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Mil-Std-882E Safety Analysis

System of Systems Hazard Analysis

In this full-length (38-minute) session, The Safety Artisan looks at System of Systems Hazard Analysis, or SoSHA, which is Task 209 in Mil-Std-882E. SoSHA analyses collections of systems, which are often put together to create a new capability, which is enabled by human brokering between the different systems. We explore the aim, description, and contracting requirements of this Task, and an extended example to illustrate SoSHA. (We refer to other lessons for special techniques for Human Factors analysis.)

This is the seven-minute demo version of the full 38-minute video.

System of Systems Hazard Analysis: Topics

  • System of Systems (SoS) HA Purpose;
  • Task Description (2 slides);
  • Documentation (2 slides);
  • Contracting (2 slides);
  • Example (7 slides); and
  • Summary.

Transcript: System of Systems Hazard Analysis

Click here for the Transcript

Introduction

Hello everyone and welcome to the Safety Artisan. I’m Simon and today we’re going to be talking about System of Systems Hazard Analysis – a bit of a mouthful that. What does it actually mean? Well, we shall see.

System of Systems Hazard Analysis

So, for Systems of Systems Hazard Analysis, we’re using task 209 as the description of what to do taken from a military standard, 882E. But to be honest, it doesn’t really matter whether you’re doing a military system or a civil system, whatever it might be – if you’ve got a system of systems, then this will help you to do it.

Topics for this Session

Looking at what we’ve got coming up.

So, we look at the purpose of system of systems – and by the way, if you’re wondering what that is what I’m talking about is when we take different things that we’ve developed elsewhere, e.g. platforms, electronic systems, whatever it might be, and we put them together. Usually, with humans gluing the system together somewhere, it must be said, to make it all tick and fit together. Then we want this collection of systems to do something new, to give us some new capability, that we didn’t have before. So, that’s what I’m talking about when I say a system of systems. I’ll show you an example – it’s the best way. So, we’ve got a couple of slides on task description, a couple of slides or documentation, and a couple of slides on contracting. Tasks 209 is a very short task, and therefore I’ve decided to go through an example.

So, we’ve got seven slides of an example of a system of systems, safety case, and safety case report that I wrote. And hopefully, that will illustrate far better than just reading out the description. And that will also give us some issues that can emerge with systems of systems and I’ll summarize those at the end.

SOSHA Purpose

So, let’s get on. I’m going to call it the SOSHA for short; Systems of Systems Hazard Analysis. The purpose of the SOSHA, task 209, is to document or perform and document the analysis of the system of systems and identify unique system of systems hazards. So, things we don’t get from each system in isolation. This task is going to produce special requirements to deal with these hazards, which otherwise would not exist. Because until we put the things together and start using them for something new – We’ve not done this before.

Task Description (T209) #1

Task description: As in all of these tasks, the contractor shall perform and document an analysis of the system of systems to identify hazards and mitigation requirements. A big part of this, as I said earlier, we tend to use people to glue these collections, these portfolios, of systems together and humans are fantastic at doing that. Not always the ideal way of doing it, but sometimes it’s the only way of doing it within the constraints that we’ve got. The human is very important. The human will receive inputs from one or more systems and initiate outputs within the analysis and in fact within the real world, to be honest, which is what we’re trying to analyse. That’s probably a better way of looking at it.

And we’ve got to provide traceability of all those hazards to – it says – architecture locations, interfaces, data and stakeholders associated with the hazard. This is particularly important because with a system of systems each system tends to come with its own set of stakeholders, its own physical location, its own interfaces, etc, etc. The issue of managing all of those extraneous things and getting the traceability, it goes up. It is multiplied with every system you’ve got. In fact, I would say it was the square of. The example we’ll see: we’ve got three systems being put together in a system of systems and, in effect, we had nine times the amount of work in that area, I would say. I think that’s a reasonable approximation.

Task Description (T209) #2

Part two of the task description: The contractor will assess the risk of each hazard and recommend mitigation measures to eliminate the hazards. Or, very often, we can’t eliminate the hazards to reduce the associated risks. Then, as always with this standard, it says we’re going to use tables one, two and three, which are the severity, probability and the risk matrix that comes with the standard. Unless, of course, we have created or tailored our own matrix. Which we very often should do but it isn’t often done – I’ll have to do a session on how to do tailoring a matrix.

Then the contractor has got to verify and validate the effectiveness of those recommended mitigation measures. Now, that’s a really good point and I often see that missed. People come up with control measures or mitigation measures but don’t always assess how effective they’re going to be. Sometimes you can’t so we just have to be conservative but it’s not always done as well as it could be.

Documentation (T209) #1

So, let’s move on. Documentation: So, whoever does the analysis- the standard assumes it’s a contractor – shall document the results to include: you’ve got to describe the system of systems, the physical and functional characteristics of the system of systems, which is very important. Capturing these things is not a given. It’s not easy when you’ve got one system, but when you’ve got multiple systems, some of which are being misused to do something they’ve never done before, perhaps, then you’ve got to take extra care.

Then basically it says when you get more detail of the individual systems you need to supply that when it becomes available. Again, that’s important. And not only if the contractor supplies it, who’s going to check it? Who’s going to verify it? Etc., etc.

Documentation (T209) #2

Slide two on documentation: We’ve got to describe the hazard analysis methods and techniques used, providing a description of each method and technique used, and the assumptions and the data used in support. This is important because I’ve seen lots of times where you get a hazard analysis’ results and you only get the results. It’s impossible to verify those results or validate them to say whether they’ve been done in the correct context. And it’s impossible to say whether the results are complete or whether they’re up to date or even whether they were analysing the correct system because often systems come in different versions. So, how do you know that the version being analysed was the version you’re actually going to use? Without that description, you don’t know. So, it’s important to contract for these things.

And then hazard analysis results. What contents and formats do you want? It’s important to say. Also, we’re going to be looking to put the key items, the leading particular’s, from the results. The top-level results are going to go into the hazard tracking system which is more commonly known as a hazard log or a risk register, whatever it might be. Might be an Excel spreadsheet, might be a very fancy database, but whatever it’s going to be you’re going to have to standardize your fields of what things mean. Otherwise, you’re going to have – the data is going to be a mess and a poor quality and not very usable. So, again, you’ve got a contract for these things upfront and make sure you make clear definitions and say what you want.

Contracting #1

Contracting; implicitly, we’ve been talking about contracting already, but this is what a standard says. So, the request for proposal or statement of work has got to include the following. Typically we have an RFP before we’ve got a contract, so we need to have worked out what we need really early in the program or project, which isn’t always done very well. To work out what you need the customer, the purchaser, has probably got to do some analysis of their own in order to work all this stuff out. And I know I say this every time with these tasks, but it is so important. You can’t just dump everything on the contractor and expect them to produce good results because often the contractor is hamstrung. If you haven’t done your homework to help them do their work, then you’re going to get poor results and it’s not their fault.

So, we’ve got to impose the requirement for the task if we want it or need it. We’ve got to identify the functional disciplines. So, which specialists are going to do this work? Because very often the safety team are generalists. They do not have specialist technical knowledge in some of these areas. Or maybe they are not human factor specialists. We need somebody in, some human factor specialists, some user representatives, people who understand how the system will be used in real life and what the real-world constraints are. We need those stakeholders involved – That’s very important. We’ve got to identify those architectures and systems which make up the SOS -very important. The concept of operations. SOS is very much about giving capability. So, it’s all about what are you going to do with the whole thing when you put it together? How’s all that going to work?

Contracting #2

Interesting one, E, which is unique, I think, to task 209, what are the locations of the different systems and how far apart are they? We might be dealing with systems where the distance between them is so great that transmission time becomes an issue for energy or communications. Let’s say you’re bouncing a signal from an aircraft or a drone around the world via a couple of satellites back to home base. There could be a significant lag in communications. So, we need to understand all of these things because they might give rise to hazards or reduce the effectiveness of controls.

Part F; what analysis, methods, techniques do you want to use? And any special data to be used? Again, with these collections of systems that becomes more difficult to specify and more important. And then do we have any specific hazard management requirements? For example, are we using standard definitions and risk matrix from a standard or have we got our own? That all needs to be communicated.

Example #1

So, that is the totality of the task. As you can see, there’s not much to Task 209, so I thought it would be much more helpful to use an example, an illustration, and as they used to say in children’s TV, “Here’s one I made earlier” because a few years ago I had to produce a safety case report. I was the safety case report writer, and there was a small team of us generating the evidence, doing the analysis for the safety case itself.

What we were asked to do is to assure the safety of a system and – in fact, it was two systems but I just treat it as one – of a system for guiding aircraft onto ships in bad weather. So, all of these things existed beforehand. The aircraft were already in service. The ships were already in service. Some of the systems were already in service, but we were putting them together in a new combination. So, we had to take into account human factors. That was very important. We’ll see why in just a moment.

The operating environment, which was quite demanding. So, the whole point is to get the aircraft safely back to the ships in bad weather. They could do it in good weather you could do it visually, but in bad weather, visual wasn’t going to cut it. So, the operating environment- we were being asked to operate in a much more difficult environment. So, that changed everything and drove everything.

We’ve got to consider operating procedures because, as we’re about to see, people are gluing the systems together. So, how do they make it work? And also got to think about maintenance and management. Although in actual fact, we didn’t really consider maintenance and management that much. As an ex-maintainer, this annoys me, but the truth is people are much more focused on getting their capability and service. Often, they think about support as an afterthought. We’ll talk about that one day.

Example #2

Here’s a little demonstration of our system of systems. Bottom right-hand corner, we’ve got the ship with lots of people on the ship. So, if the aircraft crashes into it that could be bad news, not just for the people in the aircraft, but for the people on the ship – big risks there!

We’ve got our radar mounted on the ship so the ship is supplying the radar with power and control and data, telling it where to point for example. Also, the ship might be inadvertently interfering with the radar. There are lots of other electronic systems on the ship. There are bits of the ship getting in the way of the radar, depending on where you’ve put it, and so on and so forth. So, the ship interacts with the radar, the radar interacts with the ship, radars producing radiation. Could that be doing anything to the ship systems?

And then the radar is being operated. Now, I think that symbol is meant to indicate a DJ, but we’ve got the DJ wearing headphones and we got a disk there but it looks like a radar scope to me. So, I’ve just hijacked that. That’s the radar operator who is going to talk to the pilot and give the pilot verbal commands to guide them safely back to the ship. So, that’s how the system works.

In an ideal world, the ship would use the radar and then talk electronically direct to the aircraft and guide it – maybe automatically? That would be a much more sensible setup. In fact, that’s often the way it’s done. But in this particular case, we had to produce a bit of a – I hesitate to call it a lash-up because it was a multi-million-dollar project, but it was a bit of a lash-up.

So, there is the human factors. We’ve got a radar operator doing quite a difficult job and a pilot doing a very difficult job trying to guide their aircraft back onto the ship in bad weather. How are they going to interact and perform? And then lastly, as I alluded to earlier, the aircraft and the ship do actually interact in a limited way. But of course, it’s a physical interaction, so you can actually hurt people and of course, if we get it wrong, the aircraft interacts with the surface of the ocean, which is very bad indeed for the aircraft. So, we’ve got to be careful there. So, there’s a little illustration of our system of systems.

Example #3

And – this is the top-level argument that we came up with – it’s in goal structuring notation. But don’t worry too much about that – We’ll have a session on how to do GSN another time.

