Welcome Guest! The IOSH forums are a free resource to both members and non-members. Login or register to use them

Postings made by forum users are personal opinions. IOSH is not responsible for the content or accuracy of any of the information contained in forum postings. Please carefully consider any advice you receive.

Notification

Icon
Error

Options
Go to last post Go to first unread
Ime Alfred  
#1 Posted : 29 August 2012 09:25:58(UTC)
Rank: Forum user
Ime Alfred

How do you and your organization define and practice the concepts of "acceptable risk" and "as low as reasonably practicable (ALARP)?"

teh_boy  
#2 Posted : 29 August 2012 09:38:01(UTC)
Rank: Super forum user
teh_boy

http://www.hse.gov.uk/risk/theory/r2p2.pdf

A good place to start!

I assume this is an exam question?
Bruce Sutherland  
#3 Posted : 29 August 2012 10:05:43(UTC)
Rank: Forum user
Bruce Sutherland

and if its a for real question then it depends............

IMHO all you can do is clearly document why you reached your conclusion. As categorically if it goes pear shaped this will be tested and regardless of what HSE or any regulator puts on their website, societal pressure is to look at enforcement

I saw a summary of the recently revised and much thinner guidance for schools and then remembered a crown court case following a fatality involving a school party caving in Yorkshire - HSE lost the case

My point is that Tolerability of Risk and SFARP has not really changed at all but it takes a brave regulator not to " allow the courts" to take the decision - others may argue that is the purpose of the legal system to take the decision away from an individual and place the responsibility on a group of 12 normal citizens. And again I would say that depends.....

Kind regards

Bruce
Steveeckersley  
#4 Posted : 29 August 2012 11:02:51(UTC)
Rank: Forum user
Steveeckersley

Bruce Sutherland wrote:
and if its a for real question then it depends............

IMHO all you can do is clearly document why you reached your conclusion. As categorically if it goes pear shaped this will be tested and regardless of what HSE or any regulator puts on their website, societal pressure is to look at enforcement

I saw a summary of the recently revised and much thinner guidance for schools and then remembered a crown court case following a fatality involving a school party caving in Yorkshire - HSE lost the case

My point is that Tolerability of Risk and SFARP has not really changed at all but it takes a brave regulator not to " allow the courts" to take the decision - others may argue that is the purpose of the legal system to take the decision away from an individual and place the responsibility on a group of 12 normal citizens. And again I would say that depends.....

Kind regards

Bruce

Bruce I have a problem with this term "Tolerable" For me this term goes against the grain of the whole ethos of safety. It implies that not doing something is acceptable when principles of H&S in simplistic terms is to Identify the level of risk and reduce SFAIRP or SFAIP.

Hypothetical Example: Number of deaths in hospital across Scotland due to MRSA or some other nasty little bacteria might be 20 per year. Risk reduction plan is put into place and the number is reduced to 15 per year. The statement is then used that this number is "Tolerable" To me this is just wrong Morally and ethically forgetting the HSE aftermath. One death due to these diseases is not tolerable and therefore I am aghast to see this term being used within any context of health and safety as in my opinion it flies in the face of the heirachy of controls which we alll recognise. "Lets not eliminate the peoblem because its tolerable" It may be tolerable but is it acceptable!
JJ Prendergast  
#5 Posted : 29 August 2012 11:17:52(UTC)
Rank: Super forum user
JJ Prendergast

To say a risk is 'Tolerable' is acceptable - otherwise money/time/effort will be expended in trying to mitigate every risk/hazard whether it is reasonably forseeable or not.

Haven't we heard this somewhere before ..... like HASWA!!

The law does not require 100% safety. Sadly even with the best of efforts people will die at work/as a result of work activities.

So what is the cost of a life? That is for a Court and society to accept/define.

To endorse 100% safety / risk mitigation and you end up with some of the stupid decisions that are often seen in the press, slating h&s experts and so often discussed on this forum.

To take silly example - even in a well designed building with multiple floors, its is still foreseeable that a defect may develop and someone falls down a flight of stairs and is seriously injured or killed.

It may happen only every 100yrs.

However it is still possible to prevent this type of accident by designing all building to be on a ground floor level - but is this what society wants....

So what is your acceptable and Tolerable risk level that society will accept??

