SAFETY REPORTS • Reg 4 • Every operator shall take all measures necessary to prevent major accidents and limit their consequences to persons and the environment
SAFETY REPORTS • 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
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.
Schedule 4 -Part 2Minimum 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 -----------
Schedule 4 -Part 2Minimum 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)
ALARP in COMAH • For practical purposes: • All Measures Necessary (AMN)=SFAIRP=ALARP
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);
Existing Guidance (continued) • 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.
'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
Risk Matrix (Illustrative) Likely >10-2 Intolerable Intolerable Intolerable Intolerable Intolerable TIFALARP(Intolerable if Fatality >10-3) TIFALARP(Intolerable if Fatality >10-3) Unlikely 10-4-10-2 Intolerable Intolerable Intolerable TIFALARP TIFALARP TIFALARP/Intolerable TIFALARP/Intolerable Intolerable Very Unlikely 10-6-10-4 TIFALARP/Broadly Acceptable? TIFALARP TIFALARP Remote 10-6-10-8 Broadly Acceptable Broadly Acceptable Single Fatality 2-10 Fatalities 11-50 Fatalities 50-100 Fatalities 100+ Fatalities
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.