So, our top goal, or claim if you like, is that our system of systems is adequately safe for the aircraft to locate and approach the ship. So, that’s a very basic, very simple statement, but of course, the devil is in the detail and all of that detail we call the context. So, surrounding that top goal or claim, we’ve got descriptions of the system, of the aircraft and the ship. We got a definition of what we mean by adequately safe and we’ve got safety targets and reporting requirements.

So, what supports the top goal? We’ve got a strategy and after a lot of consultation and designing the safety argument, we came up with a strategy where we said, “We are going to show that all elements of the system of systems are safe and all the interactions are safe”. To do that, we had to come up with a scope and some assumptions to underpin that as well to simplify things. Again, they sit in the context, we just keep the essence of the argument down the middle.

And then underneath, we’ve got four subgoals. We aim to show that each system equipment is safe to operate, so it’s ready to be operated safely. Then each one is safe in operation so it can be operated safely with real people, etc. And then we’ve got all system safety requirements are satisfied for the whole collection of stuff and then finally that all interactions are safe. So, if we can argue all four of those, we should have covered everything. Now, I suspect if I did this again today, I might do it slightly differently. Maybe a little bit more elegantly, but that’s not the point. The point is, we came up with this and it worked.

Example #4

So, I’m going to unpack each one very briefly, just to illustrate some points. First of all, each component system is safe to operate. Each of these systems, bar one, had all been purchased already, sometimes a long time ago. They all came with their own safety targets, their own risk matrices, etc, etc. So, we had to make sure that when an individual system said, “This is what we’ve got to achieve” that that was good enough for the overall system of systems. So, we had to make sure that each system met its own safety requirements and targets and that they were valid in context.

Now, you would think that double-checking existing systems would be a foregone conclusion. In reality, we discovered that the ship’s communication system and its combat data system were not as robust as assumed. We discovered some practical issues were reported by stakeholders and we also discovered some flaws in previous analysis that had been accepted a long time ago. Now, in the end, those problems didn’t change the price of fish, as we say. It didn’t make a difference to the overall system of systems.

The frailty of the ship’s comms got sorted out and we discovered it didn’t actually matter about the combat system. So, we just assumed that the data coming out of the combat system was garbage and it didn’t make any difference. However, we did upset a few stakeholders along the way. So beware, people don’t like discovering that a system that they thought was “tickety-boo” was not as good as they thought.

Example #5

The second goal was to show that the system of systems is safe in operation. So, we looked at the actual performance. We looked at test results of the radar and then also we were very fortunate that trials of the radar on the ship with aircraft were carried out and we were able to look at those trials reports. And once again, it emerged that the system in the real world wasn’t operating quite as intended, or quite as people had assumed that it would. It wasn’t performing as well. So, that was an issue. I can’t say any more about that but these things happen.

Also, a big part of the project was we included the human element. So, as I’ve said before, we had pilots and we had radar air traffic talk-down operators. So, we brought in some human factors specialists. They captured the procedures and tasks that the pilots and the radar operators had to perform. They captured them with what’s called a Hierarchical Task Analysis, they did some analysis of the tasks and what could go wrong. Then they created a model of what the humans were doing and ran it through a simulation several thousand times. So in that way, they did some performance modelling.

Now, they couldn’t give us an absolute figure on workload or anything like that but what they could do – fortunately, our new system was replacing an older system which was even more informally cobbled together than the one that we were we were bringing in. And so, the Human Factor specialists were able to compare human performance in the old system vs. human performance with the new system. Very fortunately, we were pleased to find out that the predicted performance was far better with the new system. The new system was much easier to operate for both the pilots and the talk-down radar operators. So, that was terrific.

Example #6

So, the third one; All system of systems safety requirements are satisfied. Now, this is a bit more nebulous, this goal, but what it really came down to was when you put things together, very often you get what’s called emergent behaviour. As in things start to happen that you didn’t expect or you didn’t predict based on the individual pieces. It’s the saying, two plus two equals five. You get more out of a system – you get synergy for good or ill out when you start putting different things together.

So, does the whole thing actually work? And broadly speaking, the answer was yes, it works very well. There were some issues, a good example the old radar that they used to use to talk the planes down was a search radar so the operator could see other traffic apart from the plane they were they were guiding in. Now, the operator being able to see other things is both good and bad because on the one hand gives them improved situational awareness so they can warn off traffic if it’s a collision situation develops. But also, it’s bad because it’s a distraction for the operator. So, it could have gone either way.

So, the new radar was specialized. It focused only on the aircraft being talked down. So, the operator was blind to other traffic. So that was great in terms of decreasing operator workload and ultimately pilot workload as well. But would this increase the collision risk with other traffic? And I’ll talk about that in the summary briefly.

Example #7

And then our final goal is to show that all interactions are safe between the guidance system, the aircraft and the ship. This was a non-trivial exercise because ships have large numbers of electronic systems and there’s a very involved process to go through to check that a new piece of kit doesn’t interfere with anything else or vice versa.

And also, of course, does the new electronic system/the new radar does the radiation effect ship? Because you’ve got weapons on the ship and some of those explosive devices that the weapons uses are electrically initiated. So, could the radiation set off an explosion? So, all of those things had to be checked. And that’s a very specialized area.

And then we’ve got, does the system interfere with the aircraft and the aircraft with the system? What about the integration of the ship and the aircraft and the aircraft to the ship? Yet another specialized area where there’s a particular way of doing things. And of course, the aircraft people want to protect the aircraft and the ship people want to protect the ship. So, getting those two to marry up is also another one of those non-trivial exercises I keep referring to but it all worked out in the end.

Summary

Points to note: When we’re doing system of systems – I’ve got five points here, you can probably work some more points out from what I’ve said for yourself – but we’re putting together disparate systems. They’re different systems. They’ve been procured by different organizations, possibly, to do different things. The stakeholders who bought them and care about them have got different aims and objectives. They’ve got different agendas to each other. So, getting everyone to play nicely in the zoo can be challenging. And even with somebody pulling it all together at the top to say “This has got to work. Get with the program, folks!” there’s still some friction.

Particularly, you end up with large numbers of stakeholders. For example, we would have regular safety meetings, but I don’t think we ever had two meetings in a row with exactly the same attendees because with a large group of people, people are always changing over and things move up. And that can be a challenge in itself. We need to include the human in the loop in systems of systems because typically that’s how we get them all to play together. We rely on human beings to do a lot of translation work and in effect. So, how do the systems cope?

A classic mistake really with systems design is to design a difficult-to-operate system and then just expect the operator to cope. That can be from things as seemingly trivial as amusement park rides – I did a lesson on learning lessons from an amusement park ride accident only a month or two ago and even there it was a very complex system for two operators, neither of whom had total authority over the system or to be honest, really had the full picture of what was going on. As a result, there were several dead bodies. So, how did the operators cope, and have we done enough to support them? That’s a big issue with a system of systems.

Thirdly, this is always true with safety analysis, but especially so with system of systems. The real-world performance is important. You can do all the analysis in the world making certain assumptions and the analysis can look fine, but in the real world, it’s not so simple. We have to do analysis that assumes the kit works as advertised because you’ve got nothing else to go on until you get the test results and you don’t get them until towards the end of the program. So, you’re going down a path, assuming that things work, that they do what they say on the tin, and perhaps you then discover they don’t do what they say on the tin. Or they don’t do everything they say on a tin. Or they do what they say and they do some other things that you weren’t expecting as well and then you’ve got to deal with those issues.

And then fourthly, somewhat related to what I’ve just talked about, but you put systems together in an informal way, perhaps, and then you discover how they actually get on – what really happens. In reality, once you get above a certain level of complexity, you’re not really going to discover all the emergent behaviours and consequences until you get things into service and it’s clocked up a bit of time in service under different conditions in the real world. In fact, that was the case with this and I think with a system of systems, you’ve just got to assume that it’s sufficiently complex that that is the case.

Now, that’s not an unsolvable problem but, of course, how do you contract for that? Where you’ve got your contractors wanting you to accept their kit and pay them at a certain date or a certain point in the program, but you’re not going to find out whether it all truly works until it’s got into service and been in service for a while. So, how do you incentivize the contractor to do a good job or indeed to correct defects in a timely manner? That’s quite a challenge for system systems and it’s something that needs thinking about upfront.

And then finally, I’ve said, remember the bigger picture. It’s very easy when you’re doing analysis and you’ve made certain assumptions and you set the scope, it’s very easy to get fixated on that scope and on those assumptions and forget the real world is out there and is unpredictable. We had lots of examples of that on this program. We had the ship’s comms that didn’t always work properly, we couldn’t rely on the combat system, the radar in the real world didn’t operate as well as it said in the spec, etc, etc. There were lots of these things.

And, one example I mentioned was that with the new radar, the radar operator does not see any traffic other than the aircraft that is being guided in. So, there’s a loss of situational awareness there and there’s a risk, maybe an increased risk, of collision with other traffic. And that actually led to a disagreement in our team because some people who had got quite fixated on the analysis and didn’t like the suggestion that maybe they’d missed something. Although it was never put in those terms, that’s the way they took it. So, we need to be careful of egos. We might think we’ve done a fantastic analysis and we’ve produced hundreds of pages of data and fault trees or whatever it might be but that doesn’t mean that our analysis has captured everything or that it’s completely captured what goes on in the real world because that’s very difficult to do with such a complex system of systems.

So, we need to be aware of the bigger picture, even if it’s only just qualitatively. Somebody, a little voice, piping up somewhere saying, “What about this? And we thought about that? I know we’re ignoring this because we’ve been told to but is that the right thing to do?” And sometimes it’s good to be reminded of those things and we need to remember the big picture.

Copyright Statement

Anyway, I’ve talked for long enough. It just remains for me to point out that all the text in quotations, in italics, is from the military standard, which is copyright free but this presentation is copyright of the Safety Artisan. As I’m recording this, it’s the 5th of September 2020.

For More …

And so if you want more, please do subscribe to the Safety Artisan channel on YouTube and you can see the link there, but just search for Safety Artisan in YouTube and you’ll find us. So, subscribe there to get free video lessons and also free previews of paid content. And then for all lessons, both paid and free, and other resources on safety topics please visit the Safety Artisan at www.safetyartisan.com/  where I hope you’ll find much more good stuff that you find helpful and enjoyable.

End: System of Systems Hazard Analysis

So, that is the end of the presentation and it just remains for me to say thanks very much for watching and listening. It’s been good to spend some time with you and I look forward to talking to you next time about environmental analysis, which is Task 210 in the military standard. That’ll be next month, but until then, goodbye.

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Start Here Work Health and Safety

Introduction to WHS Codes of Practice

In the 30-minute session, we introduce Australian WHS Codes of Practice (CoP). We cover: What they are and how to use them; their Limitations; we List (Federal) codes; provide Further commentary; and Where to get more information. This session is a useful prerequisite to all the other sessions on CoP.

Codes of Practice: Topics

  • What they are and how to use them;
  • Limitations;
  • List of CoP (Federal);
  • Further commentary; and
  • Where to get more information.

Codes of Practice: Transcript

Click Here for the Transcript

Hello and welcome to the Safety Artisan, where you will find professional, pragmatic, and impartial teaching and resources on all thing’s safety. I’m Simon and today is the 16th of August 2020. Welcome to the show.

Introduction

So, today we’re going to be talking about Codes of Practice. In fact, we’re going to be introducing Codes of Practice and the whole concept of what they are and what they do.

