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Date: 14th March 2015

Document Number: J15069-02-TRA-006

Document Title: Training Module 6 Exercises – As Low As Reasonably Practicable (ALARP)

Revision: 0 (Approved)

REV DATE DESCRIPTION PREPARED CHECKED APPROVED QA


A 13/03/2015 Issued for Client Use M. Saim G. Monaco G. Monaco -

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CONTENTS
ABBREVIATIONS 4
HOLDS 5
1.0 EXERCISE 1 - HAZARD MANAGEMENT HIERACHY 6
1.1 Objectives 6
1.2 Exercise Task 1 6
1.3 Exercise Task 1 - Example Answers 7

2.0 EXERCISE 2 - HAZARD MANAGEMENT HIERACHY EXAMPLE 9


2.1 Objectives 9
2.2 Exercise Task 2 9
2.3 Exercise 2 Answers 12

3.0 EXERCISE 3 - CONSTRUCTION ALARP REVIEW 14


3.1 Objectives 14
3.2 Exercise Task 3 14

4.0 EXERCISE 4 - UKOOA DECISION FRAMEWORK 22


4.1 Objectives 22
4.2 Exercise Task 4 22
4.3 Exercise Task 4 - Answers 22

5.0 EXERCISE 5 - COST BENEFIT ANALYSIS 24


5.1 Objectives 24
5.2 Exercise Task 5 24
5.3 Exercise Task 5 - Answers 25

6.0 EXERCISE 6 - ALARP SHEETS 26


6.1 Objectives 26
6.2 Exercise Task 6 26
6.3 Exercise 6 Answers 28

7.0 EXERCISE 7 - ALARP THROUGH PROJECT LIFECYCLE 29


7.1 Objectives 29
7.2 Exercise Task 6 29

8.0 MODULE TEST 32


8.1 Objectives 32
8.2 End of Module Test 32
8.3 Answers 36

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APPENDICES
APPENDIX I RISK MATRIX

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ABBREVIATIONS

AFP Active Fire Protection


ALARP As Low As Reasonably Practicable
CBA Cost Benefit Analysis
DF Disproportion Factor
FEED Front End Engineering Design
FLNG Floating Liquefied Natural Gas
HAZID Hazard Identification
HAZOP Hazard and Operability
HSE Health, Safety and Environment
HSSE Health, Safety, Security and Environment
ICAF Implied Cost of Averting a Fatality
PF Proportion Factor
PFP Passive Fire Protection
PLL Potential Loss of Life
PPE Personal Protective Equipment
PTW Permit To Work
RRM Risk Reduction Measure
Q Qualitative
QRA Quantitative Risk Assessment
SQ Semi-quantitative

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HOLDS
No Holds.

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1.0 EXERCISE 1 - HAZARD MANAGEMENT HIERACHY
1.1 Objectives
The purpose of this task is to understand the hazard management hierarchy and which risk reduction
measures should be prioritised over others.
1.2 Exercise Task 1
Complete the table below to provide examples of each type of risk reduction measure.

Type of Risk Reduction Measure Example

Eliminate

Substitute

Isolate / Separate

Engineer

Organisation

Procedures

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Type of Risk Reduction Measure Example

Personal Protective Equipment (PPE)

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2.0 EXERCISE 2 - HAZARD MANAGEMENT HIERACHY EXAMPLE
2.1 Objectives
The purpose of this task is to understand the hazard management hierarchy and which risk reduction
measures should be prioritised over others.
2.2 Exercise Task 2
Helen’s garage and convenience store is situated near a main road and has four gasoline pumps and
several parking spaces as shown.
Helen has decided to install a propane cylinder to the north of the store to supply heating for the store.
The tank will be above ground and fitted with a pressure relief valve, no other safety provisions are
planned.
Based on the Hazard Management hierarchy, identify at least one possible additional control for each
control type, together with any advantages and negative aspects of implementing that control.

