Proceedings of Tailings and Mine Waste 2023

November 5–8, 2023, Vancouver, Canada

ALARP for Safety Management

of Tailings Storage Facilities
Yi Zhu, Rio Tinto, USA
Marnie Pascoe, Rio Tinto, Australia

Abstract
ALARP – as low as reasonably practicable – refers to the principle of testing risk reduction against the
cost of the corresponding risk reduction effort. The principle of societal risk acknowledges that there is no
absolute safety (zero risk) from engineered systems, and neither society nor a company have infinite
resources to spend on managing risks. However, it requires risk management to reduce risks to “as low as
reasonably practicable.” ALARP is built into requirements under the Global Industry Standard on Tailings
Management. This paper reviews the history of the ALARP principle and the tolerability of risk framework,
and introduces the roadmap produced by Rio Tinto for demonstrating dam safety to an ALARP requirement
in relation to tailings storage facilities.

Introduction
ALARP principle and the tolerability of risk framework
ALARP – as low as reasonably practicable – refers to the principle of testing risk reduction against the
cost or sacrifice of the corresponding risk reduction effort. The concept of “reasonably practicable” was
explicitly formulated for the first time as a result of the court case of Edwards v National Coal Board in
1949 in the UK. The term ALARP has become a fundamental concept under UK legislation, originating
with the Health and Safety at Work etc. Act 1974, which requires “provision and maintenance of plant and
systems of work that are, so far as is reasonably practicable, safe and without risks to health.” The phrase
So Far As is Reasonably Practicable (SFAIRP) and similar clauses are interpreted as being synonymous
with a requirement that risks must be reduced to a level that is As Low As Reasonably Practicable (ALARP).
Criticisms of the ALARP principle arose during the Sizewell B Public Inquiry (Layfield, 1987;
Hartford, 2021). One of those criticisms was that there was an absence of clear definition or widely
understood meaning of ALARP. Further, it was noted that the determination of what constitutes
“reasonably practicable” is not straightforward. The Tolerability of Risk (ToR) framework emerged in
response to these criticisms (UKHSE, 1988/1992; UKHSE, 2001; Hartford, 2021).

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Both the SFAIRP or ALARP principle and the ToR framework imply the acceptance of the following,
otherwise there is no basis for proceeding with the implementation of the ALARP principle. It is noted that:

• Nothing is ever wholly “safe” or risk-free. Some degree of risk is always present in any human
activity and must be tolerated to a degree (for securing certain benefits).
• A deterministic view that adherence to engineering standards and judgement can be accepted as
sufficient is implicitly rejected by implementing ALARP.
• “Good practice” is regarded as the minimum requirement. A deterministic view that adherence
to good practice alone can be accepted as sufficient is implicitly rejected by implementing
ALARP.
• There has to be a process whereby duty-holders must show that they are doing whatever they
reasonably can to reduce risk, taking into account what is technically possible, what is good
practice, and what is the cost in money and difficulty of doing more.
The ToR framework includes the risk carrot diagram (Figure 1) intended to show high (normally
unacceptable) risks at the upper/wider end and low (broadly acceptable) risks at the lower/narrower end.
The region in between is called the “ALARP region.” For risks falling in this region, they are considered
to be tolerable only if the duty-holders demonstrate that the risk is significant in relation to the sacrifice (in
terms of money, time, or trouble) required to avert it and that there is a gross disproportion between the cost
and benefit to further reduce the risk.

Unacceptable
Increasing risk

Limit of Tolerability (LoT)

Tolerable if ALARP

Broadly acceptable

Figure 1: Conceptual ToR framework

The ToR framework inevitably deals with risk quantification and the concept of Limit of Tolerability
(LoT). The ToR approach takes as a premise that estimates of risk are uncertain and that this uncertainty
must be taken into account in decision-making. However, uncertainty in the risk estimates does not
invalidate the approach (Hartford, 2021). The development of the ToR framework considered the concern
raised by the Sizewell B Public Inquiry about why the public should accept the residual risk from nuclear

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power stations as tolerable. Its starting point was to ask what levels of risk the public accept (even if
unknowingly) both from specific high hazard industrial plants and from natural occurrences. Based on these
“accepted” risk levels, levels of risk tolerability for nuclear plants were proposed (UKHSE, 1988/1992).
The report of the Royal Society study group on risk assessment (Royal Society, 1983) significantly
influenced the conclusions concerning the matter of the level of risk that the public might accept as being
tolerable. The concept of LoT (Figure 1) has both political and cultural aspects not addressed in this paper.

