WHAT IS “REASONABLY PRACTICABLE” EARTHING DESIGN?
S.E Oosthuizen J.F. Peyper
Western Power, Perth, Australia
The new Workplace Health and Safety (WHS) legislation recently adopted
in Australia, together with AS 5577 and the next version of AS 2067, require
due diligence from all persons designing or working on or near electrical
installations. This legislation requires all to comply with the concept of “So
Far As Is Reasonably Practicable” (SFAIRP) and gives rise to the question,
“what risk is reasonable and tolerable and what is practicable?
How does a designer know where or when to draw the line between
applying more precautions that incur additional cost and accepting the
risk?
What are the main variables to consider with “risk vs cost” approach and
how are they defined?
When considering the concept of SFAIRP, a risk treatment option is
justifiable when it is “reasonably practicable” and the cost to implement
the option is not grossly disproportionate to the cost of the benefit gained.
By defining what is “Reasonably Practicable” provides a means by which
the designer can demonstrate due diligence with the methodology
followed, as well as showing why certain options were discarded. This
defined approach supports the “So Far As Is Reasonably Practicable”
(SFAIRP) concept required by AS 5577 and the next version of AS 2067.
Keywords: So Far As Is Reasonably Practicable (SFAIRP), As Low As
Reasonably Practicable (ALARP), Value of Statistical Life (VoSL),
Disproportion Factor (DF), Grossly Disproportionate (GD)
1. Introduction
Electricity supply networks are an essential part of the infrastructure
supporting the Australian community. Electricity supply networks
are physically embedded throughout the community and differ from
others in that they have the potential to be lethal. Network safety is
therefore essential for both utility business employees who work in
and on the networks, customers receiving electrical supply and the
community at large. Eliminating all the risks related to electrical
network assets is practically impossible other than by removing the
assets themselves.
The solution lies in managing network risks in a controlled,
financially viable manner while meeting all legal, ethical and
technical requirements. (Due diligence)
Irrespective of whether a risk is ‘negligible’, ‘broadly acceptable’,
‘tolerable’ or ‘intolerable’, the new legislation requires due diligence
from every person designing or working on or near electrical
installations and to comply with the concept of “So Far As Is
Reasonably Practicable” (SFAIRP).
It is also important that all precautions or mitigations to reduce a
risk be applied in an economic way. The question that comes to
mind is, where does one stops? The same question was raised by
“Risk Targets – Where to Start, What to Calculate and When to
Stop” [1].
The concept of “So Far As Is Reasonably Practicable” (SFAIRP) should
be done using a risk vs cost benefit analysis, either to establish the
relative cost of risk treatment or the value of the risk reduction
options, to establish whether a possible risk treatment option is
justifiable.
Page 1 of 8
People and society are generally willing to live with a particular risk
to secure social and economic benefits with the expectation that
they are told the nature and level of the risks and confidence that
the risks are being controlled as low as reasonably practicable. This
provides utilities with the basis for justifying regulatory decisions
whereby the costs of reducing a risk are judged to be worth the
benefits and allows a sensible balance to be struck between the two
sides, “The use of risk assessment within departments” [4].
2. Reasonably Practicable
In the context of SFAIRP a risk treatment option is justifiable when it
is “reasonably practicable”. This means the cost to implement the
option is not grossly disproportionate to the value of the risk benefit
gained. The main question here is: How does one calculate the cost
of the benefit?
The objective test to what is ‘Reasonable Practicable’ has two
elements, i.e. i) A duty holder must first consider what can be done,
that is, what is possible in the circumstances for ensuring health and
safety, then ii) consider whether it is reasonable in the
circumstances to do all that is possible, “Near enough not safe
enough” [5]. This means that what can be done should be done
unless it is reasonable in the circumstances for the duty holder to do
something less.
The level of risk resulting from this approach might be as low as
reasonably practicable but that is not the test that is applied by the
courts after the event. The courts test for the level of precautions,
not the level of risk, i.e. was all practicable precautions identified for
each critical hazard and was it determined which of these
practicable precautions are ‘reasonable’, “Near enough not safe
enough” [5].
“Reasonably Practicable” is defined by two main variables, namely
Value of Statistical Life (VoSL) and Disproportion Factor (DF).
The authors are in agreement with “Risk Targets – Where to Start,
What to Calculate and When to Stop” [1], that there is some point
where the whole process needs to stop. Instead of using only the
‘risk target’ values, i.e. 1 x 10-6, as used by the “Environmental
Protection Authority Guideline” [2], ‘risk bright lines’, as defined in
“Risk Targets – Where to Start, What to Calculate and When to
Stop” [1], or ‘tolerability region’, as described in “The use of risk
assessment within departments” [4], it is important that the benefit
of applying additional mitigation options be compared to the cost of
implementing those mitigation options.
In order to do that, the VoSL and DF have to be defined and
quantified.
2.1 Value of Statistical Life (VoSL)
Value of Statistical Life is often used to estimate the benefits of
reducing the risk of death or to do an estimate of the financial value
society places on reducing the average number of deaths by one,
“Value of statistical life “[3]. This is an important parameter in
calculation of the cost of additional risk control measures versus the