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Category Possible Additional Risk Reduction Measures Advantages Disadvantages

Eliminate

Substitute

Isolate / Separate

Engineer

Organisation

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Category Possible Additional Risk Reduction Measures Advantages Disadvantages

Procedures

PPE

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3.0 EXERCISE 3 - CONSTRUCTION ALARP REVIEW
3.1 Objectives
The purpose of this task is to understand the role of bowtie analysis to aid ALARP demonstration.
3.2 Exercise Task 3
You are responsible for the management of a construction operation on an existing brown-field site
adjacent to an operating refinery. It is known that there are buried gas and oil lines serving this refinery
that cross your site, and your construction activities will require excavation in and around some of the
existing buried lines which may require to be exposed (and in some cases supported) for an extended
period of time. Your construction operations are expected to last 2 years, although ground disturbance
(trenching, excavations etc.) will only occur during the first six months.
As part of the construction operations HSE Management, a bowtie assessment has been performed for
this work, and in particular the possibility that a release may occur from one of these buried lines. The
review team have colour coded the bowtie barriers for their effectiveness red, yellow, green (ineffective,
partially-effective, effective).
The first four threats of the bowtie are reproduced below. For each threat line in turn consider:

 How effective are the existing controls at preventing each cause? Is this enough? Do they meet
minimum standards?
 What additional risk reduction measures (RRMs) could be put in place?
 Using a simple effort/benefit matrix (example provided below), rank each of these additional RRMs
 Which RRMs should be implemented to reach ALARP risk levels?
Figure 3.1
Example ALARP Matrix

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Figure 3.2
Example Bowtie Overview

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Figure 3.3
Example Bowtie Threats (1)

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Figure 3.4
Example Bowtie Threats (2)

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Bowtie
1 Hazard Top Event H-01.02/03/04 - Hydrocarbon Streams Loss of Containment
No.
Eliminate or minimise hazard
Possible additional Benefit vs Effort of
RRM ease of implementation Comments Recommendations
RRM implementing RRM

Prevent realization of the hazard


Possible additional Benefit vs Effort of
No. Threat Description RRM ease of implementation Comments Recommendations
RRM implementing RRM

Excavation of existing
T1
lines

Collapse of temporary
T2
supported exposed line

Load transiting over top of


T3
line

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Bowtie
1 Hazard Top Event H-01.02/03/04 - Hydrocarbon Streams Loss of Containment
No.

T4 Piling

Dropped object / Impact


T5
with exposed lines

Loss of control leading to


T6 impact with above ground
lines

T7 Hot taps into existing lines

Prevent escalation of the event


Possible additional Benefit vs Effort of
No. Consequence Description RRM ease of implementation Comments Recommendations
RRM implementing RRM

Unignited release - health


C1 hazard & environmental
impact

C2 Ignited release

Minimize exposure of personnel to hazards

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Bowtie
1 Hazard Top Event H-01.02/03/04 - Hydrocarbon Streams Loss of Containment
No.
Possible additional Benefit vs Effort of
RRM ease of implementation Comments Recommendations
RRM implementing RRM

Ensure personnel can reach of place of safety


Possible additional Benefit vs Effort of
RRM ease of implementation Comments Recommendations
RRM implementing RRM

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4.0 EXERCISE 4 - UKOOA DECISION FRAMEWORK
4.1 Objectives
The purpose of this task is to understand the relative importance of various decision making approaches
when selecting barriers to reduce risks to ALARP.
4.2 Exercise Task 4
What type of UKOOA decision would you categorise the following and how far up or down would you
place these?
Part 1 - Upstream
1. North Sea Wellhead Platform
2. Carbon Capture and Storage (CO2)
3. Subsea Isolation Valve (SSIV) for offshore platform
Part 2 - Miscellaneous
1. Adding an additional tank into an existing tank farm that already has tanks of the same type, size or
product or adding a second independent high level alarm to an existing tank.
2. Gas to chemicals, well established processes at the front and back end with well understood risk,
some uncertainty and deviation from the established norm (known controllable feedstock).
3. FLNG
4.3 Exercise Task 4 - Answers
Part 1

Part 2

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5.0 EXERCISE 5 - COST BENEFIT ANALYSIS
5.1 Objectives
The purpose of this task is to understand the inputs of cost benefit analysis and how calculations are
made at a high level.
5.2 Exercise Task 5
The integrity of the central control building of an onshore gas processing facility is at high risk of external
fires. Two options have been proposed to reduce the risk:
1. Active Fire Protection (AFP)

 1600 man-hours to install at $20 / manhour


 Labour costs = $32,000
 Capital cost = $1 million
 Reduce PLL by 2.5 x 10-2/year
 Design life = 25 years
4. Passive Fire Protection (PFP)

 400 man-hours to install at $15 / manhour


 Labour costs = $6,000
 Capital cost = $250,000
 Reduce PLL by 1.75x10-2/year
 Design life = 5 years

What is the ICAF and proportion factor?


Which option should be selected (if any)?