Application of ALARP principle for safety management of Tailings Storage Facilities

Many dam engineers and managers have taken the view that safety is ensured if a dam meets the traditional
engineering standards. However, it should be recognized that regardless of what actions are taken or not
taken, there always is a level of residual risk for dams. With the increasing role of ESG (environmental,
social, and governance) in human activities, since dam failures have implications to the general public,
there is an increasing need to elaborate on how the residual risk relates to what is tolerable or acceptable by
a society. The Sizewell B Public Inquiry (Layfield, 1987) was an example of public scrutiny of risks posed
by engineered systems.
Owners, agencies, regulators, and professional organizations within various industries across the
world have been using risk concepts and the ALARP principle for some time. In particular for dams, notable
references include ANCOLD (2003/2022), ICOLD (2005, 2017), CDA (2013), DEFRA (2013), USACE
(2014), FEMA (2015), Victoria (2015), FERC (2016, 2021), NSW (2019), and BOR and USACE (2019).
In concert with facilitating the risk-informed dam safety evaluations, Target Risk Guidelines (TRGs)
including LoT for life safety are proposed in some of these references. Recently both Global Industry
Standard on Tailings Management (GISTM, 2020) and ICMM Tailings Management Good Practice Guide
(2021) have embedded risk related requirements.
The ALARP principle is referenced across multiple Rio Tinto Standards and Group Procedures. Rio
Tinto’s risk management standard and HSE management system standard both require that health and safety
risks are managed to ALARP. To facilitate Rio Tinto’s commitment to the implementation of GISTM for
its tailings storage facilities (TSFs), Rio Tinto has recently developed a process (roadmap) to demonstrate
ALARP related requirements in the GISTM.
This paper first presents an overview of the Rio Tinto’s ALARP roadmap for dam safety, it then
presents an example of preparing documentation to demonstrate ALARP for GISTM conformance.

The ALARP roadmap for dam safety

The Rio Tinto ALARP roadmap for dam safety is presented in Figure 2 with the relevant sections of this
paper presented below.

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Start – ALARP for dam safety

Demonstrate that good practices have been observed and implemented

and that arrangements are in place (including periodic reviews) to ensure
Section 2.1
on-going conformance to good practices, for both technical applicability
and governance of the subject storage facility

Conduct a risk analysis to

• Identify all hazards that would lead to dam safety incidents
• Identify failure pathways of significant (risk-driving) failure scenarios
• Identify and evaluate existing risk controls in place
• Carry out estimation of probability and consequences of failure for each
significant failure scenario
• Present risk result on FN (cumulative risk) chart for the set of
comprehensive and non-duplicative failure scenarios
• Identify and assess cost and effectiveness of additional risk reduction
measures

Compare the cumulative risk with Rio

Tinto risk criteria
If below Limit of Tolerability • ALARP demonstration is not possible
• Some of the risk reduction measures
• Implement additional risk reduction measure(s) identified must be implemented to
identified unless it is demonstrated that it is not If above Limit of Tolerability reduce the risk posed by this storage
reasonably practicable to do so (for example, facility
through the cost benefit analysis methodology in Section 2.2
the group ALARP guidance note)
• Considerations that can override the decision to
implement or not to implement a new risk
reduction measure usually include creation of
If below Limit of Tolerability Compare the cumulative risk with Rio
new risks, risk equity, other specific stakeholder
Tinto risk criteria after implementing No
considerations, etc.
risk reduction measure(s)
• Based on identified failure pathways of significant
failure scenarios and risk controls in place or to
be implemented, create well-reasoned arguments
to demonstrate that there are a mix of controls
along each significant failure pathway to ensure If above Limit of Tolerability
that there is an adequate spread of type of
controls, depth of controls, and control
effectiveness for each significant failure scenario Have all reasonably practicable
measures been implemented?