cost of the risk benefit brought about by implementing these risk
measures.
This value of statistical life for Australia has been set at $3.5m in
2007 dollar value, “Value of statistical life” [3], and is adjusted every
year with CPI.
2.2 Disproportion Factor (DF)
The public has an expectation that power systems are safe as long as
it is not tampered with and therefore places value on the absence of
risk that can be expected whilst at home. People do not expect to
receive an electric shock when they walk past a utility asset in a park
or near their houses. People and society are, however, averse to
certain kinds of hazards and place significant greater value on the
vulnerable and, in particular, young people.
The VoSL is sometimes modified, or adjusted to account for the
publics’ expectation of ‘absence’ of risk, especially in cases where
the risks are ‘unseen’, ‘inescapable’ or of ‘involuntary’ nature to the
public. This factor, by which the VoSL is modified, is referred to as
the Disproportion Factor (DF).
There is no such factor given in any Australian standard or
legislation. A disproportion factor of not less than three (3) has been
proposed, “The use of risk assessment within departments” [4],
‘where there is no escape and no warning with no free play for the
operation of individual judgment‘, “Guide to Risk Based Earthing
System Design” [7].
Earthing systems are part of every electrical connection that impacts
every aspect of human life. Where there is electricity, there will be a
connection to earth. Failure of the electrical system is rare, but it
does happen in an un-predictable manner. These hazards, earth
potential rise (EPR), from network failure are therefore involuntarily
imposed on the public and they have ‘no escape’, ‘no warning’ and
‘no free play for individual judgment’.
The involuntary effect of earth faults on the public and the inability
of the public to respond to it places earth potential rise risk under
the same umbrella as the criteria for the disproportion factor as
proposed by “The use of risk assessment within departments” [4].
This means a risk treatment need not be applied if the cost to
implement is greater than the reduction in value of liability (i.e.
benefit gained) for implementing the risk treatment. A
recommended value of at least three (3) is proposed to assess
“gross disproportion” when it comes to EPR risk assessment and
mitigation options.
2.3 Risk Cost Benefit Analysis
Previously a design target or safety criteria was used as the goal to
be achieved. When considering the risk associated with a design, an
alternative measure is required. A possible approach is a cost vs
benefit approach, where the ultimate assessment criteria become
the point where cost of further reduction becomes grossly
disproportional to the benefit from that reduction option.
Even though the implementation of risk mitigation options may not
entirely eliminate the risk but merely reduce the probability of
fatality, the risk cost benefit analysis shall be applied, using the
amount by which the probability has been reduced, to determine
whether the mitigation option is worthwhile.
The benefit to any utility owner is a reduction in risk of electrocution
(probability of fatality- Pf), while the cost, in today’s value, (present
value – PV) is the cost of a successful mitigation strategy. The risk is
the probability of fatality and is the product of the probability of
Page 2 of 8
coincidence (Pcoinc) and probability of fibrillation (Pfib). The Pf is
defined by the following equation Pf  Pcoinc  Pfib and calculated
using an industry accepted software, “EG-0 Power System Earthing
Guide – Part 1: Management Principles” [6]. The benefit in reducing
the risk can be measured as the reduction in a utility’s corporate
liability.
3. Methodology Followed
Standard equations were used to calculate the various parameters
for the evaluation, “EG-0 Power System Earthing Guide – Part 1:
Management Principles” [6].
1
Liability: L  VoSL P f ……………………………………………………….……..(1)
Where ‘L’ - the asset owners’ liability ($/year), VoSL – Value of
Statistical Life and Pf – probability of fatality
L   1  
Y
2
Present Value: PV   1     ……………………….………..(2)
D   1  D  
Where PV – Present Value ($) over ‘Y’ years the asset will present a
risk, ‘L’ – asset owners’ liability ($/year) and ‘D’ – discount rate (%)
FC
Present Value of Mitigation Cost: PVCost  ………….(3)
(1  rOPEX ) x
Where PVCost – present value ($) of costs incurred at a future year
‘x’, ‘FC’ – future costs incurred in year ‘x’, and rOPEX – interest rate for
labor and material
The design is started by employing a standard, functional or
template design (Figure 1) that meets the asset owners’ functional
requirements for an earthing design, i.e. current carrying capacity
and thermal rating of conductors, fault levels, protection fault
clearing time, insulation coordination, etc.
This functional design is implemented at the site and all hazards are
identified, i.e. EPR, step and touch, transferred potentials, etc.
Consideration of future developments and infrastructure in the
affected area of the site is also assessed.
A risk assessment is performed by including likelihood of
occurrence. For these hazards the contact scenario and the
probability of fatality (Pf) is determined, “Argon” [8].
Mitigation assessment comprises identification of all reasonable and
practicable mitigation options that will mitigate all identified
hazards. Mitigation or risk reduction options forms part of the
design process and assist not only to demonstrate due diligence, but
demonstrate that any further expenditure to reduce the risk would
not produce benefits that can be supported. It is important not to
consider hazards individually as some mitigation options, while
decreasing the level of risk of some identified hazard would increase
the level of risk of other, hence reducing the overall benefit. This
would not be visible if risk is treated individually.
The Risk Cost / Benefit review includes the calculation of the liability
(L) and the present value of the liability (PV) over the number of
