The Risk Management Tool Box Blog

Australian Drinking Water Guidelines

Graham Marshall - Thursday, April 05, 2012

In order to provide an improved framework for good management of drinking water, the National Health and Medical Research Council (NHMRC) has released a new Australian Drinking Water Guideline (ADWG).

The new guideline applies particularly to small water supplies such as those found in remote communities, mine sites and offshore oil and gas installations.

The purpose of the new NHMRC guideline is to ensure the water is safe to drink.

The guideline addresses both the health and aesthetic aspects of good quality drinking water.

The advantage of the ADWG guideline is that it places emphasis on a preventive approach to managing water quality, with less reliance on water testing - which can be problematic for remote camps.

Thus the focus, in relation to small water supplies, should be on regular inspection of the system to check for any sources of contamination, and the use of a clean, unpolluted water source.

The new NHMRC Australian Drinking Water Guidelines can be found by clicking here (note PDF document is a little over 5 MEG so may take a few moments to upload).

Kiken Yochi

Graham Marshall - Tuesday, January 03, 2012

Now I know we've all heard of the standard risk management tools for operational activites, the JSA, JHA, TRA, PRA, HazID, HazOP, LOPA Study, erc, etc.

It's a long list of acronyms for the average safety guy to remember!

Well, now there is a new one - well, new to me anyway!

KYT.  I must admit that I'd never heard of it before.  But it stands for "Kiken Yochi Training", which in Japan equates roughly to what we would call a cross between a JSA and a tool-box meeting. 

K= Kiken = "hazard".

Y = Yochi = "prediction".

T = training.

Like a typical JSA, the objective of KYT is to identify hazards, identify and predict incident and consequence potential and identify and select appropriate controls. 

Sounds good to me.




Four Myths about ALARP

Graham Marshall - Tuesday, November 08, 2011

Following up on my post yesterday, I'm including some useful information from the UK HSE about common myths associated with the ALARP principle, and also why these myths are mistaken.

Myth 1 - Ensuring that risks are reduced to ALARP means that standards of HSE performance have to continually rise.

Although it is a good philosophy to seek to continually improve performance in HSE standards,  improvements should always be made in a responsible manner.  It is widely recognized that the best risk controls available are not necessarily reasonably practicable to implement. It is only if the cost of implementing the best methods of control is not grossly disproportionate to the reduction in risk they achieve that their implementation should be considered.

Deciding whether something is safe enough at the ALARP level is a different exercise from seeking a continual improvement in HSE standards. But as technology develops and new and better methods of risk control become available, these should be implemented when possible.

All work places should review new methods of controls that become available from time-to-time and consider how they can implement the new controls.  For a variety of reasons, however, it may not be reasonably practicable to upgrade older plant and equipment to the most modern standards.

The decision about what is ALARP is also affected by changes in knowledge about the magnitude of the risk presented by a given hazard.  If there is strong evidence to show that a hazard presents significantly greater levels of risk than previously thought, then stronger controls to tackle the new situation may be required to reduce the risk to ALARP.  If the new evidence indicates that a specific hazard presents significantly lower risk than previously thought, however, then a relaxation in control may actually be warranted.

Myth 2 - If a few organizations have adopted a high standard of risk control, that standard sets the ALARP risk level for the whole industrial sector.

Some organizations implement risk controls that are more stringent than simple standards of good practice.   It does not follow that these risk control standards are reasonably practicable in all cases, just because a few organizations have adopted them.

Myth 3 - Ensuring that risk is reduced to the ALARP level means adopting all possible risk controls.

The “belt and braces” approach  to risk reduction in which every possible control is touted is not justifiable.  Remember that ALARP means that a barrier can be required only if its introduction does not involve grossly disproportionate cost, effort or resources.  ALARP does not mean that every HSE control that could possibly be implemented to reduce risk should be implemented. There is often more than one way of reducing risk to ALARP, so start with the easiest and most convenient controls.

Myth 4 - Ensuring that risk is reduced to the ALARP level means that there will be no accidents or ill-health.

ALARP does not represent zero risk.  In any activity involving people, there is never no risk and the risk arising from a hazard may be realized sometimes even though the risk is ALARP.

All organizations should, however, strive to reduce and maintain the risk within their business at the ALARP level.   Senior Management should never be complacent but the only way that the risk within any business activity can be entirely eliminated is if the activity is abandoned altogether. This will often make no business sense at all!

ALARP and Cost-Benefit Analysis

Graham Marshall - Monday, November 07, 2011

ALARP is short for “as low as reasonably practicable” and the core of this concept is “reasonable practicality”.  

That means weighing the risk of something occurring and its level of consequences against the time, effort, and resources needed to control it.

