Please read this before using presentation 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 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: or visit 1

How do you demonstrate that risks are ALARP (or SFAIRP or reasonably practicable)? Shane Daniel Manager Critical Risks, Dangerous Goods and Petroleum Safety Submission of a safety case or report 2

RISK is UNAVOIDABLE What is important is how you MANAGE it

Leadership 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

SAFE EXPLORATION 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

Reduction 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

Q: 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)

Get the balance right The balance between any benefits in terms of reduced risk and the costs of control measures will play a part in achieving and justifying ALARP

Balance – what’s that? High benefit – Low cost High cost – Low benefit High cost – High benefit Low cost – Low benefit

Q: 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)

Q: 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

Q: 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: logical structured efficient

Performance standards Should be set for MAE control measures The safety case needs to include an argument as to why these standards are appropriate

Q: 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 rationale criteria basis for decisions made

Safety 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 ALARP

Safety 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 ALARP Safety case content that is consistent with regulatory requirements

Safety 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 ALARP Safety case content that is consistent with regulatory requirements Involvement of people who know the facility or a very similar operation

Safety 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 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)

Safety 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

Safety 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 Transparent 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

DMP needs to know ….

References 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 relationship between ‘reasonably practicable’ and risk management regulation: National Research Centre for OHS Regulation, Canberra Safe Work Australia, 2013, How to determine what is reasonably practicable to meet a health and safety duty guideline - reasonably practicable.pdf Safe Work Australia, 2011, Interpretive Guideline – model Work and Safety Act – the meaning of ‘reasonably practicable’ ALARP ‘at a glance’ The Institution of Engineering and Technology, 2012, Reasonable practicability: Health & Safety Briefing No. 17

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