Health Risk Assessment

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Health Risk Assessment
Controlling health risks at work
2
What is HRA ?
3
Identifying and Assessing Health Hazards

• Selection of team
• Identifying and assessing Health Hazards
• Identifying Control Standards
• Identifying nature and degree of Exposure
• Evaluating Risk to Health
• Deciding on Remedial Action

4
Selection of team

• The selection and expertise of the Health Risk
  Assessment Team will be dictated by
• Size and complexity of the Assessment Unit or
  activity being assessed e.g. Platform, Gas Plant
• Nature and severity of of the hazards and risks
  involved
• Familiarity of the activities

5
Selection of team

• Team Leader / Asset ownerLine manager such as
  OIM, plant manager or representative of facility
  being assessed
• Team Member Individuals such as operational
  staff, line supervisor familiar with plant
  operation and process
• Local Advisor Individuals such as medic/OH
  nurse, HSE advisor, who can advise on the HRA
  process and exposure controls
• Specialist Staff Occupational hygienist, OH
  physician, toxicologist, ergonomist

6
Selection of team

• To gather necessary information team members must
  be able to
• Observe the activity being performed
• Predict any potential departure from observed
  practice
• Ask supervisors, staff etc. the relevant
  questions
• Undertake simple diagnostic tests
• Identify and review relevant technical literature
• Gather the information systematically
• Form valid, justifiable conclusions about
  exposures and risks

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Selection of team

• To gather necessary information team members must
  be able to
• Follow up fundamental questions about any
  exposures to occur.
• Appreciate the range and limitations of possible
  control measures and their relative reliability
• Look critically at existing arrangements
• Specify the type of control measures needed
• Ask for specialist assistance if required

8
Selection of Team

• The required level of skill and level of
  competency for the team
• Team Leader Awareness - Working knowledge
• Team Member Working knowledge - Skilled
• Local Advisor Skilled
• Specialist Mastery

9
Competent Persons

• .. a man who has the knowledge to know what he
  is looking for and the experience to recognise it
  when he sees it ...
• Competence is a function of
• Knowledge
• Skill
• Experience

10
Gathering Information

• How to select Assessment Units
• Identify Health Hazards
• Identify harmful effects
• Assign Hazard Rating (RAM Consequence)

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How to select Assessment Units

• The assessment unit is what is within the
  boundaries of the HRA
• Assessment units should be self-contained, either
  physically or as a process
• It should cover all aspects of the working
  environment
• The nature and the severity of the hazards and
  risks involved, the familiarity of the task,
  available resources and country-specific
  requirements should be taken into account

12
Organisation and Preparation

• Do not forget to
• Set a realistic time frame to actually carry out
  an HRA
• Conduct an HRA according to a mutually agreed
  program
• Use standardized HRA formats
• Provide sufficient time for report writing,
  sharing comments and feedback
• Keep ownership of HRA with the Business Unit

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Organisation and Preparation

• Collect pre reading material and references such
  as
• Plans and drawings for plant specifications
• Incident / injury reports (incl. occupational
  illnesses) and incident investigations
• Plant and equipment fault reports
• Maintenance records for control measures
• Records of health surveillance and sickness
  absence
• Occupational hygiene surveys, health and safety
  surveys
• Minutes of health and safety committee meetings

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Additional sources of information

• Collect pre reading material and references such
  as
• Relevant Shell HSE publications
• Business Health Hazard Inventories
• Company standards
• National legal standards
• Local health regulations
• (Inter)national guidelines and standards (WHO,
  ISO)
• Industry standards, manufacturers/suppliers data

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What are Health Hazards

• A Health Hazard has the potential to cause harm
  to health
• Health hazards may be divided into the following
  groups
• chemical
• biological
• physical
• ergonomic
• psychological

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Health hazards of primary concern

• Cause fatalities in the short or long term
• e.g. infectious diseases (short term),
  carcinogenic substances (long term)
• Expose the company to substantial future social
  and monetary liabilities
• e.g. noise induced hearing loss, repetitive
  strain injury, psychological stress
• Cause minor health effects which could cause
  severe business disruption
• e.g. major food poisoning outbreak

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How to identify Health Hazards

• Walk through surveys
• Looking, smelling, talking, listening use your
  senses!
• Refer to Health Hazard Inventories
• Use HRA Yellow Guide, appendix 2
• Look at Records
• incident/fault reports, inspections, maintenance,
  sickness absence, hygiene surveys, operating
  procedures
• Use experience from elsewhere

