Thoughts on AS/NZS ISO 31000
In Australia, we are currently undergoing a paradigm shift in the way safety risk management is conducted. The new Work Health & Safety Act is replacing the old approach typified by the standard, AS/NZS ISO 31000.
We have heard conversation in the Engineering community that the move away from AS/NZS ISO 31000 doesn’t necessarily it present a better way forward and the standard can in fact demonstrate safety due diligence. R2A does not share this view.
The key issue arises from the use of the notion of target (tolerable or acceptable) levels of risk. The standard is quite specific in the definitions and process explanations:
2.24 risk evaluation
process of comparing the results of risk analysis (2.21) with risk criteria (2.22) to determine whether the risk (2.1) and/or its magnitude is acceptable or tolerable
5.4.4 risk evaluation
Risk evaluation involves comparing the level of risk found during the analysis process with risk criteria established when the context was considered. Based on this comparison, the need for treatment can be considered.
The section on the treatment options is more careful.
5.5.2 Selection of risk treatment options
Selecting the most appropriate risk treatment option involves balancing the costs and efforts of implementation against the benefits derived, with regard to legal, regulatory, and other requirements such as social responsibility and the protection of the natural environment. Decisions should also take into account risks, which can warrant risk treatment that is not justifiable on economic grounds, e.g. severe (high negative consequence) but rare (low likelihood) risks.
The point of the new due diligence approach is to deal with the severe safety (high negative consequence) but rare events. The standard seems to suggest that this is a supplementary risk management concern, not a primary focus.
Unfortunately by following the standard for safety risk management, businesses may in fact be heading towards a ‘beyond reasonable doubt’ proof of recklessness in the event of a serious injury or death, which potentially creates criminal liabilities for responsible officers under the provisions of the new WHS Act.
R2A has described on a number of occasions how the standard fails. In particular, RES 2010 regarding the use of iso-risk contours for Major Hazards land use safety planning after the Buncefield incident, CORE 2010 regarding rock falls in rail cuttings and the Tunnel Conference in Lyon.
At R2A, we are excited by the paradigm change and believe it is a better way forward. Please drop us a line if you have any questions.