Topics for this Session

What we’re going to cover is what Codes of Practice are and how to use them – several slides on that; a brief word on their limitations; a list of federal codes of practice – and I’ll explain why I’m emphasizing it’s the list of federal ones; some further commentary and where to get more information. So, all useful stuff I hope.

CoP are Guidance

So, Codes of Practice come in the work, health and safety hierarchy below the act and regulations. So, at the top you’ve got the WHS Act, then you’ve got the WTS regulations, which the act calls up. And then you’ve got the Codes of Practice, which also the act calls up. We’ll see that in a moment. And what Codes of Practice do are they provide practical guidance on how to achieve the standards of work, health and safety required under the WHS act and regulations, and some effective ways to identify and manage risks. So, they’re guidance but as we’ll see in a moment, they’re much more than guidance. So, as I said, the Codes of Practice are called up by the act and they’re approved and signed off by the relevant minister. So, they are a legislative instrument.

Now, a quick footnote. These words, by the way, are in the introduction to every Code of Practice. There’s a little note here that says we’re required to consider all risks associated with work, not just for those risks that have associated codes of practice. So, we can’t hide behind that. We’ve got to think about everything. There are codes of practice for several things, but not everything. Not by a long way.

…Guidance We Should Follow

Now, there are three reasons why Codes of Practice are a bit more than just guidance. So, first of all, they are admissible in court proceedings. Secondly, they are evidence of what is known about a hazard, risk, risk assessment, risk control. And thirdly, courts may rely, or regulators may rely, on Codes of Practice to determine what is reasonably practicable in the circumstances to which the code applies. So, what’s the significance of that?

So first of all, the issue about being admissible. If you’re unfortunate enough to go to court and be accused of failing under WHS law, then you will be able to appeal to a Code of Practice in your defence and say, “I complied with the Code of Practice”. They are admissible in court proceedings. However, beyond that, all bets are off. It’s the court that decides what is anadmissible defence, and that means lawyers decide, not engineers. Now, given that you’re in court and the incident has already happened a lot of the engineering stuff that we do about predicting the probability of things is no longer relevant. The accident has happened. Somebody has got hurt. All these probability arguments are dust in your in the wake of the accident. So, Codes of Practice are a reliable defence.

Secondly, the bit about evidence of what is known is significant, because when we’re talking about what is reasonably practicable, the definition of reasonably practicable in Section 18 of the WHS act talks about what it is reasonable or what should have been known when people were anticipating the risk and managing it. Now, given that Codes of Practice were published back in 2012, there’s no excuse for not having read them. So, they’re pre –existing, they’re clearly relevant, the law has said that they’re admissible in court. We should have read them, and we should have acted upon them. And there’ll be no wriggling out of that. So, if we haven’t done something that CoP guided us to do, we’re going to look very vulnerable in court.  Or in the whatever court of judgment we’re up against, whether it be public opinion or trial by media or whatever it is.

And thirdly, some CoP can be used to help determine what is SOFARP. So in some circumstances, if you’re dealing with a risk that’s described a CoP, CoP is applicable. Then if you followed everything in CoP, then you might be able to claim that just doing that means that you’ve managed the risk SFARP. Why is that important? Because the only way we are legally allowed to expose people to risk is if we have eliminated or minimized that risk so far as is reasonably practicable, SFARP. That is the key test, the acid test, of “Have we met our risk management obligations? “And CoP are useful, maybe crucial, in two different ways for determining what is SFARP. So yes, they’re guidance but it’s guidance that we ignore at our peril.

Standards & Good Practice

So, moving on. Codes of Practice recognize, and I reemphasize this is in the introduction to every code of practice, they’re not the only way of doing things. There isn’t a CoP for everything under the sun. So, codes recognize that you can achieve compliance with WHS obligations by using another method as long as it provides an equivalent or higher standard of work, health and safety than the code. It’s important to recognize that Codes of Practice are basic. They apply to every business and undertaking in Australia potentially. So, if you’re doing something more sophisticated, then probably CoP on their own are not enough. They’re not good enough.

And in my day job as a consultant, that’s the kind of stuff we do. We do planes, trains and automobiles. We do ships and submarines. We do nuclear. We do infrastructure. We do all kinds of complex stuff for which there are standards and recognized good practice which go way beyond the requirements of basic Codes of Practice. And many I would say, probably most, technical and industry safety standards and practices are more demanding than Codes of Practice. So, if you’re following an industry or technical standard that says “Here’s a risk management process”, then it’s likely that that will be far more detailed than the requirements that are in Codes of Practice.

And just a little note to say that for those of us who love numbers and quantitative safety analysis, what this statement about equivalent or higher standards of health and safety is talking about  –We want requirements that are more demanding and more rigorous or more detailed than CoP. Not that the end –result in the predicted probability of something happening is better than what you would get with CoP because nobody knows what you would get with CoP. That calculation hasn’t been done. So, don’t go down the rabbit hole of thinking “I’ve got a quantitatively demonstrate that what we’re doing is better than CoP.” You haven’t. It’s all about demonstrating the input requirements are more demanding rather than the output because that’s never been done for CoP. So, you’ve got no benchmark to measure against in output terms.

The primacy of WHS & Regulations

A quick point to note that Codes of Practice, they are only guidance. They do refer to relevant WHS act and regulations, the hard obligations, and we should not be relying solely on codes in place of what it says in the WHS Act or the regulations. So, we need to remember that codes are not a substitute for the act or the regs. Rather they are a useful introduction. WHS ACT and regulations are actually surprisingly clear and easy to read. But even so, there are 600 regulations. There are hundreds of sections of the WHS act. It’s a big read and not all of it is going to be relevant to every business, by a long way. So, if you see a CoP that clearly applies to something that you’re doing, start with the cop. It will lead you into the relevant parts of WHS act and regulations. If you don’t know them, have a read around in there around the stuff that – you’ve been given the pointer in the CoP, follow it up.

But also, CoP do represent a minimum level of knowledge that you should have. Again, start with CoP, don’t stop with them. So, go on a bit. Look at the authoritative information in the act and the regs and then see if there’s anything else that you need to do or need to consider. The CoP will get you started.

And then finally, it’s a reference for determining SOFARP. You won’t see anything other than the definition of reasonably practicable in the Act. You won’t see any practical guidance in the Act or the regulations on how to achieve SOFARP. Whereas CoP does give you a narrative that you can follow and understand and maybe even paraphrase if you need to in some safety documentation. So, they are useful for that. There’s also guidance on reasonably practicable, but we’ll come to that at the end.

Detailed Requirements

It’s worth mentioning that there are some detailed requirements in codes. Now, when I did this, I think I was looking at the risk management Code of Practice, which will go through later in another session. But in this example, there are this many requirements. So, every CoP has the statement “The words ‘must’, ‘requires’, or ‘mandatory’ indicate a legal requirement exists that must be complied with.” So, if you see ‘must’, ‘requires’, or ‘mandatory’, you’ve got to do it. And in this example CoP that I was looking at, there are 35 ‘must’s, 39 ‘required’ or ‘requirement’ – that kind of wording – and three instances of ‘mandatory’. Now, bearing in mind the sentence that introduces those things contains two instances of ‘must’ and one of ‘requires’ and one of ‘mandatory’. So, straight away you can ignore those four instances. But clearly, there are lots of instances here of ‘must’ and ‘require’ and a couple of ‘mandatory’.

Then we’ve got the word ‘should’ is used in this code to indicate a recommended course of action, while ‘may’ is used to indicate an optional course of action. So, the way I would suggest interpreting that and this is just my personal opinion – I have never seen any good guidance on this. If it says ‘recommended’, then personally I would do it unless I can justify there’s a good reason for not doing it. And if it said ‘optional’, then I would consider it. But I might discard it if I felt it wasn’t helpful or I felt there was a better way to do it. So, that would be my personal interpretation of how to approach those words. So, ‘recommended’ – do it unless you can justify not doing it. ‘Optional’ – Consider it, but you don’t have to do it.

And in this particular one, we’ve got 43 instances of ‘should’ and 82 of ‘may’. So, there’s a lot of detailed information in each CoP in order to consider. So, read them carefully and comply with them where you have to work and that will repay you. So, a positive way to look at it, CoP are there to help you. They’re there to make life easy for you. Read them, follow them. The negative way to look at them is, ”I don’t need to do all this says in CoP because it’s only guidance”. You can have that attitude if you want. If you’re in the dock or in the witness box in court, that’s not going to be a good look. Let’s move on.

Limitations of CoP

So, I’ve talked CoP up quite a lot; as you can tell, I’m a fan because I like anything that helps us do the job, but they do have limitations. I’ve said before that there’s a limited number of them and they’re pretty basic. First of all, it’s worth noting that there are two really generic Codes of Practice. First of all, there’s the one on risk management. And then secondly, there’s the one on communication, consultation and cooperation. And I’ll be doing sessions on both of those. Now, those apply to pretty much everything we do in the safety world. So, it’s essential that you read them no matter what you’re doing and comply with them where you have to.

Then there are other codes of practice that apply to specific activities or hazards, and some of them are very, very specific, like getting rid of asbestos, or welding, or spray painting – or whatever it might be – shock blasting. Those have clearly got a very narrow focus. So, you will know if you’re doing that stuff. So, if you are doing welding and clearly you need to read the welding CoP. If welding isn’t part of your business or undertaking, you can forget it.

However, overall, there are less than 25 Codes of Practice. I can’t be more precise for reasons that we will come to in a moment. So, there’s a relatively small number of CoP and they don’t cover complex things. They’re not going to help you design a super –duper widget or some software or anything like that. It’s not going to help you do anything complicated. Also, Codes of Practice tend to focus on the workplace, which is understandable. They’re not much help when it comes to design trade –offs. They’re great for the sort of foundational stuff. Yes, we have to do all of this stuff regardless. When you get to questions of, “How much is enough?” Sometimes in safety, we say, “How much margin do I need?” “How many layers of protection do I need?” “Have I done enough?” CoP aren’t going to be a lot of use helping you with that kind of determination but you do need to have made sure you’ve done everything CoP first and then start thinking about those trade –offs, would be my advice. You’re less likely to go wrong that way. So, start with your firm basis of what you have to do to comply and then think “What else could I do?”

List of CoP (Federal) #1

Now for information, you’ve got three slides here where we’ve got a list of the Codes of Practice that apply at the federal or Commonwealth level of government in Australia. So, at the top highlighted I’ve already mentioned the ‘how’ to manage WHS risks and the consultation, cooperation, and coordination codes. Then we get into stuff like abrasive, blasting, confined spaces, construction and demolition and excavation, first aid. So, quite a range of stuff, covered.

List of CoP (Federal) #2

Hazardous manual tasks – so basically human beings carrying and moving stuff. Managing and controlling asbestos, and removing it. Then we’ve got a couple on hazardous chemicals on this page, electrical risks, managing noise, preventing hearing loss, and stevedoring. There you go. So, if you’re into stevedoring, then this CoP is for you. The highlighted ones we’re going to cover in later sessions.

List of CoP (Federal) #3

Then we’ve got managing risk of Plant in the workplace. There was going to be a Code of Practice for the design of Plant, but that never saw the light of day so we’ve only got guidance on that. We’ve got falls, environment, work environment, and facilities. We’ve got another one on safety data sheets for another one on hazardous chemicals, preventing falls in housing – I guess because that’s very common accident – safe design of structures, spray painting and powder coating, and welding processes. So, those are the list of – I think it’s 24 – Codes of Practice are applied by Comcare, the federal regulator.

