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Reliability Engineering and System Safety 169 (2018) 160–165

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Reliability Engineering and System Safety


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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

sumed benefits in reduced risks due to releases of hazardous substances.


In that sense, the ALARP principle gives strong weight to the caution-
ary principle, which is a basic principle in risk management, expressing
that in the face of uncertainty, caution should be a ruling principle, for
example by not starting an activity, or by implementing measures to
reduce risks and uncertainties [15,27].
In contrast to the ALARP principle, decisions can be made with refer-
ence to expected values, as discussed in Ale et al. [7] and Ale [6]. Little
or no weight is then given to the cautionary principle. The arguments for
using expected values as a basis for decision-making under uncertainties
is from the portfolio theory [33]. This theory is based on the statement
that the expected value of the portfolio plus the systematic risk (uncer-
tainties), caused by events affecting the whole market, is the value of
a portfolio of projects and that the unsystematic risk (specific project
uncertainties) can be ignored in case of a large number of project.
Based on the above argument, we discuss the implications of using
the ALARP principle in safety management of chemical industry. Two
Fig. 1. Layered approach for implementing ALARP and the gross disproportionate crite-
cases are investigated, one relates to an inefficient use of resources, the rion [10].
other one concerns when scarce resources are available for safety. Even
if the attention is focused on chemical industry our discussion is to a
large extent general and could also be applied to other industries. safety measure should be implemented according to the ALARP prin-
We show that the ALARP principle is considered an appropriate prin- ciple if such an investment is appropriate from a cost-benefit (cost-
ciple in safety management only if the grossly disproportionate crite- effectiveness) analysis point of view. This is intuitively appealing. One
rion is interpreted differently for different decision-making contexts, can, for example, conclude that the costs are not grossly disproportion-
such that the principle ranges from one extreme, where decisions are ate to the benefits obtained if the expected benefit is higher than the ex-
made with reference to an expected value, to another, in which the pected costs. One may also decide to implement a safety measure accord-
cautionary principle is adopted without any reference to cost-benefit ing to the layered approach, even if the cost-benefit (cost-effectiveness)
(cost-effectiveness) analyses. A static decision-making principle, where analysis concludes upon no investments, which is shown in the third
the balance between the expected values and the safety concerns is step of the approach. High levels of uncertainty, among many other
fixed, cannot be appropriate as a ruling principle in safety management, issues can justify investments in a safety measure. Examples of issues
as different decision-making contexts require different decision-making other than uncertainties that need to be taken into consideration are:
principles. Does the measure significantly increase the manageability? Does the
The paper is organised as follows. Section 2 focuses on how to imple- measure contribute to obtaining a more robust solution? Is the measure
ment ALARP and the grossly disproportionate criterion. Section 3 dis- based on best available technology (BAT)? Are there unsolved problem
cusses how much weight should be given to the uncertainties in safety areas: personnel safety-related and/or work environment-related? Are
management. In Section 4, we examine the appropriateness of using there possible areas where there is conflict between these two aspects?
ALARP as a ruling principle in safety management. Then in Section 5, Is there a need for strategic considerations? For a full review of the lay-
by means of some case studies, collected from the energy production ered approach, we refer to Aven [10]. See also NORSOK Z-013 [34].
sector, we provide a discussion and comments about the application of
the ALARP principle in chemical industry and its dynamic interpreta- 3. Different perspectives on how much weight should be given to
tion. Finally, in Section 6, we draw some conclusions. the cautionary principle

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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extreme perspective, where decisions are made with reference to a tra-


