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4 ALARP in Chemical Industry 2018
4 ALARP in Chemical Industry 2018
Using the ALARP principle for safety management in the energy production
sector of chemical industry☆
Eirik Bjorheim Abrahamsen a,∗, Håkon Bjorheim Abrahamsen a,b, Maria Francesca Milazzo c,
Jon Tømmerås Selvik a
a
Department of Industrial Economics, Risk Management and Planning, University of Stavanger, 4036 Stavanger, Norway
b
Department of Anaesthesiology and Intensive Care, Stavanger University Hospital, 4011 Stavanger, Norway
c
Department of Engineering, University of Messina, Contrada di Dio 98166 Messina, Italy
a b s t r a c t
In the context of chemical industry, in particular in high hazard industries, the adoption of safety measures is essential to reduce risks and environmental impacts,
due to the release of dangerous substances, at level that is reasonably practicable. The ALARP (As Low As Reasonably Practicable) principle is broadly used for
decision-making in safety management, supported by cost-benefit analyses and the grossly disproportionate criterion, but without paying the proper attention to the
decision frame (defined by the level of uncertainty and knowledge of the chemical phenomena, the use of best available technologies, the potential of major losses
due to the release of hazardous materials and other items). In this paper, by examining the energy production sector of chemical industry, it will be argued that the
decision context makes the application of the ALARP principle not always proper, whereas a dynamic interpretation, in which decisions are made oscillating between
two borderlines, where in one case reference is made to expected values and in the other one to the precautionary principle, is more appropriate.
© 2017 Published by Elsevier Ltd.
1. Introduction tolerability region), the application of measures for risk reduction are pre-
scribed, with respect to the ALARP principle. Such limits are fixed in the
Chemical industries, in particular those subject to the Seveso Direc- United Kingdom and the Netherlands, with the Dutch limits being more
tive (so-called high hazard industries), pose several safety concerns that restrictive than their British counterparts, which are commonly used
are due to potential releases of hazardous materials in the environment in risk management in many other European countries. Moreover, the
and their following escalation in fires, explosions and toxic dispersions. CCPS guidelines assert that the ‘gross disproportion’ test, required for
The adoption of safety measures for a company is essential in order ALARP in the UK, allows authorities to demand the achievement of risk
to reduce risks and environmental impacts. Several risk management levels much lower than the specified risk criteria and that in most indus-
principles are available to guide the decision-making in safety manage- tries the actual risk levels achieved are at least an order of magnitude
ment [19], amongst them one is the ALARP principle. According to this below the risk criteria. In contrast, in the Netherlands, the process for
principle, risks and environmental impacts should be reduced at a level balancing the costs of risk reduction against the derived benefits does
that is “as low as reasonably practicable”, which means that measures not require a gross disproportion. The Petroleum Safety Authority Nor-
for the prevention of equipment failures and losses of containment and way [35] sets requirements for oil and gas companies operating on the
for the mitigation of the consequences of potential accidental scenarios Norwegian continental shelf (NCS), stating that: “In reducing the risk,
have been implemented, provided that it cannot be demonstrated that the responsible party shall choose the technical, operational or organ-
the costs are grossly disproportionate to the benefits obtained; ref. e.g. isational solutions that, according to an individual and overall evalu-
[27], IRGC [30], Bedford and Cooke [17], Bahr [16] and Vinnem et al. ation of the potential harm and present and future use, offer the best
[37]. results, provided the costs are not significantly disproportionate to the
The CCPS [21] guidelines for the Chemical Process Quantitative Risk risk reduction achieved”. Although the acronym ALARP is not specifi-
Analysis, commonly used in the context of industries at major risk re- cally mentioned here, a ‘disproportionate’ criterion is specified to guide
fer to the use of the ALARP approach. Their application is firstly based decision-making.
on distinguishing between an intolerable risk level, which must not From a chemical company perspective, there is a burden of proof on
be exceeded, and a negligible risk level which does not raise either the company in applying the ALARP principle [29]. A safety measure is
individual or public concern. Between these two limits (the so-called to be implemented unless the manager can demonstrate an investment
cost that is assessed to be unreasonable when compared with the as-
☆
A short version of this paper was presented at the ESREL-conference 2015 in Zürich.
∗
Corresponding author.
