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

2. 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

3. 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.

4. Schedule 4 -Part 2 Minimum 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 -----------

5. 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)

6. ALARP in COMAH For practical purposes: All Measures Necessary (AMN)=SFAIRP=ALARP

7. 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);

8. 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.

9. Relationship between R2P2 and the ALARP Suite * 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 Information to Stakeholders legal commentary + policy 'R2P2' 'ALARP Principles and Guidelines' 'Good Practice' 'Design' D/Ds' Guidance HSE's expectation/enforcement policy HSE's expectation e.g. TOR framework, primacy of Good Practice, tolerability criteria informs * informs ** Guidance to Staff

22. Risk Matrix (Illustrative) Single Fatality2-10 Fatalities11-50 Fatalities50-100 Fatalities100+ Fatalities Remote 10 -6 -10 -8 Very Unlikely 10 -6 -10 -4 Unlikely 10 -4 -10 -2 Likely >10 -2 Intolerable Broadly Acceptable Intolerable Broadly Acceptable TIFALARP(Int olerable if Fatality >10-3) TIFALARP/Int olerable TIFALARP TIFALARP/Br oadly Acceptable? TIFALARP Intolerable TIFALARP(Int olerable if Fatality >10-3) TIFALARP TIFALARP/Int olerable

23. 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.

24. Proportionality: Type of ALARP Demo.