Citation

Ho P. Safety Sci. 2023; 159: e106042.

Copyright

(Copyright © 2023, Elsevier Publishing)

DOI

10.1016/j.ssci.2022.106042

PMID

unavailable

Abstract

Australian major hazard facilities (MHF) are regulated through a 'safety case' regime requiring operators to submit a safety report to the regulator demonstrating all risks have been reduced so far as is 'reasonably practicable'. The Work Health and Safety Act (2019) has codified the definition of what is reasonably practicable, requiring consideration of five matters: the likelihood of the risk; degree of harm; what is known about the risk; availability and suitability of risk control measures; and the cost of the control measures. Thirteen interviews with MHF regulators were conducted across Australia to understand how they regulated safety cases and applied the concept of reasonably practicable. The regulators revealed they relied on the operator to provide the safety case to demonstrate how the facility had reduced risks so far as is reasonably practicable. The regulators stated that the four most common tools used to demonstrate reasonable practicability were: quantitative risk assessment, layer of protection analysis, cost-benefit analysis, and risk matrices. These tools were examined against the five considerations of reasonable practicability. None of these tools addressed all five considerations. Four suggestions are provided to improve the safety case process: 1. Safety case should demonstrate how the risk is acceptable. 2. Safety case should outline how the operator has met their legal obligations. 3. Safety case should place greater emphasis on the use of consequence-based analysis. 4. Regulators should be granted additional powers to enforce their interpretation of what is reasonably practicable.

Language: en

Keywords

ALARP; As low as is reasonably practicable; Health and safety; Occupational health and safety; Reasonably practicable; Safety case; Work health and safety