E-mail address: eirik.b.abrahamsen@uis.no (E.B. Abrahamsen).
http://dx.doi.org/10.1016/j.ress.2017.08.014
Received 20 January 2017; Received in revised form 10 August 2017; Accepted 17 August 2017
Available online 19 August 2017
0951-8320/© 2017 Published by Elsevier Ltd.
E.B. Abrahamsen et al. Reliability Engineering and System Safety 169 (2018) 160–165
2. Implementation of ALARP and the grossly disproportionate One main challenge in decision-making under uncertainty is to de-
criterion cide how much weight could be given to the cautionary principle. Three
different perspectives could be applied as described in Abrahamsen and
The ALARP principle is adopted by several industries, such as, for Abrahamsen [2] and Sørskår and Abrahamsen (2016).
example, the oil & gas and nuclear industries (see e.g. [31,36]) and One perspective is to use a traditional cost-benefit (cost-
chemical industry i.e. oil refining, energy production, conversion of raw effectiveness) analysis. The decisions are then made with reference to
materials, etc. (see e.g. [18,23,26]). expected values, which means that limited or no weight is given to the
In verification of ALARP and the grossly disproportionate crite- uncertainties and the cautionary principle; see also Fig. 2. We refer to
rion, different tools are used, such as cost-benefit analysis and cost- this way of interpreting the ALARP principle as the ‘extreme economic
effectiveness analysis (see e.g. [32]). The role of such analyses in ALARP perspective’.
processes was discussed, e.g. Aven and Abrahamsen [13], where it was The argument for focusing on expected values is related to the port-
concluded that cost-benefit (cost-effectiveness) analyses should be used folio theory, which states that the average of a number of random quan-
with care, as they do not give sufficient weight to the uncertainties, since tities can be accurately approximated by the expected value when the
the methods applied are based on an attitude to risks and uncertainties number of quantities is high.
which is risk neutral and thus in conflict with the use of the cautionary The use of expected values as a basis for decision-making under un-
principle and ALARP. certainty has been thoroughly discussed in the literature; see for exam-
To better take the uncertainties into consideration, Aven and Vinnem ple Abrahamsen et al. [5], Ale et al. [7], Aven [11] and Aven and Renn
[15] suggested an alternative approach, which was further developed [14]. It is argued that expected values should be used with care, as the
by Aven [10]. This approach, which we refer to in the following as the uncertainties are not fully addressed. More weight should be placed on
layered approach, consists of three steps as shown in Fig. 1. the cautionary principle than what is made through expected values.
In the first step, a crude analysis is carried out. According to the ap- The problem is that, if one has the potential for large losses, the use
proach, the safety measure should be implemented in situations with of expected values could be misleading. With many activities/projects
low costs. Otherwise, one needs to carry out more detailed analyses (having a societal perspective), the expectation could be more
before a decision is made. From the second step of the approach, a informative, more like the average value, but the prediction can still
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5. Examples and discussion whereas Case B is the adoption of a measure to achieve a further risk
decrease within the acceptable zone (from RB0 to RB1 ). In both cases the
To discuss the appropriateness of the ALARP approach, and its dy- risk reduction has the same factor (x).