Commentary #1

Now, I’m being explicit about which regulator and which set of CoP, because they vary around Australia. Basically, the background was the model Codes of Practice were developed by Safe Work Australia, which is a national body. But those model Codes of Practice do not apply. Safe Work Australia is not a regulator. Codes of Practice are implemented or enforced by the federal government and by most states and territories. And it says with variations for a reason. Not all states and territories impose all codes of practice. For example, I live in South Australia and if you go and look at the WorkSafe South Australia website or Safe Work – whatever it’s called – you will see that there’s a couple of CoP that for some reason we don’t enforce in South Australia. Why? I do not know. But you do need to think about these things depending on where you’re operating.

It’s also worth saying that WHS is not implemented in every state in Australia. Western Australia currently have plans to implement WHS, but as of 2020 but I don’t believe they’ve done so yet. Hopefully, it’s coming soon. And Victoria, for some unknown reason, have decided they’re just not going to play ball with everybody else. They’ve got no plans to implement WHS that I can find online. They’re still using their old OHS legislation. It’s not a universal picture in Australia, thanks to our rather silly version of government that we have here in Australia – forget I said that. So, if it’s a Commonwealth workplace and we apply the federal version of WHS and Codes of Practice. Otherwise, we use state or territory versions and you need to see the local regulator’s Web page to find out what is applied where. And the definition of a Commonwealth workplace is in the WHS Act, but also go and have a look at the Comcare website to see who Comcare police. Because there are some nationalised industries that count as a Commonwealth workplace and it can get a bit messy.

So, sometimes you may have to ask for advice from the regulator but go and see what they say. Don’t rely on what consultants say or what you’ve heard on the grapevine. Go and see what the regulator actually says and make sure it’s the right regulator for where you’re operating.

Commentary #2

What’s to come? I’m going to do a session on the Risk Management Code of Practice, and I’m also, associated with that, going to do a session on the guidance on what is reasonably practicable. Now that’s guidance, it’s not a Code of Practice. But again, it’s been published so we need to be aware of it and it’s also very simple and very helpful. I would strongly recommend looking at that guidance if you’re struggling with SFARP for what it means, it’s very good. I’ll be talking about that soon. Also, I’m going to do a session on tolerability of risk, because you remember when I said “CoP aren’t much good for helping you do trade–offs in design” and that kind of thing. They’re really only good for simple stuff and compliance. Well, what you need to understand to deal with the more sophisticated problems is the concept of tolerability of risk. That’ll help us do those things. So, I’m going to do a session on that.

I’m also going to do a session on consultation, cooperation, and coordination, because, as I said before, that’s universally applicable. If we’re doing anything at a workplace, or with stuff that’s going to a workplace, that we need to be aware of what’s in that code. And then I’m also going to do sessions on plant, structures and substances (or hazardous chemicals) because those are the absolute bread and butter of the WHS Act. If you look at the duties of designers, manufacturers, importers, suppliers, and installers, et cetera, you will find requirements on plant, substances and structures all the way through those clauses in the WHS Act. Those three things are key so we’re going to be talking about that.

Now, I mentioned before that there was going to be a Code of Practice on plant design, but it never made it. It’s just guidance. So, we’ll have a look at that if we can as well – Copyright permitting. And then I want to look at electrical risks because I think the electrical risks code is very useful. Both for electrical risks, but it’s also a useful teaching vehicle for designers and manufacturers to understand their obligations, especially if you operate abroad and you want to know, or if you’re importing stuff “Well, how do I know that my kit can be safely used in Australia?” So, if you can’t do the things that the electrical risk CoP requires in the workplace if your piece of kit won’t support that, then it’s going to be difficult for your customers to comply. So, probably there’s a hint there that if you want to sell your stuff successfully, here’s what you need to be aware of. And then that applies not just to electrical, I think it’s a good vehicle for understanding how CoP can help us with our upstream obligations, even though CoP applies to a workplace. That session will really be about the imaginative use of Code of Practice in order to help designers and manufacturers, etc.

And then I want to also talk about noise Code of Practice, because noise brings in the concept of exposure standards. Now, generally, Codes of Practice don’t quote many standards. They’re certainly not mandatory, but noise is one of those areas where you have to have standards to say, “this is how we’re going to measure the noise”. This is the exposure standard. So, you’re not allowed to expose people to more than this. That brings in some very important concepts about health monitoring and exposure to certain things. Again, it’ll be useful if you’re managing noise but I think that session will be useful to anybody who wants to understand how exposure standards work and the requirements for monitoring exposure of workers to certain things. Not just noise, but chemicals as well. We will be covering a lot of that in the session(s) on HAZCHEM.

Copyright & Attribution

I just want to mention that everything in quotes/in italics is downloaded from the Federal Register of Legislation, and I’ve gone to the federal legislation because I’m allowed to reproduce it under the license, under which it’s published. So, the middle paragraph there – I’m required to point that out that I sourced it from the Federal Register of legislation, the website on that date. And for the latest information, you should always go to the website to double–check that the version that you’re looking at is still in force and is still relevant. And then for more information on the terms of the license, you can go and see my page at the www.SafetyArtisan.com because I go through everything that’s required and you can check for yourself in detail.

For More…

Also, on the website, there’s a lot more lessons and resources, some of them free, some of them you have to pay to access, but they’re all there at www.safetyartisan.com. Also, there’s the Safety Artisan page at www.patreon.com/SafetyArtisan where you will see the paid videos. And also, I’ve got a channel on YouTube where the free videos are all there. So, please go to the Safety Artisan channel on YouTube and subscribe and you will automatically get a notification when a new free video pops up.

End

And that brings me to the end of the presentation, so thanks very much for listening. I’m just going to stop sharing that now. It just remains for me to say thank you very much for tuning in and I look forward to sharing some more useful information on Codes of Practice with you in the next session in about a month’s time. Cheers now, everybody. Goodbye.

There’s more!

You can find the Model WHS Codes of Practice here. Back to the Topics Page.

Categories
Mil-Std-882E Safety Analysis

Health Hazard Analysis

In this full-length (55-minute) session, The Safety Artisan looks at Health Hazard Analysis, or HHA, which is Task 207 in Mil-Std-882E. We explore the aim, description, and contracting requirements of this complex Task, which covers: physical, chemical & biological hazards; Hazardous Materials (HAZMAT); ergonomics, aka Human Factors; the Operational Environment; and non/ionizing radiation. We outline how to implement Task 207 in compliance with Australian WHS. (We refer to other lessons for specific tools and techniques, such as Human Factors analysis methods.)

This is the seven-minute-long demo. The full version is a 55-minute-long whopper!

Health Hazard Analysis: Topics

  • Task 207 Purpose;
  • Task Description;
  • ‘A Health Hazard is…’;
  • ‘HHA Shall provide Information…’;
  • HAZMAT;
  • Ergonomics;
  • Operating Environment;
  • Radiation; and
  • Commentary.

Health Hazard Analysis: Transcript

Click here for the Transcript

Introduction

Hello, everyone, and welcome to the Safety Artisan. I’m Simon, your host, and today we are going to be talking about health hazard analysis.

Task 207: Health Hazard Analysis

This is task 207 in the Mil. standard, 882E approach, which is targeted for defense systems, but you will see it used elsewhere. The principles that we’re going to talk about today are widely applicable. So, you could use this standard for other things if you wish.

Topics for this Session

We’ve got a big session today so I’m going to plough straight on. We’re going to cover the purpose of the task; the description; the task helpfully defines what a health hazard is; says what health hazard analysis, or HHA, shall provide in terms of information. We talk about three specialist subjects: Hazardous materials or hazmat, ergonomics, and operating environment. Also, radiation is covered, another specialist area. Then we’ll have some commentary from myself.

Now the requirements of the standard of this task are so extensive that for the first time I won’t be quoting all of them, word for word. I’ve actually had to chop out some material, but I’ll explain that when we come to it. We can work with that but it is quite a demanding task, as we’ll see.

Task Purpose

Let’s look at the task purpose. We are to perform and document a health hazard analysis and to identify human health hazards and evaluate what it says, materials and processes using materials, etc, that might cause harm to people, and to propose measures to eliminate the hazards or reduce the associated risks. In many respects, it’s a standard 882 type approach. We’re going to do all the usual things. However, as we shall see it, we’re going to do quite a lot more on this one.

Task Description #1

So, task description. We need to evaluate the potential effects resulting from exposure to hazards, and this is something I will come back to again and again. It’s very easy dealing in this area, particularly with hazardous materials, to get hung up on every little tiny amount of potentially hazardous material that is in the system or in a particular environment and I’ve seen this done to death so many times. I’ve seen it overdone in the UK when COSHH, a control of substance hazardous to health, came in in the military. We went bonkers about this. We did risk assessments up the ying-yang for stuff that we just did not need to worry about. Stuff that was in every office up and down the land. So, we need to be sensible about doing this, and I’ll keep coming back to that.

So, we need to do as it says; identification assessment, characterisation, control, and communicate assets in the workplace environment. And we need to follow a systems approach, considering “What’s the total impact of all these potential stressors on the human operator or maintainer?” Again, I come from a maintenance background. The operator often gets lots of attention because a) because if the operator stuffs up, you very often end up with a very nasty accident where lots of people get hurt. So, that’s a legitimate focus for a human operator of a system.

But also, a lot of organizations, the executive management tend to be operators because that’s how the organization evolves. So, sometimes you can have an emphasis on operations and maintenance and support, and other things get ignored because they’re not sexy enough to the senior management. That’s a bad reason for not looking at stuff. We need to think about the big picture, not just the people who are in control.

Task Description #2

Moving on with task description. We need to do all of this good stuff and we’re thinking about materials and components and so forth, and if they cause or contribute to adverse effects in organisms or offspring. We’re talking about genetic effects as well. Or pose a substantial present or future danger to the environment. So in 882, we are talking about environmental impact as well as human health impact. There is a there is an environmental task as well that is explicitly so.

Personally, I would tend to keep the human impact and the environmental impact separate because there are very often different laws that apply to the two. If you try and mix them together or do a sort of one size fits all analysis, you’ll frequently make life more difficult for yourself than you need to. So, I would tend to keep them separate. However, that’s not quite how the standard is written.

A Health Hazard is …

So what is a health hazard? As it says, a health hazard is a condition and it’s got to be inherent to the operation, etc, through to disposal of the system. So, it’s cradle to grave – That’s important. That’s consistent with a lot of Western law. It’s got to be capable of causing death, injury, illness, disability, or even in this standard, they’ve just reduced the job performance of personnel by exposure to physiological stresses.

Now I’m getting ahead of myself because, in Australia, health hazards can include psychological impacts as well, not just impacts on physical health. Now reduced job performance? – Are we really interested in minor stuff? Maybe not. Maybe we need to define what we mean by that. Particularly when it comes to operators or maintainers making mistakes, perhaps through fatigue that can have very serious consequences.

So, this analysis task is going to address lots of causes or factors that we typically find in big accidents and relate them to effects on human performance. Then it goes on to specify that certain specific hazards must be included chemical, physical, biological, ergonomic – for ergonomic, I would say human factors, because when you look at the standard, what we call ergonomics is much wider than the narrow definition of ergonomics that I’m used to.

Now, this is the first area that chops some material because where in a-d it says e.g. in those examples there is in effect a checklist of chemical, physical, biological, and ergonomic hazards that you need to look at. This task has its own checklist. You might recall when we talked about preliminary hazard identification, a hazard checklist is a very good method for getting broad coverage in general. Now, in this task, we have further checklists that are specific to human health. That’s something to note.