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Practical ExerciseIdentify Health Hazards
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Identify Harmful Effects

• The harmful effects potentially caused by a
  hazard need to be identified
• Examples of harmful effects
• Death
• Acute or chronic illnesses
• Disability
• Reduced job performance
• Reduced health
• Concern

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Types of Effects

• Acute, immediate
• Lung, skin or eye damage from corrosive liquid
• Acute, late onset
• Sick building syndrome
• Chronic, intermittent / on-off
• Repetitive Strain Injury
• Chronic permanent
• Lung cancer

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Identification of Effects

• Datasheets, labels, manuals
• Guidance material, e.g Health Hazard Inventories
• Occupational health advisors
• Journals and reference literature
• National competent bodies and institutes
• Governmental bodies
• NGOs

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Identify Health Hazards and their Harmful Effects
Hazard
Source
Route
Harmful Effect
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Identify Health Hazards and their harmful Effects
Agent
Source
Route
Harmful Effect
Silica dust (crystalline) Used mineral
oils Noise Heat Legionella bacteria Repetitive
movements
Refractory bricks Engine oil Process noise above
85dB(A) Plant heat Spray cooling towers Workplace
design
Inhalation Skin Hearing Whole body Inhalation Who
le or part of body
Lung disease (silicosis) Dermatitis,
cancer Hearing Loss Heat stress, heat
stroke Legionnaires Disease Musculo-skeletal
disorders
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Factors influencing the Relationship between
Hazard and Risk

• Cumulative exposure
• Individual susceptibility
• Threshold levels
• Knowledge gaps
• Workstyle changes
• Real world practices

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Assigning Hazard Ratings
Hazard Rating Definition Consequence Category (harm to people)
1 Slight health effects Not affecting work performance or causing disability, e.g. non toxic dusts (as an acute hazard)
2 Minor health effects Agents capable of minor health effects which are reversible, e.g. irritant and defatting agents, many food poisoning bacteria
3 Major health effects Agents capable of irreversible health damage without loss of life, e.g. noise, poor manual handling tasks, hand/arm vibration, chemicals causing systemic effects, sensitisers
4 1 to 3 fatalities or Permanent Total Disability Agents capable of irreversible damage with serious disability or death, e.g. corrosives, known human carcinogens (small exposed population), heat, cold, psychological stress
5 Multiple fatalities Agents with the potential to cause multiple fatalities, e.g. chemicals with acute toxic effects (hydrogen sulphide, carbon monoxide), known human carcinogens (large exposed population)
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Hazard Ratings

• Consider Harm to
• People
• Assets
• Reputation
• Select the category with the highest consequence
  rating!

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Practical Exercise - Assigning Hazard Ratings

• Assign hazard ratings to the selection of health
  hazards identified
• Discuss in open forum

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Risk Assessment Matrix

• The Risk Assessment Matrix (RAM) is the tool
  which allows assessment of the risk to the
  business from each identified health hazard
• It will assist you in prioritizing potential
  health risks and determine which risks need
  documented demonstration of controls
• Ensure that health risks are assessed properly by
  taking into account acute and chronic harmful
  health effects

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Health Risk Consequences X Probability
(Likelihood)
Likelihood Acute - Estimated on the basis of
experience and or evidence that a certain outcome
has previously occurred Chronic - Estimated based
on the historical evidence that excess exposure
has occurred
Consequence Estimate of what could happen (acute
and chronic)
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Risk Assessment Matrix
Manage for continuous improvement
Incorporate risk reduction measures
Intolerable investigate alternatives
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Generic RAM HRA outcomes
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Low RAM Ratings

• Manage for continuous improvement
• via standard procedures and competences in HSE-MS
  (ensure these are adequate)
• ensure Exposure Limits and other control
  standards are met

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Medium and High RAM Ratings

• Detailed review of controls
• Standards of control
• Who is exposed and when
• Estimate or measure exposure
• Compare existing controls against standards (are
  OELs met and risks As Low As Reasonably
  Practicable - ALARP?)
• Consider need for routine exposure monitoring
  and/or health surveillance
• For risks assessed as High
• give serious consideration to alternative ways of
  carrying out the operation

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Control and Recovery

• Identify exposure
• Hierarchy of controls
• Control standards
• Use of control chart for individual risk
• Apply ALARP principle
• Exposure measurements
• Health Surveillance

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What is exposure?

