SFAIRP not equivalent to ALARP
The idea that SFAIRP (so far as is reasonably practicable) is not equivalent to ALARP (as low as reasonably practicable) was originally discussed in Richard Robinson’s article in the January 2014 edition of Engineers Australia Magazine. At the time, it generated much commentary to the effect that major organisations like Standards Australia, NOPSEMA and the UK Health & Safety Executive say that it is.
Fast forward to 2022 and this is still the case.
The following review considers each briefly. This is an extract from the 2022 update of the R2A Text Engineering Due Diligence – How To Demonstrate SFAIRP (Section 19.3).
The UK HSE’s document, ALARP “at a glance”1 notes:
“You may come across it as SFAIRP (“so far as is reasonably practicable”) or ALARP (“as low as reasonably practicable”). SFAIRP is the term most often used in the Health and Safety at Work etc Act and in Regulations. ALARP is the term used by risk specialists, and duty-holders are more likely to know it. We use ALARP in this guidance. In HSE’s view, the two terms are interchangeable except if you are drafting formal legal documents when you must use the correct legal phrase.”
R2A’s view is that the prudent approach is to always use the correct legal term in the way the courts apply it, irrespective of what a regulator says to the contrary.
NOPSEMA are quite clearly focussed on the precautionary approach to risk. Their briefing paper on ALARP2 indicates in the Core Concepts that:
“Many of the requirements are qualified by the phrase “reduce the risks to a level that is as low as reasonably practicable”. This means that the operator has to show, through reasoned and supported arguments, that there are no other practical measures that could reasonably be taken to reduce risks further.” (Bolding by R2A).
That is, NOPSEMA wish to ensure that all reasonable practicable precautions are in place which is the SFAIRP concept. Indeed, later in Section 8, Good practice and reasonable practicability, there is a discussion concerning the legal, court driven approach to risk. Whilst ALARP is mostly used elsewhere in the document, here NOPSEMA notes:
“When reviewing health or safety control measures for an existing facility, plant, installation or for a particular situation (such as when considering retrofitting, safety reviews or upgrades), operators should compare existing measures against current good practice. The good practice measures should be adopted so far as is reasonably practicable. It might not be reasonably practicable to apply retrospectively to existing plant, for example, all the good practice expected for new plant. However, there may still be ways to reduce the risk e.g. by partial solutions, alternative measures, etc.” (Bolding by R2A).
Standards Australia seems to be severely conflicted in this area in many standards, some of which are called up by statute. For example, the Power System Earthing Guide presents huge difficulties.
Another example is AS 5577 – 2013 Electricity network safety management systems. Section 1.2 Fundamental Principles point (e): which requires life cycle SFAIRP for risk elimination and ALARP for risk management:
Hazards associated with the design, construction, commissioning, operation, maintenance and decommissioning of electrical networks are identified, recorded, assessed and managed by eliminating safety risks so far as is reasonably practicable, and if it is not reasonably practicable to do so, by reducing those risks to as low as reasonably practicable. (Bolding by R2A).
It seems that Standards Australia simply do not see that there is a difference. The terms appear to be used interchangeably.
Safe Work Australia is only SFAIRP3. There does not appear to be any confusion whatsoever. For example, the Interpretative Guideline – Model Work Health and Safety Act The Meaning of ‘Reasonably Practicable’ indicates:
“What is ‘reasonably practicable’ is determined objectively. This means that a duty-holder must meet the standard of behaviour expected of a reasonable person in the duty-holder’s position and who is required to comply with the same duty.
“There are two elements to what is ‘reasonably practicable’. A duty-holder must first consider what can be done - that is, what is possible in the circumstances for ensuring health and safety. They must then consider whether it is reasonable, in the circumstances to do all that is possible.
“This means that what can be done should be done unless it is reasonable in the circumstances for the duty-holder to do something less.
“This approach is consistent with the objects of the WHS Act which include the aim of ensuring that workers and others are provided with the highest level of protection that is reasonably practicable.”
ALARP is simply not mentioned, anywhere.
Although the ALARP verses SFAIRP debate continues in many places and the current position of many is that SFAIRP equals ALARP; nothing could be further from the truth.
For engineers, the meaning is in the method; results are only consequences.
SFAIRP represents a fundamental paradigm shift in engineering philosophy and the way engineers are required to conduct their affairs.
It represents a drastically different way of dealing with future uncertainty.
It represents the move from the limited hazard, risk and ALARP analysis approach to the more general designers’ criticality, precaution and SFAIRP approach.
That is;
From: Is the problem bad enough that we need to do something about it?
To: Here’s a good idea to deal with a critical issue, why wouldn’t we do it?
SFAIRP is paramount in Australian WHS legislation and has flowed into Rail and Marine Safety National law, amongst others.
In Victoria, SFAIRP has now also been incorporated into Environmental legislation.
Apart from the fact that SFAIRP is absolutely endemic in Australian legislation with manslaughter provisions to support it proceeding apace, SFAIRP is just a better way to live.
It presents a positive, outcome driven design approach, always testing for anything else that can be done rather than trusting an unrepeatable (and therefore unscientific) estimation of rarity for why you wouldn’t.
If you'd like to learn more about SFAIRP for Engineering Due Diligence, you may be interested in purchasing our textbook. If you'd like to discuss how R2A can help your organisation, fill out our contact form and we'll be in touch.
Editor's note: This article was originally published on 22 January 2014 and has been updated for accuracy and comprehensiveness.
1 https://www.hse.gov.uk/managing/theory/alarpglance.htm viewed 21 February 2022
2 https://www.nopsema.gov.au/sites/default/files/documents/2021-03/A138249.pdf viewed 21 February 2022
3https://www.safeworkaustralia.gov.au/system/files/documents/2002/guide_reasonably_practicable.pdf viewed 21 February 2022