Please read this before using presentation
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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 or Graham
Bower-White
For information about this presentation, please contact the author
Graham Bower-White, gbw@tsrhorizons.com
For other information, please contact:
RSDComms@dmp.wa.gov.au
or visit
www.dmp.wa.gov.au/ResourcesSafety
www.dmp.wa.gov.au/ResourcesSafety
1
What is “reasonably practicable”?
Graham Bower-White
Executive Director Operations
TSRhorizons Consulting
www.dmp.wa.gov.au/ResourcesSafety
2
ALARP – What is reasonably
practicable?
Graham Bower-White
4
Overview
•
•
•
•
A Reminder
Core Concepts
ALARP – How it works
2-Step Process
5
A Reminder
MONTARA - 2009
• failure to follow good oilfield practice
• failure to follow internal procedures
• lack of understanding of controls in place
• failure to realise that only one effective barrier was in place and that
the integrity of that barrier was compromised
6
A Reminder
MACONDO - 2010
• failure to recognise that primary barrier integrity was compromised
• failure to conduct appropriate tests on controls in place
• poor design of the blowout preventer
• failure of the blowout preventer
• lack of control of ignition sources
7
Establishing
context
Risk assessment
Risk identification
Risk analysis
Risk evaluation
Risk treatment
REF: ISO 31000: Risk Management
Monitoring and review
Communication and consultation
Risk Management
8
ALARP Background
‘Reasonably practicable’ is a narrower term than
‘physically possible’ … a computation must be made by
the owner in which the quantum of risk is placed on
one scale and the sacrifice involved in the measures
necessary for averting the risk (whether in money, time
or trouble) is placed in the other, and that, if it be
shown that there is a gross disproportion between
them – the risk being insignificant in relation to the
sacrifice – the defendants discharge the onus on them.
UK Court of Appeal (Edwards v. National Coal Board [1949])
9
ALARP Principle
• If a measure is practicable and it cannot be
shown that the cost of the measure (in money,
time and effort) is grossly disproportionate to
the benefit gained; then the measure is
considered reasonably practicable and should
be implemented.
• The criterion is reasonably practicable not
reasonably affordable: justifiable cost and
effort is not determined by the budget
constraints/viability of a project.
10
Risk-based Decision Making
REF: NOPSEMA, N-04300-GN0166, ALARP
Safety Case Lifecycle
Figure 5 - Continuous Improvement in Safety through Implementation of the Safety Case
Level of RIsk
Safety Case Development
Continuous Improvement
Identify
Hazards
Assess
Risks
Implement
Controls
Identify
Controls
Identify
Hazards
Manage
Safety
Implement
Controls
Identify
Controls
Assess
Risks
ALARP
Safety Case
Submission
11
If carried out properly, the process of developing the safety case will improve safety of offshore activities by
ensuring a systematic review of the hazards, their associated risks and the control measures that are
applied at the facility to either eliminate the hazards or otherwise reduce the risks. Progress, in terms of
risk reduction, is achieved by applying the process both during initial development of the safety case and
subsequently in the course of continuous improvement (Figure 5).
REF: NOPSEMA, N-04300-GN0166, ALARP
It is expected that over the life of a facility an operator’s risk management processes will identify
opportunities to enhance the effectiveness of existing control measures or implement additional control
Many operators of offsho re facilities may elect to assess and evaluate risks in a quantitative or
semi-quantitative manner, and to develop criteria against which to compare the estimated risk
levels. It must be noted , however, that all risk assessment is subject to uncertainty. For this
reason, most approaches evaluate risk based on broad ranges of risk, ra ther than on specific
criteria.