Answers on a postcard ....
John J  
#6 Posted : 29 August 2012 12:08:05(UTC)
Rank: Super forum user
John J

Perhaps a good example of the publics view of tolerability was when asbestos was found in (new york I think) schools. Parents were up in arms demanding action be taken. The authorities closed the schools with immediate effect. Within a week the parents were demanding the schools be reopened and the children re admitted. The reason, cost of child care and inconvenience through missing work. An intolerable risk was suddenly tolerable.
chris.packham  
#7 Posted : 29 August 2012 12:14:04(UTC)
Rank: Super forum user
chris.packham

May I add another element for confusion? COSHH requires the exposure to a substance hazardous to health to be eliminated so far as is reasonable practicable or "where this is not possible, adequately controlled". However, nowhere is what is meant by adequately controlled defined. In earlier versions of COSHH it was defined as: "Controlled to a standard such that nearly all the population could be exposed repeatedly without adverse effect to health"
"Nearly all, repeatedly, adverse effect to health" - what do these mean?
In the latest version even this doubtful definition has been omitted.

Given that according to the EU Agency for Safety and Health at Work measuring the effect of skin exposure is not possible how could we determine 'adequately controlled' anyway?

“However, there is no scientific method of measuring the results of the body’s exposure to risk through dermal contact. Consequently no dermal exposure standards have been set.” - Occupational skin diseases and dermal exposure in the European Union (EU-25):policy and practice overview - European Agency for Safety and Health at Work

Chris
peter gotch  
#8 Posted : 29 August 2012 12:45:32(UTC)
Rank: Super forum user
peter gotch

In its guidance as to the interpretation of reasonable practicability, HSE reference the Court of Appeal judgment in Edwards v National Coal Board (1949) which concluded

“‘Reasonably practicable’ is a narrower term than ‘physically possible’ and seems to me to imply that 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 on 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.”

However, in the subsequent case of Marshall v Gotham (1954), the House of Lords judgment was slightly different:

“The test …… is not simply what is practicable as a matter of engineering, but depends on the consideration, in the light of the whole circumstances at the time of the accident, whether the time, trouble and expense of the precautions suggested are or are not disproportionate to the risk involved, and also an assessment of the degree of security which the measures may be expected to afford”.

There has been some criticism of HSE’s continued reference to gross disproportion e.g. in a House of Lords Select Committee report on the Management of Risk. See www.publications.parliam...ct/ldeconaf/183/183i.pdf from paragraph 62.
jericho  
#9 Posted : 29 August 2012 12:51:29(UTC)
Rank: Forum user
jericho

Some good points made here but the question was how do YOU define the phrases. And I think that is the key; DO you define these in your organisations? We do. In our risk management documentation we set out what we mean by tolerable and acceptable. Now others may disagree with those definitions and that's fine, but they are ours. To us, tolerable is something to be put up with for now. It absolutely does not mean 'that's it, stop looking' but we are also very clear that chasing rainbows is not what what we are about. The concept of continuous improvement is fine until you reach where you want to be. Typically that point is ALARP. For some activities ALARP may actually be high risk, so we have to tolerate that until something comes along that we can apply. To accept that in our view would simply be to stop looking. However, that must be inked to the level of risk. High risk would be tolerated after consideration and there'd be a management plan in place. Medium risk stuff may be slightly harder to shift and it's entirely possible that no further gains may be possible. But still we'd tolerate although me may not look quite as hard into the future. Once we reach low risk activities, we have a slightly different view. Locally the managers must have them in mind but are unlikely to be asked to do more than the usual periodic management of them. As a business, low risk activities would be pretty much accepted as part of normal operations. As to insignificant risk - well, that's the point - it's insignificant. So setting definitions for phrases like tolerability, for us, are actually set not only against the levels of risk, but the levels of the business too. This means that only the important stuff is reported to the people who need to act and they are not inundated with trivia (at their level) This has allowed us to:
Identify significant risk
Act upon it in priority order
Outline residual (what's left)
Manage accordingly in line with what's tolerable for us

We (all of us) are expected to manage our business appropriately and rather then looking outwards for others' definitions and examples, we need to set our own boundaries and be confident with them. We actually put all of this into a summary document that managers can pass to enforcement officers when they visit. Sure they can have policies and whatnot too, but a single simple outline of why we do what we do, like we do, has gone down very well.

