03/02/2016
ALARP "Practicable application" for safety professionals and duty holders.
The application of health and safety does not have to be complicated, costly or time-consuming and although many safety professionals know about “as low as reasonably practicable” (ALARP) they sometimes struggle to clearly advise duty holders about whether those control measures reduce risks ALARP without the cost being grossly disproportionate in the benefits of achieving risk reduction.
For safety professionals, the application of “reasonably practicable” allows us to advise duty-holders, rather than being unbending while for the duty holder it allows them to choose the method that is best for them and so it supports innovation, however it has its drawbacks, too. Deciding whether a risk is ALARP can be challenging because it requires duty-holders to exercise judgment between achieving compliance and ‘best practice’. In the great majority of instances, duty holders can rely on established ‘best practice’ that has been implement within industry. For high hazards, complex or novel situations, duty holders should use a more formal decision making process, including consultation and cost-benefit analysis, to assist in their judgement.
Of course, in reality many decisions about risk and the controls that achieve ALARP are not so obvious. Factors come into play such as ongoing costs set against remote chances of one-off events, or daily expense and supervision time required to ensure that, for example, employees wear ear protection against a chance of developing hearing loss at some time in the future. It requires judgment. There is no simple formula for computing what is ALARP
Once what is ‘best practice’ has been determined, much of the discussion with duty-holders about if a risk is or will be ALARP is likely to be affected with the application of the ‘best practice’, and how appropriately it has been (or will be) implemented - Where there is established, appropriate and recognised ‘best practice’, duty-holders need to follow it. If they want to do something different, they must be able to demonstrate that the measures they propose to use are at least as effective in controlling the risk.
Our decision about what is ALARP is constant evolving process, which is affected by changes in knowledge about the size or nature of the risk presented by a hazard. If there is sound evidence to show that a hazard presents significantly greater risks than previously thought, then of course we should press for stronger controls to tackle the new situation. However, if the evidence shows the hazard presents significantly lesser risks than previously thought, then we should accept a relaxation in control provided the new arrangements ensure the risks are ALARP.
As safety professionals we need recognise that ALARP does not represent zero risk. We have to expect the risk arising from a hazard to be occur at some time, and as a consequence that harm may result, even though the risk is ALARP. This is an uncomfortable thought for many safety professionals, however it is inevitable. Of course we should always strive to make sure that duty-holders reduce and maintain the risks ALARP, and we should never be complacent, nevertheless, the reality is that we need to accept that risk from an activity can never be entirely eliminated unless the activity is stopped.