“ALARP”
is short for “as low as reasonably practicable”. “SFAIRP” is short for “so far
as is reasonably practicable”. The two terms mean essentially the same thing
and at their core is the concept of “reasonably practicable”; this involves
weighing a risk against the trouble, time and money needed to control it. Thus,
ALARP describes the level to which we expect to see workplace risks controlled.
How we use ALARP
Using
“reasonably practicable” allows us to set goals for duty-holders, rather than
being prescriptive. This flexibility is a great advantage but it has its
drawbacks, too. Deciding whether a risk is ALARP can be challenging because it
requires duty-holders and us to exercise judgement. In the great majority of
cases, we can decide by referring to existing ‘good practice’ that has been
established by a process of discussion with stakeholders to achieve a consensus
about what is ALARP. For high hazards, complex or novel situations, we build on
good practice, using more formal decision making techniques, including
cost-benefit analysis, to inform our judgement.
Why do I need to know about ALARP?
The
concept of “reasonably practicable” lies at the heart of the British health and
safety system. It is a key part of the general duties of the Health and Safety
at Work etc. Act 1974 and many sets of health and safety regulations that we
and Local Authorities enforce. HSC’s policy is that any proposed regulatory
action (Regulations, ACoPs, guidance, campaigns, etc.) should be based on what
is reasonably practicable. In some cases, however, this may not be possible
because the Regulations implement a European directive or other international
measure that adopt a risk control standard different from “reasonably
practicable” (i.e. different from what is ALARP).
Because
ALARP is fundamental to the work of the whole organisation, it is important
that everyone, whatever their role, knows about it. Here are some specific
reasons for you to know about ALARP and its relationship with good practice,
but this is not an exhaustive list.
- Policy makers and those
engaged in Programme delivery need to know about ALARP because when you
make proposals for HSC/E action to control health or safety risks, you
need to make sure that, as far as possible, those controls will reduce the
risks to employees (or other people, as the case may be) ALARP.
- Enforcers need to know about ALARP
because you will have to decide whether duty-holders have reduced their
risks ALARP and so have complied with the law.
- Technical specialists in HSE need to know about
ALARP because you advise colleagues in HSE about whether control measures
reduce risks ALARP and you help identify standards of risk control that
are ALARP.
What is meant by reasonably practicable?
You may
come across it as SFAIRP (“so far as is reasonably practicable”) or ALARP (“as
low as reasonably practicable”). SFAIRP is the term most often used in the
Health and Safety at Work etc Act and in Regulations. ALARP is the term used by
risk specialists, and duty-holders are more likely to know it. We use ALARP in
this guidance. In HSE’s view, the two terms are interchangeable except if you
are drafting formal legal documents when you must use the correct legal phrase.
The
definition set out by the Court of Appeal (in its judgment in Edwards v.
National Coal Board, [1949] 1 All ER 743) is:
“‘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.”
In
essence, making sure a risk has been reduced ALARP is about weighing the risk
against the sacrifice needed to further reduce it. The decision is weighted in
favour of health and safety because the presumption is that the duty-holder
should implement the risk reduction measure. To avoid having to make this
sacrifice, the duty-holder must be able to show that it would be grossly
disproportionate to the benefits of risk reduction that would be achieved.
Thus, the process is not one of balancing the costs and benefits of measures
but, rather, of adopting measures except where they are ruled out because they
involve grossly disproportionate sacrifices. Extreme examples might be:
- To spend £1m to prevent five
staff suffering bruised knees is obviously grossly disproportionate; but
- To spend £1m to prevent a
major explosion capable of killing 150 people is obviously proportionate.
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 defenders set 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.
It can
get very complicated. More detailed ALARP suite of guidance[1] and your Directorate/Divisional
ALARP guidance (where available) explains how to deal with some of these
complications.