• Exposure is defined as
• The amount of the hazard to which a person has
  been exposed(dose). This is a combination of the
  magnitude, frequency and duration of exposure

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Exposure

• Duration
• Frequency
• Magnitude (extent of exposure) is affected by
• Concentration/intensity of the agent
• Work practices
• Agents physical characteristic impacting on the
  exposure route
• Existing controls

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Exposure routes
Eye
Ear
Nose
Mouth
Lung
Musculo-skeletal
Skin
Whole body
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Hazards and Exposure routes
Hazard Exposure route
Noise ear
Chemical Liquids skin (through uptake of the skin, or through injection) Eye transferred from hand to mouth ingestion
Chemical gases, vapours and dusts nose, mouth, lungs inhalation
Chemical dusts trapped in the nose and throat, or transferred from hand to mouth, leading to ingestion
Vibrations whole body or specific parts e.g. hands, eyes
Heavy lifting other ergonomic hazards muscoloskeletal system
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Target Organs
Central nervous system
Eye
Nose
Ear
Mouth
Lung
Heart
Musculo-skeletal system
Digestive tract
Liver
Skin
Kidneys
Reproductive system
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Hazard, exposure route and target organ
Hazard Exposure route Target organ
Noise Ear Ear
Chemical liquids and dusts (hazard dependent on the specific chemical) Inhalation, skin, eye Direct contact with lungs, skin and eyes. May also be absorbed in blood stream and carried to susceptible organs central nervous system, reproductive system, kidney, liver
Stress Mind Heart, mental impairment
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Factors Affecting Intake for chemical and
biological agents

• Physical form
• Gas/vapour/liquid/solid
• Particle size
• Particle shape
• Solubility
• Carriers
• Breathing rate

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How to identify exposure

• Identify who is exposed
• Divide workforce into groups (Job Types) with
  expected similar exposures
• Estimate the exposure level
• Identify and review tasks involving potential
  exposure
• Base estimate on a combination of qualitative and
  quantitative assessments of exposure, as needed
• Establish the effectiveness of existing controls

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Identify who is exposed

• Typical Job Types
• Plant Operators - divided by operational group
• Road Tanker Drivers - divided by product group
• Maintenance Staff - mechanical, electrical,
  vehicle etc.
• Cleaning Staff - plant and/or office
• Laboratory Technicians - sub-divide as
  appropriate
• Administrators - office based with minimal plant
  exposure
• Field Staff - geologists

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Estimate exposure level

• Identify tasks
• Use workplace experience
• Review historical records
• Discuss with staff involved in doing the task
• Visit work area/walk through survey
• Include tasks involved in
• Normal operations
• Maintenance
• Abnormal conditions and foreseeable emergencies

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Estimate exposure level

• What is a task ?
• An activity which a competent person can be
  instructed to do in a single sentence
• A plant operator could be asked to take a
  process stream sample
• A plant cleaner could be asked to deal with a
  spillage
• A fitter could be asked to take a pump out of
  service
• A laboratory technician could be asked to
  analyse a sample for benzene content

46
Estimate exposure level

• Review tasks
• Frequency, duration and estimates of
  concentration/intensity of exposure
• Work practices and existing controls
• Effectiveness of existing control measures
• Compare existing controls against relevant
  control standards
• Who else is exposed?
• Employees, contractors, third parties

47
Estimate exposure level-without exposure
measurement

• Exposure may be acceptable when
• evidently so
• operations are in accordance with suppliers
  documented procedures
• previous measurements under similar or worst
  case conditions indicate low exposure
• process operated in accordance with recognised
  guidance on good practice

48
Estimate exposure level-without exposure
measurement

• Exposure may be unacceptable when
• there is evidence of fine dust deposits
• fume or particles are visible in light beams
• there are broken, defective or poorly maintained
  controls
• the process is not operated in accordance with
  recognised guidance on good practice
• complaints are made of discomfort or excessive
  odour
• ill-health related to exposure is detected

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Hierarchy of controls

• The hierarchy of controls is a list in
  preferential order of the means by which exposure
  to health hazards can be controlled
• Elimination
• Substitution (alternatives)
• Engineering (plant and equipment)
• Procedural
• Personal protective equipment