years the asset will remain potentially hazardous.
This forms the base case (mitigation free case) for all further
assessment at the site.
1
“EG-0 Power System Earthing Guide – Part 1: Management Principles” [6] – equation
F1
2
“EG-0 Power System Earthing Guide – Part 1: Management Principles” [6] – equation
F2
At the evaluation stage the total cost of each mitigation option over
the life of the asset is required. These costs are a combination of
capital (CAPEX) and operational (OPEX) expenditure. Capital cost is
upfront, i.e. material, labor, etc. to establish the asset and
operational is typically the maintenance cost over the life of the
asset to maintain it in an operational condition to meet the design
requirements.
Figure 1: Iterative Hazard Evaluation Process
Each of the mitigation options has a different impact on the
identified hazard and the outcome with regards to the risk the
public is exposed to, Pf, and the liability to the asset owner. For each
of the reasonable and practicable mitigation options listed the
following ‘after mitigation’ or ‘residual’ values are calculated:
 The probability of fatality (Pf - after) after implementation of
the mitigation option (‘after mitigation’ or ‘residual’ Pf -
after), “Argon” [8].
 Asset owners Liability (L - after) ($/year) over the lifetime of
the asset after mitigation option is applied – using
equation (1) and the ‘after mitigation’ or ‘residual’
probability of fatality (Pf - after).
 Asset owners present value liability (PV - after) ($) over the
lifetime of the mitigation option – using equation (2) and
the asset owners liability after mitigation, L - after.
 Asset owners present value benefit (PV Benefit - after) after
the mitigation option was applied – the difference
between the present value of the liability (PV) for the base
case and the present value liability after implementation
of mitigation option (PV – after).
 Asset owners total present value cost (PVCost), CAPEX and
OPEX, for implementing the mitigation option over the
lifetime of the asset – cost incurred at year ‘0’ and, using
equation (3), the respective OPEX cost at a future year ‘x’.
 Cost disproportionality – the total cost for mitigation
(PVCost) divided by the asset owners net present benefit
(PV Benefit – after). The cost incurred is considered
disproportionate if the ratio is larger than (>) the
Disproportion Factor (DF).
These calculations are done for each mitigation option and all
options are then compared to determine how reasonable and
practicable each is. A mitigation option will not only be selected
based on the cost/benefit assessment alone, but also includes the
hierarchy of control and factors such as access to maintain or
monitor mitigation option and maintainability of selected option.
This process is iterative until all mitigation options have been
assessed and the most viable option has been determined. Once the
Page 3 of 8
most viable option has been determined, this now becomes the new
‘base case’ and the process is repeated for the remainder of the
mitigation options. This continues until all options have been
exhausted or discarded (Figure 1), at which point SFAIRP is satisfied.
4. Hypothetical Worked Example
Project Scope
A typical 132/22 kV substation, Substation X, with one transformer,
is cut-in (looped-in) to an existing 132 kV line, 10 km from
Substation A and 5 km from Substation B. The line do not have
overhead earth wires and due to insulation coordination
requirements, 500 m of earth wire is installed either side of new the
substation (Figure 3). The ultimate layout of the site will comprise 4
x 132 kV lines and 3 x transformers. The “functional earth grid
design” is shown in Figure 2 that is in line with AS 2067
requirements.
Figure 2: Functional Earth Grid Layout
A total of eight vertical rods are located at lightning masts and surge
arrester locations. A grading ring 1 m beyond the fence line is
included and bonded to the earth grid.
Soil model
A typical three-layer soil model at the site is shown in Table 1.
Layer Impedance (.m) Depth (m)
Top 2000 5
Middle 200 10
Bottom 50 ∞
Table 1: Soil Model Results
Transmission Network
A single phase to ground fault with contributions from both
Substation A at 10 kA and Substation B at 5 kA respectively,
delivered the highest zero sequence current for this case study. See
Figure 3. The earth wire is earthed at every pole with a 20 m stake
that gives a typical impedance of 10.
Figure 3: Transmission Network Layout
Distribution Network
The substation service a mixed overhead and underground
distribution network that comprise three feeders, two overhead,
100 m and 2 km respectively in length, with a single 30  stake each
and an underground feeder that terminates at a distribution
substation, comprising a ground mounted ring main unit (RMU), 22
kV / 415 V transformer and LV distribution frame.
The “functional design” for a distribution substation includes a
grading ring with two 12 m stakes and employs combined MV and
LV earthing, i.e. multiple earthed neutral (MEN). A 240 mm², three
phase aluminium cable provide this connection to the LV network
and therefore extends the substation earthing system to the
serviced low voltage network of the substation.
Low Voltage Network
The LV underground network comprise pillars, each with a 1.1 m
earth stake and a 16 mm² service cable to connect to the customer
earth stake, refer to Figure 4.
Present Value (PV) Liability, equation (2), were calculated. These
results are summarised in Table 3.
The terms used in Table 3 has the following meaning:
 TSI (Transmission Substation Inside) refers to the hazard
inside the substation fence;
 Backyard, “EG-0 Power System Earthing Guide – Part 1:
Management Principles” [6], contact with items in a
backyard (taps, fences) where there is likely to be regular
contact over a year. (416 contacts/year with a contact
duration of 4 s)
 MEN, “EG-0 Power System Earthing Guide – Part 1:
Management Principles” [6], multiple contacts with items
associated with the MEN on a daily basis. (2000
contacts/year with a contact duration of 4 s)