Yes

Elevate to Accountable Executive and consider

decommissioning the storage facility

Section 2.3
Complete ALARP documentation
Section 3

End

Figure 2: Rio Tinto ALARP roadmap for dam safety

The “good practice” test

Rio Tinto requires “good practice” for all its TSFs as part of its group policy to meet any specific statutory
legal requirements. “Good practice” often refers to recognized industry, national, or international standards
or regulations. However, it is acknowledged that:

• “Good practice” is site specific.

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• “Good practice” continues to evolve with time and development of new technologies.
• There is no list of exhaustive practices agreed by industry stakeholders to be “good practice” for
dam safety.
To the extent possible, Rio Tinto requires an examination of the implementation of specific applicable
good practice to each of its TSFs, from both engineering and governance points of view. Conformance with
good practice is the first and mandatory step to be completed as part of the ALARP demonstration.

The risk analysis

Rio Tinto has designed a risk analysis (HBRA) to be conducted to support the ALARP demonstration. The
HBRA largely follows what is practiced by the Bureau of Reclamation of US Department of the Interior
and US Army Corps of Engineers (BOR and USACE, 2019) and US Federal Energy Regulatory
Commission (FERC, 2021) as quantitative risk analysis (QRA) for dam safety. The state-of-practice of risk
characterization for dam safety relies in part on subjective probability estimates (quantification of expert
judgment). Efforts are made to ensure a rigorous and documented HBRA to be conducted to:

• Identify all hazards that would lead to dam safety incidents.

• Identify failure pathways of significant (risk-driving) failure scenarios.
• Identify and evaluate existing risk controls in place.
• Carry out estimation of probability and consequences of failure for each significant failure
scenario.
• Present risk result on F-N (cumulative risk) chart for the set of comprehensive and non-
duplicative failure scenarios.
• Identify and assess cost and effectiveness of additional risk reduction measures.
The HBRA includes consideration of nonlife-safety (e.g. environment, community, and social
performance aspects) consequences, as there is a general view that if the life-safety consequence-based risk
is reduced to ALARP, other consequence-based risks for the same dam are potentially tolerable.

Societal risk tolerability

The F-N chart presents cumulative (combined) risk effect required for societal risk (public safety)
evaluations. F-N is the relation between the estimated number of fatalities (N) and the estimated annual
probability of failure of the dam (F) causing loss of life ≥ N. Rio Tinto has adopted a LoT (Figure 3) based
on a study of R2P2 (UKHSE, 2001) FN curves and from a benchmarking exercise for various countries,
which is also in general conformance with dam safety risk guidelines from regulators (Victoria, 2015, NSW,
2019), professional bodies (ANCOLD, 2003/2021, CDA, 2007/2013), and US federal dam owners (BOR
and USACE, 2019).

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Rio Tinto considers the total population potentially to be impacted by a dam failure and does not
distinguish among different groups of people, e.g., workers, local resident, or transient population. While
Rio Tinto also considers the individual risk guideline, the societal risk guideline often dictates the risk
evaluation for dam safety.

Figure 3: Rio Tinto LoT for dam safety

The risk result from HBRA is presented on the F-N chart to assess societal risk tolerability. The
comparison with LoT provides an immediate indication whether or not any risk reduction measure is likely
to be required. Risk estimates are inherently uncertain (Section 1.1) and the HBRA requires an assessment
of the confidence level for the risk characterization (Table 1) which helps to decide what future actions
should be taken and how urgent they might be.
When the risk result is plotted above or in the vicinity of the LoT, attention is naturally drawn to
implement risk reduction measures. The higher the level of risk, the greater the degree of rigor that is
required to show that risks have been reduced to ALARP. The Rio Tinto ALARP roadmap ensures that the
highest level of the organization is involved in the implementation of all reasonably practicable measures.
When the risk result is plotted within the ALARP region (clearly below the LoT), the risk would be
considered to be tolerable only if it has been reduced to ALARP (Section 2.2.2)

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Table 1: Confidence levels for risk characterization (modified after BOR and USACE, 2019)

Confidence level Description

High The team is confident in the risk characterization, and it is unlikely that additional
information would reduce uncertainty to influence the decision to take (or not take)
action to reduce risk.
Moderate The team is relatively confident in the risk characterization, but key additional
information might reduce uncertainty to influence the decision to take (or not take)
action to reduce risk.
Low The team is not confident in the risk characterization, and it is entirely possible that
additional information would reduce uncertainty to change the decision to take (or
not take) action to reduce risk.

