14 September 2021
There is no prescribed methodology for demonstrating that necessary control measures are actively managed to ensure risks are reduced to 'As Low as Reasonably Practicable' (ALARP). However, there are several basic approaches that may be used to support provision of evidence and justification.
ALARP demonstration can be justified in several ways such as through navigating regulatory requirements by focusing on the relevant and applicable local and international legislation, regulatory guidance, codes and standards or through sound engineering judgement to ensure robust decision-making is made through application of engineering and scientific principles and methods.
For key safety decisions, engineering judgement should follow the hazard management hierarchy
in the decision-making process. The hazard management hierarchy requires a focus on inherent safety principles as shown in Figure 1.
Where feasible, inherently safer solutions produced through elimination or prevention of a hazard are always preferred over other engineering controls. These are also preferred over administrative or procedural controls which rely on human interactions.
A key element of ALARP demonstration is to ensure that there are no other practical measures that could reasonably be taken to further reduce safety risks. To achieve this objective, effort should be targeted at the major risk contributors associated with a facility or activity.
Potential additional control measures should always be evaluated in terms of technical feasibility, cost, time to implement, and risk reductions achieved as shown in Figure 2 to ensure the trade-offs in the decision-making process are understood.
There is no silver bullet for demonstrating what the necessary control measures have been and will continue to be identified to reduce risks to ALARP. BMT uses the following approach, which can be used in addition to other methods. This is determined by the nature of the facility and the scenario in consideration. The ALARP triangle, shown at Figure 3, demonstrates the decreasing of risk and the diminishing proportional benefits of risk.
We, consider the following approaches to demonstrate ALARP:
Risk Criteria Based Approach: In this approach, the company or regulatory risk tolerability targets are assigned, and ALARP is demonstrated by comparing against the assigned.
Cost-Benefit Analysis (CBA): A numerical assessment is performed on the costs of implementing a control barrier or modification and the likely reduction in fatalities that would be expected. Also, criteria on the value of a life or implied cost of averting a statistical fatality (ICAF) is considered. There is no simple cut-off and additional factors, including uncertainty, need to be considered in the decision-making.
Qualitative Approach: A combination of various practices are assessed in this approach, including comparing against industry specific codes and standards, audit against good practices, technical analysis, performance data on the operational effectiveness or the reliability of a control measure
Engineering Judgement: In this approach, as the name suggests we consider if the engineering judgement has sufficient controls in place, the nature of the controls are within parameters, and their position in the control is relevant. Similarly passive measures are more suitable than active engineering measures which in turn shall be considered more suitable than administrative or procedural controls.
BMT has experience in preparing ALARP demonstration reports for all type of facilities and is able to offer safety and risk solutions to overcome safety and regulatory challenges.
Client A: Chemical Production Facility
ALARP Demonstration example: Gap analysis with relevant codes and standards (Qualitative approach)
In this example the existing chemical production facility had to undergo an ALARP demonstration to meet the new local safety case regulations. Considering the complexity of the facility, a qualitative approach was adopted for the ALARP demonstration. As part of this approach, a gap analysis was performed against applicable industry codes and standards (e.g., API, ISO, and RP) to identify areas for improvement in the existing control barriers as well as design principles. Following the gap analysis, a brainstorming session with all stakeholders was conducted to assess how the identified gaps should be addressed and implemented to schedule. We recommended that the overall requirement for evidence of ALARP applies equally to operations and ongoing maintenance as well as being applicable to future facility design and construction programs.
Client B: Onshore Storage Terminal
ALARP Demonstration example: Combined approach
A Major Accident Event (MAE) scenarios was assessed as high risk against the company’s risk matrix. A combined approach was adopted for this scenario, initially existing control barriers were assessed based on a qualitative approach followed by assigning risk tolerability targets as per company tolerance criteria. A Layer of Protection Analysis (LOPA) was applied to identify initiating events as well as calculating the residual risks to determine the amount of risk reduction required to bring the risk to ALARP. BMT assigned the Safety Integrity Level (SIL) to this barrier and proposed to install SIL1 system to demonstrate ALARP. Based on the detailed review of the system, an independent level switch or transmitter was recommended. This would provide an alarm to a control room and/or independent operator such that procedural action can be taken.
This technical article has discussed how various approaches can be taken to demonstrate ALARP for a facility or specific activity. The article provides a proven structured framework to ALARP demonstration for how an organisation manages safety and how it should guide future decision around selecting and assessing control barriers.
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