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Types of controls

• Elimination and substitution
• Engineering (plant and equipment)
• Equipment/processes designed to prevent or
  minimize release of the hazard
• Examples containment (enclosure), exhaust
  ventilation, remote venting/vapor recovery
  systems

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Types of controls

• Procedural
• Safe systems of work / Permit to work system
• Record systems
• Staff Instruction, Information training
• Supervision, Emergency arrangements
• Personal Protective Equipment (PPE)
• Respiratory Skin Protection as a secondary
  line of defence or as the only option

52
Effectiveness of Controls
The types of control vary in their effectiveness
according to the control hierarchy Elimination
Most Effective Substitution Engineering Procedu
ral PPE Least Effective
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Control selection

• Control selection to achieve ALARP must consider
  the control effectiveness and cost
• consider the most effective controls first
• limit PPE to
• infrequent tasks
• temporary use until more effective controls are
  in place
• as a precaution should other controls fail

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Maintenance of controls

• Controls are only effective if they work
• Engineering controls
• Preventive maintenance, inspections and tests
• Procedural controls
• Record systems, information and training
• Effective supervision
• PPE
• Routine maintenance, inspection and training
• Emergency measures
• Inspections and realistic exercises

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Control standards

• Occupational Exposure Limits (OELs)
• Specifications for control
• Engineering Control Standards (SES, DEP)
• Procedural (manufacturers/suppliers
  info/industry good practice)
• Personal Protective Equipment
• National, Company, Group, Industry and
  International Standards

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What are exposure limits?

• Chemical agents
• Occupational Exposure Limits are levels of
  airborne concentrations of hazardous compounds
  that are considered safe for the workplace
• OELs and recommendations are set by competent
  national authorities
• OELs are normally used for chemical agents, but
  the concept can also be applied for physical,
  biological and psychosocial agents and for
  ergonomics

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Occupational exposure limits

• Physical Agents, e.g.
• Shell Noise Guide recommended criteria
• Daily Noise Dose - 85 dB(A) Leq
• Design Limit - 85 dB(A) at 1 meter
• Cold stress
• Ionising radiation
• Heat stress
• Lasers
• Vibrations

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Occupational exposure limits

• Biological agents
• Control to as low as reasonably practicable
• Ergonomics
• Include ergonomic principles to all work
  activities
• Psychological
• Refer to specialist for evaluation and treatment

59
Engineering control standards

• Face velocities of Lab Hoods should meet
  recognized design standards
• Rotating equipment mechanical seals that do not
  leak
• Transfer lines/hoses with disconnect fittings
  that do not leak
• Capture velocities for welding hoods meet
  recognized ventilation standards
• Engineering controls are inspected regularly
• Engineering controls are on a PM (preventive
  maintenance) schedule

60
Procedural standards

• written procedures for tasks involving exposure
  (permit to work system)
• procedures include work practices that minimize
  exposure
• work practices are understood (e.g. training
  validated by testing) and followed by employees
  (supervision, validated by auditing)

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Personal Protective Equipment

• respirators
• gauntlets (gloves)
• goggles
• protective clothing
• foot protection

62
Personal protective equipment

• Adequate use of PPE includes an assessment of
• PPE requirement for each task
• PPE selection to match the hazard
• PPE is practical functional for the task
• PPE requirements are understood by employees
  (e.g. training validated by testing)
• PPE is used correctly (e.g. training validated
  by audit))
• PPE is used when required (validated by audit)
• PPE is inspected and maintained regularly
  (validated by audit)

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Practical ExerciseSelecting Control Standards

• Select a chemical, physical, biological and
  ergonomic hazard
• Using available references, identify criteria
  for each hazard selected, including
• Exposure Limit
• Engineering Control
• Procedural control
• Personal Protective equipment
• Recovery (preparedness) measures

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Practical ExerciseFeedback on Control Standards

• Each group should give a short description of
  how they decided on each criteria and what extra
  information they might require to do the task
  better.

