ON THE ALARP APPROACH TO RISK MANAGEMENT

1. INTRODUCTION
   The management of risks associated with potential hazardous activities in society remains a
   matter of profound public and technical interest. There has been and continues to be
   considerable development in the range and extent of regulatory activity. Many new
   regulatory frameworks have been established. Except for public input to risk assessments
   for very specific and contentious projects, there appears to have been remarkably little
   public debate (and perhaps even understanding) of the more general and philosophical
   issues involved. This is despite the rather spectacular failure in recent years of electricity,
   gas and other services over large regional areas and the occurrence of several major
   industrial accidents.
   One issue which might have been expected to have received some public discussion is how
   decisions about hazardous facilities and activities are to be regulated. Should it be through
   regulatory or consent authorities, and if so, what form and allegiances should such bodies
   have? Alternatively, should it be through ‘self-regulation’, or should there be some other
   mechanism(s)? These options have been explored in an interesting discussion paper.1
   However, it appears largely to have been ignored in practice. Perhaps by default, the
   regulatory approach is the most common route in attempting to exert control over
   potentially hazardous activities. This trend is being followed in a number of countries. It is
   appropriate, therefore, to review some aspects of these directions. In particular, the present
   paper will focus on the use of the so-called as low as reasonably practicable (ALARP)
   approach [also sometimes known as the as low as reasonably attainable/achievable
   (ALARA) approach]. It will be viewed primarily from the perspective of so-called
   ‘Common Law’ countries, that is those with a legal system parallel to that of the USA or the
   UK. For countries such as Norway, where ALARP is also very extensively used, some of
   the comments to follow may not be completely applicable. However, it is considered that
   the bulk of the discussion is sufficiently general.
   The ALARP approach grew out of the so-called safety case concept first developed
   formally in the UK. 2 It was a major innovation in the management of risks for potentially
   hazardous industries. It requires operators and intending operators of a potentially
   hazardous facility to demonstrate that (i) the facility is fit for its intended purposes, (ii) the
   risks associated with its functioning are sufficiently low and (iii) sufficient safety and
   emergency measures have been instituted (or are proposed). Since in practice there are
   economic and practical limits to which these actions can be applied, the actual
   implementation has relied on the concept of ‘goal setting’ regulations. The ALARP
   approach is the most well known of these. It is claimed by some as being a more
   ‘fundamental’ approach to the setting of tolerable risk levels.3,4
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   Conceptually the ALARP approach can be illustrated as in Fig. 1. This shows an upper
   limit of risk that can be tolerated in any circumstances and a lower limit below which risk is
   of no practical interest. Indicative numbers for risks are shown only for illustration—the
   precise values are not central to the discussion herein but can be found in relevant countryspecific
   documentation. The ALARP approach requires that risks between these two limits
   must be reduced to a level ‘as low as reasonably practicable’. In relevant regulations it is
   usually required that a detailed justification be given for what is considered by the applicant
   to satisfy this ‘criterion’.
   Fig. 1: Levels of risk and ALARP, based on UK experience.3
   As a guide to regulatory decision-making the ALARP concept suggests both ‘reason’ and
   ‘practicality’. It conveys the suggestion of bridging the gap between technological and
   social views of risk and also that society has a role in the decision-making process. In
   addition, it has a degree of intuitive appeal, conveying feelings of reasonableness amongst
   human beings. As will be argued in more detail below, these impressions are somewhat
   misleading. There are also considerable philosophical and moral short-comings in the
   ALARP approach. Perhaps rather obliquely, the discussion will suggest what should be
   done to improve the viability of ALARP or what characteristics need to be embodied in
   alternatives. However, it is acknowledged that this is not a paper offering ‘solutions’ but
   rather one which it is hoped will focus more attention on the issues and stimulate discussion
   in order to bring about solutions.
   To allow attention to be focussed more clearly on the difficulties with the philosophy of
   ALARP, it is necessary first to review some matters fundamental to the interpretation and
   management of risk in society. These issues include: (i) risk definition and perception, (ii)
   risk tolerance, (iii) the decision-making framework, and (iv) its implementation in practice.
