What level of safety risk is acceptable to your organization?
“None” is an easy but ultimately unacceptable answer because it’s unattainable, says Jan Wachter, Sc.D., CSP, CIH, adjunct faculty member at Embry-Riddle Aeronautical University Worldwide and retired professor of safety sciences at Indiana University of Pennsylvania. That’s why every organization must collectively accept some risk and safety professionals are often tasked with helping to determine an organization’s level of risk acceptance.
By determining the level of risk that is “as low as reasonably practicable” or ALARP, safety professionals can inform risk acceptance.
Doing so means wading through a lot of morally ambiguous gray areas. To help, our Hispanic Safety Professionals Common Interest Group recently invited Wachter to explore the intersection of ethics and risk and take a hard look at how risk is determined in the first place.
By clearly identifying the safety leader’s role, seeking to reduce uncertainty in risk assessments and improving the methods by which risk is determined, safety leaders can more ethically protect workers and the community.
ALARP vs. Acceptable Risk: What Is the Safety Leaders’ Responsibility?
While determining ALARP and defining acceptable risk are related concepts, they are not synonymous, Wachter says.
To break it down: ALARP is more of a technical feasibility, one that safety professionals can and should define.
Acceptable risk is a higher-level concept that makes a value judgment, Wachter says. It is strategically, ethically and organizationally driven. A safety professional cannot and should not be solely responsible for determining acceptable risk, he contends.
“From my point of view, I do not think safety and health professionals are paid enough money to determine what acceptable risk is to an organization,” Wachter says.
The key lies in the phrase itself: Acceptable risk to whom? Safety professionals, employees, managers, executives, shareholders, regulators, courts, the public? Many stakeholders are involved in determining risk acceptance.
But Wachter warns that while many viewpoints are involved in determining risk acceptance, they all should not carry equal weight.
“It really is the people who would be affected the most by our decisions who should determine mainly what is acceptable risk,” he says.
Therefore, he says managers should ultimately make decisions about risk acceptance because they will be held most accountable, he adds.
Determining ALARP: What to Consider and What to Avoid
Even though safety professionals may not be responsible for determining risk acceptance, they can inform it by appropriately determining ALARP. But deciding what is “reasonably practicable” is still complicated, so safety professionals should take many approaches and factors into consideration.
Some objective and practical considerations include:
- Meeting or exceeding regulatory requirements
- What is considered best in the industry
- Adhering to the company’s best management practices and consensus standards
- Deference to safety and health expertise to impart knowledge and experience
- Professional association guidance
- Technical feasibility
Beyond these, risk assessments are excellent tools for determining ALARP. But when completing these assessments, it’s important to acknowledge some inherent issues often go unconsidered, such as the role of the unknown, the limitations of risk matrices and the problems with approaches like the commonly used cost-benefit analysis.
Reduce the Unknown in Your Assessments
When completing any kind of risk assessment, understanding the limitations of your knowledge is vital to determining ALARP and informing risk acceptance.
“When risk analyses have much uncertainty or lack of knowledge associated with them, ALARP should be more aggressive, meaning that you implement treatment activities with costs that may be more grossly disproportionate to benefits,” Wachter says.
He argues that safety professionals have an ethical responsibility to pursue more knowledge because this is the foundation on which decisions about risk are based.
“Any area of uncertainty concerns me,” he adds. “You can’t just stick your head in the sand.”
In any situation where you have limited knowledge or uncertainty, be as conservative as possible in accepting risk and as aggressive as possible in reducing it.
Where Risk Matrices Fall Short
Risk matrices don’t always work to assess ALARP and risk acceptance because of how risk is classified and how limited the factors involved can be.
“These criteria often drive ALARP and acceptable risk decisions in our organizations,” he says. “But when you do adopt a matrix like this, what criteria are you using to determine what is low risk, medium risk or high risk? I contend that a lot of it is a seat-of-your-pants, gut-level approach to risk classification. I do not think that’s an ethical approach because it flies in the face of your responsibility for being intentional in the decisions you make.”
Risk, he says, is not the arbitrary intersection of probability and severity. He believes safety professionals should consider other factors, including:
- Detectability, variability and controllability of the hazardous event
- Uncertainty associated with probability or impact
- Degree of user or bystander susceptibility to injury
- Voluntary nature of the exposure
“There’s so much complexity in terms of how we do our jobs . . . we have to conduct our work using more complicated ways of assessing risk,” Wachter says. “It’s our ethical duty to our profession to really look into how we do risk assessments and to see whether they can be improved by taking additional factors into consideration.”
Why You Shouldn’t Rely on Cost-Benefit Analysis to Determine ALARP
Many companies turn to cost-benefit analyses to determine the point at which certain safety programs, procedures or interventions are no longer “practicable” due to their high cost and limited benefit.
However, this analysis is often flawed, Wachter says.
The first problem is one of math: Are you effectively quantifying the cost and benefit? Are you including the cost of inaction? How does that impact the equation?
The second is one of law: Just because the cost of an intervention is not proportional to the benefits doesn’t mean your organization isn’t obligated to implement it. British courts, for example, have often ruled that any intervention is considered reasonably practicable up until the point that it becomes “grossly disproportional,” Wachter says, and that point can change based on the industry and context.
Finally, there is an important ethical dimension: A cost-benefit analysis can also act as a means of endorsing pain and suffering, Wachter says. If the benefit of an intervention is not great enough to cover the cost and your organization doesn’t pursue it, the strains, sprains and soft-tissue injuries that result may be justifiable on paper — but are they ethically justifiable?
“To protect the worker and the community, you have an ethical obligation to do things you may not recover directly the benefit from in terms of the cost,” Wachter says. “You will spend more on cost than the benefit received.
Regulations may define minimum requirements and safety standards may provide tools for risk reduction, but neither declares a certain level of acceptable organizational risk. There will always be a gray area each organization must wade through to land on its level of risk acceptance. Every safety professional whose important work helps inform an organization’s accepted risk level must be able to ethically justify their decisions to employees, managers, stakeholders, regulators, the public, their peers and themselves.
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