12
Quantitative Risk Analysis
Figure 3 - Example of an ALARP triangle
REF: NOPSEMA, N-04300-GN0166, ALARP
This document may be
freely copied or reprinted
0060
- 16 of 24 -
N-04300-GN0166
Revision 3, December 2011
13
Qualitative Risk Assessment
NOTE: Example only
14
Qualitative Risk Assessment
REF: NOPSEMA, N-04300-GN0271, Control Measures and Performance Standards
15
Bow-Ties
Fault Tree
Event Tree
Toxic Gas Cloud
On Facility
Unignited Blowout
Link To BowTie
(Unignited Blowout)
7500.SH.01
Installation Of H2S
Trim Equipment
Mud Gas Separator
Connected To
Flaring System
Immediate Well
Shut In Upon H2S
Detection
Facility Ventilation
Systems
Turn Rig To Put H2S
Down Wind
Restricted Access To
Higher Risk Work
Areas
H2S Contingency
Plan
OIM Offshore Installa…
RM Rig Manager
RM Rig Manager
TP Toolpusher
ES Electrical Supervisor
OIM Offshore Installa…
OIM Offshore Installa…
RM Rig Manager
Usage Of H2S
Scavenger Material
In Mud
Maintain Higher
Than Normal Mud
PH Level
H2S Gas Detectors
In Mud Pit
Regular Mud
Properties Testing
Installation Of Extra
SCBA Sets
Installation Of H2S
Cascade System
Up Wind Mustering
MEDIVAC Of
Casualties
Facility Medical Care
RM Rig Manager
RM Rig Manager
ES Electrical Supervisor
OIM Offshore Installa…
RM Rig Manager
RM Rig Manager
OIM Offshore Installa…
OIM Offshore Installa…
MED Medic - SHE Officer
Ventilation Of Tanks
Prior To Entry
Confined Space
Entry Permit To
Work
H2S Gas Detectors
Hand Held
BE Barge Engineer
OIM Offshore Installa…
BE Barge Engineer
A3 A2 A1 A1
Present In Mud
Returns
Inhalation Of
Toxic Gas
Hydrogen
Sulphide - H2S
Bacterial H2S In
Tanks
Wind Direction
Not Known
Installation Of
Windsock
RM Rig Manager
7500.SH.04
Toxic Gas
Release
Well Testing Loss
Of Containment
Link To BowTie
(Well Testing)
7500.SH.03
Installation Of H2S
Trim Equipment
Provision Of H2S
Training For
Personnel
OIM Offshore Installa…
RM Rig Manager
RM Rig Manager
H2S Gas Detectors
On Drill Floor
Formation Core
Handling
Restrictions
Clean Shaven Policy
In H2S Area
ES Electrical Supervisor
OIM Offshore Installa…
OIM Offshore Installa…
Radio
Communication With
Adjacent Facility
Pre-Well Planning /
HAZID
Link To BowTie
(Large Scale Fire)
7500.SH.05
BE Barge Engineer
RM Rig Manager
OIM Offshore Installa…
H2S Gas Detectors
On Drill Floor
Logging Tool
Handling
Restrictions
Link To BowTie
(Facility Evacuation)
7500.VH.11
ES Electrical Supervisor
OIM Offshore Installa…
OIM Offshore Installa…
Present In
Formation Cores
SCBA Do Not Seal
Over Facial Hair
Gas Release From
Adjacent facility
Large Scale Fire
Present With
Logging Tools
A3 A1 A3 A2
Facility
Evacuation
NOTE: Example only
A2 A4 A4 A4
Personnel
Unfamiliar With
H2S Equipment
A4 A0 A1 A3
16
ALARP Demonstration
• So…
– We’ve assessed our risk using Qualitative and/or
Quantitative risk assessment.
Does that mean that risks are demonstrably
ALARP?
17
2-Step Process
• Step 1
– Demonstrate that risks are tolerable/acceptable
• Step 2
– Demonstrate that all practicable risk reduction
measures have been implemented
– Justifying what HASN’T been implemented is as
important
18
How to get over that 2nd Step!
•
•
•
•
Identify all further risk reduction measures
Assess the potential risk benefit
Assess the potential cost ($, risk, schedule)
Is cost grossly disproportionate to benefit?
– If yes, REJECT measure and document
– If no, measure should be implemented
19
Gross Disproportionality
ICAF (Implied Cost of Averting a Fatality)
*PLL = Probability of Loss of life
REF: Safe Work Australia, Guide for Major Hazard Facilities: Safety Case: Demonstrating The Adequacy of Safety
Management and Control Measures
20
Case Study: Qualitative
• Small pipelay barge
• ~75m in length
• SOLAS / IMO / Class Compliant
• Life-rafts only – NO LIFEBOATS
Case 1: Littoral waters, no live HC present
• Is Evacuation risk ALARP?
Case 2: Pipelay in vicinity of HC-producing asset
• Is Evacuation risk still ALARP?
21
Case Study: Quantitative
QRA sensitivity analysis shows risk reduction
measure would achieve 0.005 reduction in PLL
Therefore:
Justifiable Spend = Reduction in PLL x ICAF
= 5.0E-03 x 100,000,000
= $500,000
So: if the measure costs less $500,000 or less it
should be implemented