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2. RISK PERCEPTION
   2.1. Risk understanding and definition
   Increased levels of education, awareness of environmental and development issues and
   greater political maturity on the part of society generally has led to a much keener interest in
   industrial risk management practices, policies and effectiveness. Apart from hazardous
   industries, public interest derives also from notable public policy conflicts over the siting of
   facilities perceived to be hazardous or environmentally unfriendly. Despite this, ‘risk’ as a
   concept perceived by the general public appears to be rather poorly defined, with confusion
   between probability, something involving both probability and consequences and something
   implying monetary or other loss.
   Vlek and Stallen5 gave some ten different definitions of ‘risk’ or riskiness, using various
   ways of ‘mixing’ all or parts of the two main component ideas. Traditional decision
   analysis, of course, simply multiplies the chance estimate by the consequence estimate.
   This is only a ‘first-order’ approach, with both the chance estimate and the consequence
   estimate being mean values. It is possible, at the expense of greater complexity in analysis,
   but perhaps reflecting more accurately personal and societal perception, to invoke measures
   of uncertainty, such as the standard deviation of each estimate.6 Nevertheless, there is likely
   to remain some disagreement over a core definition of risk (as there appears to be in most
   sociological and psychological works about any term) depending on ones view-point and
   stake in the eventual outcome.1
   In the mathematical/statistical literature and in most engineering oriented probability
   discussions, risk is simply taken as another word for probability of occurrence or ‘chance’,
   with consequences, however they might be measured, kept quite separate. Herein the
   approach will be adopted to use ‘risk’ as a generic term, implying both probabilities and
   consequences without specifying how these are to be combined.
   2.2. Risk as an objective matter
   It has become increasingly clear that ‘risk’ is not an objective matter. Thus all risk
   assessment involves both ‘objective’ and ‘subjective’ information. Matters generally
   considered to be capable of ‘objective’ representation, such as physical consequences, are
   seldom completely so, since in their formulation certain (subjective, even if well accepted)
   decisions have had to be made regarding data categorization, its representation, etc. This
   also applies to areas of science once considered to be ‘objective’, a matter which is now
   considered briefly.
   In the development of mathematical and numerical models in science, model ‘verification’ is
   the proof that the model is a true representation. It may be possible to do this for so-called
   ‘closed’ systems. These are completely defined systems for which all the components of the
   system are established independently and are known to be correct. But this is not the
   general case or the case for natural systems. For these ‘verification’ is considered to be
   impossible.7
   Model ‘validation’, on the other hand, is the establishment of legitimacy of a model,
   typically achieved through contracts, arguments and methods. Thus models can be
   confirmed by the demonstration of agreement between observation and prediction, but this
   is inherently partial. “Complete confirmation is logically precluded by the fallacy of
   affirming the consequent … and by incomplete access to natural phenomena … Models can
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   only be evaluated in relative terms.”7 Philosophical arguments also point to the
   impossibility of proving that a theory is correct—it is only possible to disprove it.8,9
   Moreover, in developing scientific work, models are routinely modified to fit new or
   recalcitrant data. This suggests that models can never be ‘perfect’.10 It follows that for
   theories and models to be accepted, there is necessarily a high degree of consensus-forming
   and personal inter-play in their development and the scientific understanding underpinning
   them.11 Some of this can be brought about by ‘peer’ reviews of risk assessments and
   procedures, such as widely practiced in the nuclear industry.
   These concepts carry-over directly to risk estimation since risk estimates are nothing but
   models of expectation of outcomes of uncertain systems (i.e. ‘open’ systems), couched in
   term of the theory of probability. Thus, in the context of PSA, “… often the probabilities
   are seen as physical properties of the installation and how it is operated …” and while this
   view is useful for making comparative statements about riskiness or for comparison to
   standards, this interpretation is inconsistent with “all standard philosophical theories of
   probability …”12
   2.3. Factors in risk perception
   There are many factors involved in risk perception.1 These include:
   (i) the likely consequences should an accident occur;
   (ii) the uncertainty in that consequence estimate;
   (iii) the perceived possibilities of obviating the consequences or reducing the probability of
   the consequences occurring, or both;
   (iv) familiarity with the ‘risk’;
   (v) level of knowledge and understanding of the ‘risk’ or consequences or both; and
   (vi) the interplay between political, social and personal influences in forming perceptions.
