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

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

Speak with our team to scope an engagement tailored to your facility, regulatory context, and lifecycle stage.