We’ve also got to think about hazardous materials that may be formed by test, operation, maintenance, disposal, or recycling. That’s very important, we’ll come back to that later. Thinking about crashworthiness and survivability issues. We’ve got to also think about it says non-ionizing radiation hazards, but in reality, we’ve got to consider ionizing as well. If we have any radioactive elements in our system and it does say that in G. So, we’ve got to do both non-ionizing and ionizing.

HHA Shall Provide Info #1

What categories of information should this health hazard analysis generate? Well, first of all, it’s got to identify hazards and as I’ve said or hinted at before, we’ve got to think about how could human beings be exposed? What is the pathway, or the conditions, or mode of operations by which a hazardous agent could come into contact with a person? I will focus on people. So, just because there is a potentially hazardous chemical present doesn’t mean that someone’s going to get hurt. I suspect if I looked around in the computer in front of me that I’m recording this on or at the objects on my desk, there are lots of materials that if I was to eat them or swallow them or ingest them in some other way would probably not do me a lot of good. But it’s highly unlikely that I’m going to start eating them so maybe we don’t need to worry about that.

HHA Shall Provide Info #2

We also need to think about the characterization of the exposure. Describing the assessment process: names of the tools or any models used; how did we estimate intensities of energy or substances at the concentrations and so on and so forth? This is one of those analyses that are particularly sensitive to the way we go about doing stuff. Indeed, in lots of jurisdictions, you will be directed as to how you should do some of these analyses and we’ll talk about that in the commentary later. So, we’ve got to include that. We’ve got to “show our working” as our teachers used to tell us when preparing us for exams.

HHA Shall Provide Info #3

We’ve got to think about severity and probability. Here the task directs us to use the standard definition tables that are found in 882. I talked about those under task 202 so I’m not going to talk about further here. Now, of course, we can, and maybe should tailor these matrices. Again, I’ve talked about that elsewhere, but if we’re not using the standard matrices and tables, then we should set out what we’ve done and why that’s appropriate as well.

HHA Shall Provide Info #4

Then finally, the mitigation strategy. We shouldn’t be doing analysis for the sake of analysis. We should be doing to say, “How can we make things better?” And in particular for health, “How can we make things acceptable?” Because health hazards very often attract absolute limits on exposure. So, questions of SFARP or ALARP or cost-benefit analysis simply may not enter into the equation. We simply may be direct to say “This is the upper limit of what you can expose a human being to. This is not negotiable.” So, that’s another important difference with this task.

Three More Topics

Now, at this point, I am just foreshadowing. We’re about to move on to talk about some different topics. First of all, in this section, we’re going to talk about three particular topics. Hazardous material or HAZMAT for short; ergonomics; and the operational environment. When we say the operational environment, it’s mainly about the people, aspects of the system, and the environment that they experience. Then after these three, we would go on to talk about radiation. There are special requirements in these three areas for HAZMAT, ergonomics, and operational environment.

HAZMAT (T207) #1

First of all, we have to deal with HAZMAT. If it’s going to appear in our system, or in the support system, we’ve got to identify the HAZMAT and characterize it. There are lots of international and national standards about how this is to be done. There’s a UN convention on hazardous materials, which most countries follow. And then there will usually be national standards as well that direct what we shall do. More on that later. So, we’ve got to think about the HAZMAT.

A word of caution on that. Certainly in Australian defence, we do HAZMAT to death because of a recent historical example of a big national scandal about people being exposed to hazardous materials while doing defence work. So, the Australian Defence Department is ultrasensitive about HAZMAT and will almost certainly mandate very onerous requirements on performing this. And whilst we might look at that go “This is nuts! This is totally over the top!” Unfortunately, we just have to get on with it because no one is going to make, I’m afraid, a sensible decision about the level of risk that we don’t have to worry about because it’s just too sensitive a topic.

So, this is one of those areas were learning from experience has actually gone a bit wrong and we now find ourselves doing far too much work looking at tiny risks. Possibly at the expense of looking at the big picture. That’s just something to bear in mind.

HAZMAT (T207) #2

So, lots of requirements for HAZMAT. In particular, we need to think about what are we going to do with it when it comes to disposal? Either disposal of consumables, worn components or final disposal of the system. And very often, the hazardous material may have become more hazardous. In that, let’s say engine or lubricating oil will probably have metal fragments in it once it’s been used and other chemical contamination, which may render it carcinogenic. So, very often we start with a material that is relatively harmless, but use – particularly over a long period of time – can alter those chemicals or introduce contaminants and make them more dangerous. So, we need to think about the full life of the system.

Ergonomics (T207) #1

Moving on to ergonomics, and this is another big topic. Now, Mil.standard 882 doesn’t address human factors, in my view, particularly well. The human factors stuff gets buried in various tasks and we don’t identify a separate human factors program with all of the interconnections that you need in order to make it fully effective. But this is one task where human factors do come in, very much so, but they are called ergonomics rather than human factors. Under this task description, we need to think about mission scenarios. We need to think about the staff who will be exposed as operators or maintainers, whatever they might be doing. We’ve got to start to characterize the population at risk.

Ergonomics (T207) #2

We’ve got to think about the physical properties of things that personnel will handle or wear and the implications that has on body weight. So, for example, there is a saying that the “Air Force and the Navy man their equipment and the army equip their men”. Apologies for the gendered language but that’s the saying. So, we’re putting human beings – very often – inside ships and planes and tanks and trucks. And we’re also asking soldiers to carry – very often – lots of heavy equipment. Their rations, their weapons, their ammunition, water, various tools and stuff that they need to survive and fight on the battlefield. And all that stuff weighs and all of that stuff, if you’re running about carrying it, bangs into the body and can hurt people. So, we need to address that stuff.

Secondly, we need to look at physical and cognitive actions that operators will take. So, this is really very broad once we get into the cognitive arena thinking about what are the operators going to be doing. And exposures to mechanical stress while performing work. So, maybe more of a focus on the maintainer in part three. Now, for all of this stuff, we need to identify characteristics of the design of the system or the design of the work that could degrade performance or increase the likelihood of erroneous action that could result in mishaps or accidents.

This is classic human factor’s stuff. How might the designed work or the designed equipment induce human error? So, that’s a huge area of study for a lot of systems and very important. And this will be typically a very large contributor to serious accidents and, in fact, accidents of all kinds. So, it should be an area of great focus. Often it is not. We just tend to focus on the so-called technical risks and overdo that while ignoring the human in the system. Or just assuming that the human will cope, which is worse.

Ergonomics (T207) #3

Continuing with ergonomics. How many staff do we need to operate and maintain the system and what demands are we placing on them? Also, if we overdo these demands, what are we going to do about that? Now, this can be a big problem in certain systems. I come from an aviation background and fatigue and crew duty time tend to be very heavily policed in aviation. But I was actually quite shocked when I sort of began looking at naval surface ships, submarines, where it seemed that fatigue and crew duty time was not well policed. In fact, there even seemed to be, in some places, quite a macho attitude to forcing the crew into working long hours. I say macho attitude because the feeling seemed to be “Well if you can’t take it, you shouldn’t have joined.”

So, it seems to be to me, quite a negative culture in those areas potentially, and it’s something that we need to think about. In particular, I’ve noticed on certain projects that you have a large crew who seem to be doing an extraordinary amount of work and becoming very fatigued. That’s concerning because, of course, you could end up with a level of fatigue where the crew might as well – they’re making mistakes to the same level as a drunk driver. So, this is something that needs to be considered carefully and given the attention it deserves.

Operating Environment #1

Moving on to the operating environment. How will these systems be used and maintained? And what does that imply for human exposure? This is another opportunity where we need to learn from legacy systems and go back and look at historical material and say “What are people being exposed to in the past? And what could happen again?”

Now, that’s important. It’s often not very systematically done. We might go and talk to a few old, bold operators and maintainers and ask their advice on the things that can go wrong but we don’t always do it very systematically. We don’t always survey past hazard and accident data in order to learn from it. Or if we do there is sometimes a tendency to say, “That happened in the past, but we will never make those mistakes. We’re far too clever to stuff up like that – like our predecessors did.” Forgetting that our predecessors were just as clever as we are and just as well –meaning as we are but they were human and so are we.

I think pride can get in the way of a lot of these analyses as well. And there may be occasions where we’re getting close to exposure limits, where regulations say we simply cannot expose people to a certain level of noise, or whatever, and then “How are we going to deal with that? How are we going to prevent people from being overexposed?” Again, this can be a problem area.

Operating Environment #2

This next bit of operating environment is really – I said about putting people in the equipment. Well, this is this bit. This is part A and B. So, we’re thinking about “If we stick people in a vehicle – whether it be a land vehicle, marine vehicle, an air vehicle, whatever it might be – what is that vehicle going to do to their bodies?” In terms of noise, of vibration and stresses like G forces, for example, and shock, shock loading? Could we expose them to blast overpressure or some other sudden changes of pressure or noise that’s going to damage their ears, temporarily or permanently? Again, remarkably easy to do. So, that’s that aspect.

Operating Environment #3

Moving on, we continue to talk about noise and vibration in general. In this particular standard, we’ve got some quite stringent guidance on what needs to be looked at. Now, these requirements, of course, are assuming a particular way of doing things, which we will come to later. There are a lot of standards reference by task 207. This task is assuming that we’re going to do things the American government or the American military way, which may not be appropriate for what we’re doing or the jurisdiction we’re in. So, we’ll just move on.

Operating Environment #4

Then again, talking about noise, blast, vibration, how are we going to do it? Some quite specific requirements in here. And again, you’ll notice, two-thirds of the way down in the paragraph, I’ve had to chop out some examples. There is some more in effect, hazard checklists in here saying we must consider X, Y, Z. Now, again, this seems to be requiring a particular way of doing things that may not be appropriate in a non-American defence environment.

However, the principle I think, to take away from this is that this is a very demanding task. If we consider human health effects properly, it’s going to require a lot of work by some very specialist and skilled people. In fact, we may even get in some specialist medical people. If you work in aviation or medicine, you may be aware that there is a specialist branch of medicine for called aviation medicine where these things are specifically considered. And similarly, there are medical specialists are a diving operations and other things where we expose human beings to strange effects. So, this can be a very, very demanding task to follow.

Operating Environment #5

So, when we’re going to equip people with protective equipment or we’re going to make engineering changes to the system to protect them, how effective are these things going to be? And given that most of these things have a finite effectiveness – they’re rarely perfect unless you can take the human out of the system entirely, then we’re going to be exposing people to some level of hazard and there will be some risk that that might cause that injury.

So, how many individuals are we going to expose per platform or over the total population exposed over the life of the system? Now, bearing in mind we’re talking sometimes about very large military systems that are in service for decades. This can be thousands and thousands of people. So, we may need to think about that and certainly in Australia, if we expose people to certain potential contaminants and noise, we may have to run a monitoring program to monitor the health and exposure of some of this exposed population or all of them. So, that can be a major task and we would need to identify the requirements to do that quite early on, hopefully.

And then, of course, again, we’re not doing this for the sake of it. How can we optimize the design and effectively reduce noise exposure and vibration exposure to humans? And how did we calculate it? How did we come to those conclusions? Because we’re going to have to keep those records for a long, long time. So, again, very demanding recording requirements for this task.

Operating Environment #6

And then I think this is the final one on operating environment. What are the limitations of this protective equipment and what burden do they impose? Because, of course, if we load people up with protective equipment that may introduce further hazards. Maybe we’re making the individual more likely to suffer a muscular musculoskeletal disorder.

