GUIDANCE Guidance about safety duties and

the concept of ensuring safety

so far as is reasonably practicable
(SFAIRP) for Victoria’s bus industry
GUIDANCE
Guidance about safety duties and the concept of
ensuring safety so far as is reasonably practicable
(SFAIRP) for Victoria’s bus industry

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
Table of Contents
Glossary. .......................................................................................................................3
Section 1
Legislation............................................................................................................................ 4
Why is this important for me?..........................................................................5
About Transport Safety Victoria. .....................................................................6
Purpose of this guide.............................................................................................7
Legislative requirements......................................................................................8
Underlying purpose of Bus Safety Act 2009 (Vic)..................................9
Risk............................................................................................................................... 10
What does risk mean?.............................................................................. 10
Risk management....................................................................................... 10
Can you measure risk?............................................................................. 10
Suggested framework. ..............................................................................11
Explaining the framework with legislative requirements............... 12
The cost of eliminating or reducing the hazard or risk.......... 16
Things to consider................................................................................................ 17
Document the risk assessment............................................................ 17
Review the risk assessments................................................................ 17
Section 2
Safety steps...................................................................................................................... 18
Gather people who are knowledgeable about the process............ 20
Why is this important?............................................................................. 20
How do I do it?............................................................................................. 20
Identify the hazards. ........................................................................................... 21
Why is this important?............................................................................. 21
What is a hazard?....................................................................................... 21
How do I do it?............................................................................................. 21
Identify the causes............................................................................................... 22
Why is this important?............................................................................. 22
What is a cause?. ........................................................................................ 22
How do I do it?............................................................................................. 22
Identify the consequences............................................................................... 23
Why is this important?............................................................................. 23
What is a consequence?. ........................................................................ 23
How do I measure it?................................................................................ 23
Determine the likelihood.................................................................................. 24
Page 1
Why is this important?............................................................................. 24
What is the likelihood?............................................................................ 24
How do I measure it?................................................................................ 24
Determine the risk score................................................................................... 25
Why is this important?............................................................................. 25
How do I do it?............................................................................................. 25
What is the risk score?............................................................................. 25
Identify control measures. ............................................................................... 26
Why is this important?............................................................................. 26
What is a control?. ..................................................................................... 26
How do I do it? ............................................................................................ 28
Identify any other alternative controls available...................... 28
Feel like you have been climbing a mountain?........................... 30
Summarise SFAIRP................................................................................................ 31
Appendix A
Hazards & Causes......................................................................................................... 32
Hazards and causes associated with bus operations....................... 33
Appendix B
Hazard identification................................................................................................. 44
Hazard identification techniques................................................................. 45
Appendix C
Risk assesment............................................................................................................... 46
Examples of risk assessment matrices...................................................... 47
Qualitative...................................................................................................... 47
Semi-Quantitative....................................................................................... 48
Likelihood ratings. ...................................................................................... 50
Consequence ratings ............................................................................... 50
Quantitative................................................................................................... 51
Appendix D
Further reading.............................................................................................................. 52
Further reading for risk management....................................................... 53
Disclaimer.......................................................................................................................... 54
Bus safety – your responsibility
Practical guidance for Victoria’s bus industry
© State Government of Victoria 2011.
Copyright in this publication resides with
the Director, Transport Safety and the State
of Victoria. No part of this publication
may be reproduced by any process except
in accordance with the provisions of the
Copyright Act 1968 (Cth).
Glossary Page 3

Term Definition
Bowtie A graphical representation of a risk assessment that identifies the
causes and consequences of a hazard including the description of
controls. See Figure 7 (p26).

Bus A motor vehicle with seating positions for 10 or more adults (including
the driver) built to comply with the requirements specified in the
Australian Design Rule for a passenger omnibus.

Bus operator The person who is responsible for controlling or directing the operations
of a bus service.

Bus safety worker A person who carries out bus safety work activities, including but not
limited to driving a bus, repairing, testing, modifying or maintaining a
bus or its equipment, and setting bus schedules and timetables.

Cause Something that may result in a hazard. That is, the way in which a
hazard occurs.

Consequence An outcome or impact of a hazard or incident. In the context of this

publication, consequences relate to injury (minor, serious or fatalities).

Control A process, device, practice or other action that acts to minimise risk i.e.
a way to eliminate or reduce risk.

Decision basis A rationalised basis for deciding that risks are eliminated or reduced so
far as is reasonably practible (SFAIRP).

Hazard A source of potential harm or what can go wrong. That is, events that
can affect safety and are called ‘hazards’ in this publication.

Likelihood How often does the hazard or associated cause occur?

Procurer A person who charters a bus service or otherwise engages with a bus
operator for using a bus service (regardless of whether or not the bus
service is provided on a commercial basis).

Risk The effect of uncertainty on organisational objectives. In this

publication, it is measured in terms of the combination of the
consequences of an event and their likelihood i.e. risk = consequence
x likelihood.

SFAIRP A legal standard for ensuring safety. In this case, the Bus Safety
Act 2009 (Vic) requires risks to safety to be eliminated so far as
is reasonably practicable and, if it is not reasonably practicable
to eliminate the risk, to reduce these risks to safety so far as is
reasonably practicable.

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
section

Legislation
Why is safety important for me? Page 5

Accidents and incidents in bus operations can result in serious injuries and
fatalities to bus employees and members of the public. Risks need effective
management so, ideally, they do not occur. However, if they do occur, controls or
actions should be in place to manage these risks.

Bus operators, bus safety workers, procurers of bus servics and designers of bus
stops all have a role to play in managing these risks to safety. Importantly, this
has been legislated as ‘safety duties’ in the Bus Safety Act 2009 (Vic).

This guide aims to help you act safely in accordance with the safety duties under
the Bus Safety Act 2009 (Vic). In particular, it explains how you may ensure
safety to the standard required under safety duties i.e. ‘so far as is reasonably
practicable’ (SFAIRP). The concept of the SFAIRP standard is not new. For
example, there are similar requirements for employers to ensure the health and
safety of employees under the Occupational Health and Safety Act 2004 (Vic).

The consequences of not meeting your safety duties can be significant. Not only
can people suffer serious injuries or fatalities (including members of the public),
but potential compliance and enforcement actions may be taken.

Note: For a list of definitions used in these materials, refer to the Glossary.
For a list of further reading materials on risk management, see Appendix D:
Further reading for risk management.

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
Section 1—Legislation Page 6
About Transport Safety Victoria

Transport Safety Victoria (TSV) regulates the

safety of all bus, maritime and rail operations
in Victoria, and promotes the continuous
improvement of transport safety.
Purpose of this guide Page 7

This guide aims to provide a practical

explanation of safety duties and the concept
of ensuring safety so far as is reasonably
practicable (SFAIRP). It suggests the use of
an adaptable risk management framework to
assist you to undertake a SFAIRP process.
This guide is relevant to anyone who has safety
duties under the Bus Safety Act 2009 (Vic).

