Tony Cox

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Slide1: Seminar organised by Aberdeen and Grampian Chamber of Commerce Co-Sponsors: Maclay Murray & Spens Wednesday 17th November 2004 “Practical Risk Assessment and Management” Dr. Tony Cox MBE FIMechE 20 Pollard Road Morden Surrey SM4 6EG 020 8648 5012 tony.cox@safetycraft.com

Recent trends in UK workplace safety: Recent trends in UK workplace safety

Continuous improvement in safety performance: Continuous improvement in safety performance The UK has been a leader in workplace safety over the past 20 years but progress slowed in the 1990’s The HSC has determined that the improving trend should be regained – I think, rightly Accident frequency reductions of the order of 10% to 30% are aimed for, over a decade The questions is - how best to secure this gain?

The classical risk management answer: The classical risk management answer First identify the hazards and develop a risk profile Identify the dominant contributors and/or their underlying causes Reduce risk by “preventive” safeguards that address the causes or “protective” ones that mitigate the consequences These ideas are reflected in the provisions of the Management Regulations 1992 and 1999 (“MHSWR”)

“suitable and sufficient” risk assessment : “suitable and sufficient” risk assessment MHSWR 1999 guidance (HSE L21) : identification of “all” risks and hazards (an impossible ideal) assessment of potential consequences – focus on people who might be harmed most practitioners include an assessment of likelihood (not explicitly in the guidance) identification of preventive and protective safeguards and further actions

What do we mean by “Risk”?: What do we mean by “Risk”? A “hazard” is a thing or situation which possesses the potential for injury or damage, due to physical or chemical or pathogenic properties. “Risk” exists when there is a hazard present and there is some possibility that it may cause a real accident. A measure of risk from a single hazard is obtained by combining (usually by multiplication) the estimated frequency of such an accident with its estimated consequences. The risk borne by an individual is the totality of the risks due to all hazards that may affect that person.

Slide7: Hazard Identification Methods Sector-specific checklists Accident experience Hazardous material inventories Equipment counts HAZOP, FMEA etc.

Slide8: Hazard checklist (HSE “5 steps”) slipping/tripping fire chemicals machinery work at height ejection of material pressure systems vehicles electricity dust fumes manual handling noise poor lighting low temperature

The Risk Matrix: The Risk Matrix

The Risk Matrix: The Risk Matrix

Risk Ranking - Frequency Scale: Risk Ranking - Frequency Scale

Risk Ranking - Consequence Scale: Risk Ranking - Consequence Scale

Typical Risk Matrix (oil industry): Typical Risk Matrix (oil industry)

A poor example: A poor example

Risk Matrix Example: Risk Matrix Example

Technical problems with the Risk Matrix approach: Technical problems with the Risk Matrix approach It is difficult to assign a frequency category to a single isolated event; frequency depends strongly on the event definition. It is unclear in which matrix cell to place (say) 10 hazards with similar risks (should they equal one hazard in the next higher frequency rank? Difficult to aggregate the risks, e.g. for generating an overall risk score, or for comparison and profiling

Quantification of Risk: Quantification of Risk frequency is inherently a numerical measure, a rate per unit time. consequences are of different kinds, but in the final analysis they all have to be weighed and prioritised, and society places a value upon them. when the consequences are multiplied by the frequency, the result is an average rate of loss, which has units such as “pounds per year”.

Example of a Risk Profile: Example of a Risk Profile

Risk reduction: Risk reduction The selection of safeguards should address: significant contributors to the risk profile avoidance of unwanted side effects avoidance of overkill and diminishing returns cost-effectiveness You should do ALL that is “reasonably practicable”

Workplace safeguards hierarchy (from HSE’s “5 steps”): Workplace safeguards hierarchy (from HSE’s “5 steps”) get rid of the hazard try a less risky option prevent access to the hazard (eg by guarding) organise work to reduce exposure to the hazard Provide personal protective equipment or welfare facilities

“Principles of Prevention” (EU Framework Directive & UK MHSWR): “Principles of Prevention” (EU Framework Directive & UK MHSWR) Avoid risks Combat risks at source Adapt work to the individual (workplace, equipment, methods) Adapt to technical progress Replace the dangerous by the less dangerous Develop overall prevention policy Give collective measures priority over individual measures Give appropriate instructions to employees