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Use of Control Chart

• Are controls meeting the control standards?
• Control chart tool for decisions
• Use of information on exposures and controls
• Combining hazard rating and exposure rating

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Hazard rating categories
 

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Exposure Rating
Exposure Rating Exposure Band Definition
a) Very Low lt 0.1 x OEL Exposures are negligible
b) Low gt 0.1 - lt0.5 x OEL Exposure are controlled well below OEL and are likely to remain so in accordance with standards
c) Medium gt 0.5 1 x OEL Exposures are currently controlled below OEL to meet standards but control may be reliant on less robust measures such as personal protective equipment
d) High gt OEL Exposure are not adequately controlled to meet standards and continuously/regularly exceed OEL
e) Very High gtgt OEL Exposures are excessive and will almost certainly result in health damage to persons exposed
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Control Chart
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Evaluate the Adequacy of Controls

• What is the nature of the hazard to health ?
• Use Hazard Rating (RAM Consequence Category)
• What is the nature and degree of exposure for
  the task ?
• Assign Exposure Rating
• Combine in Control Chart

70
Remedial Action Plan

• The Remedial Action Plan must cover
• Recommendations divided into four levels of
  action (first, second, third priority and no
  immediate action required)
• Is recommendation agreed or not?
• Responsible person
• Due date

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Actions Control Chart (1)To aid priority setting

• Action 1st priority
• Stop the exposure notify management immediately
• Identify all sources
• Implement immediate control improvements e.g.
  PPE
• Consider need for exposure measurement
• Identify and implement work practice and control
  improvements
• Review HRA, including measurements

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Actions Control Chart (2)To aid priority setting

• Action 2nd priority
• Reduce exposure to below OEL (Hazard Ratings
  1-2)
• Consider reducing to below 0.5 x OEL (Hazard
  Ratings 3-5)
• Identify and implement work practice and control
  improvements ()
• Consider need for exposure measurement ()
• Review HRA, including measurements ()
• Action 3rd priority
• Actions with asterisk under 2nd priority
• Action No Immediate Action Required
• Normally no need for immediate action to improve
  controls. Manage for continuous improvement

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ALARP Definition

• Definitions of ALARP
• balancing the reduction in risk against the
  time, difficulty and cost of achieving it
• This level represents the point, objectively
  assessed, at which the time, difficulty and cost
  of further reduction measures become unreasonably
  disproportional to the additional risk reduction
  obtained.

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ALARP

• ALARP is influenced by the following factors
• risk to be avoided
• sacrifice involved in taking measures to avoid
  the risk (money, time and trouble)
• comparison of the two

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ALARP- rule of thumb

• List the measures that have been taken to reduce
  the risk
• Go on to identify an additional option which
  might be introduced to reduce the risk further
• Give reasons why this additional control is not
  adopted

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ALARP
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ALARP

• A team of specialist working together to identify
  all possible controls measure through the
  hierarchy (tiered challenge)
• Encouragement of good practice within the system
• Adhering to the codes and standard of practice
  with reference to past experience
• Application of engineering judgement and
  scientific principles
• Consultation with stakeholders
• Application of HAZID and HAZOP to assist in ALARP
  selection.
• Application of Cost benefit analysis
• ..

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What remedial action?

• Is risk to health ALARP?
• Yes, when only a small reduction in risk would
  require an unreasonable amount of time, trouble,
  difficulty or cost.
• Otherwise
• Select appropriate additional controls/barriers
  considering
• Hierarchy of controls including recovery
  preparedness measures
• Other measures like measurements, monitoring,
  health surveillance, maintenance of controls,
  instruction training
• Priorities for implementation

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Exposure measurements

• Identify who may be exposed to health risks
• Identify the relevant exposures to individuals in
  the workplace
• Assess your work environment to determine when
  you need to do exposure monitoring/measurements

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Types of exposure

• Chemical
• Physical
• Biological
• Ergonomic

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Purpose of exposure measurements

• Verification of the efficiency of control
  measures
• Justification for additional control measures
• Choice of control measures (eg for noise control)
• To establish and document historical records of
  exposure levels for all workers
• To ensure and demonstrate compliance with
  regulatory and other exposure guidelines
• Epidemiological studies or investigating reported
  health effects
• To alleviate employee concerns

82
Objectives of exposure measurement

• Baseline - to define range and distribution of
  exposure for defined jobs
• Worst case to identify potentially high
  exposure
• Detailed when baseline study provides
  insufficient data
• Routine periodic exposure monitoring to check
  that control measures remain effective
• Compliance - to ensure that exposure is below
  regulatory and other guidelines

