.dmp.wa.gov.au/ResourcesSafety
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Slide2How do you demonstrate that risks are ALARP (or SFAIRP or reasonably practicable)?Shane DanielManager Critical Risks, Dangerous Goods and Petroleum Safety
Submission of a safety case or report
2
Slide3RISK is UNAVOIDABLEWhat is important is how you MANAGE it
Slide4Leadership and accountability
It is ALWAYS the responsibility of
senior leaders
in an organisation to actually
LEAD
—
lead
by WORDS, lead by ACTIONS
—
and be ACCOUNTABLE
Slide5SAFEEXPLORATION
Controlling major accident events
Basic requirement for MAE control measures — must collectively reduce risk to health and safety of people to a level as low as is reasonably practicable (ALARP)Use a risk assessment process
Slide6Reduction of risk to ALARP
Depends on:recognition of hazards having potential to cause MAEs implementation of necessary control measures for each hazard Essential that demonstration of ALARP principle is included in the safety case
Slide7Q: How do I demonstrate ALARP?
A: There
is no single correct way to “demonstrate”
ALARP. However
,
for each
MAE identified for the facility,
demonstration should
contain elements of
following:
Identification and consideration of a range of potential measures for risk reduction (both those adopted and those rejected
)
Systematic analysis of each of the identified measures and a view formed on the safety benefit associated with each of
them
Evaluation of the reasonable practicability of the identified measures and the adoption or rejection of
each
Recording of the process and
results (to
be summarised in the safety
case)
Slide8Get the balance rightThe balance between any benefits in terms of reduced risk and the costs of control measures will play a part in achieving and justifying ALARP
Slide9Balance – what’s that?
Slide10Q: What if all my controls aren't in place?
A: Implementation arrangements should be included for any risk control measures that are planned but not yet in place (i.e. scheduled implementation)
Slide11Q: Do I have to include all hypothetical control measures in my safety case?
A: While
there is no explicit requirement within the regulations to record in the safety case the full range of control measures that has been
considered ….
the
content and level of detail
need
to be sufficient to gain an appreciation of the scope and process for undertaking the
consideration, including:
sources
of
data
rationale
for excluding or discounting items from
consideration
Slide12Q: What approach should I use?
A: Given all the issues that may need consideration when demonstrating the necessary control measures have been identified … it is appropriate to develop an approach that is:logicalstructuredefficient
Slide13Performance standardsShould be set for MAE control measuresThe safety case needs to include an argument as to why these standards are appropriate
Slide14Q: How will my safety case be assessed?
A: For safety case acceptance purposes, DMP will consider the operator’s approach in terms of its robustness, transparency and appropriateness to the facility.Operator should therefore define the following for the case:underlying rationalecriteriabasis for decisions made
Slide15Safety case submission — critical factors for success
O
perator
should attempt to address at least
following
specific factors in their consideration of
ALARP:
Timeliness
— t
he
earlier an operator undertakes an ALARP evaluation, the greater the ability to reduce risks to a level that is
ALARP
Slide16Safety case submission — critical factors for success
Operator should attempt to address at least following specific factors in their consideration of ALARP:Timeliness — the earlier an operator undertakes an ALARP evaluation, the greater the ability to reduce risks to a level that is ALARPSafety case content that is consistent with regulatory requirements
Slide17Safety case submission — critical factors for success
O
perator
should attempt to address at least
following
specific factors in their consideration of
ALARP:
Timeliness
— t
he
earlier an operator undertakes an ALARP evaluation, the greater the ability to reduce risks to a level that is
ALARP
Safety
case
content
that is
consistent
with
regulatory requirements
Involvement
of people
who
know the facility
or a very similar
operation
Slide18Safety case submission — critical factors for success
O
perator
should attempt to address at least
following
specific factors in their consideration of
ALARP:
Timeliness
— t
he
earlier an operator undertakes an ALARP evaluation, the greater the ability to reduce risks to a level that is
ALARP
Safety
case
content
that is
consistent
with
regulatory requirements
Involvement
of people
who
know the facility
or a very similar
operation
Access
to and inclusion of information from a wide range of
reference material
(e.g. standards
, safety alerts, best
practice)
Slide19Safety case submission — critical factors for success
Description
with
sufficient level
of
detail
that
explains
means
by which
operator
ensures suitability
of the
design
,
construction
,
installation
,
operation
,
maintenance
or
modification
appropriate to
the
facility
Slide20Safety case submission — critical factors for success
Description
with
sufficient level
of
detail
that
explains
means
by which
operator
ensures suitability
of the
design
,
construction
,
installation
,
operation
,
maintenance
or
modification
appropriate to
the
facility
T
ransparent
and robust presentation of
evidence
showing:
adopted
control measures reduce risk to
ALARP
SMS
provides
for and will
continue
to provide
for
reduction of risk to ALARP
, and
is
comprehensive and
integrated
Slide21DMP needs to know ….
Slide22References to consider
regnet.anu.edu.au/publications/wp-27-relationship-between-reasonably-practicable-and-risk-management-regulation
Bluff, L., and Johnstone, R., 2004,
Working Paper 27
–
The
r
elationship
b
etween ‘reasonably
p
racticable
’
and risk
m
anagement
r
egulation
:
National
Research Centre for
OHS Regulation, Canberra
www.safeworkaustralia.gov.au/sites/swa/about/publications/pages/guide-reasonably-practicable
Safe Work Australia,
2013,
How to determine what is reasonably practicable to meet a health and safety duty
www.safeworkaustralia.gov.au/sites/SWA/about/Publications/Documents/607/Interpretive guideline - reasonably practicable.pdf
Safe Work Australia, 2011,
Interpretive Guideline – model Work and Safety
Act –
the meaning of ‘reasonably
p
racticable’
www.hse.gov.uk/risk/theory/alarpglance.htm
ALARP ‘at a glance
’
www.theiet.org/factfiles/health/hsb17-page.cfm?type=pdf
The
Institution of Engineering and
Technology, 2012,
Reasonable
p
racticability
: Health & Safety Briefing No. 17
Slide23Don’t forget – Stay informed!
Visit www.dmp.wa.gov.au/ResourcesSafetyto sign up for our weekly news alerts
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