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6.0 EXERCISE 6 - ALARP SHEETS
6.1 Objectives
The purpose of this task is to understand the importance of documenting the ALARP decision making
process in a clear, comprehensive and structured method.
6.2 Exercise Task 6
The associated gas produced at Production Station X (PSX) is compressed and sent as export gas
(through export compressors) to the Power Station and other consumers at nearby facilities.
The high H2S flash gas from PSX tanks is currently flared via Gas Recovery Compressor to avoid
contaminating the PSX gas system with high H2S gas.
The Power Station is nearing the end of design life and planned for retirement from March 2021 onwards.
In order to address the above issues, it is proposed that the associated gas will be mixed with gas
recovered from storage tanks. The mixed gas will be compressed, dehydrated and dew pointed and will
be sent through a sour gas pipeline ready for gas injection.
The facilities are located in a remote area in the Middle-East.
Associated gas from PSX from compressor (K-101) and flash gas from Gas Recovery Compressor
(K-102) will be received to the new Booster Compressors (3 x 50%) at a pressure of 3.2 barg and
compressed to 64 barg pressure. The gas will be further dehydrated and dew pointed in the TEG unit and
Hydrocarbon Dew Pointing Unit before being sent through a sour gas pipeline ready for gas injection.
There will be three new booster compressors with one working and one standby during initial years. After
Two trains of Gas Conditioning Unit (Train-1 and Train-2) having similar capacity of 140,000 Sm3/d will be
operated in parallel. When the project is commissioned, both trains will be under operation. The
conditioned gas will be routed via sour gas pipeline for gas injection.
During the ALARP demonstration workshop, the following risk reduction measure was identified:

 Consider the change of process design concept of having one (1) Gas Conditioning Unit (GCU) as
oppose to the current proposed design which is based on two GCUs. Having only one GCU simplifies
the process inherently minimising the number of leak sources and hence risks during operation of the
asset.

Document the ALARP decision making process using the ALARP sheet provided on the next page.

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Problem Definition

HSSE Issues and Potential Risks


IDENTIFY

HSSE Standard and Tolerability Criteria

Options Considered

Discussion
ASSESS

Recommendations for Next Project Phase


CONTROL & EVALUATION

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7.0 EXERCISE 7 - ALARP THROUGH PROJECT LIFECYCLE
7.1 Objectives
The purpose of this task is to understand the importance of timing when applying ALARP principles
throughout the project lifecycle.
7.2 Exercise Task 7
1. Thinking of some major incidents in industry, in hind sight what are some of the ALARP decisions
that were a factor for the following 4 case studies.
2. At what stages in the life cycle could different ALARP decisions be made that could potentially control
or mitigate the incident?
3. At what stages in the life cycle could different ALARP decisions be made that could potentially control
or mitigate the incident? (Some incidents you might consider: Piper Alpha, BP Texas City, BP
Macondo, Recent Venezuelan refinery, Bonga, Bukom Fire, Puget Sound Coker, etc.)

Case Study 1 - Explosion and fire at Shell refinery, Stanlow, UK. 20th March 1990
On 20 March 1990 the halogen exchange reactor on the Fluoroaromatics plant was ruptured by the
pressure generated by a runaway reaction. The plant was partially destroyed and missiles were projected
over 500m. Six employees were injured and one subsequently died from post-operative complications.
A batch had been charged into the vessel and was being heated up as normal. When it reached 165°C,
the temperature continued to rise and the operators adjusted the jacket temperature. The display screen
in use did not display pressure and they were unaware of a corresponding rise in pressure. By the time
they were alerted to the rise in pressure the pressure relief valves had lifted. Before any other corrective
action could be taken, the reactor exploded. The pressure in the vessel reached a value of about 60-80
barg compared with the relief valve set pressure of 5 barg.
The resulting blast was enhanced by the formation of a fireball, which occurred when the contents of the
reactor ignited within the plant structure. This started local fires and initiated what became a major
conflagration in an adjacent unit where vessels containing xylene were damaged by the blast/missile
effects. The ensuing fires were brought under control in four hours by the Shell fire team and Cheshire fire
service.
The initial cause of the incident was the ingress of excessive water into the process leading to the
formation of acetic acid which, upon recycle to the reactor, reacted vigorously with the reactor contents
initiating the explosion. Water was present as a part of the process, however a massive incursion led to
the formation of a separate water layer in the process vessel which was not removed but was instead
recycled back into the reactor.

