4.2 Reasonably Practicable

4.2 Reasonably Practicable

Quick Answer: “So far as is reasonably practicable” (SFAIRP) means you must reduce risk until the sacrifice (money, time, trouble) of further control is grossly disproportionate to the risk reduction you would gain. Significant risks still need strong action. SFAIRP is not “do whatever is cheapest.”

After ERICPD tells you what kinds of control exist, reasonably practicable tells you how far the law and good practice expect you to go. Managing Safely does not turn you into a lawyer, but managers must understand SFAIRP well enough to justify control decisions, challenge “we can’t afford safety,” and avoid both reckless under-control and paralysis over trivial residual risk.

What SFAIRP means in plain English

Health and safety law in Great Britain often requires employers to ensure health and safety so far as is reasonably practicable. In practice that means:

1. Identify the risk (likelihood × consequence after current controls, or before if you are deciding new ones).
2. Identify further controls that would reduce that risk (climbing ERICPD where you can).
3. Weigh the sacrifice required to implement those controls — money, time, effort, disruption, and any new risks created.
4. Implement controls where the sacrifice is not grossly disproportionate to the risk reduction achieved.

The classic idea (rooted in cases such as Edwards v National Coal Board) is that risk and sacrifice sit on opposite sides of a balance. You keep adding controls until further sacrifice would be out of all proportion to the tiny extra safety gained.

What “sacrifice” includes

Sacrifice is broader than a purchase order:

A control that is “cheap to buy” but forces unsafe workarounds may not be a good SFAIRP choice. Always think in systems, not only unit price.

Gross disproportion — the key phrase

Gross disproportion means the cost (in the broad sense) of the next control is vastly greater than the benefit in risk reduction. It is not a precise formula with a magic number. Managers use judgment supported by:

• Severity of potential harm (death and life-changing injury push the balance hard toward more sacrifice)
• Number of people exposed and how often
• How much risk remains after existing controls
• Industry norms and HSE/industry guidance for similar risks
• Whether a cheaper, nearly as effective option exists higher or sideways in ERICPD

Worked idea

• Residual risk of a minor bruise once a year to one person → spending £250,000 redesigning the whole line may be grossly disproportionate if a simple guard and training already cut risk to a very low level.
• Residual risk of fatal entanglement or toxic exposure for many workers daily → the same £250,000 redesign may be entirely reasonable and expected.

Significant risks still demand action. SFAIRP never means “if it costs anything, skip it.” For high-consequence hazards, the acceptable sacrifice is high.

Absolute, practicable, and reasonably practicable (overview)

Managing Safely expects an overview of duty standards — not detailed case law.

Exam tip: if a question contrasts the three, remember the severity of the test runs roughly:

Absolute (strictest / no cost balance) → Practicable → Reasonably practicable (allows risk–sacrifice balance)

Do not invent which specific regulation uses which phrase unless the materials give it; the skill is knowing what each standard expects of decision-making.

Linking SFAIRP to ERICPD

SFAIRP and ERICPD work together:

1. Start at the top of ERICPD.
2. Ask for each level: Is this control reasonably practicable for this risk?
3. Implement all levels that pass the test.
4. Accept residual risk only when further measures would be grossly disproportionate (or technically impossible without creating worse risks).
5. Record the reasoning.

A manager who jumps to PPE because “engineering is expensive” without comparing the size of the risk has not applied SFAIRP correctly.

Worked scenarios

Scenario A — cheap guard vs plant redesign

A packaging machine has an accessible in-running nip. Risk assessment shows serious crushing injury is foreseeable for operators clearing jams.

• Option 1: Fixed interlocked guard and revised jam-clearance SSoW — moderate cost, high risk reduction.
• Option 2: Complete redesign of the machine line for a slightly lower residual risk after Option 1 already makes entanglement extremely unlikely.

SFAIRP reasoning: Option 1 is almost certainly required — serious harm, clear engineering control, cost not extreme relative to risk. Option 2 may be grossly disproportionate if residual risk after Option 1 is tiny and redesign costs are enormous. Document why Option 2 is not pursued; do not skip Option 1.

Scenario B — “We have always done it this way”

Workers hand-feed a dusty powder with no LEV. Several people could develop long-term respiratory disease. Management rejects LEV as “too expensive” and issues only disposable masks.

SFAIRP reasoning: Long-latency serious ill health for multiple people is a significant risk. LEV and process enclosure are classic higher ERICPD controls. Masks alone are weak and often poorly used. Cost of LEV is unlikely to be grossly disproportionate to that risk in most industrial settings. Refusing engineering control without a strong evidence-based balance fails the spirit of SFAIRP.

Scenario C — tiny residual risk after good controls

A warehouse has racking inspected, good traffic segregation, trained FLT drivers, speed limits, high-visibility clothing, and mirrors at blind corners. Someone proposes a full automated goods system costing millions solely to remove a residual risk already assessed as very low.

SFAIRP reasoning: Further huge spend for negligible extra risk reduction may be grossly disproportionate. Keep monitoring and maintain existing controls; revisit if traffic density or incident data changes.

What good managers document

When you choose controls, leave a trail others can follow:

• What risks were significant?
• Which ERICPD options were considered?
• What was implemented and why?
• Which higher options were rejected and on what sacrifice vs risk basis?
• How residual risk will be monitored (supervision, inspections, health surveillance where relevant)?

This protects people and also supports defence of decisions if challenged by senior management, workers’ representatives, or regulators.

Common misconceptions

Manager checklist — SFAIRP decisions

1. Have I quantified (at least qualitatively) who is exposed, how often, and how bad harm could be?
2. Have I listed higher ERICPD options, not only PPE and rules?
3. Have I estimated sacrifice honestly (money + time + effort + disruption)?
4. Would a reasonable person say further control is grossly disproportionate to the residual risk left?
5. For significant risks, have I still implemented robust controls even if they cost money?
6. Have I recorded the decision for the risk assessment and project form?

Next, safe systems of work and permits to work show how administrative Control measures formalise residual-risk management when the hazard cannot be fully eliminated.