Or maybe we are making them less agile or reducing their sensitivity to noise? Maybe if we give people hearing protection, if somebody else has assumed that they will hear a hazard coming, well, they’re not going to anymore, are they? If they’re wearing lots of protective equipment, they may not be as aware of the environment around them as they once were. So, we can introduce secondary hazards with some of this stuff. And then we need to look at the trade-offs. When and where? Is it better to equip people or not to equip people and limit their exposure or just keep them away altogether?

Radiation (T207)

So moving on briefly, we’re just going to talk about radiation. Now in this task – again, I’ve had to chop a lot of stuff out – you’ll see that in square brackets this task refers to certain US standards for radiation. Both ionizing and non-ionizing, lasers and so forth. That’s appropriate for the original domain, which this standard was targeted at. It may be wholly inappropriate for what you and I are doing.

So, we need to look at the principles of this task, but we may need to tailor the task substantially in order to make it appropriate for the jurisdiction we’re working in. Again, we’re going to have to keep these records for a long time. Radiation is always going to be dreaded by humans so it’s a controversial topic. We’re going to have to monitor people’s exposure and protect them and show that we have done so, potentially decades into the future. So, we should be looking for the very highest standards of documentation and recording in these areas because they will come under scrutiny.

Contracting #1

Moving onto contracting, this is more of a standard part of this task or part of the standard, I should say. These words or very similar words exist in every task. So, I’m not going to go through all of these things in any great detail. It’s worth noting, and I’ll come back to this in part B, we may need to direct whoever is doing the analyses to consider or exclude certain areas because it’s quite possible to fritter away a lot of resources doing either a wide but shallow analysis that fails to get to the things that can really hurt people.

So, we might be doing a superficial analysis or we might go overboard on a particular area and I’ve mentioned HAZMAT but there are many things that people can get overexcited about. So, we might see people spending a lot of time and effort and money in a particular area and ignoring others that can still hurt people. Even though they might be mundane, not as sexy. Maybe the analysts don’t understand them or don’t want to know. So, the customer who is paying for this may need to direct the analysis. I will come on to how you do that later.

Also the customer or client may need to specify certain sources of information, certain standards, certain exposure standards, certain assumptions, certain historical sets of data and statistics to be used. Or some statistics about the population, because, of course, for example, the military systems, the people who operate military systems tend to be quite a narrow subset of the population. So, there are very often age limits. Frontline infantry soldiers tend to be young and fit. In certain professions, you may not be allowed to work if you are colour-blind or have certain disabilities. So, it may be that a broad analysis of the general population is not appropriate for certain tasks.

It may be perfectly reasonable to assume certain things about the target population. So, we need to think about all of these things and ensure that we don’t have an unfocused analysis that as a result is ineffective or wastes a lot of money looking at things that don’t really matter, that are irrelevant.

Contracting #2

Standards and criteria. In part F, there are 29 references which the standard lists, which are all US military standards or US legal standards. Now, probably a lot of those will be inappropriate for a lot of jurisdictions and a lot of applications. So, there’s going to be quite a lot of work there to identify what are the appropriate and mandatory references and standards to use. And as I said, in the health hazard area, there are often a lot. So, we will often be quite tightly constrained on what to do.

And Part H, if the customer knows or has some idea of the staff numbers and profile, they’re going to be exposed to this system of operating and maintaining the system. That’s a very useful information and needs to be shared. We don’t want to make the analyst, the contractor, guess. We want them to use appropriate information. So, tell them and make sure you’ve done your homework, that you tell them the right thing to do.

Commentary #1

So, that’s all of the standard. I’ve got four slides now of commentary. And the first one, I just want to really summarize what we’ve talked about and think about the complexity of what we’re being asked to do. First bullet point, we are considering cradle to grave operation and maintenance and disposal. Everything associated with, potentially, quite a complex system. Now, this lines up very nicely with the requirements of Australian law, which require us to do all of this stuff. So, it’s got to be comprehensive.

Second bullet point, we’ve got to think about a lot of things. Death and injury, illness, disability, the effects on and could we infect somebody or contaminate somebody with something that will cause birth defects in their offspring? There’s a wide range of potential vectors of harm that we’re talking about here, and we will probably – for some systems, we will need to bring in some very specialist knowledge in order to do this effectively. And also thinking about reduced job performance – this is one aspect of human factors. This task is going to linking very strongly to whatever human factors program we might.

Thirdly, we’ve got to think about chemical, physical, and biological hazards. So, again, there’s a wide range of stuff to think about there. An example of that is hazmat and the requirements on hazmat are, in most jurisdictions, tend to be very stringent. So, that is going to be done and we need to be prepared to do a thorough job and demonstrate that we’ve done a thorough job and provide all the evidence.

Then we’ve also got ergonomics. Actually, strictly speaking, we’re talking human factors here because it’s a much wider definition than what the definition of ergonomics that I’m used to, which tends to be purely physical effects on a human. Because we’re talking about cognitive and perception and job performance as well and also we’ve got vibration and acoustics. So, again, particular medical effects and stringent requirements. So, a whole heap of other specialists work there.

And operating environment, thinking about the humans that will be exposed. How are we going to manage that? What do we need to specify in order to set up whatever medical monitoring program of the workforce we might have to bring in in the future through life? So, again, potentially a very big, expensive program. We need to plan that properly.

Then finally, radiation. Another controversial topic which gets lots of attention. Very stringent requirements, both in terms of exposure levels and indeed we will often be directed as to how we are to calculate and estimate stuff. It’s another specialist area and it has to be done properly and thoroughly.

Overall, every one of those seven bullet points shows how complex and how comprehensive a good health hazard analysis needs to be. So, to specify this well, to understand what is required and what is needed through life, for the program to meet our legal and regulatory obligations, this is a big task and it needs a lot of attention and potentially a lot of different specialist knowledge to make it work. I flogged that one to death, so I’ll move on.

Commentary #2

Now, as I’ve said before, too, this is an American military standard, so it’s been written to conform to that world. Now in Australia, the requirements of Australian work, health and safety are quite different to the American way of doing things. Whilst we tend to buy a lot of American equipment and there’s a lot of American-style thinking in our military and in our defence industry, actually, Australian law much is much more closely linked to English law. It’s a different legal basis to what the Americans do. So Australian practitioners take note.

It’s very easy to go down the path of following this standard and doing something that will not really meet Australian requirements. It’ll be, “We’ll do some work” and it may be very good work, but when we come to the end and we have to demonstrate compliance with Australian requirements, if we haven’t thought about and explicitly upfront, we’re probably in for a nasty shock and a lot of expensive rework that will delay the program. And that means we’re going to become very, very unpopular very quickly. So, that’s one to avoid in my experience.

So, we will need to tailor task 207 requirements upfront in order to achieve WHS compliance. And the client customer needs to do that and understand that not the – well the contractor needs to. The analysts need to understand that. But the customer needs to understand that first, otherwise, it won’t happen.

Commentary #3

Let’s talk a bit more about tailoring for WHS. For example, there are several WHS codes of practice which are relevant. And just to let you know, these codes of practice cover not only requirements of what you have to achieve, but also, to a degree, how you are to achieve them. So, they mandate certain approaches. They mandate certain exposure standards. Some of them also list a lot of other standards that are not mandated but are useful and informative.

So, we’ve got codes of practice on hazardous manual tasks so avoiding muscular-skeletal injuries. We’ve got several codes of practice on hazardous chemicals. So, we’ve got a COP specifically on risk management and risk assessment of hazardous chemicals, on safety data sheets, on labelling of HAZCHEM in a workplace. We’ve got a COP on noise and hearing loss and also, we have other COPs on specific risks, such as asbestos, electricity and others, depending on what you’re doing. So, potentially there is a lot of regulation and codes of practice that we need to follow.

And remember that COPs are, while they contain regulations, they also are a standard that a court will look to enforce if you get prosecuted. If you wind up in court, the prosecution will be asking questions to determine whether you’ve met the requirements of COP or not. If you can’t demonstrate that you’ve met them, you might have done a whole heap of work and you might be the greatest expert in the world on a certain kind of risk, but if he can’t demonstrate that you’ve met at minimum the requirements of COP – because they are minimum requirements – then you’re going to be in trouble. So, you need to be aware of what those things are.

Then on radiation, we have separate laws outside the WHS. So, we have the Australian Radiation Protection and Nuclear Safety Agency, ARPANSA, and there is an associated act and associated regulations and some COP as well. So, for radiation side, there’s a whole other world that you’ve got to be aware of and associated with all of this stuff are exposure standards.

Commentary #4

Finally, how do we do all of this without spending every dollar in the defence budget and taking 100 years to do it? Well, first of all, we need to set our scope and priorities. So, before we get to Task 207, the client/the customer should be involving end-users and doing a preliminary hazard identification exercise. That should be broad and as thorough as possible. They should also be doing a preliminary hazardous hazard analysis exercise, Task 202, to think about those hazards and risks further.

Also, you should be doing Task 203, which is system requirements hazard analysis. We need to be thinking about what are the applicable requirements for my system from the law all the way down to what specific standards? What codes of practice? What historical norms do we expect for this type of equipment? Maybe there is industry good practice on the way things are done. Maybe as we work through the specifications for the equipment, we will derive further requirements for hazard controls or a safety management system or whatever it might be. That’s a big job in itself.

So, we need to do all three of those tasks, 201, 202, 203, in order to be prepared and ready to focus on those things that we think might hurt us. Might hurt people physically, but also might hurt us in terms of the amount of effort we’re going to have to make in order to demonstrate compliance and assurance. So, that will focus our efforts.

Secondly, when we need to do the specialist analyses and we may not always need to do so. This is where 201, 202, and 203 come in. But where we need to do specialist analyses, we may need to find specialist staff who are competent to do these this kind of unusual or specialist work and do it well. Now, typically, these people are not cheap, and they tend to be in short supply. So, if you can think about this early and engage people early, then you’re going to get better support.

You’re probably going to get a better deal because in my experience if you call in the experts and ask their opinion early on, they’re more likely to come back and help you later. As opposed to, if you ignore them or disregard their advice and then ask them for help because you’re in trouble, they may just ignore you because they’ve got so much work on. They don’t need your work. They don’t need you as a client. You may find yourself high and dry without the specialists you need or you may find yourself paying through the nose to get them because you’re not a priority in their eyes. So do think about this stuff early, I would suggest and do cultivate the specialist. If you get them in early and listen to them and they feel involved, you’re much more likely to get a good service out of them.

So thirdly, try not to do huge amounts of work on stuff that doesn’t really have a credible impact on health. Now, I know that sounds like a statement of the blinking obvious, but because people get so het up about health issues, particularly things like radiation and other hazards that humans can’t see: we dread them. We get very emotional about this stuff and therefore, management tends to get very, very worried about this stuff. And I’ve seen lots of programs spend literally millions of dollars analyzing stuff to death, which really doesn’t make any difference to the safety of people in the real world. Now, obviously, that’s wasted money, but also it diverts attention from those areas that really are going to cause or could cause harm to people through the life of the system.

So, we need to use that risk matrix to understand what is the real level of risk exposure to human beings and therefore, how much money should we be spending? How much effort and priority should we be spending on analyzing this stuff? If the risk is genuinely very low, then probably we just take some standard precautions, follow industry best practice, and leave it at that and we keep our pennies for where they can really make a difference.