Continuing risk reduction measures

Risks falling within the ALARP region are not considered to be tolerable until after assessing continuous
risk reduction measures. These are risks that we do not regard as negligible but rather something we need
to keep under review and reduce further if we can. The ToR framework includes the concept of “broadly
acceptable risk” that is at normally two orders of magnitude lower than the LoT and generally regarded as
adequately controlled. The Rio Tinto ALARP roadmap for dam safety does not involve this concept of
“broadly acceptable risk.” Good dam safety management practice requires continuous risk monitoring and
reviews even for risks at two orders of magnitude lower than the LoT. The Rio Tinto ALARP roadmap
requires assessing continuous risk reduction measures for all risk levels, by doing so, it maintains a
downward thrust on an already low risk level.
Risk reduction measures identified during the HBRA are assessed for continuous risk reduction
opportunities. It is required to consider implementation of these additional risk reduction measure(s) unless
it is demonstrated that it is not reasonably practicable to do so. Rio Tinto has a cost benefit methodology
in place to support the decision-making. However, if the risk reduction measures identified are considered
to be “good practice”, they shall be implemented without involving the cost benefit argument. Considering
this being a risk-informed (not risk-based) decision process, the Rio Tinto ALARP roadmap provides the
flexibility to override the decision to implement or not to implement a new risk reduction measure based
on considerations including creation of new risks, risk equity, other specific stakeholder considerations, etc.
This flexibility is governed by a documented management of change process.

Effectiveness and sufficiency of risk controls

The Rio Tinto ALARP roadmap for dam safety lastly requires a review of the effectiveness and sufficiency
of risk controls. This review leads to well-reasoned arguments demonstrating that there are a mix of controls
along each significant potential failure development pathway to ensure that there is an adequate spread of
type of controls, depth of controls, and control effectiveness for each significant failure scenario.

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Documenting the ALARP demonstration

All activities for the ALARP assessment, including the HBRA, should be well documented, including
actions and timing for actions, inactions (where proposed actions are not to be implemented), and associated
arguments explaining the rationale behind the decision to implement or not implement actions. The
Engineer of Record (EoR), whilst leading or as a minimum participating in the ALARP process, shall review
the ALARP assessment result with the Independent Tailings Review Board (ITRB) or senior independent
technical reviewer as part of the GISTM requirements. The approval and documentation of implementation
measures to reduce both the probability and the consequences of a potential TSF failure to ALARP will be
undertaken by the Accountable Executive (AE).

An example of documenting ALARP demonstration

The result of an ALARP assessment could be one of the following:

• Existing risk is confirmed to be ALARP.

• Risk would be ALARP after implementing action(s).
• The confidence level for the risk characterization is low (Table 1) so that additional studies are
required before an ALARP conclusion.
• ALARP is not possible, and other actions are required e.g. the removal of the storage facility
should be considered.
An example of the ALARP documentation ready for the AE to review and approve is described below.
It starts with a summary of the ALARP assessment result and approvals of key people (TSF subject matter
expert, EoR, ITRB, etc.) signifying their respective endorsement of the ALARP assessment result and
includes four pillars of evidence.