   The last two items in particular deserve some comment. Knowledge and understanding of
   risk issues on the part of individuals and society generally implies that (risk) communication
   exists, that it is utilized to convey meaningful information and that the capacity exists to
   understand the information being conveyed and to question it. Perhaps the most critical
   issue is the actual availability of relevant and accurate information. For a variety of
   reasons, there has been an increasing requirement placed on governments and industry to
   inform society about the hazards to which its members might be exposed. There has
   developed also greater possibility for access to government and government agency files
   under ‘Freedom of information’-type legislation. Whether these developments have been
   helpful in creating a better informed public is not entirely clear, as it involves also issues
   such as truthfulness in communications and the trust which society is willing to place in the
   available information.
   That there will be an interplay between individual and societal perceptions of risk follows
   from individuals being social beings. Their very existence is socially and psychologically
   intertwined with that of others. Formal and informal relationships and institutions “set
   constraints and obligations upon people’s behavior, provide broad frameworks for the
   shaping of their attitudes and beliefs, and are also closely tied to questions both of morality
   and of what is to be valued and what is not. There is no reason to suppose that beliefs and
   values relating to hazards are any different from other more general beliefs and values …”1
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3. DECISION FRAMEWORKS
   3.1. New technology
   Society as a whole is constantly faced with the need to make decisions about existing
   hazardous or potentially hazardous projects. Usually these decisions are delegated to
   organizations with recognized expertise in the area. For existing technology, that expertise
   will rely on past experience, including accident statistics and ‘incident’ (or ‘near-miss’)
   statistics for hazardous facilities. In many cases hazard scenario and contingency planning
   also will be carried out. It is in this area that the techniques of probabilistic risk analysis are
   recognized to have validity in the sense of Section 2.2.6
   For the potential risks associated with new technologies, however, the problem of
   management is more acute. This is because the basis for making decisions, that is a base of
   accumulated knowledge and experience, is not available. The dilemma can be seen clearly
   in the earlier writings related to nuclear risks, prior to the occurrence of the accidents at
   Three Mile Island, Chernobyl and the like. For example, Stallen13, in reviewing the works
   of Hafele and Groenewold notes that the only solutions for the control of risks caused by
   new technology tend to involve extensive use of other (and older) forms of technology.
   History suggests that a new technology will only survive if it has no major catastrophes
   early in its development. Thereafter, the risks are apparently small because: (i) the
   operating experience base is small; (ii) particular care tends to be taken; and (iii) there has
   not been enough time for in-service problems to become sufficiently evident. This may lead
   to the false sense that the actual risks involved are small. Further, for new technologies it is
   generally the case that the scientific understanding of the total socio-technical system, its
   limitations and assumptions, is rather incomplete, adding further to the difficulties of
   satisfactory risk estimation. The ‘trial-and-error’ underpinning much of the understanding of
   conventional and well-developed technology is missing.
   In connection with the development of science, Popper8,9 has argued that only falsifications
   (i.e. failures) lead to new developments—verifications of existing ideas merely add to our
   apparent confidence in them, but they could be wrong. The inferences for risk analysis are
   not difficult to make.14
   3.2. A wider perspective
   Under these circumstances, how can society deal with the evaluation of risks imposed by
   new technology? It is suggested that some light may be thrown on this question by an
   examination of the parallel issue of the rationality of science. Noted philosopher
   Habermas15 has argued that the rationality of science stems not from any objective, external
   measures such as ‘truth’ but from agreed formalisms (see also Section 2.2). This involves
   transactions between knowledgeable human beings and agreement between them about what
   can be considered to be ‘rational’, given the base of available knowledge and experience. It
   presupposes a democratic and free society with equal opportunities for contributing to the
   discussion, for discourse and for criticism. It also requires truthfulness of viewpoint and the
   absence of power inequalities. Although these might seem like tall orders indeed,
   Habermas argues that there are very few situations where these conditions are not met or
   cannot be met eventually since open and free discourse will uncover the limitations which
   might exist. The implication for risk analysis and evaluation is that the rationality of the
   criteria and the degree to which risk might be accepted should be based, ultimately, on the
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   agreed position of society obtained through internal and open transactions between
   knowledgeable and free human beings.
   Such a position has been put in different, but essentially analogous ways by others.1 The
   importance of giving consideration to public opinion underlies much writing on risk criteria.