Now, having said that, there are some exceptions. We do need to think about accident survivability. So, what stresses are people going to be exposed to if their vehicle is an accident? How do we protect them? How do they escape afterward? Hopefully. How do we get them to safety and treat the injured? And so on and so forth. That may be a very significant thing for your system.

Also post-accident scenarios in terms of – very often a lot of hazardous materials are safely locked away inside components and systems but if the system catches fire or is smashed to pieces and then catches fire, then potentially a lot of that HAZMAT is going to become exposed. Very often materials that pose a very low level of risk, if you set them on fire and then you look at the toxic residue left behind after the fire, it becomes far more serious. So, that is something to consider. What do we do after we’ve had an accident and we need to sort of clean up the site afterward? And so on and so forth.

Again, this tends to be a very specialist job so maybe we need to get in some specialists to give us advice on that. Or we need to look to some standards if it’s a commonplace thing in our industry, as it often is. We learn we learned from bitter experience. Well, hopefully, we learn from bitter experience.

Copyright Statement

So, that’s it from me. I appreciate it’s been a long session, but this is a very complex task and I’ve really only skimmed the surface on this and pointed you at sort of further reading and maybe some principles to look at in more depth. So, all the quotations are from the Mill standard, which is copyright free. But this presentation is copyright of the Safety Artisan.

For More…

And for more information on this topic and others, and for more resources, do please visit www.safetyartisan.com. There are lots of free resources on the website as well, and there’s plenty of free videos to look at.

End: Health Hazard Analysis

So, that is the end of the session. Thank you very much for listening. And all that remains for me to say is thanks very much for supporting the work of the Safety Artisan and tuning into this video. And I wish you every success in your work now and in the future. Goodbye.

Categories
Mil-Std-882E Safety Analysis

Operating & Support Hazard Analysis

In this full-length session, The Safety Artisan looks at Operating & Support Hazard Analysis, or O&SHA, which is Task 206 in Mil-Std-882E. We explore Task 206’s aim, description, scope, and contracting requirements. We also provide value-adding commentary, which explains O&SHA: how to use it with other tasks; how to apply it effectively on different products; and some of the pitfalls to avoid. We refer to other lessons for specific tools and techniques, such as Human Factors analysis methods.

This is the seven-minute-long demo. The full version is about 35 minutes long.

Operating & Support Hazard Analysis: Topics

  • Task 206 Purpose:
    • To identify and assess hazards introduced by O&S activities and procedures;
    • To evaluate the adequacy of O&S procedures, facilities, processes, and equipment used to mitigate risks associated with identified hazards.
  • Task Description (six slides);
  • Reporting (two slides);
  • Contracting (two slides); and
  • Commentary (four slides).

Operating & Support Hazard Analysis: Transcript

Click here for the Transcript

Introduction

Hello everyone and welcome to the Safety Artisan; home of safety engineering training. I’m Simon and today we’re going to be carrying on with our series on Mil. Standard 882E system safety engineering.

Operating & Support Hazard Analysis

Today, we’re going to be moving on to the subject of operating and support hazard analysis. This is, as it says, task 206 under the standard. Operating and support hazard analysis, I’ll just call it O&S or OSHA (also O&SHA) for short. Unfortunately, that will confuse people if I call OSHA. Let’s call it O&S.

Topics for this Session

The purpose of O&S hazard analysis is to identify and assess hazards introduced by those activities and procedures and also to evaluate the adequacy of O&S procedures, processes, equipment, facilities, etc, to mitigate risks that have been already identified. A twofold task but a very big task. And as we’ll see, we’ve got lots of slides today on task description, and reporting, contracting, and commentary. As always, I present the full text as is of the task, which is copyright free, but I’m only going to talk about the things that are important. So, we’re not going to go through every little clause of the standard that would be pointless.

O&S Hazard Analysis (T206)

Let’s get started with the purpose. As we’ve already said, it’s to identify and assess those hazards which are introduced by operational and support activities and procedures and evaluate their adequacy. So, we’re looking at operating the system, whatever it may be- And of course, this is a military standard, so we assume a military system, but not all military systems are weapon systems by any means. Not all are physical systems. So, there may be inventory management systems, management information systems, all kinds of stuff. So, does operating those systems and just supporting them (maintaining them are resupplying them, disposing of them, etc.,) does that create any hazards or introduce any hazards? And how do we mitigate? That’s the purpose of the task.

Task Description (T206) #1

Let’s move on to the task description. Again, we’re assuming a contractor is performing the analysis, but that’s not necessarily the case. For this task, this actually says this typically begins during engineering and manufacturing development, or EMD.  So, we’re assuming an American style lifecycle for a big system and EMD comes after concept and requirements development. So, we are beginning to move into the very expensive stage of development for a system where we begin to commit serious money. It’s suggesting that O&SHA can wait until then which is fine in general unless you’ve identified any particularly novel hazards that will need to be dealt with earlier on. As it says, it should build on design hazard analyses, but we’ll also talk about the case later on when there is no design hazard analyses. And the O&SHA shall identify requirements or alternatives or eliminating hazards, mitigating risks, etc. This is one of those tasks where the human is very important – In fact, dominant to be honest. Both as a source of hazards and the potential victim of the associated risks. A lot of human-centric stuff going on here.

Task Description (T206) #2

As always, we’re going to think about the system configurations. We’re going to think about what we’re going to do with the system and the environment that we’re going to do it in. So, a familiar triad and I know I keep banging on about this, but this really is fundamental to bounding and therefore evaluating safety. We’ve got to know what the system is, what we’re doing with it, and the environment in which we’re doing it. Let’s move on.

Task Description (T206) #3

Again, Human Factors, regulatory requirements, and particularly specified personnel requirements need to be thought of. Particularly for operating and support, we need to take into account the staffing and personnel concept that we have. It’s frighteningly easy to produce a system that needs so much maintenance, for example, or support activity that it is unaffordable. And lots and lots of military systems and, it must be said, government and commercial systems in the past have come in that required enormous amounts of support, which soon proved to be unaffordable or no one would sign up to the commitment required. So, lots of projects have simply died because the system was going to be too expensive to sustain. That’s a key point of what we’re doing with O&S here. It’s not just about health and safety. It’s about health and safety, which is affordable.

We also need to look at unplanned events. So, not just designed in things, but things introduced- It says human errors. Again, I’m going to re-emphasize it’s erroneous human action because human error makes it sound like a human is at fault. Whereas very often it’s the design or the concept or the requirements that are at fault and place unacceptable burdens on the human being. Again, lots of messy systems seen in the past, which didn’t quite work and we just kind of expected the operator to cope. And most of the time they cope and then every so often they have a bad day at the office or a bunch of factors come together and lots of people die. And then we blame the human. Well, it’s not the human’s fault at all. We put them in that position. And as always, we need to look at past- Past evaluations of related legacy systems and support operations. If you have good data about legacy systems or about similar systems that your organization or another organization has operated, then that’s gold dust. So, do make an effort to get hold of that information if you can. Maybe a trade association or some wider pan organization body can help you there.

Task Description (T206) #4

At a minimum, we’ve got to identify activities involving known hazards. This assumes that we’ve done some hazard analysis in the past, which is very important. We always need to do that. I’ll come back to that commentary. Secondly, changes needed in requirements, be they functional requirements – what we want the system to do. Or design requirements, if we put constraints on how the system may do it for whatever it may be, hardware, software, support equipment, whatever to make those hazards and risks more manageable. Requirements for safety features – so requirements for engineered features and devices, equipment, because always, in almost any jurisdiction, we will have a hierarchy of control that recognizes that designed and engineered in safety features are more effective than just relying on people to get it right. And then we’ve also got to communicate to people the hazards associated with the system. Warnings, cautions, and whatever special emergency procedures might be required associated with the system. Again, that’s something that we see reinforced in law and regulations in many parts of the world. This is all good stuff. It’s accepted good practice all across the world.

Task Description (T206) #5

Moving on, we also need to think about how are we going to move the system around and the associated spares and supplies? How are we going to package them, handle them, stole them, transport them? Particularly if there are hazardous materials, etc, etc, involved. That’s the next part, G. Again, training requirements. We’re thinking about a human-centric approach. Whatever we expect people to do, they’ve got to be trained in how to do it. Point I, we’ve got to include everything, whether it’s developmental or non-developmental terms. We can’t just ignore stuff because it’s GFE or it’s off the shelf. It doesn’t mean it can never go wrong. Far from it. Particularly if we are putting stuff together that’s never been put together before in a novel combination or in a novel environment. Something that might be perfectly safe and stable in an air-conditioned office might start to do odd things in a much more corrosive and uncontrolled environment, let’s say.

We need to think about what modes might the system be potentially hazardous when under operative control. Particularly, we might think about degraded modes of operation. So, for whatever reason, a part of the system has gone wrong or the system has got into an operating environment within which it doesn’t operate as well as it could. It’s not in an optimal operating environment or state. The human being in control of it, we’re assuming, has still got to be able to operate the system, even if it’s only to shut it down or to get it back into a safer state or safer environment. We’ve got to think about all of those nuances.

Then because we’re talking about support as well, we need to think about a related legacy systems, facilities and processes which may provide background information. Also, of course, the system presumably will very often be operating alongside other systems or it will be supported by all systems maybe that exist or being procured separately. So, we’ve got to think about all those interactions as well and all those potential contributions. As you can see, this is quite a wide-ranging broadly scoped task.

Task Description (T206) #6

Finally, on this section, the customer/the end-user/or whoever may specify some specific analysis techniques. Very often they will not. So, whoever is doing the analysis, be they a contractor or third party outside agency, needs to make sure that whatever they propose to do is going to be acceptable to the program manager. In the sense that it is going to be compatible and relevant and useful. And then finally, the contractor has got to do some O&SHA at the appropriate time but maybe more detailed data will come along later. In which case that needs to be incorporated and also operational changes.

An absolute classic [situation] with military and non-military systems is; the system gets designed, it goes into test and evaluation and we discover that things- assumptions that were made during development- don’t actually hold up. The real world isn’t like that or whatever it might be and we find we’re making changes- making changes in assumptions. Those need to be factored in which, sadly, is often not done very well. So, that’s an important point to think about. What’s my change control mechanism and how will the people doing the and O&SHA find out about these changes? Because very often it’s easy to assume that everybody knows about this stuff but when you start making assumptions, the truth is that it very often goes adrift.

Reporting (T206) #1

Let’s talk about reporting- Just a couple of slides here. In the reporting, there’s some fairly standard stuff in here, the physical and functional characteristics of the system- that’s important. Again, we might assume that everybody knows what they are, but it’s important to put them in. It may be that the people doing the analysis were given a different system description to the people developing the system, to the people doing the personnel planning, etc. All the different things that have to be brought together, we need to make sure that they join up again. It’s too easy to get that wrong. Reinforcing the point I made on the previous slide, as more detailed descriptions and specifications come in that needs to be supplied when it becomes available and provided.

Hazard analysis methods and techniques. What techniques are we using? Give a description. If you’re doing it to a particular standard, so much the better. Great- that saves a lot of paper. What assumptions that we made? What data, both qualitative and quantitative have we used to support analysis? That all needs to be declared. By the way, one of the reasons is to be declared is that when things change- not if- that’s when these assumptions and the data and the techniques get exposed. So, if there are changes, if we don’t have this kind of information declared, we can’t assess the impact changes. And it gets even more difficult to keep up with what’s going on.