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
 Section 1—Legislation Page 8
Legislative requirements

Bus Safety Act 2009

No. 13 of 2009

Part 3—Bus Safety Duties

Key bus safety legislation includes the:
 Bus Safety Act 2009 (Vic)
 Bus Safety Regulations 2010 (Vic)
PART 3—BUS SAFETY DUTIES
Division 1—The concept of ensuring safety
14 The concept of ensuring safety
(1) To avoid doubt, a duty imposed on a person under this Act or the
regulations to ensure, so far as is reasonably practicable, safety
requires the person to—
(a) eliminate risks to safety so far as is reasonably practicable; and
(b) if it is not reasonably practicable to eliminate risks to safety, to
reduce those risks so far as is reasonably practicable.
(2) To avoid doubt, for the purposes of this Act or the regulations, regard
must be had to the following matters in determining what is (or was
at a particular time) reasonably practicable in relation to ensuring
safety—

BSA 14 (2) (a) (a) the likelihood of the hazard or risk concerned eventuating;

BSA 14 (2) (b) (b) the degree of harm that would result if the hazard or risk
eventuated,

BSA 14 (2) (c) (c) what the person concerned knows, or ought reasonably to know,
about the hazard or risk and any ways of eliminating or reducing
the hazard or risk;

BSA 14 (2) (d) (d) the availability and suitability of ways to eliminate or reduce the
hazard or risk;

BSA 14 (2) (e) (e) the cost of eliminating or reducing the hazard or risk.

Division 2—Safety duties

BSA 15 15 Duty of operator
(1) An operator of a bus service must, so far as is reasonably practicable,
ensure the safety of the bus service.
Penalty In the case of a natural person, 1800 penalty units;
In the case of a body corporate, 9000 penalty units.
(2) An offence against subsection (1) is an indictable offence.
Note

However, the offence may be heard and determined summarily (see section 28
of the Criminal Procedure Act 2009).
 Underlying purpose of Page 9

Bus Safety Act 2009 (Vic)

BSA 16 16 Duty of procurer

(1) A procurer of a bus service must, so far as is reasonably practicable,
ensure the safety of the bus service.
Penalty In the case of a natural person, 1800 penalty units;
In the case of a body corporate, 9000 penalty units.
The purpose of the Bus Safety Act
(2) Without limiting subsection (1), a procurer of a bus service 2009 (Vic) is to promote:
contravenes that subsection if the bus service is procured on terms  the effective management of safety
that impose conditions or obligations which prevent or threaten, or risks in bus services
are reasonably likely to prevent or threaten, the safe operation of the
bus service.  continuous improvement in bus
safety management
(3) A person is not a procurer of a bus service only because the person
 public confidence in the safety of
provides funding to the operator of the bus service.
the transport of passengers by bus
(4) An offence against subsection (1) is an indictable offence.  the involvement of relevant
Note stakeholders in bus safety
 a safety culture among persons
However, the offence may be heard and determined summarily (see section
28 of the Criminal Procedure Act 2009).
who participate in the provision
of bus services.
BSA 17 17 Duty of bus safety worker
Part 3 of the Bus Safety Act 2009 (Vic)
(1) A bus safety worker must take reasonable measures to ensure the explains the shared responsibilities
safety of persons who may be affected by the acts or omissions of of the relevant persons in relation
the bus safety worker.
to safety. It has three divisions
Penalty In the case of a natural person, 1800 penalty units; or sections:
In the case of a body corporate, 9000 penalty units.  Division 1—the concept of ensuring
(2) An offence against subsection (1) is an indictable offence. safety
 Division 2—safety duties
Note
 Division 3—bus inspections and
However, the offence may be heard and determined summarily (see section safety audits.
28 of the Criminal Procedure Act 2009).
Safety duties are in addition to, and
BSA 18 18 Duties in relation to bus stopping points and bus stop separate from, any other safety-
infrastructure related requirements under bus safety
(1) A person who determines the location of, designs, constructs, law, including:
installs, modifies or maintains a bus stopping point or any bus stop  accreditation and registration
infrastructure, or who engages a person to do any of those things,  drug and alcohol management
must ensure, so far as is reasonably practicable, that the location, policy
design, construction or condition of the bus stopping point or bus
stop infrastructure is safe.  bus safety inspections.
Practically, however, there are
Penalty In the case of a natural person, 1800 penalty units;
In the case of a body corporate, 9000 penalty units. overlaps between general duties to
ensure safety and other safety-related
(2) An offence against subsection (1) is an indictable offence. obligations under bus safety law.
Note

However, the offence may be heard and determined summarily (see section
28 of the Criminal Procedure Act 2009).

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
Section 1—Legislation Page 10
Risk

Risk is the effect of uncertainty

on organisational objectives.

What does risk mean?

Risks relate to the concept of uncertainty on objectives. In bus safety, this
relates to the uncertainties that can affect the safety of bus operations.
Such ‘events’ are called ‘hazards’ in this guidance material.

Risk management
Risk management is the process of identifying what can go wrong (identify
the risk) and the ways in which you control it so that the risk is eliminated or
reduced.

A good risk management process demonstrates thorough reasoned and

supported arguments that a person or organisation could not have reasonably
reduced the risks any further. For all decisions relating to risks to safety, use an
open and transparent process and record all details. Importantly, adopt a clear
and well-documented decision process to ensure a consistent approach.

Can you measure risk?

Yes! You can measure risk using a combination of the consequences of an event
and their likelihood. That is:

Risk = consequence x likelihood

This is useful because different events can affect our safety. It is important
to address all risks, but common sense must prevail. Also, we need a process
to measure risk so we can address the highest risk first.
 Suggested framework Page 11

for risk management

Gather people Step

together who are
TSV suggests the use of an eight-
knowledgeable
about the process. step risk management framework
as shown in Figure 1. This document
details each step of this framework.
Case studies and examples show how
to follow these steps (in terms of the
type and level of detail that may be
Identify hazards— Step Identify the Step
what can go wrong? causes—how does
appropriate for documentation).
the hazard happen?

Identify the Step Determine the Step

consequences— likelihood—how often
what will happen if does the hazard (for
the hazard occurs? all instances) occur?

Determine the ‘risk Step

Document and review

ranking’ where risk

= consequence x
likelihood

Identify control measures Step

a) already in place and
b) new measures available
using the control ‘checklist’

Summarise why your Step

risks are reduced or
eliminated SFAIRP.

Figure 1. The eight-step process.

