Integration of Risks from Multiple Hazards into a
Holistic ALARA / ALARP demonstration
Pete Bryant | SRP President Electp.bryant@liverpool.ac.uk

Registered Charity No: 112804
www.srp-uk.org

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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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Introduction• The “optimisation” principle is at the core of radiation protection. It is often
referred to as ALARA, short for keeping all doses “As Low As ReasonablyAchievable”.
• The vast majority of situations involve a range of hazards.
• There is a natural tendency to assess radiological and other hazards, such as
chemical and manual handling, independently. This can result in a lack ofproportionality in the treatment of each hazard or even the introduction of
new hazards as a result of mitigating another hazard.
• Taking a balanced view of a range of hazards and risks is something that
operational safety staff do every day. But how do you make thatjudgement?
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Historical Overview• Throughout the 1980s and early 1990s, CEPN and NRPB collaborated inseveral Commission of the European Communities research projects withthe objective of developing the understanding of ALARA and its practicalimplementation.
• The initial focus for the development of an understanding of ALARA was onmechanistic approaches using quantitative decision aiding techniques.
• By the late 1980’s, it was becoming clear that, whilst the development ofstructured approaches provided ‘tools’ to pursue ALARA, this did notnecessarily achieve anything in practice unless there was a will to positively
pursue the ALARA principle.
• Over the years, the commitment to ALARA has become part of what wewould now recognise as (Radiation) Safety Culture.
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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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ALARA in the UK Regulatory Regime

Health & Safety
at Work Act 1974
ALARA
Environmental
Permitting
Regulations 2010

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SFAIRP

ALARA

BAT

Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
demonstration

ALARP

ALARA in the UK Regulatory Regime
International Requirement(e.g. BSS)
Health & Safety
at Work Act 1974
ALARA
Environmental
Permitting
Regulations 2010

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SFAIRPALARA

BATIntegration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
demonstration

ALARP

ALARA in the UK Regulatory Regime
Overarching “Act” covering
Health and Safety from allhazards.
Health & Safety
at Work Act 1974
ALARA

Overarching “Regulations”
covering discharges, andaccumulation and disposalof all waste in England andWales.

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Environmental
Permitting
Regulations 2010

SFAIRP

ALARA

BAT

Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
demonstration

ALARP

ALARA in the UK Regulatory Regime

Health & Safety
at Work Act 1974
ALARA
Environmental
Permitting
Regulations 2010

Legal requirement toreduce all risks to “So Far
As Is ReasonablyPracticable”. Introduces
Optimisation andProportionality.

SFAIRP

ALARA

BAT

Optimisation requirement
covering all aspects ofactivities leading to thegeneration and disposal ofall waste.

8Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
demonstration

ALARP

Requires the operator
to keep all radiological
exposures to thepublic As Low As
Reasonably
Achievable.

ALARA in the UK Regulatory Regime

Health & Safety
at Work Act 1974
ALARA
Environmental
Permitting
Regulations 2010

9SFAIRP

ALARP

ALARA

BATIntegration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
demonstration

Tool for demonstrating
SFAIRP, weighing therisk against thesacrifice needed tofurther reduce it.

Integration of different risks in the UK• High Hazard Industries (Nuclear, Oil and Gas, Rail etc.) are Heavily
Regulated.
• Nuclear Industry most heavily regulated. Gold Standard in UK Health &Safety.
• Significant effort in the integration of different risks as part of theALARP Argument.
• What about the Lower Hazard Industries or Medical Sector? Is there an allrisk approach?
• It appears there is not yet a consistent approach across industries for thetreatment, yet alone integration of risks. For instance Deterministic vsProbabilistic Treatment of Risks in different sectors.
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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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The Nuclear Industry and Safety Case
• The Safety Case is a requirement in UK Law (Health and Safety at Work Act
and Nuclear Installations Act).
• NIA requires a site licence to be issued prior to the construction andoperation of a Nuclear Facility.
• Safety Case - The documentation that demonstrates how the operators
meets there License Conditions and has reduced the risks to ALARP.
• The Safety Case has a strong link to the Radiological Risk Assessment andSystem of Protection. However this is applied to all hazards. Not justNuclear or Radiological.
• A learning opportunity for other sectors?
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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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Definition of Problem

Optioneering

HAZID

Nuclear & Radiological
Safety Assessment

Environmental Risk
Assessment

Deductions fromAssessments

Safe Operating Envelope...

Manual Handling Safety
Assessment

Standard Industrial
Hazard Assessment

Chemical Safety
Assessment (e.g. COSHH)

Example Framework for the Integrationof Risks from Multiple Hazards into a
Holistic ALARA / ALARP demonstration

Hazard Streaming

Demonstration ofAcceptability

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Optioneering• Provides the foundation to the ALARP argument.
• First off there must be a clear definition of the problem.
• Key Steps:• Define Requirements (e.g. Functional Requirements)• Identify Options• Define Selection Criteria - Assurance (including Radiological Safety,Conventional Safety, Environmental Risks), Engineering, Business etc.
• Analyse Options - Assess against criteria• Scoring and Ranking• Down Selection - Identify Preferred Option(s)13Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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Optioneering• When defining the selection criteria due consideration should not only given
to one hazard such as radiological or nuclear safety, but consideration isgiven to all hazards, including Environmental Risks.
• A Scoring System should be decided prior to undertaking the analysis of theoptions, along with any weighting to be applied to the criteria, to takeaccount of the relative importance.
• Recording and reporting of the above provides an auditable trail that
underpins the justification and supports the ALARP argument.
• A Quorate Group of Specialists may be required.