JJP - agree with what you are saying. What the public will tolerate or accept is sometimes very fickle. It all depends on how much 'outrage' they feel. Someone falls off a cliff, into a canal, off a station platform - well that's their fault. A child falls off a school stage - it's hilarious. Someone trips in a pothole and there is outrage. It's seldom linked to the level of risk, it's more about ownership of the hazard, perhaps. You can't set a definition of what is acceptable other than by examples where it either was or wasn't. Or you end up with something like 'Tolerable is that which the majority of people would not consider as being someone's fault other than their own' or something pointless like that.

Luckily (other than the courtroom) our definitions are not governed by the public's perceptions.

Jericho
jwk  
#10 Posted : 29 August 2012 13:03:17(UTC)
Rank: Super forum user
jwk

We have a flexible definition of tolerable risk, as our activities are diverse and very disparate.

For example, in our Warehouse we will tolerate risk (subject to the necessary controls) to which we would not expose the patients in our hospices.

The phrases you're looking for are; risk tolerance, which is a measure of the risk an organisation is able to bear without collapse; and risk appetite, which sets out how much risk the organisation thinks is acceptable. The appetite is usually smaller than the tolerance.

So our risk appetite in patient-facing services is very very low; there are certain events for which our appetite is effectively zero, though we haven't got there in all cases as yet. In our commercial arm we will tolerate risk SFARP, as it's difficult to, for example, deliver a second-hand piano without some risk (road risk, equipment risk, attitudinal risk, MHO risk etc),

John
Bruce Sutherland  
#11 Posted : 30 August 2012 09:15:20(UTC)
Rank: Forum user
Bruce Sutherland

Steve

I note your obvious dislike of tolerability but how does zero risk work?

Kind regards

Bruce
RayRapp  
#12 Posted : 30 August 2012 09:46:23(UTC)
Rank: Super forum user
RayRapp

One of better debates on this forum. Whilst there is the legal definition(s) of SFAIRP, it is and I believe always will be, subject to interpretation. Different circumstances will call for different decisions and of course the benefit of hindsight often has a part to play in the decision making process. The concept of risk is essentially subjective although there will be many areas of general agreement. However when it comes to the 'difficult' decisions there will undoubtedly be different opinions. I am not overly comfortable with the courts deciding what is SFAIRP. The law is in a constant state of flux, plus the decision makers often have poor understanding of the concepts of risk management.

The HSE document R2P2 previously highlighted explains the TOR concept from a regulators' perspective. Whilst some elements are interesting to the purist, most will not be relevant to a commercial enterprise. The concept of TOR is similar to Cost Benefit Analysis (CBA). The process of CBA is not strictly objective as some would beleive, it is a tool used to justify a commercial decision. For instance, whether a life is worth £100k or £1m depends on whose life it is. The morality of such a decision making process has no place in the cold commercial world of cost v safety.
A Kurdziel  
#13 Posted : 30 August 2012 10:27:07(UTC)
Rank: Super forum user
A Kurdziel

What we are talking about is appetite for risk. Some organisations are very tolerant of risk and are willing to spend money to take a risk right down; others are more willing to accept a certain level of risk. A simple example is we have had reports of a couples of slips/trips on the greasy flags (pavers) (it’s raining now in York). We are arranging to have the slabs cleaned and the question of where do we start was asked. The company line is “Do it nearest the entrance as this is were the visitors come in.” This means, that the appetite for risk in relation to our own staff, is greater than in relation to members of the public coming onto our site.
Can we achieve a zero level of risk? No, not unless we close down the site and all go home.
Steveeckersley  
#14 Posted : 30 August 2012 12:13:17(UTC)
Rank: Forum user
Steveeckersley