Bus safety – your responsibility
Practical guidance for Victoria’s bus industry
 Section 1—Legislation Page 12
Explaining the framework
with legislative requirements

s14 (2) (c)

Gather people Step Figure 2 shows how this framework
together who are relates to the relevant requirements
knowledgeable
under the Bus Safety Act 2009 (Vic).
about the process.
The Bus Safety Act 2009 (Vic) requires
you to eliminate risks to safety and, if
s14 (2) (a), s14 (2) (b) that is not reasonably practicable, to
reduce those risks SFAIRP, considering
the following five factors:
Identify hazards— Step Identify the Step
what can go wrong? causes—how does 1. The likelihood of the hazard or
the hazard happen? risk concerned eventuating.

2. The degree of harm that would

result if the hazard or risk
eventuated.

Step Step 3. What the person concerned

Identify the Determine the
consequences— likelihood—how often knows, or ought reasonably to
what will happen if does the hazard (for know, about the hazard or risk
the hazard occurs? all instances) occur? and any ways of eliminating or
reducing the hazard or risk.

4. The availability and suitability of

Determine the ‘risk
ranking’ where risk
= consequence x
likelihood
ways to eliminate or reduce the
Step hazard or risk.
5. The cost of eliminating or
reducing the hazard or risk.

These factors are discussed on the

following pages.
s14 (2) (c)
s14 (2) (d) Identify control measures Step
s14 (2) (e) a) already in place and
b) new measures available
using the control ‘checklist’

Summarise why your Step

risks are reduced or
eliminated SFAIRP.

Figure 2
 Page 13

s14 (2) (a), s14 (2) (b)

This involves identifying the hazards
or what can go wrong (see Step 2, 3 Identify hazards— Step Identify the Step
and 4 in Figure 3) and how likely the what can go wrong? causes—how does
the hazard happen?
hazard may be or how often it might
occur (likelihood) (Step 5).

Typically, hazards include:

 collisions with other vehicles
 a runaway bus
Identify the Step Determine the Step
 projectiles thrown at buses. consequences— likelihood—how often
Safety consequences (degree of harm) what will happen if does the hazard (for
include: the hazard occurs? all instances) occur?

 injuries
 fatalities.
Figure 3

Tip: Review the hazards in

Appendix A: Hazards and
causes associated with bus
operations to see if they
apply to your operations.

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
 Section 1—Legislation Page 14

What the person concerned knows, or

ought reasonably to know, about the hazard
or risk and any ways of eliminating or
reducing the hazard or risk.

s14 (2) (c) There are two parts to this factor:

Gather people Step 1. What you ought to reasonably
together who are know about the hazard or risk
knowledgeable
about the process. This takes into account the
information available to you when
completing risk assessments and
making judgements/decisions. It is
s14 (2) (c) important to have people who:
s14 (2) (d) Identify control measures Step  are knowledgeable about what
s14 (2) (e) a) already in place and
can go wrong and the ways in
b) new measures available
using the control ‘checklist’ which this can be controlled—that
is getting the right people together
to discuss the issues (Step 1).
Figure 4  can consider not only your
own experiences, but also the
Tip: To be effective: experiences and knowledge from
 Use knowledgeable people other bus operators, bus accidents
 Consider the experience of etc, especially if that information
other operators is publicly available.
 Consider all known controls.
2. What you ought to reasonably
know about any ways of
eliminating or reducing the
hazard or risk
This requires you to consider all
known control measures (Step 7)
available to you and could include
considering:
 What other operators are doing or
what is considered good practice
 Any other new control measure
available to you.
 Page 15

The availability and suitability of ways to

eliminate or reduce the hazard or risk

This is similar to the consideration in s14 (2) (c)

that it relates to the identification of s14 (2) (d) Identify control measures Step
all known control measures (Step 7). s14 (2) (e) a) already in place and
b) new measures available
Again, consider: using the control ‘checklist’
 What other operators are doing or
what is considered good practice
 Any other new control measure Figure 5
available to you.
Note: A control measure is a process, Tip: Consider all known controls.
device, practice or other action that
acts to minimise risk. That is, a way
to eliminate or reduce risk.

The identification of the available

and required levels of control to
reduce a risk is fundamental to
the SFAIRP process.

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
 Section 1—Legislation Page 16

The cost of eliminating or

reducing the hazard or risk
It is important to consider the cost of  the nature of the ‘danger’ (in terms Assuming occupational health and
a control in terms of effort, time and of factors 1 and 2) on the one safety cases are relevant to transport
money in Step 7 when assessing what hand, versus safety, this implies that you are
is reasonably practicable.  the nature of the measures to required to take all measures to
avoid it (including the expected risk eliminate or reduce your identified
In general, considering the five
reduction and likely cost (factors 4 risk, unless you can show that the cost
factors in total involves balancing
and 5) on the other. of the available measures are so high
the benefit of implementing a control
These court cases balance the compared to the risk that it would
measure versus its cost. Court cases
nature of the risk and the cost not be reasonable to expect you to
under occupational health and safety
of the requirements addressing implement them.
law have stressed that determining
what meets the SFAIRP standard the risk using the so-called ‘gross
involves a ‘value judgement’ of all the disproportion’ test. This means it Tip:
factors according to each particular is likely that a control measure is  Demonstrate low risk/very high cost
circumstance, based on the facts at ‘reasonably practicable’ unless the to fix + gross disproportion = not
that time, and would consider: cost of addressing a risk is so much reasonably practicable
higher than the risk as to be greatly  Demonstrate caution with costs
‘disproportionate’ (see Figure 6).  Consider negative and positive
costs, as there may be some
savings due to a control.

Figure 6

Proportional—
reasonably practical
Costs/time/effort required in averting risk

Costs/time/effort required in averting risk

Gross disproportion
—not reasonably
practical
Risk

Risk
Things to consider Page 17

Document the risk Review the risk

assessment assessments
The ability to carry out a structured, Regularly review your risk
detailed and comprehensive process assessments to keep them up to date.
to identify all hazards and associated An appropriate team must review
risks arising from the operation risk assessments every time bus
of a bus service may be impaired operations change significantly.
without a written analysis. While the
Also, the ‘what you ought to know’
Bus Safety Act 2009 (Vic) does not
section regularly changes, so review
expressly require such an analysis,
and change your risk assessments,
TSV recommends that, in order to
as required. For example, if you
ensure your risk management process
become aware of a new hazard
is adequate, it be documented in
associated with your bus operations,
some form.
or learn about an incident from
Whatever form of documentation another operator that can affect
you adopt, you must demonstrate your operations, then review your
that it incorporates all of the steps to risk assessments and document
eliminate/reduce all risks SFAIRP. The any changes.
documentation must detail a thorough
Note: Be aware that the reasons for
and detailed risk management
rejecting a control may change—
process. Appendix A—provides
it may become easier/cheaper to
examples of different ways to
implement over time.
document an assessment:
 Example 1—a risk register for bus
collision with car
 Example 2—a narrative for bus
collision with car
 Example 3—a matrix for bus
collision with car.