Probability of
Risk Location

year period
Fatality (Pf)

PV Liability
Figure 4: LV Underground Network

Liability (L)

(L) Over 50
($/year)
Hazard
Risk Cost / Benefit Input Parameters
Typical values used for the Risk Cost Benefit analysis are listed in
Table 2 below.
Substation - Touch TSI 5.6E-6 $22.56 $330.80
Voltage
Symbol Definition Value
3
Substation - Step TSI 0.0E+0 $- $-
VoSL Value of Statistical Life - 2014 $4.065 m
Voltage
D Discount Rate 6.53% Substation - Fence Backyard 1.45E-6 $5.50 $80.66
Y Number of years the asset will 50 Touch
remain potentially hazardous Tx Line – Step Voltage Backyard 0.0E+0 $- $-
r Interest rate 5% Dx - Touch Voltage Backyard 3.26E-7 $1.29 $18.85
rOPEX Interest rate for labor and material 3.42% Dx - Step Voltage Backyard 0.0E+0 $- $-
DF Disproportion Factor 3 Dx - MEN Touch MEN 1.4E-5 $57.65 $845.56
Table 2: Worked Example Summary Values Voltage
Dx - MEN Step Voltage MEN 0.0E+0 $- $-
Appropriate rigor should be applied when these values, Table 2, are Totals 2.1E-5 $86.99 $1,276
selected. These values should not be project specific, but corporate
Table 3: Functional Design Values
values that are well defined and can be used repeatedly.
Practicable Mitigation Options
Identified Hazards
All practicable mitigation options considered to address identified
Based on the location of the site, the following hazards were
hazards are listed below.
identified:
1. Reduce Fault Duration - Reduce the fault clearing time from
1. Possible touch voltage inside the substation (mesh voltage) –
0.3 s to 0.1 s
Substation Touch Voltage;
2. Longer OHEW - Extended the OHEW from 500 m to 2 km on
2. Step voltage inside the substation – Substation Step Voltage;
line to Substation A
3. Touch voltage 1 m from the substation fence – Substation
3. Continues OHEW - Extended Substation A line OHEW to 10
Fence Touch;
km terminating at adjacent substation earth grid
4. Step voltage around transmission line down earths – Tx Line
4. Substation deep earths – 100 m - Extending the 8 x 12 m
Step;
Substation X electrodes to 100 m
5. Touch voltage to ground mounted distribution equipment –
5. Substation deep earths – 50 m - Extending the 8 x 12 m
Dx Touch Voltage;
Substation X electrodes to 50 m
6. Step voltage around ground mounted distribution
6. Substation deep earth – 100 m with 6 additional earths -
substations – Dx Step Voltage;
Extending the 8 x 12 m Substation X electrodes to 100 m and
7. Touch voltage due to transfer with regards to the
install additional 6 electrodes at ‘hot spot’ locations
distribution LV neutral network – Dx MEN Touch Voltage;
7. Deep line earths – 100 m - Extend the 20 m electrodes (~10
and
Ω) earthing the OHEW to 100 m along the Substations A and
8. Step voltage due to transfer with regards to the distribution
B 132 kV lines
LV neutral network – Dx MEN Step Voltage.
8. DX Connections - Installing ground mounted substation at
underground / overhead transition point to allow
Modelling Results
connection into the LV MEN at the two overhead
The “Functional Design” was simulated using CDEGS modelling
distribution feeders
software and the actual touch and step voltages were used to
9. Substation deep earths – 30 m - Extending the 8 x 12 m
calculate the respective probability of fatality (Pf), “Argon” [8]. For
Substation X electrodes to 30 m
each of the identified hazards the Liability (L), equation (1), and
10. DX Connection removed - Lifting the distribution cable
screen earth that supply ground mounted equipment at the
3
The VoSL of $4 m in 2007 dollar value has been escalated with CPI to a current 2014
value of $4,065,279.82
Page 4 of 8
 substation and earth the cable screen to a separate earth

