009ONE CELL, ONE CASE
The Cell Is Not a Decision
An illustrative solvent tank moves from a marked cell to a decision record: rule, owner, price, scenario. Its controls and loss estimates remain unverified; the colour supplies no permission to operate.
RULE FIRST
Establish the rule before trading cost against risk
- A tolerable region still requires assessment and control
- Broadly acceptable does not remove reasonably practicable duties
The applicable requirements come first. In Great Britain, HSE's tolerability framework distinguishes unacceptable risk from risk that is tolerable only under conditions including ALARP: as low as reasonably practicable. It also requires periodic review. This is an illustration of that framework, not a legal determination for a particular tank.
REOPEN THE INPUTS
A category has discarded information
- Specify what the probability refers to
- Trace consequence estimates to evidence and assumptions
Cox describes how cases can share a rating while their probabilities and consequences differ. That range compression prevents a reviewer from recovering the tank's loss distribution from its cell. Reopen the underlying evidence: time period, exposure, failure pathways, consequences and uncertainty.
Escalating a case leaves its acceptance unresolved
A useful triage instrument can direct attention without settling a spending decision. A reviewer still needs grounds to approve a control, request more evidence or withhold acceptance. A completed form still needs evidence.
TEST THE NEXT CONTROL
What would the proposed trip change?
- Proposed control: independent high-level trip
- Reduction and sacrifice still require evidence
- The dutyholder must justify the decision
Consider an independent high-level trip intended to stop feed before overfilling. Establish its expected reduction, failure modes, independence and maintenance needs, alongside money, time and disruption. Where the reasonably practicable test applies, HSE's account asks whether that sacrifice is grossly disproportionate to the risk reduction. It supplies no universal multiplier.
GIVE BARRIERS OWNERS
The barrier needs an owner and evidence
- Check who owns the trip and its test evidence
- Check the recovery control and what can defeat it
- A diagram cannot establish either control's effectiveness
The hazard is stored flammable solvent. Loss of containment is the top event: control over that hazard has been lost. In the CAA's bowtie method, preventive controls sit before this event; recovery controls act afterward to reduce the chance or severity of consequences. An escalation factor can weaken a control. The bund shown here provides secondary containment around the tank. This selected overfill-to-fire path omits other threats and consequences.
STATE THE LOSS ASSUMPTIONS
The model must supply what the cell cannot
- P(L > €2M) = 0.1% per year
- P(L > €20M) = 0.01% per year
- No appetite boundary or accepted position has been supplied
Suppose a toy model for this tank assigns these mutually exclusive annual total losses: €0 with probability 99.9%; €3M with 0.09%; €25M with 0.01%. They sum to 100%. The resulting strict exceedance function is P(L > x): it steps down at €3M and €25M. These invented inputs illustrate the calculation, not the facility's risk.
Record what a controlled exercise exposes
Agree the exercise scope and stop criteria before testing a loss-of-containment scenario. Use simulation to examine a missed alarm or delayed handoff. Record the gap before correcting the response, then retest what changed. A rehearsal can expose a response failure. One successful run cannot prove barrier reliability or readiness.
FOUR FIELDS, ONE CASE
Keep the unresolved decision visible
- Rule: applicable requirements and reasons for the control decision
- Owner: accountable people and current barrier evidence
- Price: loss assumptions, uncertainty and any acceptance boundary
- Scenario: exercised response, recorded gaps and retest
The dutyholder must justify any decision within the applicable requirements. These fields make its grounds inspectable; they do not authorize operation. In this illustrative case, control evidence, an accepted loss position and a completed rehearsal are still missing. The next question is what it costs to keep watching as conditions change.