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
section

Safety steps

Important: Use knowledgeable people.

Important: Get advice—use technical experts if needed.

Important: Use categories that make sense to you.

Important: Be consistent with ratings.

 Section 1—Legislation Page 20
Step
Gather people who are
knowledgeable about the process
Why is this important?
The purpose of this step is to ensure
that all people involved in the
provision of a bus service have the
opportunity to be involved in the
planning and implementation of risk
management processes. Stakeholder
consultation (with affected parties)
can greatly assist you to obtain a
proper understanding of the hazards.
How do I do it?
Ideally, get a team together who have
a comprehensive understanding of
your operations and bus systems,
including the behaviour of technical
components, how workers behave and
the operating environment.
People who should participate
include management and bus safety
workers such as supervisors, drivers
and maintainers. Relevant technical
advisors such as human factors and
risk assessment specialists may also
be involved, where appropriate.

It is important to involve bus safety
workers because hazards may not be
visible to management but frontline
workers understand them. In addition,
employees can have a significant
impact on safety because of their
behaviour, attitude and competence
in carrying out any safety-related
role. Therefore the involvement of
appropriate employees (or their
representatives) in risk identification
enhances their awareness of these
issues and is critical to achieving safe
operation in practice.
You may also need to engage with
external parties (e.g. contractors
or other operators). For example,
if you operate in conjunction with
other bus companies, and your
operations affect theirs, seek the best
practicable safety outcome through
the principles of shared responsibility
and participation/consultation.

Step
Identify the hazards
Why is this important?
The purpose of this step is to
identify all hazards in a logical and
transparent way.
What is a hazard?
Hazards, in this guidance material,
are events that can affect our safety.
Examples of hazards in the bus
industry include:
 collisions with other vehicles
 a runaway bus
 projectiles thrown at buses.
More examples of hazards
associated with bus operations are
in Appendix A: Hazards and causes
associated with bus operations.
Page 21
How do I do it?
To identify hazards, either: Note: The obligation to ensure safety
SFAIRP is not avoided because a
 Review the list in Appendix A:
hazard has not been identified. If it is
Hazards and causes associated
considered reasonable for an operator
with bus operations to see
to be aware of the hazard, then the
whether they apply to your
operator should have demonstrated
operations
that it has ensured safety SFAIRP.
 Identify your own hazards using the
methods described in Appendix B:
Hazard identification techniques.
In either case, make sure your list
is complete and does not miss any
hazards. It is important to include all
hazards, including:
 The most likely
 Those in an emergency
 The worst credible
 Those occurring during
maintenance activities
 Those occurring in normal and
abnormal or non-routine operations
 Those associated with change, both
temporary and permanent.
Bus safety – your responsibility
Practical guidance for Victoria’s bus industry
 Section 1—Legislation Page 22
Step
Identify the causes
Why is this important?
The purpose of this step is to
identify all hazards and their
associated causes in a logical
and transparent way.
What is a cause?
A cause is the way in which a hazard
occurs. Causes of hazards can include:
 equipment faults
 people making errors of judgement
 environmental conditions.
How do I do it?
To identify the cause of a hazard,
either:
 Review the list in Appendix A:
Hazards and causes associated
with bus operations to see
whether they apply to your
operations
 Identify your own causes for
your hazards using the methods
described in Appendix B: Hazard
identification techniques.
As with Step 1, it is important to:
 identify all causes
 review your list
 check that you have the full set of
hazards/causes.
Note: To identify causes effectively:
 Use knowledgeable people
 Get advice
 Use technical experts, if needed.
Important: Ask yourself—how does the hazard happen?
There are a variety of ways to identify
causes including:
 Learning from accidents or
incidents from:
 your organisation
 other bus operators
(similar to you)
 safety alerts published by TSV
 international experience.
 Analysis of failures and
investigations including failure
of technical components as
well as human errors/violations.
For example, the inspection/
maintenance schedule may also
identify a component (control)
that regularly fails, or you may find
that a certain situation can make
people prone to making mistakes or
encourage them not to comply with
rules and procedures.
 Analysis of near-miss situations
 Audits and inspections
 Conducting a task analysis may
help identify causes, if it relates
to human actions. For example,
a bus driver could fail to interpret
a stop signal correctly, which leads
to a collision at an intersection.
The task analysis may help identify
the aspects that lead to the driver
making the mistake.

Step
Identify the consequences
Why is this important?
The purpose of this step is to
recognise all consequences relating
to hazards.
What is a consequence?
Consequences with respect to safety
relate to the degree of harm to
people (passengers, worker groups,
members of the public) and may
involve injuries or fatalities. Note that
risk assessment can apply to broader
aspects of business and could include
risks to property (bus equipment/
road infrastructure/private property),
reputation and finances. However, the
focus of the Bus Safety Act 2009 (Vic)
is on risks to safety only.
How do I measure it?
To measure consequence, identify
the consequence if a hazard occurs
due to a cause. It may be easier to
categorise consequences into bands
to differentiate between low and high
consequences, for example:
Ranking Consequence
1 Minor injury
2 Major injury
3 Multiple major injuries
4 Single fatality
5 Multiple fatalities
Page 23
When ranking consequences:
 Do not to underestimate the
consequence. Underestimating
a consequence may rank the risk
lower than it actually is. If you are
not sure which category a hazard
falls in you should choose the most
serious consequence.
 Consider all potential outcomes.
For example, a low-speed collision
may result in minor injuries, but
there is still a potential for multiple
fatalities and injuries in certain
circumstances.
 Consider consequence with controls
in place and ensure that the
controls are actually in place and
working as expected. That is, test
and/or prove the reliability of the
control to avoid underestimating
the ranking.
Bus safety – your responsibility
Practical guidance for Victoria’s bus industry
 Section 1—Legislation Page 24

Step
Determine the likelihood

Why is this important? What is the likelihood? How do I measure it?

The purpose of this step is to decide This is the chance or frequency To measure likelihood, it may be
how likely a hazard may be or how that the hazard, due to the cause, easier to categorise likelihood into
often it might occur. may occur. bands to differentiate between low
and high consequences. For example:

Ranking Likelihood
4 Definitely will occur

3 Likely to occur

2 Unlikely to occur

1 Won’t occur

Do not underestimate the likelihood,

as it may rank the risk lower than it
actually is. If you are not sure which
category a hazard falls in take a more
conservative approach.