Case Study 2 - The fire at Hickson & Welch Limited, Castleford, UK. 21st September 1992

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A clean out operation of a batch still, known as “60 still base”, was organised in order to remove residues.
This vessel had never been cleaned since it was installed in the nitrotoluenes area in 1961.
An operator dipped the sludge to examine it and reported the sludge as gritty with the consistency of soft
butter to management. No sample was sent for analysis nor was the atmosphere inside the vessel
checked for a flammable vapour. It was mistakenly thought that the material was a thermally stable tar.
In order to soften the sludge, which was estimated to have a depth of 34 cm (14 in), steam was applied to
the bottom battery. Advice was given not to exceed 90°C.
Employees started the clean out operation using a metal rake. The material was tar-like and had liquid
entrained in it. Approximately one hour into the cleaning process a longer rake was used to reach further
into the still.
The vessel’s temperature gauge in the control room was reported to be reading 48°C, instructions were
given to isolate the steam.
At approximately 13:20 hrs a number of employees involved in the raking left the still base for other tasks.
One person left on the scaffold had stopped raking and noticed a blue light, which turned instantly to an
orange flame. As he leapt from the scaffold an incandescent conical jet erupted from the vessel’s
manhole. This projected horizontally towards the control building. A vertical jet of burning vapours shot
out of the top rear vent to the height of the distillation column nearby.
The jet fire lasted for approximately one minute before subsiding to localised fires around the manhole
and buildings nearby. The force of the jet destroyed the scaffold and propelled the manhole cover into the
centre of the control building. The jet severely damaged this building and then impacted on the north face
of the main office block causing a number of fires to start inside.
A total of 22 fire appliances and over 100 fire fighters attended the incident. Five people were killed (two
in the control and three in the office block) and over 200 injured.
Case Study 3 - Gas release at bulk terminals complex, Chicago, Illinois, USA. 26th April 1974
Bulk Terminals was a storage tank farm with 78 tanks ranging in size up to 4900m3. At about 12:30 hours
on Friday 26 April a dull thud was heard and fumes seen rising from the bund surrounding a 3300m3 tank
of silicon tetrachloride. It was discovered that a pressure relief valve on a 6-inch line leading to the tank
had been inadvertently closed. The pressure in the system was sufficient to burst a flexible coupling in the
line, shifting the piping system and cracking a 3-inch line on the tank wall. Liquid silicon tetrachloride
escaped forming an irritant cloud containing hydrogen chloride gas.
The terminal management waited for the owners of the chemical to take emergency action and the fire
service did not respond, as there was no fire. The Environment Protection Agency (EPA) sent lime trucks
to neutralise the chemical, but these were refused entry to the site. By 15:00 hours the cloud was 400 m
wide, 300-450 m high and 1600 m long.
At 04:10 hours on Saturday 27 April, foam was added to blanket the liquid in the bund but this failed. At
09:00 hours fuel oil was added along with eight truck loads of lime. The vaporisation reduced dramatically
and operations began to transfer the liquid from the damaged tank. At 08:00 hours on Sunday 28th April,
it began to rain. Power lines were corroded by the hydrochloric acid in the rain, and four pumps became
inoperable due to corrosion before a general power failure stopped all pumping.

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The materials added into it had reduced the capacity of the bund, and a further pit had to be dug to take
the overflow in the event of a full tank failure. It was attempted to seal the leak on the tank using quick
drying cement. The first attempt failed and it wasn’t until 23:30 hours on Monday 29 April that the leak
was sealed. It took until 3 May to empty the tank and until 15 May before emissions had reduced to
tolerable levels. One person was killed, 160 hospitalised and 16,000 people were evacuated during this
incident.
Case Study 4 -The Abbeystead Explosion, UK. 23rd May 1984
On Wednesday 23 May 1984, a group of 44 people was assembled in a valve house set into a hillside at
the outfall end of the Lune/Wyre Transfer Scheme at Abbeystead. The visitors were attending a
presentation to allay anxieties about the effects of the installation on the winter flooding of the lower Wyre
Valley.
As part of this presentation, water was to be pumped over the weir regulating the flow of water into the
Wyre. Shortly after pumping commenced there was an intense flash, followed immediately by an
explosion causing severe damage to the valve house.
Sixteen people were killed; no one escaped without injury from the valve house.
The explosion was caused by the ignition of a mixture of methane and air, which had accumulated in the
valve house. The methane had been displaced from a void, which had formed in the end of the
Wyresdale Tunnel during a period of 17 days before the explosion when no water was pumped through
the system.
No source of ignition for the explosion has been positively identified. Thorough examination and testing of
the electrical equipment has not revealed any faults likely to have caused ignition and there is insufficient
evidence to confirm any of the other explanations which have been considered. Smoking in the Valve
House was not prohibited because the likelihood of a flammable atmosphere arising there had not been
envisaged.