Assessing if something is “reasonably practicable” allows for a risk-based approach to health and safety rather than a prescriptive approach. This flexibility is a great advantage of the safety-case regime found in the UK and Australia over the OSHA regime found in the USA.

Deciding whether a risk is ALARP requires good judgement.  In most cases, decision-making about ALARP is straight-forward and uses reference to existing standards of good practice.

 "Good practice” is defined by the UK Health and Safety Executive as: “those standards for controlling risk that HSE has judged and recognized as satisfying the law, when applied to a particular relevant case, in an appropriate manner.”

For hazards in complex or novel situations, however, ALARP builds on good practice, using more formal risk assessment and risk management processes such as Cost-Benefit Analysis (CBA).

You should also remember, as well, that "reasonably practicable" is a narrower term than "physically possible".  In essence, making sure a risk has been reduced to ALARP is about weighing the risk against the sacrifice needed to further reduce it.

The decision is weighted in favour of health and safety because the presumption is that the duty-holder should implement the risk reduction measure.

To avoid having to make unwarranted sacrifices in time, effort, or resources, however,  the organization involved must be able to show that it would be grossly disproportionate to the benefits of risk reduction that would be achieved.

Thus, the process is not one of balancing the costs and benefits of measures but, rather, of adopting measures except where they are ruled out because they involve grossly disproportionate sacrifices.  Extreme examples might be:

+   To spend £1m to prevent an employee suffering a cut finger is obviously grossly disproportionate; but

+   To spend £1m to prevent 150 fatalities in a gas explosion is obviously proportionate.

In most situations, deciding whether the risk is ALARP involves a comparison between the control measures an organization has in place and the control measures one would normally expect to see in such circumstances.

Once what is good practice has been determined,  assessing if a particular risk is ALARP is likely to be concerned with the relevance of the good practice, and how appropriately it has been (or will be) implemented.  Where there is relevant, recognized good practice, the regulators in both the UK and Australia will expect organizations to follow it.

 If organizations want to implement something different, they must be able to demonstrate to the Regulators satisfaction that the measures they propose to use are at least as effective in controlling the risk.

Where the situation is complex, it may be difficult to reach a decision on the basis of good practice alone. There may be cases involving a new technology or process condition where there is no relevant good practice. In such cases, good practice should be followed as far as it can be, and then consideration given to whether there is any more that can be done to reduce the risk. If there is more, the presumption is that duty-holders will implement these further measures but this needs to be confirmed by going back to first principles to compare the risk with the sacrifice involved in further reducing it.

Often such “first principles” comparisons can be done by applying common sense and/or exercising professional judgment or experience.

For example if the costs are clearly very high and the reduction in risk is only marginal, then it is likely that the situation is already ALARP and further improvements are not required.

In other circumstances the improvements may be relatively simple or cheap to implement and the risk reduction significant: here the existing situation is unlikely to be ALARP and the improvement is required. In many of these cases a decision can be reached without further analysis.

But there are some instances in high hazard industries with potentially serious consequences where the situation is less clear-cut.

In these instances, a more formal Cost Benefit Analysis (CBA) may provide additional insight to help come to a judgment about ALARP.

In a standard CBA, the usual rule applied is that the measure should be adopted only if benefits outweigh costs.

However, in ALARP judgments, the rule is that the measure must be adopted unless the sacrifice is grossly disproportionate to the risk.

So, the costs can outweigh benefits and the measure could still be reasonably practicable to introduce.

How much costs can outweigh benefits before being judged grossly disproportionate depends on many  factors.  In all cases, however, good judgement and sound use of the risk assessment methodology will assist to arrive at the right decisions.

Safe Evacuation of People With Disabilities

Graham Marshall - Thursday, August 18, 2011

The safety-critical component to any emergency evacuation of a facility is to get everyone away from the danger zone quickly and safely. 

In the case of people with a disability, if they can get into a facility then there is no reason for them not to be able to get out again during an evacuation.
To assist property and facility managers with developing sound planning for such emergencies, Standards Australia has developed AS/NZ 3745 2010.

The objective of AS/NZ 3745 is to provide a framework for emergency planning, utilizing the built facilities as appropriate to ensure the safety of all occupants.

The new Standard also includes expanded and revised sections on the following topics:

(a) Developing the emergency plan;

(b) Duties of the emergency planning committee and emergency control organization;

(c) Provisions for occupants with a disability;

(d) Education and training; and

(e) Guidance on how to determine the size of the emergency control organization.

A useful website for those with a further interest in planning emergency response requirements for people with disabilities can be found here.




Lost Time Injury Reporting Codes

Graham Marshall - Tuesday, June 21, 2011

On the 1 July 2011, WorkSafe (WA) will commence using the latest versions of industry, occupation and injury coding standards for the reporting and investigation of all work related traumatic fatalities and lost time injuries and diseases in Western Australia.

