Hazard Studies & Risk Assessment

ALARP Demonstration Studies

Defensible 'reasonably practicable' argument — engineered for HSE, COMAH, and CSB-style scrutiny

What this study delivers

ALARP Demonstration
Studies

ALARP — derived from UK Edwards v National Coal Board (1949) and codified in HSE's R2P2 (Reducing Risks, Protecting People) — is the dominant Western risk-acceptance test. The principle is asymmetric: as risk approaches the intolerable region (typically 10⁻³ worker / 10⁻⁴ public per year), the disproportion factor required to reject further mitigation increases sharply (HSE's gross-disproportion factor of 3–10 for high-hazard cases). ALARP is not a single calculation but a documented argument that combines codes-and-standards adherence, good practice benchmarking, cost-benefit analysis (CBA) for genuinely novel decisions, and ALARP-by-design at FEED. The post-Buncefield, post-Macondo, and post-Texas-City regulatory environment has tightened scrutiny: ALARP arguments must now defensibly address Bow-Tie barrier escalation, low-frequency / high-consequence cases, and the so-called 'cliff edge' where modest investment crosses from intolerable to tolerable. ALARP also increasingly applies in Indian PSM contexts (PESO Schedule 7, MoEFCC EIA) and across Australian / Canadian / Brazilian safety case regimes.

ALARP Demonstration Studies — Overview
Study execution

How the study is executed

A structured, facilitated process — from scope definition through close-out — producing defensible, actionable outputs.

Tolerability Framework & Risk Baseline

Establish applicable tolerability criteria (HSE R2P2 / CCPS / NORSOK / MoEFCC framework); overlay QRA risk contours (LSIR / IRPA / F-N) against broadly-acceptable, tolerable-if-ALARP, and intolerable bands; identify scenarios in the ALARP region requiring structured justification.

Risk-Reduction Option Register

Compile all technically feasible risk-reduction measures from engineering, operational, and administrative domains; categorise as codes-and-standards, good-practice benchmarking, ISD (FEED-stage Substitute / Minimise / Moderate / Simplify), or novel engineering measures; document status (implemented / under consideration / rejected).

Codes & Standards Compliance Defence

Demonstrate ALARP-by-compliance where well-established codes (OSHA PSM, IEC 61511, API RP 752, NFPA) are fully met; document gap analysis against current code editions; identify code-exceedance Good Engineering Practices (GEP) adopted voluntarily as ALARP credit.

Cost-Benefit Analysis (CBA)

Perform CBA for genuinely novel or disproportionately costly risk-reduction options using HSE VPF (£2.36m / fatality, 2024) or national equivalent; calculate Net Present Value of risk reduction (ΔPLL × VPF × NPV factor) versus implementation cost; document CBA inputs and uncertainty ±50% sensitivity.

Gross Disproportion Assessment

Select Gross Disproportion Factor (GDF) from HSE 1× to 10× sliding scale based on risk-tolerability proximity and hazard nature; reject measures where cost > GDF × benefit; document disproportion narrative per option with engineer-of-record attribution; map against Bow-Tie barrier-upgrade options.

Decision Record & ALARP Archive

Issue ALARP demonstration report with risk-tolerability framework, option register, CBA worksheets, GDF selection rationale, BAT benchmarking dossier, and residual-risk acceptance statement signed at appropriate corporate authority; build ALARP archive reusable for MOC, 5-year safety case, and post-incident review.

ALARP Demonstration Studies — Scope
Study scope

What the study covers in full

Tolerability framework — broadly acceptable / tolerable-if-ALARP / intolerable per HSE risk triangle
Codes-and-standards (good practice) ALARP defence — adequate where well-established
ALARP-by-design at FEED — Substitute / Minimise / Moderate / Simplify per CCPS ISD
Cost-Benefit Analysis (CBA) with HSE Value of Preventing Fatality (VPF — £2.36m / fatality, 2024) and Net Present Value of risk reduction
Gross Disproportion Factor selection (HSE 1× → 3× → 10× sliding scale by tolerability proximity)
Sensitivity / uncertainty analysis — CBA inputs typically vary by ±50% to test robustness
Bow-Tie integration — barrier upgrade options scored against ALARP CBA
Disproportion documentation — engineer's narrative justifying rejected options
Reasonable practicability defence under HSWA s.2 / s.3 (UK) or equivalent jurisdictions
ALARP demonstration archive — reusable across MOC, periodic safety case, post-incident review
Why it matters

Outcomes of ALARP Demonstration Studies

Risk-Reduction Option Rigour
  • Tests every credible barrier-upgrade option against quantitative CBA
  • Anchors residual-risk acceptance with engineer-of-record traceability
  • Drives ISD adoption upstream where ALARP-by-design is cheaper
  • Holds up to post-incident litigation and CSB-style scrutiny
R2P2 / COMAH ALARP Defence
  • Audit-defensible under UK COMAH, HSE R2P2, and Inspection Manual
  • Withstands HSE / EA / OSHA NEP / MoEFCC ALARP challenge
  • Provides decision-record evidence for post-incident litigation defence
  • Supports Director / corporate-officer due-diligence demonstration
Decision-Record & MOC Governance
  • Captures collective engineering judgement at the right moment
  • Prevents re-litigation of risk decisions through documented disproportion
  • Provides MOC reviewers with a defensible ALARP baseline
  • Builds organisational ALARP literacy for future safety cases
Gross-Disproportion Investment Logic
  • Defends non-implementation of grossly disproportionate (3–10× CBA-rejected) measures
  • Sequences risk-reduction capex against quantified benefit
  • Avoids gold-plating that compliance-only approaches drive
  • Sharpens insurer dialogue on residual loss expectancy
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