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Risk analyses or ‘predictive’ aspects of comah safety reports guidance for explosives sites

The COMAH Safety Report Process for Predictive Assessment of Explosives Sites

Step 5: Demonstration of ALARP for the Representative Set

For all MA’s, the starting point will be to demonstrate that relevant good practice is in place, or if not, to justify why not. Thereafter, having characterised the risk associated with each of the MAS’s, it will be necessary to provide clear demonstrations that they are not unacceptable…….

Note: on HSE’s Tolerability of Risk (TOR) framework, the risks arising to workers and members of the public from the operations undertaken on site can fall in one of three regions; ‘broadly acceptable’, ‘tolerable’ if ALARP and ‘unacceptable’ as set out in the HSE publication Reducing Risks, Protecting People framework, below.

ALARP diagram

…. and have been reduced as low as is reasonably practicable (ALARP).

Note: An individual risk of death of less than 10-6 per annum is regarded as "broadly acceptable". Individual risks above this threshold are acceptable only if all necessary measures have been taken to achieve a level as low as reasonably practicable. Further guidance can be found in HSE’s/HID’s Semi Permanent Circular SPC/Permissioning/12 ‘Guidance on ALARP Decisions in COMAH’.

In simple terms this ALARP demonstration should identify both ‘what more could be done (i.e. what additional measures could be put in place) and ‘why these are not necessary ’. This exercise will:-

The ALARP demonstration described in the safety report should:

It is sometimes impractical for new Duty Holders to perform case specific demonstrations for all identified events immediately. A more pragmatic option in such cases is for the "representative set " of MAS’s to be considered immediately, with the remaining risk generators being subject to scrutiny in a rolling program, leading up to the time of the next safety report submission. For such cases, the safety report should explain and justify the basis of action taken and provide justifiable plans for completion of additional assessments within a reasonable timeframe (not later than 5 years). If the additional assessments lead to material changes to the safety report and the demonstration of ALARP, a revision report may be required before the next 5 yearly submission.