Is there a difference between ALARP & SFAIRP? The debate continues.

We recently discovered a Linkedin post and comment trail where an old R2A ‘ALARP versus SFAIRP’ image was used. Some extra words had been inserted on it by others emphasising the two terms - adding confusion. There were a lot of varying comments in the thread debating if there’s a difference between ALARP & SFAIRP, but rather than go through them individually, we have chosen to summarise R2A’s take on where this is at:

1. Risk assessment (especially QRA - quantified risk assessment) using technical risk targets is now and always has been flawed as it can prevent consideration of possible further controls due to the perceived lowness of the risk.
   
   Often when looking at a corporate risk register, the last items on the list are the critical ones in consequence terms but placed at the bottom in risk terms because of their perceived rareness.
   
   Discounting consequences (and thereby possible controls) by the unlikeliness of the event has always been in error. The MHF regulator in Victoria corrected this last year (read Risk Paradigm Shifts Take a Generation) releasing a pent-up Kraken of land use planning pain.

2. ALARP and SFAIRP are not terms created by R2A. They come from the UK.
   
   ALARP was created by the Health and Safety Executive. We think it was an unfortunate and unnecessary development. It encouraged the use of risk targets, thereby inhibiting consideration of possible further practicable controls. Just do a search for ALARP in Google and dagger diagrams with risk targets abound. It may not be what was intended but that is what it encouraged. It flowed into dam safety, maritime and aviation safety and many other areas. 
   
   SFAIRP appears to have been created to contrast the difficulties with ALARP. For example: Felix Redmill from Newcastle University (UK) observed in 2010:
   
   What confidence can there be that a risk deemed ALARP would also be judged to have been reduced SFAIRP? Can the two concepts be said to be identical? They cannot. As already pointed out, they were defined by different parties (the law-makers and the safety regulator) for different purposes (stating a legal requirement and offering guidance on a strategic approach to meeting it). But does one imply the other? No.
   
   There can be no guarantee that the same ALARP decision would be arrived at by two different practitioners, and certainly none that an ALARP decision arrived at now in an industrial context would, later be judged by non-engineers in a legal context to have met the SFAIRP test.
   

3. The UK HSE’s document, ALARP “at a glance” equates the two concepts. But later in the same document notes:
   
   You may come across it as SFAIRP (“so far as is reasonably practicable”) or ALARP (“as low as reasonably practicable”). SFAIRP is the term most often used in the Health and Safety at Work Act and in Regulations. ALARP is the term used by risk specialists, and duty-holders are more likely to know it. We use ALARP in this guidance. In HSE’s view, the two terms are interchangeable except if you are drafting formal legal documents when you must use the correct legal phrase.
   

4. In R2A’s view, it has always been about ensuring that all reasonably practicable precautions are in place.
   
   You should strenuously avoid any ‘risk assessment’ process that may prematurely exclude viable potential controls from further consideration. And the prudent approach is to always use the correct legal term in the way legislation and the courts apply it, irrespective of what a regulator says to the contrary. Why create confusion by having two terms?

Also read: SFAIRP Not Equivalent to ALARP

Listen to Risk! Engineers Talk Governance episode on SFAIRP vs ALARP