ERICPD (Part 2) – Refocusing on first principles for safety in the energy transition

ERICPD helps bring order to the complex world of risk control. But in the fast-moving energy transition it can also become a trap: a neat checklist that distracts from deeper questions. ERICPD asks, “How can we eliminate or control this hazard we have identified?” It does not ask, “How should the approach to design, work, and organisation evolve to prevent it?”. This article argues that navigating the future of safety requires looking beyond the mnemonic and returning to the Principles of Prevention as the strategic compass. ERICPD is a valuable tool, but first principles must guide the direction of travel.

This is the second article of a two-part series exploring ERICPD’s role in the energy transition

Introduction

In the first article of this series (Ref. 1), we introduce ERICPD (said simply as “Eric P D”) as a specific application of the more general hierarchy of risk controls (HORC). We clarify the meaning and purpose of each tier to support ERICPD’s consistent use across energy transition sectors.

In this second article we compare the clarified ERICPD with the UK HSE’s “Principles of Prevention” and highlight its limitations. Whilst ERICPD provides a simplified framework for applying the fundamental principles, it should be seen as an aid – not a replacement. An over-focus on any one specific tool, however refined, risks exceeding the limits of the tool and potentially obscuring the fundamental goal.

To ensure a safe and successful energy transition, navigating novel risks requires going beyond any single tool such as ERICPD and refocusing on the first principles for safety.

BEYOND ERICPD – WHY ONE TOOL IS NOT ENOUGH

The safety landscape of the energy transition is shaped by a variety of risk control frameworks. Some organisations may take a one-size-fits-all approach to safety, where a model like ERICPD is applied without fully considering the wider issues of managing safety risks.

While it is helpful to clarify frameworks like ERICPD for modern contexts, an over-focus on any single tool could obscure the deeper, foundational principles of safety that should guide risk management. This is especially important as novel risks emerge in energy transition sectors. The core objective is always to achieve the highest practicable level of safety.

The Strategic Compass – The principles of prevention

The truly fundamental control requirements are not found in ERICPD or other hierarchies, although these are valuable tools. They are explicitly mandated under UK law, primarily within the Management of Health and Safety at Work Regulations 1999 (Ref. 2) and CDM Regulations 2015 (Ref. 3). These are the “General Principles of Prevention” (GPP):

• a. avoiding risks;
• b. evaluating the risks which cannot be avoided;
• c. combating the risks at source;
• d. adapting the work to the individual, especially as regards the design of workplaces, the choice of work equipment and the choice of working and production methods, with a view, in particular, to alleviating monotonous work and work at a predetermined work-rate and to reducing their effect on health;
• e. adapting to technical progress;
• f. replacing the dangerous by the non-dangerous or the less dangerous;
• g. developing a coherent overall prevention policy which covers technology, organisation of work, working conditions, social relationships and the influence of factors relating to the working environment;
• h. giving collective protective measures priority over individual protective measures; and
• i. giving appropriate instructions to employees.

These nine principles provide the strategic compass to navigate safety (Figure 1).

Figure 1 – The nine General Principles of Prevention (GPP)

Comparing ERICPD with the Principles of Prevention

A comparison between ERICPD and the GPP is summarised in Table 1 and expanded further below.

Table 1 – Comparison of ERICPD and GPP

Purpose

ERICPD is a useful implementation tool – it helps practitioners select and apply risk controls in the right order (from elimination to discipline). Embodied in UK law, the HSE’s GPP are the strategic compass – they ask whether the right risks are being tackled, whether the organisation is learning and adapting, and whether systems are designed safely, considering people, from the start.

Focus

ERICPD focuses narrowly on how to control hazards once identified – it is about prioritising specific measures. The GPP, however, ask deeper, strategic questions:

• Have the risks been avoided altogether rather than controlled (principle A)? Whilst elimination in ERICPD is a design action to remove a hazard once considered or present, the principle of avoiding risk is a strategic decision taken at the conceptual stage to not create the hazard at all. The distinction between the two is subtle, as effective elimination during early design can, in practice, achieve the same outcome. However, the use of the term avoid in the GPP explicitly emphasises preventing the creation of risk in the first place – before the need for any control arises.
• Are we combating the risk at source rather than managing its effects (principle C)?
• How does the organisation’s overall prevention policy integrate technology, work organisation, and social factors (principle G)?

In other words, ERICPD, as a hierarchy of risk control, helps to decide what control measure to apply, including making design changes to eliminate a hazard, while the principles ask whether that control is even necessary or whether the hazard should exist at all.

Substitution and design thinking

ERICPD addresses substitution only indirectly within reduce, encouraging risk minimisation. The GPP go further, requiring a deliberate search for inherently safer alternatives:

• Are there different substances, materials, or processes that remove or decrease the danger present (principle F)?

