Acting upon the Risk Ranking

Many systems are available for risk control, but in general the more effective they are, the more effort they require. Hence, a risk ranking approach allows us to economise on effort by suiting the controls to the risk. A simple application of this approach is given in Figure 1, where rules, work permits and procedures are used at different levels of risk for tasks or activities.

The types of activity in an SMS that can be adjusted for graduations of risk level are discussed below.

1 Workplace Inspections

The frequency and depth of workplace inspections should be related to the ranking of the risks in the workplace. Thus, the area risk assessment can be used to categorise areas according to the cumulative risk in each. Inspections can not only look for hazardous conditions and practices, but can also inspect the existence, state and effectiveness of controls. Controls for the highest risk scenarios may require daily inspection, or where appropriate pre-use inspections.

2 Critical Equipment and Critical Part Inspections

Equipment may also be ranked according to the risk from its malfunction, whether that risk is to people, property, production or environment. Such a ranking process can lead to risk based inspection systems, and to risk based spare parts philosophies. For some critical equipment and parts, legal requirements already exist (e.g. for cranes, lifting equipment and passenger lifts). However, these requirements are mainly based on risk to people, so may need to be extended to other types of risk. The Nuclear Industry uses a "QA Grading" system, which ranks equipment and systems against the consequences of their failure.

3 Task Related Risk

Critical tasks may be chosen by application of risk ranking. The critical tasks would be those where there is a moderate to high risk to people, business, or the environment. These tasks, once chosen, can be given special attention in terms of procedures, training and task observation. There is a danger in setting our risk ranking threshold too low, as this could mean so many critical tasks that the extra attention we give to them is ineffective. The "Pareto Principle" suggests that 20% of tasks could lead to 80% of our total risk. If task teams change, the risk ranking will need to be reassessed based upon the competence of those who will actually be undertaking the task. Experience and familiarity with the task should be considered when determining the level of supervision or control actually required.

4 Incident Investigation

Whether or not an event results in injury or damage, the decision to carry out an investigation, and the depth of the investigation should not be determined just by "gut feel." A risk ranking approach allows us to consider the potential consequences of a similar event, and the likelihood of its recurrence. Using the ranking we can determine a sliding scale of response, from only recording for trend analysis to a full-blown expert panel investigation. Investigation may often lead us to the realisation that a task considered low risk is actually "critical."

5 Emergency Preparedness

The proposed COMAH Regulations [6] include a requirement for "adoption and implementation of procedures to identify foreseeable emergencies by systematic analysis and to prepare, test and review emergency plans to respond to such emergencies." The systematic analysis required is a major hazard risk assessment, and is not limited only to consideration of the substance or substances that cause the site to fall under the Regulations. This approach to major hazard risk ranking is just as applicable to operations that will not fall under the Regulations. It requires the preparation of an Emergency Plan that identifies appropriate actions for all major hazard scenarios with significant risk potential.

6 Work Rules and Work Permits

The example of Figure 1 shows how a risk ranking approach to work activities can be used to identify particular work regimes for control of different levels of risk. An area risk assessment can be used to identify the need for specific work rules. A risk assessment process as part of a Work Permit system can identify graduated controls related to the risk ranking. As the assessed risk rises, so the need for assessment at the work site by the work designer, the permit issuer and the worker becomes greater. The ranking process can specify these steps, and ensure that more attention is given at all stages to the higher ranked risks.

7 Training

The competence of those undertaking tasks can have a significant influence on the risks associated with undertaking a specific task. Training for high risk tasks should naturally be more thorough, and the emphasis on risk controls should be greater than for low risk tasks. The "critical task" principle can help with this identification process, as can the risk assessment for Work Permits.

8 Personal Protective Equipment (PPE)

Area risk assessment can be used to identify PPE needs. Analysis of critical tasks often identifies PPE as a requirement for risk control. Although in many companies the rules for PPE have "grown like Topsy", a risk assessment approach can often identify areas where PPE requirements can be relaxed, as well as identifying those where additional requirements are appropriate.

9 Occupational Health

In UK the COSHH Regulations [7] were originally published before the words "risk assessment" were in common use. Therefore a COSHH assessment was considered to be something different, and this misapprehension persists today. In fact there is no theoretical difference, and risk assessment should be the approach we use to control risk from hazardous chemicals. The risk ranking approach can therefore be used to manage task based risk and area risk, and can be used to determine appropriate controls, including training and monitoring requirements.

10 Monitoring and Audits

The need to assure management that controls are in place and working is seen as vitally important in "Successful Health and Safety Management" [3]. Monitoring and audit may be vital, but we still need to decide the frequency of these activities, since they consume resources. Since each part of our SMS is there to control risk, we should be able to use risk ranking to decide how important each part is, and choose an appropriate frequency for monitoring and audit. In practice this seems a rather complex approach, and the authors have only seen fixed frequencies used.

11 New Projects and Change Management

There are many techniques used for the review of engineering projects, and for the management of change to industrial processes [8]. The choice of technique can be based on risk ranking, with the simpler processes such as "What If" studies used for low to medium risk situations, and more rigorous processes such as HAZOP, Fault Tree Analysis and QRA being reserved for high risk situations.

12 Special Topic Promotion

Special topic promotions are used in many companies to concentrate communications to a specific theme. The choice of the theme, though, is often somewhat ad hoc. A risk ranking list can be used to produce much better informed choices. However, it must be remembered that topic promotion is normally aimed at large groups, so choices should not be made the basis of high ranked risks where they apply only to a small number of workers. Appropriate topics would relate to perhaps moderate risks shared by the majority of workers.

13 Capability Assessment

Critical task identification allows us to target high risk occupations. For these employees it is vital that their capability and capacity match the job requirements. In some jurisdictions we are told that workers may not be selected for their physical capability. However, in terms of who does what, it must make sense not to expose workers of lesser capability to high risk situations. Whether our choice is who to employ or where to employ them, a risk based approach seems best in meeting the duties under Health and Safety at Work legislation!

14 Purchasing and Spares Philosophy

The specification, selection and purchase of equipment and materials should be based on risk. This can link back to our "Critical Parts" identification process, and ensure that the business risk associated with failure is identified. The specification of the equipment, part or material can then take into account that risk. Decisions on whether to purchase, or even install spare parts and equipment can then be made against a risk background.

15 Maintenance

Just as spares philosophy can be determined by risk ranking, so can maintenance philosophy. The decision on which equipment requires planned maintenance, and how often this should occur, can be made based on the likelihood of failure of the part or system, and its consequences. While many maintenance philosophies are determined solely upon manufacturer’s recommendations, no manufacturer knows the full consequences of failure of his machine in any particular plant. Risk Based Inspection [9] has developed strongly in recent years, fuelled by this realisation.

16 Contractors

Selection of contractors is often made on purely commercial considerations, without the clear realisation that high risk contracts require more advanced contractors than low risk contracts. The paper by Colin Bennet [10] in this symposium addresses the process of assessing contract risk, and specifying a contractor’s SMS accordingly, as does the recent paper by Phil Charsley [11].