Simple workplace risk assessments: Simple workplace risk assessments

Workplace risk assessment – HSE’s “5 steps to Risk Assessment”: Workplace risk assessment – HSE’s “5 steps to Risk Assessment” Look for the hazards Decide who might be harmed and how Evaluate the risks and decide whether the existing precautions are adequate or whether more should be done Record your findings Review your assessment and revise it if necessary

Risk assessment format (“5 steps”): Risk assessment format (“5 steps”)

Risk assessment format (better): Risk assessment format (better)

Risk assessment format (CITB): Risk assessment format (CITB)

Risk assessment format (recommended): Risk assessment format (recommended)

Method Statement format (CITB): Method Statement format (CITB)

Methd Statements and Risk Assessments: Methd Statements and Risk Assessments These two are related, but distinct, things; they should not be confused, nor merged into a single test A Method Statement says what should be done, how and by whom, in a particular work activity A Risk Assessment says what might go wrong, and what precautions should be in place, during that work activity. The risk assessment may result in changes to the Method Statement. The drafting of a Risk Assessment calls for a different thought process from the drafting of a Method Statement. They can be placed in the same document, but must be separately identifiable.

Demonstrating ALARP: Demonstrating ALARP

ALARP and Goal Setting: ALARP and Goal Setting 1972 Robens Report and 1974 H&S@W Act reaffirmed “ALARP” and provided basis for goal-setting safety regulation Piper Alpha Inquiry gave new impetus to corporate safety management systems based on ALARP (1990) Ladbroke Grove Inquiry endorsed ALARP, Safety Cases and Safety Management Systems (2001)

The two halves of ALARP: The two halves of ALARP The first half: “We don’t have to do anything that is disproportionately expensive” The second half: “We must search continually and exhaustively for anything else that will reduce risks, that is not excessively costly”

ALARP non-compliances: ALARP non-compliances On new industrial projects, the ALARP process has often reduced to endorsement of the chosen design On existing operations, the cost-benefit test is applied to single options without consideration of all the alternatives This does not represent the whole of the ALARP duty - it should be a driver for continuous improvement

After an accident - does the risk assessment stand up?: After an accident - does the risk assessment stand up?

After an accident - does the risk assessment stand up?: After an accident - does the risk assessment stand up? Events considered in a risk assessment are a selected set, hopefully representative of the entire spectrum of possibilities A real event is a singularity somewhere in that spectrum - was it omitted from the selected set? Was it foreseeable? If the real event was foreseen in the risk assessment, it may still be argued that the probability had been underestimated Maybe, some assumptions were incorrect, or people did not do what was assumed

Is the risk assessment “suitable and sufficient”?: Is the risk assessment “suitable and sufficient”? HSE’s “5 Steps to Risk Assessment” (INDG163): a proper check was made you asked who might be affected you dealt with all the obvious significant hazards the precautions are reasonable, and the remaining risk is low.

Poor Content: Poor Content A risk assessment was found following a fatal fall to a steel erector. It amounted to this: “There is always a risk of falling when working at heights.” “The structure is to be erected in such a way that the erectors have horizontal or vertical members to hang onto while completing their task.” “Only erectors comfortable with working at heights.....can be used.”

Failure to identify or implement safeguards: Failure to identify or implement safeguards Too often, existing safeguards are accepted as sufficient Too often, “soft” safeguards (training, procedures) are accepted but not maintained in practice The “other half” of ALARP is not fully explored (i.e. is there anything else we could do?)

“Bad luck”: “Bad luck” John Adams has recently drawn attention to the need to understand “bad luck” Thorough hazard identification, risk assessment, and implementing safeguards, reduce risk but only rarely eliminate it. Therefore, an accident could still occur even if the dutyholder has complied fully with the statutory requirements and his duty of care.

Preferred enforcement approach: Preferred enforcement approach I would prefer HSE to prosecute more for breaches of the preventative regulations, rather than (mostly) prosecuting after the event. In my practice, I regularly see risk assessments that are far from “suitable and sufficient”. Frequently, safeguards have not been implemented – accidents waiting to happen. If dutyholders were aware that they would be penalised for such breaches, this could have a powerful effect on accident rates.

Conclusions: Conclusions As one who worked to gain acceptance of risk assessment in the 1970’s and 80’s I should be glad that it is now so widely practised. Why am I not? ..........because it is so often done badly, or for the wrong motives. However, the regulatory duties are clear and the chance of being prosecuted (if you have an accident) is rising. I would prefer that regulators toughen their stance on proactive, preventive duties such as risk assessment and implementing safeguards, rather than enforce mainly in the wake of accidents.