Present Value Benefit

Probability of Fatality

Liability (PV -_after) ($)

Cost (PV Cost) ($ ‘000)

(PV Benefit – after) ($)

Total Present Value

Disproportionality
electrode

(L-after) ($/year)

Present Value
(Pf – after)

Liability
Each of the identified mitigation options has a cost associated with Mitigation

Cost
their implementation and a different outcome with regards to the Option
Pf, and therefore the liability to the asset owner or utility. These
costs are a combination of capital (CAPEX) and operational (OPEX).
The CAPEX costs are incurred in year ‘0’ and the OPEX costs, where
applicable, were applied at different years throughout the life of the additional
asset. The CAPEX cost for each identified mitigation option is earths
summarized in Table 4. There is no maintenance cost, other than Deep line 1.8E-7 $1 $11 $1,26 $43.1 34.1
inspection, associated with any of the mitigation options. earths – 100 5
m
Mitigation Option CAPEX ($) DX 1.1E-5 $43 $628 $648 $250 385.6
Reduce Fault Duration $1,000 Connections
Substation 1.2E-5 $47 $690 $585 $5.6 9.6
Longer OHEW $300,000
deep earths –
Continues OHEW $1,500,000 30 m
Substation deep earths – 100 m $44,800 DX 9.6E-6 $39 $575 $701 $1.4 2.0
Substation deep earths – 50 m $16,800 Connection
removed
Substation deep earth – 100 m with 6 additional earths $86,800
Table 5: After Mitigation Summary Values
Deep line earths – 100 m $43,120
DX Connections $250,000 The Probability of Fatality (P f – after) column in Table 5 is expanded in
Table 6 to indicate how each mitigation option affects the different
Substation deep earths – 30 m $5,600
identified hazards in the network. For ease of comparison, Table 6
DX Connection removed $1,400 also lists the values from the Functional Design. The “step voltage”
Table 4: Mitigation Implementation Cost hazards for this example all resulted in zero (0) probability of fatality
and is therefore excluded from Table 6 and all other tables of this
For each of the identified mitigation options the following “after example.
implementation” values were calculated and are summarised in
Table 5: Probability of Fatality (P f & Pf-after)
 Probability of fatality (Pf-after), “Argon” [8]
 Asset owners liability (L - after) using equation (1) ($/year)
Substation

 Hazards Substation

Dx Touch

Dx MEN
Asset owners present value liability (PV – after) using
Voltage

Voltage

voltage

TOTAL
Touch
Touch

Touch
equation (2) ($) Fence
 Asset owners present value benefit (PV Benefit – after) ($)
Mitigation Options
 Asset owners total present value cost (PV Cost) using
Functional Design 5.6E-6 1.4E-6 3.2E-7 1.4E-5 2.1E-5
equation (3) ($) and
 Cost disproportionality Reduce Fault 3.2E-6 1.1E-7 2.4E-8 8.1E-6 1.1E-5
Duration
Longer OHEW 3.6E-6 2.5E-7 3.8E-8 9.0E-6 1.3E-5
Present Value Benefit
Probability of Fatality

Liability (PV -_after) ($)

Cost (PV Cost) ($ ‘000)

(PV Benefit – after) ($)

Total Present Value

Disproportionality
(L-after) ($/year)

Continues OHEW 7.9E-6 1.2E-6 5.6E-8 1.5E-5 2.4E-5

Present Value
(Pf – after)