Where ERICPD guides the choice of control measures, the GPP drive innovation, ensuring risk is challenged at its source rather than managed after creation.

Human factors and work design

ERICPD only lightly touches human behaviour through discipline. The GPP go much further by asking:

• Has the work been adapted to the individual (principle D)?
• Are design choices avoiding monotonous or overly demanding work that could degrade safety performance (principle D)?
• Are instructions and training tailored to human capabilities and limitations (principle I)?

These require consideration of ergonomics, psychology, and organisational design – dimensions that ERICPD does not explicitly address.

Continuous improvement and technical progress

ERICPD is static: once controls are selected, it does not prompt periodic reassessment. The GPP, however, demand reflection and progress:

• Are we adapting to technical progress (principle E)?
• Could new technologies or materials make existing controls obsolete or less effective?

This principle ensures safety management evolves rather than remaining locked to historical controls.

Integration and coherence

ERICPD treats controls as discrete layers. The GPP demand a coherent prevention policy:

• How do technology, work organisation, and social relationships interact to affect risk (principle G)?
• Are control measures complementary, or do they conflict?

This ensures safety is not a checklist but a system-wide objective integrated with management decisions.

Prioritisation of collective protection

ERICPD correctly places PPE at the bottom of physical controls, but the GPP explicitly require collective protective measures to take precedence over individual ones, reflecting the greater reliability and sustainability of system-level solutions:

• Have collective protective measures been prioritised over individual ones (principle H)?
• Are we relying too much on individual compliance rather than system design?

This reinforces ALARP’s preference for inherently safer and collective solutions.

Evaluation and review

ERICPD assumes hazards have been identified. The GPP begin earlier:

• Have the risks been evaluated (principle B)?
• Have the risks been re-evaluated considering new information (principle E)?
• Are evaluation methods robust, evidence-based, and updated as operations evolve?

This embeds critical reflection before controls are even considered.

IMPLEMENTING THE GENERAL PRINCIPLES OF PREVENTION

Implementing the GPP on a new energy transition project, whether an offshore wind farm, onshore solar array, battery energy storage system, or hydrogen facility, requires embedding them directly into the Design Risk Management (DRM) process from the earliest stage. The principles provide the legal and philosophical foundation for risk reduction, ensuring that hazards are avoided, minimised, or controlled so far as is reasonably practicable.

A robust DRM process translates these principles into action by driving systematic identification, treatment, and management of risk throughout the design and build phases. This integration ensures that prevention is not a retrospective activity, but a design intent woven into every technical and organisational decision.

Within this process, ERICPD serves as a practical tool to guide the selection and prioritisation of risk control measures. During design workshops and day-to-day design activities, ERICPD provides a memorable framework – eliminate, reduce, isolate, control, PPE, and discipline – that helps engineers and designers challenge assumptions, structure discussions, and justify decisions in line with the ALARP principle. It supports teams in determining whether hazards can be designed out, reduced through engineering solutions, or, where unavoidable, controlled and managed through robust procedures and training.

However, ERICPD alone is not sufficient. It must operate alongside complementary DRM tools such as risk assessment matrices, human factors engineering, management of change, and competency assurance. Together, these methods provide the analytical depth and cross-disciplinary insight needed to ensure that the design addresses technical, human, and organisational risks comprehensively.

The outcome of this integrated approach is an asset that is safe-by-design (SBD) – one that inherently eliminates or reduces hazards at source, incorporates collective protection measures, and embodies the continuous improvement ethos central to the principles of prevention.

Conclusion

Refining ERICPD enhances its utility as a practical control hierarchy tool for diverse energy applications. However, true safety robustness, especially amidst the innovation of the energy transition, requires looking beyond any one tool.

The GPP are the immutable first principles – UK legal requirements and global safety fundamentals. They provide the objectives against which all risk management strategies must be measured.

By rigorously applying these principles through a comprehensive DRM process, asking fundamental questions, and demanding clear alignment with them, organisations can move beyond the narrow interpretations of individual tools. This ensures we are not simply applying controls but actively achieving the highest practicable level of safety and demonstrating ALARP with confidence.

In doing so, we strengthen our ability to manage the novel and interconnected risks that define the future of energy. Tools like ERICPD remain essential, but they must never obscure the fundamental goals

References

1. Cairn Risk. Refining ERICPD (Part 1) – A clearer guide to risk control in the energy transition.
2. Health and Safety Executive (HSE). Management of Health and Safety at Work Regulations 1999 (MHSWR). Regulation 4: Principles of prevention.
   https://www.legislation.gov.uk/uksi/1999/3242/regulation/4
3. Health and Safety Executive (HSE). The Construction (Design and Management) Regulations 2015.
   https://www.legislation.gov.uk/uksi/2015/51/contents