Note: To determine likelihood:

 Use knowledgeable people
 Get advice. Use technical experts,
if needed.
 Use categories that make sense to
you
 Be consistent with ratings.
 Page 25

Step
Determine the risk score

Why is this important? What is the risk score? How do I do it?

The purpose of this step is to allow
you to:
 understand the risk ranking
of the hazards
 identify the highest risks.
A risk score is the translation of an
assessment of likelihood and the
consequence. Risk is determined by
multiplying the consequence (Step 4)
with the likelihood (Step 5) to identify
the ‘risk ranking’.
Table 1 shows an example of a risk
assessment matrix, which is a tool
that combines consequence and
likelihood to identify the ‘risk score‘
or risk ranking.

This allows you to:
 compare hazards (if you have
applied the method consistently)
 identify the highest risk scores
 prioritise risk management
activities.
Note: There are many different types
of risk assessment matrices available.
Some examples are in Appendix C:
Examples of risk assessment
matrices.

Risk Assessment Matrix—Safety

Consequence
1 2 3 4 5
Injuries or ailments Number of minor Number of One fatality and or/ Numerous fatalities
not requiring medical injuries not requiring injuries, requiring significant number and/or serious
treatment hospitalisation hospitalisation of injuries requiring injuries
hospitalisation
5 Once a day Low Medium High Extreme Extreme
4 Once a week Low Medium High High Extreme
3 Once a month Low Medium Medium High High
2 Once a year Low Low Medium Medium Medium
Likelihood

1 Once every 10
years Low Low Low Low Low

Table 1: Risk Assessment Matrix—Safety

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
 Section 1—Legislation Page 26

Step
Identify control measures

Why is this important? What is a control?

This purpose of this step is to ensure
safety SFAIRP, as it establishes the
measures intended to eliminate or
reduce risks.
You must be able to show how
you considered controls that could
reduce the level of risk, including
a comprehensive assessment of all
potential controls that could improve
safety.
A control measure is a process,
device, practice or other action that
acts to minimise risk. It is a way to
eliminate or reduce risk. Possible
controls include:
 physical equipment
 management processes
 personnel procedures.
Their actions must:
 Eliminate the underlying hazard.
This is the most effective control
measure and is preferred, if
reasonably practicable. For
example, change a bus route to
avoid a hazardous situation, such
as a passive level crossing or an
unsealed road.
 Substitute the hazard with a less
hazardous one. For example,
replace a hazardous substance with
a safer one.

Preventative
If Control A fails there are two
others in place (B & C) to prevent
the cause from happening.

Cause A
B
C
Hazard

Figure 7. Multiple controls ensure protection if one control fails.

 Page 27

 Isolate (or separate) the hazard. Ideally, there needs to be multiple

For example, isolate (or limit) (independent) controls to ensure
bus operations in areas of high that protection is still available if
pedestrian traffic. one control fails when required.
 Use engineering controls. For (See Figure 7.)
example, provide automatic sensors
to detect if there are obstructions
in the door space.
 Use administrative controls. For
example, improve driver training.
 Use personal protective equipment.
For example, provide specialist
clothing.

Mitigative
If Control D fails there are two
others in place (E & F) to manage
the consequenses.

CONSEQUENCE
F
E
D

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
 Section 2—Safety Steps Page 28

Identify any other

How do I do it?
Good hazard management requires:
 Competent people
 Ensure that all relevant
personnel are aware of, and
understand, their responsibilities
and duties
 Consider their experience,
knowledge, motivation etc and
need for supervision.
 Safe work practices
 Document activities, procedures,
work instructions etc and
ensure they correctly reflect the
actions required
 Ensure that relevant personnel
are aware of, and understand,
their responsibilities and duties.
 Fit for purpose equipment and
materials
 Provide the right tools and
equipment in order to perform
work safely—including warning
devices, if there are limitations
of equipment.
 A controlled work environment
Note: The number and integrity of
controls must reflect the level of risk.
For example, a high-risk hazard must
have a number of effective controls in
place to manage the hazard.
When considering controls, always:
 Document the controls already
in place for every cause and
consequence identified.
 Aim to identify ‘preventative
controls’ first, then ‘mitigative
controls.’ It makes sense to prevent
events from happening before
they lead to a hazard, so consider
controls that may prevent a hazard
happening. Then consider controls,
if the hazard does happen. These
are ‘mitigative controls’ to manage
the consequences.
 Consider how effective the control
is. Use the Control Checklist in
Table 2 to evaluate your controls. It
is important that controls are:
 effective in reducing risk
 reliable (that is, likely to be
alternative controls available
To identify any new controls, consider
best practice, current standards
and industry knowledge (including
engineering equipment and latest
managerial actions). Examples
of additional measures include
inspections that are more frequent or
changing the staff roster to reduce
fatigue. Again, use the Control
Checklist in Table 2 to evaluate
these new controls and consider
how effective they are.
Note: If you need to construct or
include any new equipment, ensure
that the design and construction
meets the most current best practice
code or standards, if this is reasonably
practicable in light of all the
circumstances.
d work envi
e
ll Competent People r
on
ro

Selection, experience,
 Control the physical conditions
men
available on demand)
Cont

motivation supervision
of the work location, such as  suitable to the climatic
Fit for
SAFE Safe
t

noise, temperature, vibration etc conditions or operating purpose work

equipment ACTIVITIES practices
 Control the management environment. Right tools, Documented
activities, including work Important: TSV may ask for machinery, procedures,
warning work plans
on.

schedules, information,
Ma

evidence to see that these controls devices

ati
na

loc
ge

communication etc. wo Phy

th e
r.
Wo
rk

are in place and that they are

d:

rk sica
s che l: noise, lighting, wea tion.
dule er a
effective. For example, you may s, comm -op
unication, co
prove the reliability of controls with
maintenance records (function tests). Figure 8. Good hazard management.
 Page 29