Liability

Mitigation Substation deep 3.5E-8 8.1E-9 9.9E-9 1.9E-6 1.9E-6

Cost

Option earths – 100 m

Substation deep 1.4E-6 1.7E-8 1.4E-8 6.4E-6 7.8E-6
earths – 50 m
Substation deep 1.5E-8 3.1E-9 8.1E-9 4.3E-7 4.6E-7
Reduce Fault 1.1E-5 $46 $682 $594 $1 1.7
earth – 100 m with
Duration
6 additional earths
Longer 1.3E-5 $52 $768 $507 $300 591.2
Deep line earths – 2.2E-8 6.9E-9 5.2E-9 1.5E-7 1.8E-7
OHEW
100 m
Continues 2.4E-5 $96 $1,40 -$131 $1,50 N/A
DX Connections 3.7E-6 3.5E-7 1.4E-8 6.5E-6 1.1E-5
OHEW 7 0
Substation 1.9E-6 $8 $113 $1,16 $44.8 38.5 Substation deep 2.9E-6 1.1E-7 5.2E-8 8.5E-6 1.2E-5
deep earths – 2 earths – 30 m
100 m DX Connection 8.0E-6 1.6E-6 0.0E+0 9.8E-9 9.6E-6
Substation 7.8E-6 $32 $466 $810 $16.8 20.7 removed
deep earths – Table 6: After Mitigation Risk Summary Values
50 m
Substation 4.6E-7 $2 $27 $1,24 $86.8 69.5
Implement ‘Reduce Fault Duration’ Mitigation Option
The ‘Reduce Fault Duration’ mitigation option resulted in the lowest
deep earth – 8
‘Cost Disproportionality’, i.e. 1.7, Table 5. The cost disproportionality
100 m with 6
is an indication that, in order to increase the benefit by $1, one
Page 5 of 8
needs to spend $1.70 on mitigation. All the other mitigation options

Present Value Benefit

Probability of Fatality

Liability (PV -_after) ($)

Cost (PV Cost) ($ ‘000)

(PV Benefit – after) ($)

Total Present Value

Disproportionality
resulted in values significantly greater than 1.7. As this option has

(L-after) ($/year)

Present Value
the lowest disproportionality it is therefore the most economical

(Pf – after)

Liability
and feasible option to implement first. Mitigation

Cost
Option
Applying the iterative process described in Figure 1, Table 3 values
were replaced with the new values resulting from implementing
‘Reduce Fault Duration’ mitigation option -.refer to Table 7. The
values in Table 7 now become the new base values to be used. Connections
Substation 2.8E-6 $12 $169 $512 $5.6 10.9
Probability of deep earths –
Risk Location

year period
Fatality (Pf)

PV Liability
Liability (L)

(L) Over 50
30 m

($/year)
Hazard DX 5.9E-6 $24 $352 $330 $1.4 4.2
Connection
removed
Substation - Touch TSI 3.2E-06 $13.01 $190.81 Table 8: After Mitigation Summary Values - ‘Reduce Fault Duration’
Voltage
Substation - Step TSI 0.0E+00 $- $- The Probability of Fatality (P f – after) column in Table 8 is expanded in
Voltage Table 9 to indicate how each mitigation option affects the different
Substation - Fence Backyard 1.1E-07 $0.44 $6.48 identified hazards in the network. For ease of comparison the values
Touch from ‘Reduce Fault Duration’ is also shown in Table 9.
Tx Line – Step Voltage Backyard 0.0E+00 $- $-
Dx - Touch Voltage Backyard 2.4E-08 $0.10 $1.42 Probability of Fatality (P f & Pf-after)

Dx - Step Voltage Backyard 0.0E+00 $- $-

Substation

Substation
Hazards

Dx Touch

Dx MEN
Voltage

Voltage

voltage
Dx - MEN Touch MEN 8.1E-06 $32.93 $482.91

TOTAL
Touch
Touch

Touch
Fence
Voltage
Dx - MEN Step Voltage MEN 0.0E+00 $- $-
Mitigation Options
Totals 1.1E-5 $46.48 $681.61 Reduce Fault 3.2E-6 1.1E-7 2.4E-8 8.1E-6 1.1E-5
Table 7: Implement Mitigation Option ‘Reduce Fault Duration’ Duration
Longer OHEW 9.7E-7 2.2E-8 1.3E-8 1.7E-6 2.7E-6
The impact of implementing the other mitigation options is now Continues OHEW 4.5E-6 9.1E-8 2.1E-8 2.4E-6 7.0E-6
calculated, as in Table 5, and is tabulated in Table 8.
Substation deep 1.8E-8 5.2E-9 6.2E-9 1.4E-7 1.7E-7
earths – 100 m
Present Value Benefit
Probability of Fatality

Liability (PV -_after) ($)

Cost (PV Cost) ($ ‘000)

(PV Benefit – after) ($)

Total Present Value

Substation deep 1.1E-7 1.0E-8 9.4E-9 5.4E-7 6.6E-7

Disproportionality
(L-after) ($/year)

Present Value

earths – 50 m
(Pf – after)