ditional cost-benefit (cost-effectiveness) analysis, to another, in which
the cautionary principle is given strong weight without any reference to
cost-benefit (cost-effectiveness) analyses.
The appropriateness of the ALARP principle must be seen in rela-
tion to how it is implemented, as the way the principle is implemented
strongly influences how dynamic it is. Such dynamics are in line with the
HSE [27] interpretation of ALARP, which gives more weight to uncer-
tainties and a cautionary mindset when risk is closer to a non-tolerable
region, i.e. close to the limit of the acceptable risk level.
As described in Section 2, one way to implement ALARP is to define
costs as grossly disproportionate to the benefits obtained if the expected
cost (EC) is considered x times higher than the expected benefit (EX),
where x represents the grossly disproportionate factor between the costs
and benefits. This approach for implementing ALARP is considered in-
appropriate if one value of x is used for all types of decision contexts,
Fig. 2. Different perspectives on how decisions can be made, and their influence on the
weight given to uncertainties and the cautionary principle (Sørskår and Abrahamsen, as, in this way, the ALARP principle turns out to be static.
2016). With the above approach, the ALARP principle will be dynamic if dif-
ferent values of the grossly disproportionate factor are used for different
decision contexts. But, as described previously, such an approach is not
be poor when facing extreme outcomes. Moreover, there may also be considered appropriate, as focusing solely on expected values does not
aspects that our analyses and assessments have not taken into account: take the uncertainties properly into consideration; ref. Aven and Abra-
surprises with respect to our beliefs, models and assumptions may still hamsen [13].
occur. Another approach for verifying ALARP is the layered approach
A solution to the problem, as several experts have pointed out, is shown in Fig. 1. By using the layered approach, the ALARP principle
to adjust the expected values to account for uncertainties [20,24,25]. A may lead in some situations, to decisions being made with reference
paper by Aven and Flage in 2009 reviews such approaches (Aven and to expected values, while, in other circumstances, the decisions can be
Flage, 2009). The challenge pointed out was largely that the uncertainty made without any reference to costs and benefits. From how the lay-
is not properly taken into account, as attention remains on expected ered approach is presented in Fig. 1, it is difficult to see that the ALARP
values. Little weight is then placed on the potential for major accidents. principle can be as dynamic as shown in Fig. 2. To see this more clearly,
The above conclusions do not mean that the use of expected values one may look more closely into situations where all the issues assessed
cannot be appropriate to adopt as a basis for decision-making. The main in the third step of the approach are considered ‘unproblematic’ (con-
message is that expected values cannot be appropriate to use as a general texts with low levels of uncertainty, high levels of knowledge and no
decision-making principle in safety management. potential for major accidents, etc.). One may then conclude upon ‘no
A second perspective on how to weight the uncertainties in safety implementation’, even if the expected cost of the safety measure is just
management, rather than focusing on expected values, is to give strong slightly higher than the expected benefit. The decision is then based
weight to the cautionary principle without any references to cost-benefit solely on a traditional cost-benefit analysis (the extreme economic per-
(cost-effectiveness) analysis. Such a perspective, which we refer to as an spective). The checklist in the third step of the approach may also be
extreme safety perspective, is in contrast with the use of expected values instigated such that, for some contexts, the decision is to implement the
as shown in Fig. 2. The extreme safety perspective is not considered as safety measure, independently of the result from the second step of the
an appropriate way to manage risk in general, as such a perspective approach, which means that the ALARP principle turns out to be equal
certainly does not turn out to be cost-effective. to the extreme safety perspective. For most contexts one will be some-
A third perspective lies somewhere between the two extremes, mean- where between the two extremes. From this we see that the layered
ing that there is a reference to costs and benefits when decisions upon approach can be as dynamic as the one shown in Fig. 2.
investments in risk reducing measures are made, but with a stronger It can be noted that one does not necessarily end up by covering all
weight being placed on uncertainties and the cautionary principle than the perspectives (group of perspectives) drawn in Fig. 2 if the layered
is the case with expected values. approach is adopted. One may, for example, give strong weight to the
Based on the three different perspectives one may ask which one is cautionary principle in the calculation of the ENPV in the second step
the most appropriate in safety management. As already indicated, no of the approach. This is done by reflecting risk aversion in the cost-
single perspective would be appropriate for use in all decision-making benefit analysis1 . The layered approach will then not be fully dynamic.
contexts. For example, a context with a high level of uncertainty, a low For further clarifications, we refer to Abrahamsen et al. [1].
level of knowledge and the potential for major accidents demands com- The different ways of interpreting the layered approach means that
pletely different decision support and different weight on the caution- we cannot conclude upon the appropriateness of using the ALARP prin-
ary principle than a context with low levels of uncertainty, high levels ciple as a general decision-making principle in safety management if
of knowledge and no potential for major accidents (Sørskår and Abra- the layered approach is adopted, unless i) the ENPV is calculated in a
hamsen, 2016). Similar conclusions are also found in e.g. Wiencke et al. traditional way without special weight given to the uncertainties and
[38] and Abrahamsen et al. [4]. ii) the checklist (guideline) contributes to the ALARP principle’s ability
to range from an extreme economic perspective on how to weight the
4. ALARP as a general decision-making principle in safety uncertainties to an extreme safety perspective. Without covering these
management? extremes, the ALARP principle cannot be appropriate for use in general
in safety management.
If different decision-making contexts require different decision-
making principles, it then follows that the ALARP principle cannot be
appropriate as a general decision-making principle in safety manage- 1
Several methods has been developed to reflect risk aversion in cost-benefit analyses.
ment unless it is interpreted in a dynamic way - meaning that the A review is found in EAI [24]. See also Binder [20] and Hallegatte [25]. In these methods,
interpretation of the grossly disproportionate criterion ranges from one adjustments are made on either the discount rate or the contribution from the case flows.

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Fig. 3. Decision-making framework HSE [27].

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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Fig. 4. Decision-making framework integrating the uncertainty management.

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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