obtain a “neutral” view of uncertainties that is acceptable for all stakeholders and thereby confine stakeholder discourse to questions to preference only? To what extent is it possible to balance such a “neutral” view and the purely subjectivist position – that probability is a subjective, personal construction?
An important issue is the choice of appropriate risk metrics, which is particu- larly important from a risk communication perspective, and for cases involving multiple stakeholders. The approach we applied in the Risk Level Project, as discussed in Section 7.1 for assessing risk on sector level, should be compared with other approaches e.g., the social amplification of risk (Kasperson, 1992) and the analytical-deliberative process (Stern and Fineberg, 1996).
Another issue is the need for development of appropriate problem decompo- sition methods for risk and vulnerability identification and analysis (including extending the logic modelling techniques – such as Fault Tree and Event Tree to include influence diagrams), essential for capturing different dimensions of complex risk issues. The work must be seen in relation to the BORA project Aven et al. (2006a), which develops improved methodology for operational risk analysis including analysis of the performance of safety barriers, with respect to technical systems as well as human, operational and organisational factors.
To support the development of suitable theories and methods, there is a need for further research exploring the inter-relationships between economic theory, decision analysis and safety science:
x How and to what extent factors other than economic performance measures are and should be given weight, and how these factors can be measured and/or handled. Special focus should be on factors not directly related to the companies’ core activity such as social responsibility and potential loss of goodwill.
x To what extent risk reducing measures are external effects for agents (companies and organisations), in the sense that they are beneficial for society but not necessarily for the agent in question.
x How these issues are influenced by public regulations and actions.
Some of the areas that need to be addressed relate to portfolio theory and safety management, the use of the cautionary and precautionary principles, the inter- actions between government and companies, and incentives in decision processes.
This work will extend the research results reported in Chapter 2.
In such a context one also needs to be aware of the link between productivity growth and risk. Good risk management is generally claimed to be productivity enhancing, while the opposite is true of poorly designed schemes. If this is so, why is not risk management a higher priority both in theory and practice?
ALARP demonstrations in other societal activities, such as rail transport of personnel.
In the UK there are requirements for ALARP demonstration in the Health and Safety at Work Act (1974). In the past, such requirements were also stated in the Safety Case Regulations (1992) (HSE, 1992), but these regulations were revised in April 2006 (HSE, 2006). This part of the revision is merely formal however; the authorities expect that Safety Cases for offshore installations will continue to include an ALARP demonstration.
Similarly, Section 9 of the Norwegian Framework Regulations (PSA, 2002) requires that risk reducing measures are implemented unless their cost is in gross disproportion to the benefits. Thus it may be argued that the legal requirements for ALARP demonstrations are quite similar in UK and Norwegian legislation.
There are however, some distinct differences between UK and Norwegian requirements. One difference is that UK regulations call explicitly for a written statement, describing the ALARP process that has been conducted. One of the main parts of the Safety Case is an ALARP demonstration.
In Norwegian regulations there is only an implicit requirement for documenta- tion of the ALARP process. There is a general documentation requirement in Nor- wegian legislation, but no explicit requirement to document the ALARP process.
The common practice is also that ALARP processes are not documented.
Another significant difference between UK and Norway is that UK authorities have focused considerable attention on ALARP demonstration/documentation, whereas Norwegian authorities until recently have paid little or no attention to Sec- tion 9 of the Framework Regulations. For several years, the Norwegian authorities focused mainly on the use of risk acceptance limits, sometimes in a rather mechanistic manner.
The UK authorities have also published several guidance documents, intended to provide the industry with practical assistance on how to interpret and conduct the ALARP demonstrations. The main documents issued by HSE are the follo- wing:
x Reducing Risk Protecting People – HSE’s Decision-making Process (HSE, 2001a);
x “The ALARP trilogy”, consisting of the following documents:
o Principles and guidelines to assist HSE in its judgements that duty- holders have reduced risk as low as reasonably practicable (HSE, 2001b).
o Assessing compliance with the law in individual cases and the use of good practice (HSE, 2003a).
o Policy and Guidance on reducing risks as low as reasonably practi- cable in Design (HSE, 2003b).
x Guidance on ALARP for Offshore Division Inspectors making an ALARP demonstration (HSE, 2003c).
x HID’s approach to “As Low As Reasonably Practicable” (ALARP) Decisions (HSE, 2002).
8.2.1 Experience with ALARP Demonstration
A recent project on behalf of PSA (Petroleum Safety Authority) has summarised some of the experience with ALARP processes (Vinnem et al., 2006c), mainly in the Norwegian offshore industry, but also to some extent in the UK, the latter based on an interview with representatives from Health and Safety Executive.
One of the experiences in the UK is that it is difficult to document how well a process has been conducted. A good ALARP demonstration should be a broad decision-making process in which all relevant parties are invited to participate actively: management, employee representatives, safety representatives, discipline experts, etc. How this has been implemented is not always easy to document.
Another issue that has been highlighted in the UK is to what extent an ALARP demonstration can be based mainly on quantitative risk and cost-benefit analyses.
Apparently, there have been some QRA specialists who wanted to “take owner- ship” of the ALARP demonstration, claiming that ALARP demonstration should be based mainly (if not solely) on QRA and cost-benefit studies. This is a misun- derstanding.
It is documented clearly in the supporting documentation for ALARP demon- stration that both qualitative and quantitative considerations should be part of an ALARP demonstration.
In Norway, our experience is largely the same, although considerably more limited. Some companies focus solely on the use of QRA as well as cost-benefit analysis as input to decision-making about risk reduction. On the other hand, some companies have presented broad decision-making processes that include a wide range of stakeholders.
Another issue that has been noted is the lack of a formal approach to the identification of potential risk reducing measures. Again, the QRA is far too narrow, and additional techniques have to be applied.
8.2.2 What are the Characteristics of a Good ALARP Demonstration?
As noted above, the ALARP demonstration should be a broad ranging decision- making process involving a wide range of stakeholders. An important implication of the way “gross disproportion” is defined is that the burden falls on the industry to demonstrate why a proposed remedial measure should not be implemented.
This means that good reasons will have to be found why the benefit of a proposed measure is not sufficient in relation to costs and other burdens of implementation.
If such reasons cannot be demonstrated, then the measure by default must be implemented.
The way the burden of proof is placed is often not appreciated fully, and com- panies are only concerned with showing that there are insufficient reasons why a measure should be implemented.
One company has described the following tools to be used for performing an ALARP demonstration:
x good practice x codes and standards
x engineering judgement x stakeholder consultation x tiered challenge
x cost-benefit analysis.
We refer to Appendix B for an illustration of an extensive ALARP demonstration.
8.2.3 Needs in order to Improve Applications
There is no obvious need for more research in order to arrive at better risk manage- ment processes. The knowledge is available, in our view, but the weakness lies in its implementation.
Some people have argued that a standard should be developed which would provide a recommended approach to ALARP demonstration. A standard would perhaps be too rigid, but guidelines are certainly needed. With this in mind, we have provided a sample ALARP demonstration, see Appendix B.
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Foundational Issues of Risk and Risk Analysis
There are a number of measures or indices that can be used to describe risk in practice, as discussed in Section 2.1. The many indices are a result of the different perspectives of risk to be found, but also stem from a lack of precision as to what the foundation of the risk analysis is. The point is that some measures are meaningful and consistent if the foundation of your analysis is Bayesian, in the sense that you see probability as a measure of uncertainty, seen through the eyes of the assessor, and some are meaningful and consistent if the foundation is classical or traditional, as will be explained in more detail below.