This is the paper submitted by Mike Dean to the RISK2014 conference held in Brisbane 28-30th May 2014.  The  paper explains why conformity to the relevant standards for functional safety does not necessarily ensure compliance with WHS obligations for SFAIRP risk reduction measures.  By extension other engineering design processes that employ explicit tolerable risk thresholds also do not necessarily ensure compliance with WHS obligations for SFAIRP risk reduction measures.  The paper also rebuts some recent commentary that: (a)  ALARP and SFAIRP are different concepts and (b) the Model WHS Act has introduced new due diligence obligations on engineers.