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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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Hazard Identification (HAZID)• A Safety Case or Risk Assessment requires a systematic method of hazard
identification. This provides a means of testing the preferred option.
• The hazard identification process must identify all significant hazards, i.e.
those that could lead to loss of life, injury or ill health to a facility worker,
on-site worker and member of the public. Potential hazards include
radiological and standard industrial hazards (conventional hazards).
Combinations of hazards must also be considered (where these can not beeliminated by the design).
• In addition, all releases that could potentially pollute the environment mustalso be identified.
• The HAZID should be accurately recorded and documented to provide anauditable trail that underpins the ALARP argument.
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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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Hazard / Safety Assessments• Regardless of the Hazard Type whether Nuclear / Radiological, Industrial orEnvironmental in nature a proportionate approach should be undertaken toassessing the hazard.
• For those hazards capable of causing a significant consequence (fatality
or a number of serious injuries) it is reasonable to undergo additional
assessment to understand the potential fault sequences andconsequences, and to correctly determine the relevant safety controls.
• Those hazards with a lower consequence are less likely to require an in
depth assessment to identify any controls.

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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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Hazard / Safety Assessments• Relevant Good Practice should be applied to all hazards as a minimum.
• Those hazards capable of causing a significant consequence may require
specialist assessments tailored to the hazard type. For instance explosive
hazards.
• It should be noted that in certain cases controls put in place to limit or
reduce the risk associated with one hazard type, may also be used to limit or
reduce the risk associated with another hazard type. (e.g. Chemical andRadiological Contamination Hazards). In such cases it is important to makesure any claims placed on the control are recorded in both hazard
assessments.
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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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Deductions from Assessments & Safe Operating Envelope• The output of the various assessments should be reviewed in combination,
to ensure that there are no conflicts, for instance any controls or mitigations
put in place for one hazard type have not created any new hazards, orimpacted on any of the other hazard assessments.
• These deductions are then used to define the Safe Operating Envelope. This
review should be undertaken by SQEP panel, who have a demonstrable
understanding of the various hazard types.
• The SOE includes Bounding Conditions, Engineered and/or Managerial
Safety Controls (and requirements placed on the controls, including
maintenance), which are to be implemented by the facilities safety
management arrangements.
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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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Demonstration of Acceptability• As part of the Hazard / Safety Assessments claims are placed on Engineered
Controls and Managerial Controls.
• These claims need to be substantiated in order to demonstrate they can bemet.
• The extent of substantiation is proportionate to the level of risk reduction
and confidence required for the safety measure. This may range fromcompliance with relevant standards, to a more in-depth assessment offailure modes or through limiting factors.

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Challenges with the Integration of Risks• The described framework has been applied to varying degrees at several
Nuclear Facilities in the UK, in particular the Nuclear Defence
Establishments.
• This has included Research Facilities where only minor quantities of Nuclearor Radioactive Materials maybe handled, to the higher hazard facilities
handling larger quantities of enriched nuclear materials.
• The application of this framework is not without its challenges both within
its use in the Nuclear Sector, and extending it to wider industries. Asummary of some of the key challenges are provided in the subsequentslides, along with some tips and lessons learnt.
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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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Challenges with the Integration of Risks• Balancing the risks during the optioneering stage.
• For instance, one option may result in a reduction in the radiological risks
but an increase in the risks associated with industrial hazards.
• This emphasises the importance of the careful selection of the criteria
used to assess the options including due consideration of all hazards.
• It is crucial that any reasoning behind Scoring and Ranking, is well
documented and defendable. As discussed earlier this forms thefoundation of the ALARP argument.

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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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Challenges with the Integration of Risks• Lack of a consistent approach within industries.
• There is no one consistent approach for assessing risks across industries,and differences even within specific industries (e.g. Nuclear). To continue
driving an integrated approach forward it is key that we encourage:• Knowledge sharing across industries and within industries.
• Regulators encourage the use of best practice approaches as part oftheir expectations.
• Adoption of a common lexicon of risk terminology across all hazard
types and industries.

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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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Challenges with the Integration of Risks• Management of materials with multiple hazards.
• Materials such as uranium are both radiologically and chemically toxic. In
such instances, it is important to identify the dominant health detrimentfrom that form of the material, in the situation being assessed, and use
this as the primary basis for identifying the controls.
• As part of the assessment due consideration should be taken that theform of the material may change as part of the initiating event leading
the hazard being realised.
• A check should also be made to ensure the identified controls for thedominant health detriment (e.g. chemical toxicity), are suitable andsufficient to control the other hazards (e.g. radiological toxicity).
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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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Summary / Conclusions• The UK Nuclear Industry has placed significant effort of the integration ofdifferent risks as part of the ALARP Argument.
• However, there is not yet a consistent approach across industries or even
within the sector.
• Can the System of Protection be applied to all hazards?
• Challenges associated with balancing the risks from multiple hazards.
• Work still to be done!
• Opportunities to improve how we exchange experiences.
• Full paper found in Journal of Radiological Protection, Volume 38, Number 1.
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AnyQuestions?

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Integration of Risks from Multiple Hazards into a Holistic ALARA / ALARP
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