Bruce - I just dislike this word "Tolerable" in the context of Risk and safety.
Why have we brought in these terms when we had adequate standard terms that most seem to understand and could apply.Im not asking for "Zero" because in reality where their is life Zero will never happen. However in Violence and agression at work - Zero Tolerance is used (Zero is the aspiration and Tolerance is the standard)
The use of the term "Tolerable" suggests a standard known yet if you apllied it to EH 40 then you are saying every human can tolerate to that level when we know humans toleration levels are quite differenet between each other e.g 2 pints or 4 pints
If we use the term tolerable in the Safety v Business situation (Cost V Risk) Then I think its even more fraught.
Remember Management strategies originate in historical warfare theories.
To then use the term "Tolerable" is like asking Julius Caeser is losing a legion acceptable (collateral damage).
Im sure some sherrif in court is going to find it very amusing when a company tries to defend itself with the use of "It was in our opinion Tolerable" M'lord or our Risk appetite was compromised by the need to get the Vehicle unloaded quickly.
I dont want to live in a black and white world but I want some sense of guidance in common terms as to whats acceptable without using more "Buzz terms"
teh_boy  
#15 Posted : 30 August 2012 12:47:03(UTC)
Rank: Super forum user
teh_boy

@steveeckersley But I would describe road risk as tolerable.
5 - 10 deaths a day clearly not good

But society 'tolerates' this for a change to drive a few miles an hour faster.... (ducks awaiting heavy shouting from people who like fast cars)

In industry such as COMAH I can't think of a better word? - I think you are confusing the term with SFARP in your example - see my link to the HSE document for a mathematical explanation!
Steveeckersley  
#16 Posted : 31 August 2012 11:10:16(UTC)
Rank: Forum user
Steveeckersley

teh_boy wrote:
@steveeckersley But I would describe road risk as tolerable.
5 - 10 deaths a day clearly not good

But society 'tolerates' this for a change to drive a few miles an hour faster.... (ducks awaiting heavy shouting from people who like fast cars)

In industry such as COMAH I can't think of a better word? - I think you are confusing the term with SFARP in your example - see my link to the HSE document for a mathematical explanation!

Another way of interpreting the word Tolerable is "Threshold"
Again in my opinion this is about standard and therefore encourages people not to take action because the standard has been set.
Take the road deaths! One of the worst ones we have in Scotland is the Perth to Inverness A9. If you say 20 deaths per year is tolerable then that is the threshold that will be measured against what happens in 12 months time so if only 19 die then nothing will be done when infact we should be proactive about reducing the risk even further!
To me this is what the term Tolerable risk will mean in practise and thats why I dont like it!
John J  
#17 Posted : 31 August 2012 11:48:52(UTC)
Rank: Super forum user
John J

'Tolerability' does not mean 'acceptability'.
Tolerability means you are prepared to live with a particular situation understanding the benefits it may give. It involves regularly reviewing the risk and applying new technologies as they arise, should they be appropriate.
Acceptability is that you leave it as as and do nothing.
peter gotch  
#18 Posted : 31 August 2012 13:03:57(UTC)
Rank: Super forum user
peter gotch

Steve

Noone is tolerating level numbers of RTC fatalities which is why there has been a downwards trend (albeit with a slight upwards blip last year) for over 20 years.

Transport Scotland have 10 major projects in the pipeline on the A9 at various stages of procurement.

But can't be all down now, and a lot less cuts to the programme than south of the Border.

Forth Replacement Crossing on site

M8 completion and associated improvements on other M-ways and trunk roads - in procurement

Aberdeen Western Peripheral Route - procurement should start next year subject to judgment of Supreme Court

....and lots of smaller schemes.

.....and tolerability is not a new buzzword. Started off with 1988 HSE publication.
Bruce Sutherland  
#19 Posted : 31 August 2012 16:55:04(UTC)
Rank: Forum user
Bruce Sutherland

Quite agree Peter - "nuclear power and all that" and from that span off IMHO the way that modern H and S thinking was meant to be as opposed to the risk avoidance situation that frequently we seem to be in.

Then WE as like it or not and despite the fact that perhaps some of us screamed and kicked against it WE the safety profession have allowed the concept to change. Whether it is HSE or Insurance or Safety Practioners driving it is really a cart / horse or chicken and egg situation but we are certainly a long way away from where I thought it was meant to be...........

I am not sure that we can go back now either as commercially we have created some very big and powerful monsters that will not allow the necessary changes as they make money from the current situation.

SFARP does allow a balance of cost and personally I always that the idea of cost benefit analysis for safety was not only necessary in society, but also what we as professionals were paid to do? It is obviously tough if its you or your loved ones but we do seem to live in a world where we get excited over using light eye protection and then ignore the fact that people are still using disc cutters without any or the wrong type of eye protection as an example.......
Users browsing this topic
Guest
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.