Pillar of evidence #1: state-of-good-practice engineering, operation, and governance

In this part of the documentation, evidence for meeting good practice governance and engineering of the
TSF is presented. For good practice governance, the evidence includes the foundation of the Tailings
Management System (TMS) and the specific implementation of the TMS. The TMS of any TSF of Rio
Tinto is founded on the Rio Tinto corporate policy on tailings, Rio Tinto Group Safety Standard and the
associated Group Procedure – D5 on Management of Tailings and Water Storage Facilities, Rio Tinto’s
commitment to implement the GISTM, and Rio Tinto’s corporate 3-lines-of-defense assurance delivery
model:

• Rio Tinto’s tailings policy states that “our objective for tailings management is to strive for zero
fatalities and the elimination of catastrophic failures.”

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• Rio Tinto Group Safety Standard and Procedure (D5 Standard) has been in place since 2015.
• Rio Tinto’s commitment to implement the GISTM is in the public domain
(https://www.riotinto.com/en/sustainability/environment/tailings).
• Rio Tinto’s 3-lines-of-defense assurance delivery model (Figure 4) assures the proper
implementation of the D5 Standard and GISTM to meet its corporate policy on tailings.

Own and manage risks: operational management

Site, PG and Functional processes
• Identify, assess, own and manage risks. Implement controls to address
Effective design, inspection and monitoring

First Line
risks

Assurance against mandatory requirements • Risk Owners to inform themselves of the operating effectiveness of their

1stline
controls
Manage risks and determine effectiveness • Must perform assurance against mandatory requirements
Request assurance support • Actively propose annual assurance plan for material risks

Standard Owners – CoEs, AoE’s, Define mandatory requirements and proactively engage with First Line
• Monitor conformance of First Line self-assurance against “mandatory
Group Functions

Second Line
requirements” with transparent data
• Monitor performance against material risks and emerging risks and raise concerns
Define mandatory requirements
2 nd
line Provides support with material risks
where requested by 1st line
• Facilitate coaching / mentoring to develop capability where requested by the First
Line
• Work with first line to provide assurance where requested
• Have right / obligation to undertake objective assurance where concerns with
management of material risks. Do this through defined escalation process

Group Independent assurance: Internal Audit

Third Line
Internal Audit • A risk-based approach to assurance consistent with purpose as defined by the Board Committees

3 rd
line
(GIA)
•
(Audit Committee and SusCo)
Provide independent assurance on the effectiveness of governance, risk management, and internal
controls, including the manner in which the First and Second Lines of Defence achieve risk
management and control objectives

Figure 4: Rio Tinto corporate 3-lines-of-defense assurance delivery model

The implementation of the TMS is site specific, but normally includes the following:

• A clear understanding of the responsibilities and accountabilities for roles established for
tailings management.
• Regular reviews of both short- and long-range tailings management plans to ensure adequate
funding/planning for tailings management.
• Following the processes (in D5 and GISTM) to deliver quality designs or design changes, and
constructions that meet the design intent.
• Maintaining an effective Operations Maintenance and Surveillance (OMS) manual and
conducting proper TSF operations, TSF maintenance, and TSF surveillance activities
accordingly.
• Maintaining a mature level of preparedness for upset and emergency scenarios, including an
effective tailings response plan (for loss of containment dam failure scenarios) and conducting
regular response drills.
• Carrying out activities following the Rio Tinto 3-lines-of-defense assurance delivery model.

The evidence for meeting good practice engineering is also site-specific, but normally includes a well-
documented development history of the TSF supported by sufficient data collection for engineering, state-
of-practice engineering assessment methodology, and well-executed and documented construction with the

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involvement of the EoR. Some of the evidence for meeting good practice governance is for meeting good
practice engineering as well, for example, the establishment of the role of ITRB, maintaining an effective
OMS, TSF monitoring with proper Trigger Action Response Plan (TARPs) defined, etc.

Pillar of evidence #2: societal risk tolerability

The risk result from the HBRA is presented to assess societal risk tolerability. For example, Figure 5
indicates that the risk posed by a hypothetical TSF is below the LoT and the risk would be considered to be
tolerable if ALARP according to the Rio Tinto guidance.