When considering the cost of the

Control Checklist—Consider: control, estimate costs in terms of all
Is the control effective at reducing the risk? If not, it could be argued that this is not a good costs associated with the:
control.
 initial purchase
Is the control reliable? For example, is it likely to be available on demand?  installation, maintenance and
Is the control suitable to the climatic conditions or operating environment? For example, the tyres operation of the control measure
fitted are not suitable for snow conditions.  lost time involved, for example if
Is the control compatible with existing systems or operating requirements? For example, a control
a bus is out of service while fitting
may distract a driver from other duties or it may interfere with the operation of the vehicle. a component
 trouble of installing, operating
Does the employee understand the policy or procedure and can it be shown that they followed it
correctly?
and maintaining the control, for
example the impact on productivity.
What happens if this control fails? For example, if a component on the bus fails, if an individual
does not apply policy or procedure properly, etc. When introducing controls, consider
any potential savings in terms of:
If the control relates to a referenced standard e.g. AS/NZS Standard or Code of Practice, is it  fewer accidents (and the cost
applied in the right way?
savings associated with these)
Do any controls rely on other systems? For example, a component may not function if it does not  improved productivity
have a power supply, and the component does not fail in a safe position (fail-safe).
 reduced maintenance costs etc.
Does the control prevent other causes or hazards? For example, if this control fails, could it lead
to the realisation of another hazard? Rejecting controls
Are there any new hazards if a new control is implemented? For example, introducing an You can reject any controls if they are
automated system may affect the competency of the bus driver (for example, they may become not reasonably practical. However you
less alert). must provide reasons for the rejection.
Are there new standards/codes, systems or technologies that offer new ways to control risks? When you undertake your next
review, review the rejected controls
Is it relevant good practice? For example:
as the reasons for the rejection may
Is it established practice in Victoria or another comparable jurisdiction (in Australia or change. For example, it may become
internationally, in light of the scale and operation of the Victorian industry)? significantly easier to implement.
Does the control demonstrably improve safety in its current application? Also, there may be controls that
Note: The definition of good practice changes over time (for example, due to increased require further evaluation or review.
knowledge of hazards, changes in technology etc). For these controls, assign a person
Conduct a regular review of current good practice and exercise professional judgement to and a finish date for the review in
interpret this information. order to track progress.
Table 2: Control checklist

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
 Section 2—Safety Steps Page 30
Prioritising controls
Use your judgement to determine
whether the safety benefits
of implementing the control
outweigh the sacrifice. Due to
the costs involved, prioritise the
implementation of controls and
provide your reasons for this
prioritisation.
Assuming occupational health and
safety cases are relevant (given
the similarity in the wording of the
legislation and objective of ensuring
safety), consider the magnitude of the
‘danger’ against the cost, time and
effort associated with the measures
that could address it according to the
‘gross disproportion’ test.
In particular, this means that:
 A measure is not reasonably
practicable if the sacrifices or costs
grossly outweigh the risk benefit.
For example, spending $1 million to
prevent five staff suffering bruising
is clearly ‘grossly disproportionate’.
 If the measure is practicable
and the cost of the measure is
not ‘grossly disproportionate’
to the expected benefit, then
the measure is considered
reasonably practicable and should
be implemented. For example,
spending $1 million to prevent a
Feel like you have been
climbing a mountain?
major bus crash capable of killing If this feels overwhelming:
50 people is clearly proportionate.  Start at the top. That is, with risks
 If a reasonably practicable control ranked ‘extreme’ and work your
is not affordable, then avoid the way down
activity that gives rise to that  Focus on those events that could
hazard or risk. lead to serious consequences. For
 The documentation of your example, fatalities, serious injuries
analysis and any assumptions or injuries requiring hospitalisation
relating to costs or risk benefit is  Ensure that the number and
recommended, as this significantly integrity of controls reflect the level
affects the robustness of the of risk. For example, extreme, high
outcome. and medium ranked risks must have
a number of effective controls in
 The lowest risk option is generally
place to manage the hazard. If one
preferred, but if this is not the case,
control fails, then there is another
provide reasons why the higher
available to prevent or mitigate
risk level is as low as reasonably
the risk.
practicable.
 If there are available options for
eliminating or reducing a risk that
achieve the same level of reduction
in likelihood or degree of harm,
choose the least costly option.
However, choosing a low-cost
option that provides less protection
simply because it is cheaper
is unlikely to be a reasonably
practicable means of eliminating
or reducing risk.
Until safety duties under Victoria’s
bus safety legislation are tested
directly in the courts, uncertainty
remains as to the correct
legal approach.
 Page 31

Step
Summarise SFAIRP

If possible, summarise your reasons If a process or practice involves more

why you believe you have eliminated complex scenarios or there is some
or reduced your risks SFAIRP. If you uncertainty about the hazard—such
understand a hazard well—that is, as new engineering practices or
it is established practice, there is management principles that are not
nothing new or unusual, or there are as well established—further analysis
no major stakeholder implications— may be required.
show the reduction in risk SFAIRP if:
This may include increased reliance on
 The controls in place meet and
risk-based assessments (for example,
apply all recognised codes and
quantitative risk assessment, cost
standards. Use of engineering,
benefit analysis), although codes
operational or maintenance
and standards, good practices and
codes and standards etc may
engineering judgement remain
form grounds for demonstrating
significant. Organisation values may
safety is ensured SFAIRP. However,
also be influential. For very novel or
this ultimately depends on the
challenging decisions, consider the
circumstances of the case and how
values set by your organisation or
the code/standard is applied.
society. Organisation and societal
 Good practice in terms of
values tend to have the most
considering new or alternative
influence on the decision basis,
known controls has been adopted
with supporting information from risk-
or considered.
based approaches and engineering
 Competent personnel, using judgement.
effective engineering knowledge,
have evaluated the hazard and
associated risk.
 Your organisation can validate
and prove the effectiveness and
availability of the controls.

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
Appendix

Hazards & Causes

 azards and causes associated
H Page 33

with bus operations

The following hazards are suggestions

and are not an exhaustive list. However, it
may be helpful to review the following and
consider whether these hazards are relevant
to your bus operations.

Reminder: A hazard is an event that can affect safety

Reminder: A cause is the way in which a hazard occurs

Reminder: C = Consequence rating from matrix

Reminder: L = Likelihood rating from matrix

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
Appendix A—Hazards & Causes Page 34

Hazard: Collision with train at a level crossing

Does it apply? C L Risk = C x L Priority
Mechanical failure (e.g. run out of fuel, fuel starvation, breakdown on
Equipment

crossing)
Poor bus fit out (e.g. driver’s vision restricted)
Bus driver does not obey signal (e.g. flashing lights)
Bus shunted into track
Driver fatigue or inattention
Driver queued over crossing
Driver error (e.g. driver does not see train)
Complacency within area (e.g. reliance on no changes to train timetable/
timetable accuracy)
Person

Bus driver distracted internal/external

Inadequate driver control (e.g. missed gear, stalled bus, change gear on
crossing)
Excessive bus speed for approach to level crossing
Bus driver incapacity (e.g. medical issues, alcohol or drugs, fatigue)
Bus driver trying to beat train
Multiple trains: bus driver unaware
Crossing not considered safe to cross due to layout of level crossing
Environment

Weather conditions (snow, high winds, fog, poor visibility)

Poor road conditions cause bus to stop in rail corridor
Poor vision of cargo wagons including unlit wagons
Train into crossing before booms activated
Other
 Page 35