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8.0 MODULE TEST
8.1 Objectives
The purpose of this task is to assess if the participants of the course module have understood the basic
principles with ALARP Demonstration, including the various techniques adopted in the oil and gas and
other industries.
8.2 End of Module Test
Question 1:
What is an ALARP Demonstration and its objectives?
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
________________________________________________________________________________
Question 2:
True or False?
1. If risks are Tolerable, they are ALARP.
5. Ensuring that risks are reduced to ALARP means raising standards continually.
6. If some companies have adopted a high standard of risk control, that standard is ALARP.
7. Ensuring risks are reduced to ALARP means we can insist on all possible risk controls.
8. ALARP demonstration can be qualitative or quantitative (case-by-case basis).
9. Ensuring that risks are reduced to ALARP means there will be no accidents or ill-health.
10. The ALARP demonstration starts at the onset of a project, and develops throughout all phases,
11. Practicality and cost considerations may be justifications for not implementing measures.
12. ALARP demonstration is used to bridge the gap between good practice and best practice.
13. Cost benefit analysis can be used to argue that it is acceptable to reduce existing safety standards.
14. Disproportion Factor is always equal to 6.
15. ALARP Tolerability criteria should be defined when making an ALARP decision.
16. ALARP demonstration is used for identifying risk reduction measures.#
17. Risk is only ALARP once every measure has either been implemented or proven to be not
reasonably practicable.
18. Unmitigated risk takes into account barriers and safeguards.

Question 3:

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When all laws and regulations are complied with, does this mean that the Risks are both Tolerable and
ALARP?
 ___________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
________________________________________________________________________________
 
Question 4:
We do not have any conclusive scientific evidence linking a particular medical condition with the exposure
to a certain chemical. However, some people believe there is a link. Do we need to take any further
action?
 ___________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
________________________________________________________________________________

Question 5:
If laws and regulations are complied with, Industry Standards and Codes are being followed and company
guidance is being applied, does this mean that the Risks are Tolerable? Are they also ALARP?
 ___________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
_________________________________________________________________________________

Question 6:
Can applying the DEPs reduce the Risks to ALARP for the threat of an overpressure of a process
vessel?
 ___________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
________________________________________________________________________________

 
 
Question 7:

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A refinery has established a budget for minor capital projects, which is used to fund asset integrity
upgrades and HSSE improvements. Proposals are ranked using the risk matrix. The refinery
management is confident that it is applying the risk matrix consistently and that it is investing the available
capital on proposals that will have the biggest impact on reducing the overall risk to the refinery. Are the
risks being reduced to ALARP?
 ___________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
________________________________________________________________________________

Question 8:
If the whole idea behind ALARP is to reduce risks to ALARP, how can it be ALARP to allow a less
protected situation?
 ___________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
________________________________________________________________________________

Question 9:
A proposal to transport drill cuttings to shore will reduce the environmental impact of an offshore platform
operation, but it will increase the Risks to people because it involves more boat transfers. Should the
proposal be rejected?
 ___________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
________________________________________________________________________________
 

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Question 10:
When building an extension to an onshore gas plant, there are two options to dispose of the excavated
rock, either transport by road to a remote site, or dumping in the sea as part of the land reclamation to
extend the plant. The road transport option will significantly increase the risk to the local population and to
the drivers. As the prevailing driving standards in this region are low and the roads are of poor quality it
will require a major effort to effectively manage the road transport risk. Should the road transport risks be
taken into account when assessing the environmental risks of the second option of dumping the
excavated rock at sea?
 ___________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
________________________________________________________________________________

Question 11:
Current practice does not permit the use of screwed fittings in hydrocarbon service. Facility X was built a
prior to this practice and has many screwed fittings. Should all screw fitting be replaced?
 ___________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
________________________________________________________________________________

Question 12:
What types of risk reduction measures are the most effective and what is its relationship with life-cycle
phase?
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
________________________________________________________________________________
Question 13:
What is the value of the Disproportion Factor and how is it used?
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
________________________________________________________________________________

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APPENDIX I
EXAMPLE RISK MATRIX

AI.1.0 HAZARD RISK ASSESSMENT MATRIX


The risk assessment matrix that was used for the HAZID study is shown in Figure AII.1.
Figure AI.1
HAZID Risk Assessment Matrix

The risk matrix is divided into four (4) risk categories as defined below:

 Low Risk (Light Blue Zone);


 Medium Risk (Dark Blue Zone);
 High Risk (Yellow Zone); and
 Serious Risk (Red Zone).