namic interpretation, as a ruling principle in safety management, we Case 1 – Thermoelectric power plant (Extreme safety perspective)
have applied the layered approach of Fig. 1 to three case-studies from A thermoelectric power plant converts the heat, produced by the
the chemical industry, related to the sector of energy production from combustion of a heavy residue of the distillation of petroleum, to pro-
fossil fuels. The use of such materials involves several problematic vide electric energy. The heavy residue comes from a nearby refinery
factors: one concerns their availability, because fossil fuels are non- but, due to environmental and human health concerns associated with
renewable energy sources, whereas others relate to the environmental the combustion of this material, as well as the opportunity for the re-
issues and effects on human health arising from the plant’s emissions finery to extract further oil-derived products after the installation of a
[22]. Here, we focus on the adoption of solutions to reduce the risk of new unit, it cannot provide more. To deal with the unavailability of the
adverse health effects, caused by the inhalation of emitted hazardous original fuel, the plant management has two alternatives: (i) to acquire
substances, for workers and people living close to the establishment; a refined oil, which implies an increase in fuel costs and also a reduction
clearly such solutions act on the reduction of the emissions in the atmo- in the environmental and human health impacts, even if the issue related
sphere and thus of the number of fatalities due to the activity over the to the consumption of natural resources (fossil fuel) still exists, or (ii) to
long term. process a new and less expensive fuel (solid recovered fuel, SRF), which
Within the commonly used decision-making framework of HSE [27], is produced from municipal and other industrial non-hazardous wastes
as discussed above, three risk levels are identified, i.e. a lower range of and could be locally produced. The second solution requires some mod-
risk with no practical interest, an intermediate range that can be tol- ifications inside the plant but, based on a merely economic assessment,
erated in any circumstances and the upper range of unacceptable risk. it appears more convenient. Concerning the environmental and human
Such levels are indicated in Figs. 3 on a triangular diagram, which is health concerns, such an alternative fuel can suitable replace fossil fuels
commonly used to demonstrate the application of the ALARP princi- in power plants only if its composition is in accordance with some com-
ple [27]. The ALARP approach is usually applied to reduce tolerable pliance rules addressed by European technical specifications for solid
risks to a level that is ‘as low as reasonably practicable’ (represented recovered fuels.
by the grey area of Fig. 3). In such a frame, decisions are sometimes This case raises both economic and safety issues. It seems that, ac-
taken without fully accounting for the uncertainties, whereas a com- cording to a crude economic analysis (Step 1 in Fig. 1), the adoption of
plete investigation is needed for an appropriate risk management [3]. the second technical solution implies high costs, even if it is the main
Actually, risk cannot be adequately described only by probability P and orientation of the plant management. Step 2 reveals that the ENPV is less
expected consequence EC, as these are conditioned on the background than zero, as the expected costs are higher than the expected benefits.
information (i.e. knowledge about the phenomena, performance char- Step 3 shows that the decision context is affected by relevant uncertain-
acteristics and historical performance data for the system, etc.), which ties, i.e. there are currently several uncertainties related to the fuel’s
covers assumptions [8,9,12]. An objective value for probabilities and composition, as well as to the procedure for its characterisation. Thus,
expected consequences cannot be provided, as a feature of the fact that the general framework is characterised by a lacked knowledge about
different assessments could produce different values depending on the the environmental impacts and the possible consequence for the human
assumptions made by the analysts. Therefore, uncertainties affect the health associated with the activity. As a result of such uncertainties, one
positioning of the events on the triangular diagram and the application may adopt decisions based on an extreme safety perspective and con-
of the ALARP principle for decisions must not be restricted only to the cludes to not implement the solution. One may also adopt a perspective
range of tolerable risks, this means that the grey area of Fig. 3 has to be with strong weight to the uncertainties without adopting the extreme
extended as shown in Fig. 4. Based on this evidence, our discussion on safety perspective. What perspective to adopt in this case depends on
the application of the layered approach refers to the decision-making how the check-list is carried out.
framework of Fig. 4, where only an acceptability of risk threshold is Case 2 – Cogeneration combined cycle plant (extreme economic perspec-
shown. In Figs. 3 and 4, the risk vs. the disproportional factor is also tive)
shown to provide the entity of risk reduction due to the application of A company, which operates a paper factory equipped with a cogen-
some measures. In Fig. 3 risk is reduced from R0 to R1 In Fig. 4, Case eration combined cycle plant, aims at reducing the impacts associated
A refers to the application of a measure/solution, which decreases the with the production of energy by improving the efficiency of the cogen-
risk from an unacceptable value to an acceptable one (from RA0 to RA1 ), eration system. The plant currently has an efficiency level equal to 60%
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and, to pursues its goal to reach 80%, the company focuses on the best achieved, with the cost of implementing the measure (assuming a plant
use of the produced steam and analyses five potential projects: (1) the lifetime of 20 years); this can be done by calculating the implied cost
installation of a downstream economizer in the recovery boiler circuit, of avoiding a fatality (ICAF). The ICAF is more than 1.8 M€ that is the
(2) the use of spilled steam in the boiler, (3) the use of spilled steam value of a statistical fatality suggested by HSE [28]. In simplistic terms, a
to heat the establishment, (4) the installation of a sludge dryer, and measure that costs more than 1.8 M€ is considered disproportionate and
(5) the construction of a preheating system for the natural gas used in therefore not justified, triggering the need to look more closely at the
the turbine. Each project is assessed in order to understand which are decision context (Step 3). It can be absolutely stated that the measure is
potentially feasible. In each case, although the work environment is ap- based on the best available technology; moreover, some manageability
proved as sufficiently safe, safety aspects are not considered as the main factors are relevant for its implementation. At the same time the con-
driver for decisions in this analysis. However, an overall reduction in text is affected by medium uncertainties related to the knowledge of the
fuel usage for combustion is expected to be achieved from the adoption involved phenomena. This description addresses the use of an approach
of one of the previously mentioned solutions, as well as a decrease in for making a decision that lies between an extreme economic and an
the environmental impacts. extreme safety perspective. Such a situation, where the decision-maker
By using the approach of Fig. 1, it is revealed that each alternative is placed between the ‘extreme safety’ and the ‘extreme economic’ per-
implies an investment of economic resources (Step 1). The assessment, spective, is likely to be the most common occurrence.