Hazard: Collision with other (tram, other bus, car, truck, bike, animal)
Does it apply? C L Risk = C x L Priority
Mechanical failure
Equipment

Wrong vehicle type for road

Excessive speed from either vehicle

Bus driver inattention
Strike by other vehicle (e.g. other driver distracted)
Road rage
Person

Bus driver incapacity (e.g. medical issues, alcohol or drugs, fatigue)

Assault on driver while driving
Passenger intervention (e.g. steering wheel)
Performance requirements to meet contractual arrangements (e.g.
timetables)
Road design/surface, including road works
Traffic management signalling infrastructure e.g. inadequate sequencing
of lights
Weather conditions (snow, high winds, fog) (e.g. motorcyclist slips on wet
road)
Traffic density and type (e.g. log trucks, rural traffic, quarry roads, narrow
Environment

roads)
Time of day (e.g. milk trucks, peak hour)
Poor segregation (e.g. mismatch of vehicle types, road works, cycle lanes)
Cyclists/trucks/road hogging
Poor road signage
Cyclist caught in tram tracks
Loss of traction due to poor road surface
Other

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
Appendix A—Hazards & Causes Page 36

Hazard: Bus crash and rollover

Does it apply? C L Priority
Poor bus fit out (e.g. no snow chains)
Equipment

Mechanical failure (e.g. axle sheared)

Vehicle not suitable for road conditions
Excessive speed
Driver competency, skill route knowledge (e.g. inadequate training)
Driver error (e.g. braking too hard)
Distraction (e.g. other tasks)
Person

Bus overloaded/mis-loaded
Strike by other vehicle or object or evasive action
Passenger interference
Bus driver incapacity (e.g. medical issues, alcohol or drugs, fatigue)
Road design/surface including roadworks
Environment

Poor road signage/warnings

Roadside collapse including washaway
Weather conditions (snow, high winds, fog, poor visibility)
Load shift
Other
 Page 37

Hazard: Bus crash as it strikes off-road object

Does it apply? C L Risk = C x L
Mechanical failure
Equipment

Failure of component due to poor maintenance

Mismatch of vehicle for road (e.g. dirt roads)
Evasive action
Person

Bus size awareness by driver

Poor maintenance roadside conditions, including trees and vegetation
DDA structures
Environment

Road structure changed (e.g. road bumps)

Low bridge, structures, low hanging trees
Poor road infrastructure
Fallen tree due to extreme weather
Other

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
Appendix A—Hazards & Causes Page 38

Hazard: Person struck by bus

Does it apply? C L Risk = C x L
Poor location and design of bus stop (e.g. person required to step out onto road to hail
bus, poor visibility around parked bus)
Equipment

Mechanical failure (e.g. brake failure)

Poor bus fit out (e.g. driver’s vision restricted)
Person distraction/inattention internal/external
Driver distraction/inattention internal/external e.g. driver interference
Bus reverses into person
Passenger falls from bus (e.g. window/door)
Person

Parental influence (e.g. parking and calling children)

Driver error (e.g. not checking mirrors before driving off)
Excessive speed
Passenger interference
Person makes an error e.g. disobey warning sign
Weather conditions (snow, high winds, fog) (e.g. poor visibility)
Environment

Bus on angle at stop restricting vision

Time of day—twilight (poor visibility)
Vehicles parked alongside bus stops
Bus livery/paint scheme blends into background
Other
 Page 39

Hazard: Person struck by other vehicle when alighting

Does it apply? C L Risk = C x L
Mechanical failure (e.g. car loss of control)
Equipment

Poor location and design of bus stop including inadequate signs/warnings

Bus driver alcohol, drugs or fatigue

Passenger distraction/inattention internal/external
Other driver distraction/inattention internal/external
Person

Passenger forces door when closed

Passenger falls from bus (e.g. window/door)
Parental influence (e.g. parking and calling children)
Lack of awareness by the public of bus movement and traffic flow
Poor road traffic control around bus
Environment

Unapproved stopping place (e.g. failing to follow road safety rules)

Inconsistency between states/territories (e.g. bus movement rules)

Environmental conditions (e.g. dark, sunset, shadows, silhouettes)
Passing motorists
Other

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
Appendix A—Hazards & Causes Page 40

Hazard: Projectile at bus

Does it apply? C L Risk = C x L
Tyre explosion
Equipment

Projectile from other vehicle or plant

Public behaviour e.g. brick thrown off bridge

Person

Availability of projectiles
Environment

Poorly maintained infrastructure e.g. failing coping stone on bridges

Poor road surface

Other
 Page 41

Hazard: Fire
Does it apply? C L Risk = C x L
Flat tyre

Internal fire (e.g. fuel line)

Equipment

Motorised mobility devices

Poor design/construction/maintenance failure (e.g. friction on looms)

Passenger carrying hazardous material

Poor public or other behaviour (e.g. arson, sabotage)

Person

Driver error (e.g. overspill of oil engine block (maintenance error))

Maintenance error

External fire source (e.g. grass fire)

Environment

Collision and ignition (e.g. fuel tanker)

Lightning strike

Sun glare ignites combustible item

Other

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
Appendix A—Hazards & Causes Page 42

Hazard: Hazardous material release

Does it apply? C L Risk = C x L
Mobility device batteries

Bus battery
Equipment

Leak of fuel

Hybrid bus, electrical and petrochemical LPG uncontrolled mix

Passenger carrying hazardous material

factors
Human

Commercial freight carriage (uncontrolled mixes)

Environment
Other
 Page 43

Hazard: Passenger stranded

Does it apply? C L Risk = C x L

Breakdown in hazardous environment (e.g. desert, fire, freeway)
Equipment

Bus full passenger left behind

Driver error (route/info change/competency)

Driver ejects passenger in an inappropriate area

Person

Driver drops passenger off in inappropriate area

Parents/other not at destination

Environment

Bushfires/snow/flood cancel school runs

Other

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
Appendix

Hazard identification
Hazard identification techniques Page 45

There are a variety of ways to identify
hazards including:
Brainstorming—What If
In a group, discuss what can go
wrong (What If X happened and What
If Y happened) and how to manage
it. Remember to clearly define the
boundaries of the problem and be
open to discussing all ideas.
This technique is a flexible, creative
examination of an operation for
potential hazards. Team members are
encouraged to ask ‘What-If’ questions
in a logical way. Be careful with this
approach as it may miss hazards, but
for simple systems or operations as
few as one or two people can conduct
the analysis.
Checklist analysis
Complete a list of hazards known
to you and review the list in a
group to see if it is applicable to
your operations. Make sure the
list is complete and does not miss
any hazards.
Combined What If/ Safety audits
Checklist Analysis Review the information gathered
The creative, flexible, brainstorming from your audits to see if a theme is
nature of a ‘What If’ analysis can reoccurring. It may indicate something
be combined with the advantage of is not working the way it should.
the systematic, structured approach External assistance (for example, a
of a Checklist analysis. This method risk assessment facilitator) may be
makes the most of the strengths of required for this and subsequent steps
the two methods while compensating to identify and assess all hazards.
for the shortcomings of the individual
methods. The Checklist analysis,
being an experience-based technique,
may miss hazards if the checklist is
not complete.
The ‘What If’ analysis encourages the
team to consider potential hazards
not covered in the checklist. The
checklist portion of the analysis lends
a more structured and systematic
nature to the ‘What If’ analysis.
The checklists used in the What If/
Checklist analysis are somewhat more
general than conventional checklists
used in Checklist analysis. A combined
What If/Checklist analysis is more
a powerful tool than a Checklist on
its own.

