As low as reasonably practicable - guarding against 'reverse ALARP'
Article published in the Regulator | Issue 2: 2017
During a recent facility inspection, NOPSEMA discovered that the operator did not have a stand-by vessel present when rope access personnel were working over the side of the facility (i.e. outboard of the handrails). Without this vessel, if a person had fallen into the sea, rescue times would have increased from approximately 10 to 150 minutes. The operator said that the mitigation control was removed due to ‘significant cost and schedule benefits.’
While there were multiple preventative barriers in place to reduce the likelihood of a fall, removing the stand-by vessel meant that there were no barriers in place in the instance of a fall. Therefore, the removal of that mitigation control represented an increase in risk.
NOPSEMA defines the practice of moving to a higher risk but cheaper approach as ‘reverse ALARP.’ Facility operators have a duty under Clause 9(1)(b) of Schedule 3 of the Offshore Petroleum and Greenhouse Gas Storage Act 2006 to take all reasonable practicable steps to ensure that all activities carried out on the facility are safe and without risk. Therefore, NOPSEMA will not accept any increase in risk based on reverse ALARP, particularly where an existing control measure, which was once considered reasonably practicable, is removed.
In this case, the operator agreed to reinstate the stand-by vessel to ensure that the rescue time was maintained at approximately 10 minutes.
Section 3 of NOPSEMA’s ALARP guidance note (www.nopsema.gov.au/assets/Guidance-notes/A138249.pdf) outlines the principles that underpin ALARP and discusses the reverse ALARP concept. While this document is written as a safety case guidance note focusing on major accident events, the principles should be used for all hazards identified at the facility. This is particularly relevant in the current market conditions where industry continues to focus on reducing operating expenditure.