The coding standards used from this date will be:

  • AS/NZ Standard Industrial Classification 2006 (ANZSIC 2006);
  • Type of Occurrence Classification System Third Edition Revision 1 (TOOCS 3.1); and
    • AS/NZ Standard Classification of Occupations First Edition (ANZSCO).

    Further information about these changes can be found here.


    Safe Office Temperatures

    Graham Marshall - Thursday, May 05, 2011

    I get asked from time to time to offer advice about office environmental conditions in relation to light, noise, temperature, humidity and such like.

    In fact, in my experience over the years, I've noted that complaints about office heating and cooling are a common gripe.

    Is it too hot or too cold?

    Does the temperature vary too much throughout the day?

    Are draughts a problem?

    What about humidity levels and air movement?

    Under the UK system of law which applies in places like Australia, NZ, Canada and Great Britain, there are general duties within the various applicable Laws to provide a working environment that is safe and without risks to health.

    For employers and those "with control of the workplace", this so called "duty of care" means they should be proactive when managing office environmental conditions, including temperature levels.

    For employers, the duty of care also obliges them to monitor environmental conditions at workplaces under their control.

    If necessary, the employer should seek expert assistance to monitor the environmental conditions on their behalf.

    In order to meet their legal duties, employers should ensure that indoor office temperatures vary according to the outside temperature across the seasons.

    Comcare, the Australian Federal OHS Agency, has produced a guide for buildings under Commonwealth control called Air Conditioning and Thermal Comfort in Australian Public Service Offices.

    You will find the Comcare Guide by clicking here.

    The Comcare Guide suggests that the comfort level in summer when people are wearing summer clothing is between 23 and 26 degrees Celsius.

    Australian Standard AS1668.2 (The Use of Ventilation and Airconditioning in Buildings) also offers additional guidance.

    General good practice in meeting the employers duty of care in relation to office temperature includes the following advice:

    • Ensure to monitor and regulate air temperature and humidity at comfortable levels;
    • Avoid locating workstations directly in front of or below air conditioning outlets;
    • Install deflectors on air vents to direct airflow away from people;
    • Control direct sunlight (radiant heat) with good building design (passive solar design) or use blinds, louvres or outdoor shade;
    • Minimize draughts and thermal differences between the head and the feet (thermal gradients);
    • Ensure adequate air flow to at least an applicable (in-country) Standard (e.g., to AS 1668.2); and
    • Monitor and regulate humidity levels according to staff comfort levels. 


    If people in your office are concerned about the OHS impacts of office environmental conditions then they should approach management to request that the following things be checked:

    • Whether the heating and/or cooling system is working properly or needs maintenance, adjustment etc;
    • The temperature in various places within the building;
    • The amount of air flow within the office environment;  and 
    • The  level of humidity within the office.


    In the event that the heating or cooling system breaks down management should provide free standing ventilation fans or temporary heaters as an interim measure until the system is fully restored. 

    It maybe necessary to evacuate affected parts of the office when the working conditions become unacceptably uncomfortable.

    There may also be a range of other workplace options including working from home as a short term measure.

    Food Safety

    Graham Marshall - Saturday, April 30, 2011

    I don't often have so much to say about the "H" for health in Occupational Health and Safety. 

    But today is definitely a "health" topic.

    Have you ever thought about the difference between the words "Best-before", "use-by", or even "sell-by" or "display-until" that crop up on your grocery purchases?

    Well, in the greener more eco-friendly World we all now inhabit, the UK advisory body Waste and Resources Action Programme (WRAP) says that families are trashing up to a quarter of their monthly grocery purchases because of this confusion.

    The cost is said to be about £680 to the average British Family every year.

    Apparently, the confusion over product labeling means that shoppers are  unclear about the difference between "use-by" and "best-before".

    So what purpose do they actually serve?

    The UK Food Standards Agency says that "best before" dates are about quality of the product and NOT safety.

    The "best before" date shows when a product could begin to lose flavor and texture.

    It does not  indicate that the foodstuff is dangerous.

    The purpose of "best before" is really to protect product manufacturers and retailers from litigation, and has nothing to do with  the health of consumers.

    In contrast, however, the "use-by" date is to show when meat products, cooked meats, soft cheeses, dairy-based dessert and other similar "fresh" products may put people at risk if eaten after a given date.

    So the "use by" date provides the key information to consider in terms of health risk.

    Never eat food after this date.

    In all cases the "use-by" date is only reliable when the foodstuff is stored according to any given instructions on the product.

    For further information on this topic, click here to visit Food Standards (Australia and NZ).

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