These checklists are developed for a

specific operation and are regarded
as living documents that need to
be audited and updated regularly,
with recent applicable operating
experiences being incorporated after
a formal review. Using a checklist
gives you a structured and systematic
process, but it is of limited use in
uncovering unique, unexpected or
unlikely hazards.

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
Appendix

Risk assessment
Examples of risk assessment matrices Page 47

Qualitative
Examples of qualitative risk matrices
are in the Risk Management
Guidelines Companion to AS/NZS
4360:2004, and are below:

Consequence
Minor Major
Medium Risk High Risk
Probable
Likelihood

Low Risk Medium Risk

Improbable

Consequence
Major Moderate Minor
Likely High High Medium
Likelihood

Possible High Medium Low

Unlikely Medium Low Low

Qualitative assessments tend to

suit low consequence or well-
understood hazards that do not
result in catastrophic consequences.
It is difficult to compare hazards,
as a scale is not generally used and
workshop participants estimate risk
and apply judgement, therefore
there is potential for uncertainty.
Qualitative assessments are good for
identifying reputation risks.

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
 Appendix C—Risk Assessment Page 48

Consequence
Multiple major
Minor injury Major injury injuries Single fatality Multiple fatalities
1 2 3 4 5
Definitely will occur Low Medium High Extreme Extreme
4 4 8 12 16 20
Likely to occur Low Medium High High Extreme
3 3 6 9 12 15
Unlikely to occur Low Medium Medium High High
2 2 4 6 8 10
Likelihood

Won’t occur Low Low Medium Medium Medium

1 1 2 3 4 5

Semi-quantitative
Semi-quantitative assessments tend
to suit well-understood or known
hazards where the consequences
may be more severe.
A typical semi-quantitative matrix
may be a 3 x 3 matrix to a 6 x 6 matrix
and applies quantitative statements
(e.g. 1 in 10 years) with risks defined
as either qualitative statements or in
numerical form (‘high’ or 5 x 5= ‘25’).
It is more precise than a qualitative
assessment, but not as detailed as a
fully quantitative assessment.
 Page 49

Consequence
Medical Lost time Disabling
No harm reportable injury injury Fatality
1 2 3 4 5
Almost 1 a day Expected in most A
certain circumstances M H H E E

Likely 1 a week Will probably occur B M M H H E

Possible 1 a month Might occur at C
some time L M M H E

Unlikely 1 a year Could occur but D

doubtful L M M H H
Likelihood

Rare 1 in 10, May occur but E

years exceptionally L L M M H

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
 Appendix C—Risk Assessment
Likelihood ratings
Rating
5 Almost certain
4 Likely
3 Moderate
2 Unlikely
1 Rare
Consequence ratings
Rating Description
5 Fundamental
4 Major
3 Moderate
2 Minor
1 Insignificant
Page 50
Once a year or more frequently
Once every 10 years
Once every 100 years
Once every 1,000 years
Once every 10,000 years
Numerous fatalities and/or serious Multiple fatalities or significant irreversible effects to >50 people
injuries
A fatality and/or significant
number of injuries requiring
hospitalisation
Considerable number of injuries
Number of light injuries not
requiring hospitalisation
Injuries or ailments not requiring
medical treatment
The event occurs on an annual basis
The event has occurred several times or more in this company
The event has occurred in this company
Have heard of something like this happening elsewhere
Theoretically possible but not expected to occur
Single fatality and/or severe disability (>30%) to one or more
persons
Moderate irreversible disability (<30%) to one or more persons
Reversible disability requiring hospitalisation
No medical treatment required

Quantitative
Quantitative assessment tends to
suit complex or novel hazards. It
provides a framework/structure to
compare risk, and tests assumptions
and uncertainties. While being more
rigorous, it is also a much more
resource-intensive exercise.
Quantitative assessments can
evaluate whether to implement
a control measure (including
an analysis of risk benefit if the
measure is applied).
Page 51
Typically, quantitative assessments
use failure rate data to estimate
frequency and modelling to
estimate consequence. Examples of
quantitative assessments include
event tree analysis, fault tree analysis,
layers of protection assessments
and bowtie analysis etc. Fault trees
and event trees show the chain of
events and the impact if controls
fail (escalation).
Bus safety – your responsibility
Practical guidance for Victoria’s bus industry
Appendix

Further reading
Further reading for risk management Page 53

You may want to refer to the following

documents, published by Standards Australia,
relating to risk management:
 AS/NZS 4360:2004: The document AS/NZS ISO
Risk Management 31000:2009: Risk Management is
 HB 436: 2004 Risk Management a further development of AS/NZS
Guidelines Companion to AS/NZS 4360:2004, which any business,
4360:2004 ISBN 0 7337 5960 2 organisation, group or individual
can use. It supersedes AS/NZS
 AS/NZS ISO 31000:2009: Risk
4360:2004 but is built on the
Management—Principles and
processes described in the superseded
Guidelines ISBN 0 7337 9289 8
standard. It provides generic guidance
The document AS/NZS 4360:2004:
and promotes the development
Risk Management provides
of an integrated standard for
generic guidance for establishing
risk management.
and implementing effective risk
management processes in any
organisation. It demonstrates how to
establish the proper context, and then
how to identify, analyse, evaluate,
treat, communicate and monitor risks.

Bus safety – your responsibility

Practical guidance for Victoria’s bus industry
Page 54
Disclaimer

This publication provides general

information about the ‘so far as
is reasonably practicable’ test in
transport safety legislation. While the
materials seek to summarise current
understandings of the ‘so far as is
reasonably practicable’ test, they
provide practical assistance only
and should not be relied upon as a
substitute for the relevant legislation,
legal or professional advice.
Bus safety – your responsibility
Practical guidance for Victoria’s bus industry
So far as is
reasonably
practicable

Hotline 03 9655 8922

www.transportsafety.vic.gov.au
information@transportsafety.vic.gov.au