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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 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:
RSDComms@dmp.wa.gov.au
or visit
www.dmp.wa.gov.au/ResourcesSafety
www.dmp.wa.gov.au/ResourcesSafety
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Submission of a safety case or report
How do you demonstrate that risks are ALARP (or
SFAIRP or reasonably practicable)?
Shane Daniel
Manager Critical Risks, Dangerous Goods and
Petroleum Safety
www.dmp.wa.gov.au/ResourcesSafety
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RISK is UNAVOIDABLE
What is important is how you MANAGE it
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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
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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
SAFE
EXPLORATION
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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
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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)
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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
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Balance – what’s that?
High benefit – Low cost
High cost – Low benefit
High cost – High benefit
Low cost – Low benefit
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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)
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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
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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
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Performance standards
Should be set for MAE
control measures
The safety case needs to
include an argument as to
why these standards are
appropriate
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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
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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
www.dmp.wa.gov.au/ResourcesSafety
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
www.dmp.wa.gov.au/ResourcesSafety
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
www.dmp.wa.gov.au/ResourcesSafety
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)
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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
www.dmp.wa.gov.au/ResourcesSafety
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
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DMP needs to know ….
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References to consider
regnet.anu.edu.au/publications/wp-27-relationship-between-reasonably-practicable-and-riskmanagement-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
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 practicable’
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 practicability: Health &
Safety Briefing No. 17
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