addressed in Step 2, shows that the ENPV is less than 0 in all cases. After
a careful evaluation of the decision context (Step 3), it can be absolutely 6. Conclusions
stated that low uncertainties are associated with the involved phenom-
ena, conditions and consequences; other issues are also relevant, such as In this paper, we have shown that the ALARP principle is not consid-
aspects of the manageability and robustness. This frame points towards ered appropriate as a general decision-making principle in safety man-
the application of an extreme economic perspective for decision-making; agement, unless it is interpreted in a dynamic way, meaning that the
thus, the selection of the best solution can be made with respect to a cost- interpretation of the grossly disproportionate criterion ranges from one
benefit analysis. Given the low uncertainties ENPV ≈ NPV, the projects extreme, where decisions are made with reference to expected values,
undergo a careful evaluation based on the assessment of the related NPV to another extreme, in which the cautionary principle is given special
and, finally, solution (4) is proved to be practicable. The installation of weight with no reference to cost-benefit (cost-effectiveness) analyses.
a sludge dryer allows a significant reduction in the quantities of sludge The main point is that one static decision-making principle cannot be
from the process to be disposed of (currently 2700 t/year are produced appropriate for use in all decision contexts. Different contexts require a
and disposed with a cost of 63 €/t). suitable defined flexible decision-making principle. It then follows that
Case 3 – Production of heat and electricity by heavy hydrocarbons gasi- it is not appropriate to use the ALARP principle in safety management as
fication in a refinery (between an extreme economic and an extreme safety a general decision-making principle if the grossly disproportionate crite-
perspective) rion is independent of the decision-context. Furthermore, we conclude
A company, operating a refinery equipped with a plant for the pro- that it can be appropriate to adopt the ALARP principle as a general
duction of electricity in cogeneration by the gasification of heavy hydro- principle in safety management if the layered approach suggested by
carbons, has assessed the on-site and off-site risks by means of a quan- Aven [10] is adopted. This approach is formulated in such a way that
titative risk assessment (QRA). The plant management is planning to the ALARP principle can range from one extreme perspective, where
develop risk-reduction opportunities. Inside the establishment various decisions are made with reference to expected values, to another ex-
toxic and flammable materials are handled and processed; thus, several treme, in which the cautionary principle is given special weight with no
scenarios were identified. Toxic releases are the main contributors to reference to cost-benefit (cost-effectiveness) analyses.
risk. One example is a release through a pressure safety valve, installed The energy production sector of chemical industry has been the start-
on a column that currently discharges into the atmosphere. The plan ing point for the paper, but our discussions are to a large extent general
management point towards the possibility of mitigating/eliminating and could also be applied to other industries or contexts.
these scenarios by using an effluent handling system consisting of a catch
tank and an associated flare stack. Acknowledgements
A crude analysis of the applicability of the measure (Step 1 of Fig. 1)
indicates that the costs are high; thus, a more detailed analysis is needed The authors are grateful to three anonymous reviewers for useful
(Step 2). It is necessary to compare the reduction in risk, that would be comments and suggestions to an earlier version of this paper. The au-
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thors would also like to thank Professor Terje Aven at the University [19] Baybutt P. The ALARP principle in process safety. Process Safety Progress
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