   However, the practical difficulties of “arriving at consensus decisions over the question of
   acceptable risk in society ” are considerable. According to Layfield16 in commenting on
   Britain’s Sizewell B reactor … “The opinions of the public should underlie the evaluation of
   risk. There appears to be no method at present for ascertaining the opinions of the public in
   such a way that they can be reliably used as the basis for risk evaluation. More research on
   the subject is needed.”
   Moreover, society is a complex mix of sub-groups with differing aims, ambitions, views,
   opinions and allegiances. It is not surprising then that when faced with most matters about
   which profound decisions need to be made society responds with a variety of view-points
   and courses of action. Although there are always inter-plays between short-term and
   longer-term self-interests and morally ‘high-ground’ views, it appears in many cases that the
   diversity of views and the convictions with which they are held is inversely related to the
   knowledge sub-groups of society have about the matter being considered.
   Layfield16 noted …”As in other complex aspects of public policy where there are benefits
   and detriments to different groups, Parliament is best placed to represent the public’s
   attitude to risks.” In practice, of course, such a course of action might be taken only for
   major policy decisions, such as whether the nation should have nuclear power or not, etc.
   However, Wynne17 and others have argued that Parliament is ill-equipped both in time and
   expertise to fully appreciate the implications and changes likely to be brought about by the
   introduction or further development of new technologies. In his view, particularly for major
   new technology issues, the political process can only be considered to be defective.
   A historical review of the introduction of any really new technology shows, however, just
   how ill-informed and ill-equipped parliaments tend to be, mostly being even unaware of the
   changes taking place around them. For most major technological innovations (irrespective
   of their hazard potential) parliamentary interest tends to follow well after the technologies
   have been introduced. There are many examples of this in the developing Industrial
   Revolution18 and more recent examples include IVF technology, gene technology, internet
   technology, etc.
   Moreover, even within society more generally there is seldom much awareness of potential
   problems and hence little or no debate or detailed consideration of it. Usually only after the
   technology has been established and some of its problems have become evident does public
   perception become active. This suggests that risk assessment in general, and approaches
   such as ALARP, can deal only with the control of the further development of already
   established technology.
   3.3. Practical decisions
   Whatever the idealized situation ought to be, the need to make day-to-day decisions about
   lesser hazards in society has invariably led to regulatory approaches as more convenient
   substitutes for public or parliamentary debate. One reason sometimes given for leaving the
   decisions to public servants is that the public is uneducated, ill-informed and irrational in
   dealing with complex issues; arguments which can hardly be sustained as essential in a
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   modern society. However, to invoke public debate and discussion ideally requires time and,
   for many individuals, much back-ground education when the discussion is about complex
   issues. None of these conditions tends to be met in practice, for a variety of reasons (see
   also Section 2.3). Often regulators will facilitate some form of public participation, such as
   through making available documents and through providing back-ground briefings.
   Unfortunately, in advancing along this line, there is a danger that there may no longer be
   much left of Habermas’s vision of transactions between knowledgeable and free individuals
   in coming to a consensus.
   The methods which have evolved for the solution of acceptable or tolerable risk problems in
   a bureaucratic setting may be categorized broadly to include: 1
4. professional judgement as embodied in institutionally agreed standards (such as
   engineering codes of practice) or as in commonly accepted professional skills;
5. formal analysis tools such as cost-benefit analysis or decision analysis, with or without
   public discussion opportunities; and
6. so-called ‘boot-strapping’ approaches employing techniques such as ‘revealed
   preferences’ as used in social–psychology, or using extrapolations from available
   statistical data about risks currently accepted in other areas of endeavor.
   Aspects of all three are commonly in use. As will be seen, the ALARP approach falls
   essentially in the third category.
7. RISK TOLERABILITY
   The levels of risk associated with a given facility or project that might be acceptable to, or
   tolerated by, an individual or society or sub-groups is an extremely complex issue, about
   which much has been written. It is not possible to deal with this matter here, but see Reid19
   for a useful summary and critique.
   Of course, ‘tolerability’ and ‘acceptability’ are not necessarily the same, although it has been
   common in risk analysis to loosely interchange the words. According to the HSE3,
   ” ‘tolerability’… refers to the willingness to live with a risk to secure certain benefits and in
   the confidence that it is being properly controlled. To tolerate a risk means that we do not
   regard it as negligible or something we might ignore, but rather as something we need to
   keep under review and reduce still further if and when we can.” Acceptability, on the other
   hand, implies a more relaxed attitude to risk and hence a lower level of the associated risk
   criterion. According to Layfield16, in terms of the nuclear power debate, the term
   ‘acceptable’ fails to convey the reluctance that individuals commonly show towards being
   exposed to certain hazardous activities.