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AI.1.1 Severity Rankings
AI.1.1.1 Likelihood Scale

Type and Size of Likelihood


Operation or
Installation 10-5 1+
Incident has Happens a few Happens several
Standard Never heard of in Heard of in
occurred in our times in our times per year in
Operation industry industry
company company our company
Incident has Happens a few Happens several
Never heard of in Heard of in
Plant occurred in our times in our times per year in
industry industry
company company our company
Process Similar incident Similar incident
Upstream, Incident occurred occurred less occurred several
Has not occurred Has occurred in
Downstream, once in the than 5 times times in one of
in our industry our industry
Storage, Loading company since company the unites of the
Areas existence onshore / offshore

AI.1.1.2 Consequence Scale


People

Severity Definition
0 No injury or damage to health
1 Slight injury or health effects (including first aid cases and medical treatment case and
occupational Health illness – not affecting work performance or causing disability)
2 Minor injury or health effect (Lost Time Accident) – affecting work performance, such as
restriction to activities (restricted work case or Occupational Health illness) or a need to take
few days to fully recover (Lost Workday cases). Minor health effects, which are reversible,
e.g. skin diseases, food poisoning.
3 Major injury or health effects (including Permanent Partial Disability and Occupational Health
illness) - Affecting work performance in the longer term, such as prolonged absence from
work. Irreversible health damage without loss of life, e.g. noise induced hearing loss, chronic
back injuries, sensibilisation, hand/arm vibration syndrome, repetitive strain injury.
4 3 Fatalities or Permanent Total Disability – Form an accident or Occupational Health illness.
Irreversible health damage with serious disability or death e.g. corrosive burns, heat stroke,
toxic releases (small exposed populations)
5 More than 3 fatalities – From an accident or Occupational health illness e.g. chemical
asphyxiation, fire/explosions or toxic releases (large exposed population)

Asset Damage

Severity Definition (100% costs, USD)


0 Zero Damage
1 Slight damage – No disruption to operation (cost less than 10,000)
2 Minor damage – Brief disruption (cost less than 100,000)
3 Local damage – Partial shutdown (can be restarted but costs up to 1,000,000)
4 Major damage – Partial operation loss (several days shutdown costs up to 10,000,000)
5 Extensive damage – Substantial or total loss of operations (costs in excess of 10,000,000)

Environmental Effect

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Severity Definition
0 Zero Effect– No environmental damage. No financial consequences
1 Slight effect – Slight environmental damage, within the fence and within systems. Negligible
financial consequences
2 Minor effect – sufficiently large contamination or discharge to damage the environment, but
no lasting effect. Single breach of statutory or prescribed limit, or single complaint.
3 Localised effect – Limited discharges affecting the neighbourhood and damaging the
environment. Repeated breaches of statutory or prescribed limits. or many complaints.
4 Major effect – Severe environmental damage. The Company is required to take extensive
measures to restore the damaged environment. Extended breaches of statutory or prescribed
limits, or widespread nuisance.
5 Massive effect – Persistent severe damage to the environment or severe nuisance extending
over a large area. Loss of commercial, recreational use or nature conservancy resulting in
major financial consequences to the Company. Ongoing breaches will above statutory or
prescribed limits.

Reputation Effect

Severity Definition
0 No impact – No public awareness
1 Slight impact – Public awareness of the incident* may exist; there is no public concern
2 Limited impact – Some local public concern; some complaints received; slight local media
and/or local political attention with potentially negative aspects for operations.
3 Considerable impact – Regional public concern; numerous complaints; extensive negative
attention in local media; slight national media and/or local/regional political attention with
possible negative stance of local government and/or action groups.
4 National impact – National public concern; continuing complaints; extensive negative
attention in national media and/or regional/national politics with potentially restrictive
measures and/or impact on grant of licences; mobilisation of action groups.
5 International impact – International public attention; extensive negative attention in
international media and national/international politics; potential to harm access to new areas,
grants of licences and/or tax legislation; concerted pressure by action groups; adverse effects
in other countries.

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