Liability

Mitigation
Cost

Substation deep 9.3E-9 2.9E-9 5.2E-9 6.9E-8 8.6E-8

Option earth – 100 m with
6 additional earths
Deep line earths – 1.5E-8 5.1E-9 3.8E-9 5.4E-8 7.7E-8
Reduce Fault 1.1E-5 $46 $682 $- $- 0.0 100 m
Duration DX Connections 1.8E-6 2.7E-8 9.4E-9 5.4E-7 2.3E-6
Longer 2.7E-6 $11 $158 $523 $300 573.2 Substation deep 5.4E-7 1.5E-8 1.3E-8 2.3E-6 2.8E-6
OHEW earths – 30 m
Continues 7.0E-6 $28 $416 $266 $1,50 5641 DX Connection 5.6E-6 2.8E-7 0.0E+0 9.8E-9 5.9E-6
OHEW 0 removed
Substation 1.7E-7 $1 $10 $671 $44.8 66.7 Table 9: Mitigation Option Post-Implementation Risk Summary
deep earths –
100 m 5. Analysis of the Results
Substation 6.6E-7 $3 $40 $642 $16.8 28.2 All the hazards identified, Table 3, impact different areas of the
deep earths –
network differently and the risk for each is different. It is therefore
important to form a holistic picture of all possible hazards and the
50 m
risk each impose on different areas of the network. The total risk, P f,
Substation 8.6E-8 $0 $5 $676 $86.8 128.3
before implementing any of the mitigation options is determined by
deep earth –
adding the respective individual network risks together and is the
100 m with 6 total risk as a result of the project.
additional
earths The probability of fatality for a ‘Step voltage’ scenario is zero (0) for
Deep line 7.7E-8 $0 $5 $677 $43.1 63.7 this example due to the low probability of fibrillation as a result of
earths – 100 the current path through the body, foot-to-foot, and has been
m excluded in further assessments.
DX 2.3E-6 $10 $139 $542 $250 461.1