How to tell if a risk is ALARP
Using
“reasonably practicable” allows us to set goals for duty-holders, rather than
being prescriptive. This flexibility is a great advantage. It allows
duty-holders to choose the method that is best for them and so it supports
innovation, but it has its drawbacks, too. Deciding whether a risk is ALARP can
be challenging because it requires duty-holders and us to exercise judgment.
Deciding by good practice
In most
situations, deciding whether the risks are ALARP involves a comparison between
the control measures a duty-holder has in place or is proposing and the
measures we would normally expect to see in such circumstances i.e. relevant
good practice. "Good practice” is defined in the general ALARP guidance[2] as “those standards for
controlling risk that HSE has judged and recognised as satisfying the law, when
applied to a particular relevant case, in an appropriate manner.” We decide by
consensus what is good practice through a process of discussion with
stakeholders, such as employers, trade associations, other Government departments,
trade unions, health and safety professionals and suppliers.
Once what
is good practice has been determined, much of the discussion with duty-holders
about whether a risk is or will be ALARP is likely to be concerned with the
relevance of the good practice, and how appropriately it has been (or will be)
implemented.. Where there is relevant, recognised good practice, we expect
duty-holders to follow it. If they want to do something different, they must be
able to demonstrate to our satisfaction that the measures they propose to use
are at least as effective in controlling the risk.
Deciding on ‘first principles’
Where the
situation is complex, it may be difficult to reach a decision on the basis of
good practice alone. There may also be some cases (for example, a new
technology) where there is no relevant good practice. In such cases, good
practice should be followed as far as it can be, and then consideration given
to whether there is any more that can be done to reduce the risk. If there is
more, the presumption is that duty-holders will implement these further
measures but this needs to be confirmed by going back to first principles to
compare the risk with the sacrifice involved in further reducing it.
Often
such “first principles” comparisons can be done qualitatively, i.e. by applying
common sense and/or exercising professional judgment. or experience. For
example if the costs are clearly very high and the reduction in risk is only
marginal, then it is likely that the situation is already ALARP and further
improvements are not required. In other circumstances the improvements may be
relatively simple or cheap to implement and the risk reduction significant:
here the existing situation is unlikely to be ALARP and the improvement is
required. In many of these cases a decision can be reached without further
analysis.
But there
are some instances (often in high hazard industries or where there is a new
technology with potentially serious consequences) where the situation is less
clear-cut. In such cases, a more detailed comparison has to be undertaken. The
trouble is that risk and sacrifice are not usually measured in the same units,
so it’s a bit like comparing apples and pears. In these instances, a more formal
Cost Benefit Analysis (CBA) may provide additional insight to help come to a
judgment.
In a CBA,
we convert both risk and sacrifice to a common set of units – money – so that
we can compare them. We represent:
- Sacrifice as a cost; and
- Risk , in so far as it is being
reduced, as a benefit.
There’s
more detail (such as which costs to take into account and which risks to
consider) in the ‘CBA checklist’[3] and Directorates’ own guidance.
We then
compare the sacrifice (cost) and the risk reduction (benefits). In a standard
CBA, the usual rule applied is that the measure should be adopted only if
benefits outweigh costs. However, in ALARP judgments, the rule is that the
measure must be adopted unless the sacrifice is grossly disproportionate to the
risk. So, the costs can outweigh benefits and the measure could still be
reasonably practicable to introduce. How much costs can outweigh benefits
before being judged grossly disproportionate depends on factors such as how big
the risk is to begin with (the larger the risk, the greater can be the
disproportion between the cost and risk).
This
looks straightforward, but it is worth noting that there are many assumptions
and uncertainties involved in CBA – further discussion can be found in ‘HSE principles for Cost Benefit Analysis
(CBA) in support of ALARP decisions[4]’ - and indeed in many aspects of risk analysis. In
any case, the outcome of a CBA is only one of several considerations that go
towards the judgment that a risk has been reduced ALARP. For example, in policy
work and in those parts of operational work dealing with high hazards you may
also need to consider how the public feel about the risk. There is more detail
about taking account of such “societal concerns” in “Reducing Risks, Protecting
People”.