   Although the distinction between the terminology ‘acceptability’ and ‘tolerability’ is
   important, it is also the case that the term ‘acceptable’ has been used in relation to consent or
   acceptance of a proposed risk situation on the part of regulatory authorities. This suggests
   by implication that the decisions of the regulatory authorities in some manner reflect
   ‘tolerability’ on the part of society.
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8. ALARP
   5.1. Definition of terms
   As noted, the ALARP approach has been advocated as a more fundamental approach to the
   setting of tolerable risk levels, particularly suitable for regulatory purposes.20 Fig. 1
   summarizes the approach, in which the region of real interest lies between the upper and
   lower limits. This is the region in which risks must be reduced to a level ALARP. Since
   this objective is central to the approach a very careful discussion and explanation of terms
   might be expected. However, apart from appeals to sensible discussion and reasonableness
   and the suggestion that there are legal interpretations, there is little in print which really
   attempts to come to terms with the critical issues and which can help industry focus on what
   might be acceptable.3
   The critical words in ALARP are ‘low’, ‘reasonably’ and ‘practicable’. Unfortunately, these
   are all relative terms—standards are not defined. ‘Reasonably’ is also an emotive word,
   implying goodness, care, consideration etc. However, as will be discussed below, what may
   be reasonable in some situations can be seen as inappropriate in others.
   Regarding ‘practicable’, the Oxford Dictionary refers to ‘that can be done, feasible…’, i.e.
   what can be put into practice. Of course, many actions can be implemented, provided the
   financial rewards and resources are sufficient. Thus there are a very clear
   financial/economic implications—” ‘reasonable practicability’ is not defined in legislation
   but has been interpreted in legal cases to mean that the degree of risk can be balanced
   against time, trouble, cost and physical difficulty of its risk reduction measures. Risks have
   to be reduced to the level at which the benefits arising from further risk reduction are
   disproportionate to the time, trouble, cost and physical difficulty of implementing further
   risk reduction measures.”3
   It is therefore clear that financial implications are recognized—”in pursuing any safety
   improvement to demonstrate ALARP, account can be taken of cost. It is possible, in
   principle, to apply formal cost-benefit techniques to assist in making judgement(s) of this
   kind.”3 This assumes that all factors involved can be converted to monetary values.
   Unfortunately, it is well-known that there are not inconsiderable difficulties and hence
   implied value judgements in evaluating or imputing monetary values for both benefits and
   costs. This problem is particularly acute for the analysis of hazardous facilities where the
   value of human life and the (imputed) cost of suffering and deterioration of the quality of
   life may play a major role in the analysis.
   Further, an approach based on cost analysis implicitly assumes equal weighting for each
   monetary unit, a proposition known to cause difficulties with cost benefit analysis when
   applied to issues with social implications. It is considered that the selection of tolerable risk
   is of this type. Value judgements which society might make are subsumed in the valuations
   required for cost analysis.
   In addition, there is also the problem that the optimum obtained in cost benefit analyses is
   seldom very sensitive to the variables involved. This means that cost benefit analysis alone
   is unlikely to provide a clear guide to the selection of appropriate policy.
   Finally, it is unclear how value judgements such as ‘low’, ‘reasonably’ and ‘practicable’
   correlate with a minimum total cost outcome. The value judgements required involve issues
   well beyond conventional cost benefit analysis, a matter well recognized in dealing with
   environmental issues.21
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   5.2. Openness
   In the expositions of the ALARP approach it appears that the specific tolerable probability
   levels which would qualify for acceptance by a regulatory authority are not always in the
   public domain. The tolerable risk criterion may not be known to the applicant and some
   process of negotiation between the regulatory authority and the applicant is needed.
   Societal groups concerned about openness in government might well view this type of
   approach with concern.