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The different hazards resulted in different liability values over the
life, 50 years, the asset may remain hazardous, Table 3. The liability
varies as it is only determined by the VoSL and the risk (P f) each
hazard imposes on the different areas of the network.
Each of the liability values are used to determine the value in
present day terms, present value, over the life the asset may remain
hazardous. These individual present values are summated together
to give the total present value liability to the asset owner.
The summated risk, Pf, and liability forms the base values to be used
to determine the viability of each individual mitigation option.
It is important to have a holistic view of the risk profile after
implementing a mitigation option as the risk in certain areas may
increase, compared to the Functional Design value, whilst the total
risk decreases, i.e. Table 6 – ‘DX Connection removed’.
Implementing this option result in an increase in the risk (Pf) on the
‘Substation Touch Voltage’ and ‘Substation Fence Touch’ hazards
relative to that of the Functional Design risk. Implementing this
option has an inverse effect on the ‘Dx Touch Voltage’ and ‘Dx MEN
Touch Voltage’ hazard locations, while the overall risk reduces to
below that of the Functional Design.
Mitigation option ‘Continues OHEW’ resulted in a higher total risk,
2.4E-5, whilst there is a reduction in the risk at ‘Substation Fence
Touch’ and ‘Dx Touch Voltage’ and an increase in risk at ‘Substation
Touch Voltage’ and ‘Dx MEN Touch voltage’ respectively.
Implementation of a mitigation option should therefore not be
based on the total risk profile alone.
The Liability (L-after), Present Value Liability (PV -_after) and Present
Value Benefit (PV Benefit – after), Table 5, on its own is not a good
indication of which mitigation option is more feasible or will provide
the highest benefit. The Present Value Benefit (PV Benefit – after) and
Total Present Value Cost (PV Cost) should be considered together to
get a clear understanding.
‘Reduce Fault Duration’ and ‘Substation deep earths – 30 m’
mitigation options, Table 5, result in similar risk profiles (Pf), i.e.
1.1E-5 and 1.2E-5 respectively. These two mitigation options also
have similar Present Value Benefit (PV Benefit – after) values, i.e. $594
and $585 respectively, but the Total Present Value Cost (PV Cost) are
significantly different, i.e. $1,000 and $5,600 respectively. The
disproportion factor for these two options are also significantly
different, i.e. 1.7 and 9.6 respectively. It can therefore be concluded
that implementing mitigation option ‘Substation deep earths – 30
m’ will result in a similar risk profile as ‘Reduce Fault Duration’, but
at 5.6 times the cost. It is therefore clear that implementing option
‘Substation deep earths – 30 m’ is not providing any additional risk
benefit over the much cheaper option ‘Reduce Fault Duration’.
Mitigation option ‘DX Connection removed’, Table 5, results in a
much lower risk profile than ‘Reduce Fault Duration’, i.e. 9.6E-6 and
1.1E-5 respectively, and a higher Present Value Benefit (PV Benefit –
after), i.e. $701 versus that of $594, while there is very little
difference in the disproportion factor, i.e. 2 and 1.7 respectively.
Further investigation, Table 6, indicates that, even though the
overall risk is reduced, the risk at the ‘Substation Touch Voltage’ and
‘Substation Fence Touch’ increases. It is important that the actual
location of the substation be considered prior to implementing ‘DX
Connection removed’ mitigation option, especially when the
substation is located close to a park, school or recreational area
Mitigation option ‘Deep line earths – 100 m’ resulted in the lowest
total risk profile (Pf) of 1.8E-7 and has the lowest asset owner
liability, $1 per year, over the life of the asset and the lowest
Present Value Liability (PV -_after), $11. This option also has the
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highest Present Value Benefit (PV Benefit – after), but the ‘Cost
Disproportionality’ of nearly 35 times makes it an unattractive
option.
Implement ‘Reduce Fault Duration’ Mitigation Option
The mitigation options were again compared using the new values
after implementation of the ‘Reduce Fault Duration’ mitigation
option. When comparing the values of post ‘Reduce Fault Duration’,
Table 8, to that prior to implementation, Table 5, an overall
reduction in Probability of Fatality (Pf – after), Liability (L-after), Present
Value Liability (PV -_after) and Present Value Benefit (PV Benefit – after)
is noticed, whilst the Total Present Value Cost (PV Cost) remains
unchanged. An increase in the Cost Disproportionality is also noticed
and therefore, after implementation of ‘Reduce Fault Duration’
mitigation option, the other options become less attractive.
The risk profile at all the identified hazard locations is also lower
than or equal to those prior to implementing ‘Reduce Fault
Duration’ mitigation option. This can be seen when comparing the
values of Table 9 to those in Table 6.
6. Conclusions
All the mitigation options identified are practicable and reasonable
to implement.
Anyone of these would have been used in the past to achieve the
allowable voltage limits set by the relevant industry standards,
irrespective of the benefit gained or the cost of implementation.
The application of a ‘risk target’ approach, i.e. less than 1 x 10-6,
would have discarded some of the more obvious mitigations due to
its inability to deliver the required outcomes. The likely options
considered would have been limited to those resulting in a risk
profile of less than 1 x 10-6, therefore a ‘risk target’ approach does
not satisfy due diligence.
Implementing the “Reasonably Practicable” (Risk Cost – Benefit)
approach, as described in this paper, not only provides the designer
with a clear view of the cost of each mitigation option, but also the
benefit gained from implementing each. The “Reasonably
Practicable” approach provides a means by which the designer can
demonstrate due diligence in the methodology followed, as well as
why certain options were discarded. The approach supports the “So
Far As Is Reasonably Practicable” (SFAIRP) concept required by AS
5577 and the next version of AS 2067. This approach also gives
visibility with regards to the risk profile of each hazard that is
identified.
The “Reasonably Practicable” approach is very dependent on the
values listed in Table 2 and the decision on which values to use is
one that should not be taken lightly.
Selecting a different value for disproportion factor (DF) will lead to
less or more mitigation options being feasible to implement. It is
therefore important that this decision be well documented for
future reference.
7. References
[1] Bale, M.J., Palmer, S.J., Woodhouse, D.J., Tocher, W., "Risk Targets –
Where to Start, What to Calculate and When to Stop", RISK Conference, 2014
[2] Environmental Protection Authority Guideline, “Criteria for the
Assessment of Risk from Industry”, Perth, Western Australia, Bulletin 611,
February 1992
[3] Australian Government, Department of Finance and Deregulation, Office
of Best Practice Regulation, “Value of statistical life”, Best Practice Regulation
Guidance Note, 2008
[4] Health and Safety Executive, Interdepartmental Liaison Group on Risk
Assessment, Use of Risk Assessment (UK-ILGRA) within Government
Departments, “The use of risk assessment within departments”, Chapter 2,
http://www.hse.gov.uk/aboutus/meetings/committees/ilgra/minrpt1b.htm ,
accessed 07 March 2014
[5] Robinson, R., “Near enough not safe enough”, Engineers Australia, vol.
86, no. 1, pp. 32-34, January 2014
[6] “EG-0 Power System Earthing Guide – Part 1: Management Principles”,
version 1, ENA DOC 025-2010, Energy Networks Association, ACT
[7] EEA, Electricity Engineers Association, “Guide to Risk Based Earthing
System Design”, Version 1, 17 January 2006
[8] ENA, Energy Networks Association, Ausgrid, “Argon”, A Network Earthing
Application, Version 3.6.5.0, 2013

Main author
Name: Stefan Oosthuizen
Address: 363 Wellington Street, Perth
Phone: (08) 9411 7373
E-mail: stefan.oosthuizen@westernpower.com.au

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