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Monitoring methods

• Personal Monitoring
• worker exposure with normal work procedure
• breathing zone for inhalation exposure
• near ear for noise exposure
• full shifts / task samples
• Area (Environmental) Monitoring
• contaminant concentration in work area
• plant conditions
• effectiveness of controls

84
Monitoring methods

• Biological Monitoring
• Determine body absorption of potentially
  hazardous substance from all sources
• Measure changes in the composition of body fluid,
  tissue or expired air
• May be used to indicated inadequate control,
  improper work procedure
• Provides accurate information about the absorbed
  dose of a substance in the body
• Not all substances have a method or a BLV
  (biological Limit Value)

85
Sampling Strategy

• Where to Sample
• When to Sample
• Whom to Sample
• How long to Sample
• How many samples to take

86
Equipment for measuring chemical exposure

• Factors to consider
• sampling objective
• physical and chemical characteristics of chemical
• presence of other chemical(s)
• required accuracy
• type of samples (personal vs area)
• duration of samples

87
Sampling and analytical methods

• Appropriate validated methods should be used
• Acceptable methods are published by US NIOSH,
  OSHA, UK - HSE.
• Exposure records must be complete, traceable and
  stand up to legal scrutiny

88
Sampling train for dusts/fumes
89
Sampling train for hydrocarbons
90
Personal dosimeters (CO, H2S, SO2)
91
Detector tube for Grab Samples
92
Health Surveillance

• Monitoring and health surveillance aims to
  (periodically) assess exposures and health in
  order to
• Confirm the effectiveness of existing control
  measures
• Collect data for the detection and evaluation of
  hazards to health
• Confirm compliance with predetermined criteria
• Required by law

93
Monitoring and Surveillance

• In order to perform monitoring and surveillance,
  the following tasks are necessary
• Define objectives
• Identify suitable methods (sensitivity,
  specificity, ethical, non-invasive)
• Identify norms/ means to interpret the data
• Plan and evaluate the program
• Collect data
• Analyse and interpret data
• Report actions
• Communicate with various audiences of
  surveillance data users

94
Medical Surveillance

• Medical Surveillance selection criteria
• Is there a risk to health (based on HRA)
• The prevention/intervention potential ("can we do
  something about it?")
• Can we detect it?
• Are the detection methods suitable?

95
Review of Controls
PLANNING
IMPLEMENTATION
REVIEW
Review risk and existing controls
Communicate procedures to staff, visitors, 3rd
party etc.
Review systems, procedures, processes etc
Identify document specifications
Conduct regular emergency drills
Train / retrain staff
Determine adequacy
Review drills
Ensure effective communication
Assign responsibilities
Conduct routine inspections/ audits
Incident investigation - learning
Provide necessary resources
Provide regular maintenance
96
Document Review HRA

• Appropriate Depth of Records
• Linked with Medical Records
• Informing Staff
• Archiving of Records
• Reviewing Records

97
Appropriate Documentation

• Records should
• be retrievable
• Internal/external audits, authorities and review
• meet legal requirements
• be detailed enough to ensure audit trail on how
  conclusions were reached
• allow traceability from individual name via Job
  Type to tasks
• include exposure monitoring and health
  surveillance

98
Links with medical records

• Exposure profiles example of how to link staff
  to exposures
• Requires links between HRA and medical record
• Unique identifier needed per individual
• Capability to record changes in Job type per
  individual
• Ensures that
• archiving takes place when plant shuts down

99
Informing Staff of Findings

• Involves staff in HRA process
• Ensures that
• Health risks are understood
• Control measures are used
• Staff can alert assessment teams on changes
• May be a legal requirement

100
Archiving of Records

• As required by local law and/or practice
• 30 - 40 years are typical
• Allows for re-introduction of old processes

101
Reviewing HRAs

• Senior management will confirm the status of HRA
  through HSE annual letter
• Action Items
• Short term reviews of action items
• Against target dates and responsible persons
• Change in process, hazard, legislation etc
• Change in controls
• New information on the effect
• Incidents, illnesses, complaints, new knowledge
• On an agreed cycle
• Between 1 and 5 years dependent on risk

102
Assurance

• Where health risks are high, consider an HSE
  audit devoted to the adequacy of HRA
• Include
• Organisation of the system for implementation
• Resources available
• Quantity and quality
• Areas of non-compliance with control standards
• Remedial actions taken following an HRA
• Maintenance of controls and recovery measures
• Demonstration of ALARP
• Maintenance of employee work history