Figure 5: Existing risk posed by a hypothetical TSF

Pillar of evidence #3: continuing risk reduction measures

For this hypothetical example, risk reduction measures identified during the HBRA are considered to be
part of good engineering practice that should be carried out regardless of cost or time. There was no other
risk reduction measure identified during the HBRA due to the robustness of the TSF. However, for the
purpose of demonstrating ALARP regarding the benefit of further risk reduction versus the additional effort
required, an exercise was carried out to evaluate the risk reduction measure of further flattening the
downstream slopes of the dam embankments, which would be a fundamental change of the design concept.
Because the existing risk is already low, such a measure is found not to be reasonably practicable following
the Rio Tinto guidance. Through this evaluation, the existing (current) risk level is confirmed to be ALARP.

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Pillar of evidence #4: effectiveness and sufficiency of risk controls

HBRA identifies failure pathways of significant (risk-driving) failure scenarios and risk controls (Section
2.2). These risk controls, plus additional risk controls to be implemented (if needed as part of the required
continuing risk reduction assessment), are mapped out and evaluated against the potential development of
each failure pathway leading to downstream consequences to demonstrate that there is an adequate spread
of type of controls, depth of controls, and control effectiveness for each significant failure scenario. These
are well-reasoned arguments to demonstrate the effectiveness and sufficiency of risk controls, for example
as documented in Table 2.

Table 2: Evaluation of risk controls

Summary
A well-designed, constructed, and operated TSF is expected to pose a low risk. The application of the
ALARP principle is consistent with the requirements of Rio Tinto’s risk management standards, maintains
a downward thrust on this already low risk, ensures that the risk situation does not deteriorate, and drives
continuous improvement of dam safety management.
Determining whether a risk has been reduced to ALARP requires judgment. Risk characterization is
an iterative, analytical-deliberative process. There is no simple formula for computing what is ALARP. Rio
Tinto has adopted an ALARP roadmap for dam safety to help practitioners to meet the need of ALARP
demonstration. The Rio Tinto roadmap has its focus on life safety, due to the availability of life safety-
based Target Risk Guidelines such as the LoT in Figure 3. There are no generic environmental, economic,

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or cultural consequence-based risk guidelines in practice or literature (FERC, 2016) because nonlife-safety
consequences are mostly site specific. However, non-life safety consequences should be evaluated with
well-reasoned arguments such as in Table 2, to support risk-informed decision(s) for mitigating them or
otherwise.
Deciding whether a risk is reduced to ALARP is a separate exercise from seeking continuous
improvement of dam safety management. While ALARP demonstration is a focused exercise at regular
intervals (for example, GISTM requires a review of ALARP at the time of every Dam Safety Review or at
least every five years for an existing TSF classified as a “High”, “Very High” or “Extreme” consequence
facility), seeking improvement of dam safety management and conformance with good practice is
continuous throughout the lifecycle of the tailings storage facility.

References
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Large Dams.

BOR and USACE. 2019. Best practices in dam and levee safety risk analysis, version 4.1. July 2019. Bureau of
Reclamation of US Department of the Interior and US Army Corps of Engineers.

CDA. 2013. Dam safety guidelines 2007 (2013 Edition). Canadian Dam Association.

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FEMA. 2015. Federal guidelines for dam safety risk management, FEMA P-1025. January 2015. US Federal
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GISTM. 2020. Global Industry Standard on Tailings Management by the Global Tailings Review, 2020.

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ICMM. 2021. Tailings Management Good Practice Guide. International Council on Mining and Metals.

ICOLD. 2005. Bulletin 130: Risk assessment in dam safety management: a reconnaissance of benefits, methods and
current applications.

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ICOLD. 2017. Bulletin 154: Dam safety management: operational phase of the dam life cycle. 2017.

Layfield, FHB. 1987. The Sizewell B Public Inquiry. UK Department of Energy.

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Royal Society. 1983. Risk assessment – a study group report – the assessment and perception of risk. Philosophical
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UK Health and Safety Executive. UKHSE 1988/1992. Tolerability of risk from nuclear power stations.

UK Health and Safety Executive. UKHSE 2001. Reducing risks, protection people. R2P2.

USACE. 2014. ER 1110-2-1156: Safety of Dams – policy and procedures, Washington DC, March 2014.

Victoria (Australia) State Government Department of Environment, Land, Water & Planning. 2015. Guidance note
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