   A related problem with implementation of the ALARP approach can arise in the evaluation
   of two similar projects assessed at different times, possibly involving different personnel
   within the regulatory body and different proponents. How is consistency between the
   ‘approvals’ or ‘consents’ to be attained? Irrespective of the care and effort expended by the
   regulatory authority, there is a real danger that an applicant with a proposal which needs to
   be further refined or which is rejected, will cry ‘foul’. Without openness and without
   explicit criteria, such dangers are not easily avoided. Is there not also a danger of
   corruption?
   5.3. Morality and economics
   The issue of morality and how this is addressed by the ALARP approach can be brought
   most clearly into focus by a discussion based around the nuclear power industry. That
   industry took a major blow in the USA with the Three Mile Island and other incidents.
   Currently there are no new facilities planned or under construction. This is possible in the
   USA because there are alternative sources of electric power with perhaps lower perceived
   risks, including political risks. Opposition to nuclear power and the potential consequences
   associated with it are clearly in evidence. Such an open opposition may not always be
   tolerated in some other countries, nor may there be viable alternative power sources. Thus
   there may be pressures for public opposition to be ignored and to be discredited and for
   access to information to be less easy to obtain. For example, there have been claims of
   ‘cover-ups’, such as over UK nuclear accidents. Whatever the precise reasons, it is clear
   that in some countries the nuclear industry remains viable. Comparison to the US situation
   suggests that what might be considered ‘reasonable and practical’ in some countries is not so
   considered in the US, even though the technology, the human stock and intellect and the
   fear of nuclear power appear to be much the same. The only matters which appear to be
   different are: (i) the economic and political necessities of provision of electrical power; and
   perhaps (ii) acquiescence to a cultural system as reflected in the political authority and legal
   systems and which preclude or curtail the possibility of protracted legal battles apparently
   only possible on Common Law countries. Do these matters then ultimately drive what is
   ‘reasonable and practical’? And if they do, is the value of human life the same?
   The dichotomy between socio-economic matters and morality issues has other implications
   also. It is known that in some countries the nuclear power system is of variable quality,
   with some installations known to have a considerable degree of radiation leakage—far in
   excess of levels permitted under international standards. Even if, as is likely, the costs to
   bring the facilities to acceptable standards are too high, there will be economic pressures to
   keep the facilities in operation, despite the possibility that some plant workers would be
   exposed to excessive radiation. It is known that in some case maintenance problems in high
   radiation areas have been carried out through hiring, on a daily basis, members of the lowest
   socio-economic classes to do the work. Because the remuneration was good by local
   standards there was no shortage of willing workers, even though it has come to be known
   that many develop radiation sickness and serious tumors within weeks of being exposed.
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   Although somewhat starkly, this illustrates that the criteria of ‘reasonableness’ and
   ‘practicability’ so essential in the ALARP approach are ultimately issues of morality. While
   for projects having the potential for only minor or rather limited individual or social
   consequences there is probably no need to be concerned, for other, more significant projects
   the question must be asked whether it is acceptable for decisions about such issues to be left
   for private discussion between a regulatory authority and project proposers.
   5.4. Public participation
   As noted earlier, for many systems in common usage there is a long and established base of
   experience (both good and bad) upon which to draw. This is not necessarily the case for all
   facilities and projects, particularly those subject to risk assessment requirements. It would
   seem to be precisely these projects for which risk analysis should be open to public scrutiny
   and debate so that the issue of their rationality in respect to society can be considered. As
   noted, the ALARP approach would appear to permit a small group of people making
   decisions about a potentially hazardous project, away from public scrutiny, and in
   consultation with the proponents of the project. According to the Royal Society report1,
   “The (ALARP) approach has …been criticised on the grounds that it does not relate
   benefits clearly enough to tolerability. More importantly, however, it does not address the
   critical issue of how public input to tolerability decisions might be achieved, beyond an
   implicit appeal to the restricted, and now much criticised … revealed-preferences
   criterion”…and…”The question of how future public input to tolerability decisions might
   be best achieved is also closely related to recent work on risk communication…”
   It is acknowledged that public debate and participation at a level leading to worthwhile input
   is not always practical. As noted earlier, only some participants will have the time, energy
   and capability to become fully acquainted with the technical intricacies involved in significant
   projects. There are the dangers also of politicizing the debate and perhaps trivializing it
   through excessive emotional input. Nevertheless, there are strong grounds for not ignoring
   non-superficial public participation and involvement in risk-based decisions.1

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