Reporting (T206) #2

And then hazard analysis results. Again, the leading particulars of the results should be recorded in the hazard tracking system, the HTS, or hazard log, or risk register- whatever you want to call it. But there will be more detailed information that we wouldn’t want to clutter up the risk register with and we also need to provide warnings, cautions, and procedures to be included in maintenance manuals, training courses, operator manuals, etc. So, we’re going to or we’re probably going to generate an awful lot of data out of this task and that needs to be provided in a suitable format. Again, whoever the program manager on the client-side, or is the end-user representation, needs to think about this stuff quite early on.

Contracting #1

That leads us neatly on to contracting. Now, this task, in theory, can be specified a little bit down the track, after the program started. In practice, what you find is program managers tried to specify everything up front in a single contract for various reasons.

There are good reasons for doing that sometimes. Also, there are bad reasons but I’m not going to talk about this session. We’ll have a talk about planning your system safety program in another session. There’s a lot of nuances in there to be considered.

Just sticking to this task, identification of functional disciplines – who do we need to get involved in order to do this work properly? It’s likely that the safety team if you have one, may not have relevant operating experience or relevant sustainment experience for this kind of system. If they do, that’s fantastic but that doesn’t negate the read the requirement to get the end-user represented and involved. In fact, that’s a near legal requirement in Australia, for example, and in some other jurisdictions. We need to get the end-users involved. We need the discipline specialist to get involved. Typically, your integrated logistic support team, your reliability people, your maintainability, and your testability people, if you have those disciplines. Or maybe you’re calling them something else, it doesn’t really matter.

We need to know what are the reporting requirements. What, if any, analysis methods and techniques do we desire to be used? Maybe the client or end-user has got to jump through some regulatory hoops and therefore they need specific analysis work and safety results to be done and produced. If that’s the case, then that needs to be specified in the contract. And what data is to be generated in what format? And how is it to be reported on when, etc? Considering the hazard tracking system, etc? And then the client may also select or specify known hazards, known hazardous areas, or other specific items to be examined or excluded because maybe it’s being covered elsewhere or we don’t expect the contractor to be able to do this stuff. Maybe we need to use a specialist organization. Again, maybe a regulator has directed us to do so. So, all of these things need to be thought about when we’re putting together the contract requirements for task 206.

Contracting #2

Again, I say this every time, we need to include all items within the scope of the system and the environment, not just developmental stuff. In fact, these days, maybe the majority of programs that I am seeing are mostly non-developmental. So, we’re taking lots of COTS stuff, GFE components, and putting it all together. That’s all going to be included, particularly integration.

We need to think about legacy and related processes and the hazard analysis associated with them if we can get them. They should be supplied to whoever is doing the work and an analyst should be directed to review them and include lessons learned.

Then, reinforcing the previous point that has a tracking system- How will information reported in this task be correlated with tasks and analyses that are being done maybe elsewhere or by different teams? And the example here is 207 health hazard analysis. I’ll talk a little bit about the linkages between the two later. But it’s quite likely in this sort of area there will be large groups of people thinking about operations and maintenance and support. Very often those groups are very different. Sometimes they don’t even talk to each other. That’s the culture in different organizations. You don’t see airline pilots hanging around with baggage handlers very much, do you, down the pub for whatever reason? Different set of people- they don’t always mix very much. And again, you may also have different specialist disciplines, especially the Human Factors people. Again, you’ve got to tie everything in there. So, there’s going to be lots of interfaces in this kind of task that they’ve got to be managed.

Point I – concept of operations. Yes, that’s in every task. You’ve got to understand what we intend to do with this system or what the end-user intends to do with the system in order to have some context for the analysis.

And then finally, what risk definitions and what risk matrix are we using? If we’re not using the standard 882 matrix, then what are we doing?

Commentary #1

I’ve got four slides of commentary now – a number of things to say about Task 206.

Now, I’ve picked an Australian example. So, Task 206 ties in very neatly with Australian WHS requirements. I suspect Australian WHS requirements have been strongly influenced by American OSHA and system safety practices. In Australia, we are heavily influenced by the US approach. This standard and legal requirements in Australia, and in many other states and territories let’s be honest, do tie in nicely with the standard. Although not always perfectly, you’ve got to remember that. So, we do need to focus on operations and support activities. That’s a big part of WHS, thinking about all relevant activities and cradle to grave – the whole life of the system. We need to think about the working environment, the workplace. We need to think about humans as an integral part of the system, be they operators or maintainers, suppliers, other kinds of sustainers. And we need to be providing relevant information on hazards, risks, warnings, trainings, and procedures, and requirements for PPE, and so on and so forth to workers.

So, task 206 is going to be absolutely vital to achieving WHS compliance in Australia and compliance with health and safety legislation and regulations in many parts of the world. In the US and UK and I would say in virtually all developed nations. So, this is a very important task for achieving compliance with the law and regulations. It needs to get the requisite amount of attention- It doesn’t always. People so often on a program during procurement and acquisition development, the technical system is the sexy thing. That’s the thing that gets all the attention, especially early on. The operating and particularly the support side tends to get neglected because it’s not so sexy. We don’t buy a system to support it after all do we? We buy a system to do a job. So, we get the operators in and we get their input on how to optimize the system to do the job most cost-effectively and with most mission effectiveness that we can get out of it. We don’t often think about support effectiveness. But to achieve WHS compliance or the equivalent this is a very important task so we will almost always need to do it.

Commentary #2

The second item to think about – what is going to be key for the maintenance support side is a technique called Job Safety Analysis or Job Hazard Analysis. I’ve highlighted a couple of sources of information there, particularly I would recommend going to the American www.OSHA.gov site and the guidance that they provide on how to do a job hazard analysis. So, use that or use something else if something different is specified in the jurisdiction you’re working it, then go ahead and use that. But if you don’t have any [guidance] on what to do, this will help you.

This is all about – I’ve got a task to do, whatever it might be doing, how do I do it? Let’s analyse this step-by-step, or at least in reasonable size chunks, thinking about how we do the tasks that need to be done. Now, there’s the operator side, and then, of course, we’re always dealing with human beings working on the system or working with the system. So, we’re going to be seeing potentially a lot of Human Factors type techniques being relevant. And there are lots of tasks that we can think about, Hierarchical Task Analysis and that kind of approach is going to fit in with the Job Hazard Analysis as well. Those are going to link together quite well. There will also be things like workload analysis. Particularly for the operators, if we’re asking the operator to do a lot and to maintain a particular level of concentration or respond rapidly, we need to think about workload and too much workload and too little workload can make things worse.

There are lots of techniques out there, I’m not going to talk about Human Factors here. I’m going to be putting on a series on Human Factors techniques in cooperation with a specialist in that area. So, I’m not going to say more here.

For certain kinds of operators, let’s say, pilots, people navigating a ship and so on, drivers, there will be well-established ways that those operators are trained the way they have to operate. There will often be a legal framework and a regulatory framework that says how they have to operate. And then that may direct a particular kind of analysis to be done or a particular approach to be taken for how operators do their jobs. But equally, there is a vast range of operator roles in industry, in chemical plants. Various specialist operating roles where there’s an industry-specific approach to doing things. Or indeed the general approach may be left up to whoever is developing the system. So, there’s a huge range of approaches here that are going to be largely dictated by the concept of operations and also an awareness of what is relevant law, regulation, and good practice in a particular industry, in a particular situation. That’s where doing your Task 203, your safety requirements analysis really kicks in. It’s a very broad subject we’re covering here. You’ve got to get the specialist in to do it well.

Contracting #3

Now, I mention that these days we’re seeing more and more legacy and COTS systems being used and repurposed. Partly to save time and money. We’re not developing mega systems as often as we used to, particularly in defence, but also in many other walks of life as well. So, we may find ourselves evaluating a system where very little technical hazard analysis has been done because there are no developmental items and it’s even difficult to do analysis on legacy or a COTS system because we cannot get the data to do so. Perhaps we can’t get the data for commercial reasons, contractual reasons.

Or maybe we’ve got a legacy system that was developed in a different jurisdiction and whatever information is available with it just doesn’t fit the jurisdictional regulatory system that we’ve got to work in where we want to operate the system. This is very common. Australia, for example, [acquires] a lot of systems from abroad, which have not been developed in line with how we normally do things.

We could in theory just do Task 206 if there was no developmental hazard analysis to do but that’s not quite true. At a minimum, we will always need to do some Preliminary Hazard Listing and hazard analysis – that’s Tasks 201 and 202 respectively. And we will very definitely need to do some System Requirements Hazard Analysis, Task 203, to understand what we need to do for a particular system in a particular application, operating environment, and regulatory jurisdiction. So, we’re always going to have to do those and we may well have to look at the integration of COTS things and do some system-level analysis. That’s 204. We’re definitely going to need to do the early analyses. In fact, the client and the end-user representatives should be doing 201, 202 and 203 and then we may be in a position to finish things off with 206 for certain systems.

Contracting #4

Now, having said that, I’ve mentioned already that Task 206 can be very broad in scope and very wide-ranging. There’s a danger that we will turn Task 206 into a bottomless pit into which we pour money and effort and time without end. So, for most systems, we cannot afford to just do O&SHA across the board without any discernment or any prioritization.

So, we need to look at those other hazard analyses and prioritize those areas where people could get hurt. Particularly we should be using legacy and historical data here to say “What does – in reality, what does hurt people when looking after these systems or operating systems?” Again, as I’ve said before, in many industries there is a standard industry approach or good practice to how certain systems are operated, and maintained, and supported. So, if there is a standard industry approach available – particularly if we can justify that by available historical data – if that [is as good] as doing analysis, then why not just use the standard approach? It’s going to be easier to make a SFARP or a ALARP argument that way anyway. And why spend the money on analysis when we don’t have to? We could just spend the money on actually making the system safer. So, let’s not do analysis for the sake of doing analysis.

Also, there’s a strong synergy between the later tasks in the 200 series. There’s a strong linkage between this Task 206 and 207, which is Health Hazard Analysis. Also, there can be a strong linkage between Task 210, which is the Environmental Hazard Analysis. So, this trio of tasks focuses on the impact on living things, whether they be human beings or animals and plants and ecosystems and very often there’s a lot of overlap between them. For example, hazardous chemicals that are dangerous for humans are often dangerous for animals and plants and watercourses and so on and so forth. I’ll be talking about that more in the next session on Task 207.

One word of warning, however. Certainly, in Australia, we have got fixated on hazardous chemicals because we’ve had some very high-profile scandals involving HAZCHEM in the past. Now, there’s nothing wrong, of course, with learning from experience and applying rigorous standards when we know things have gone wrong in the past. But sometimes we go into a mindset of analysis for analysis sake. Dare I say, to cover people’s backsides rather than to do something useful. So, we need to focus on whether the presence of a HAZCHEM could be a problem. Whether people get exposed to it, not just that it’s there.

Certain chemicals may be quite benign in certain circumstances, and they only become dangerous after an emergency, for example. There are lots of things in the system that are perfectly safe until the system catches fire. Then when you’re trying to dispose or repair a fire damage system that can be very dangerous, for example. So, we need to be sensible about how we go about these things. Anyway, more on that in the next session.

Copyright Statement

That’s the commentary that I have on Task 206. As we said, it links very tightly with other things and we will talk about those in later sessions. I just like to point out that the “italic text in quotations” is from the Mil. standard. That is copyright free as most American government standards are. However, this presentation and my commentary, etc. are copyright of the Safety Artisan 2020.

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End: Operating & Support Hazard Analysis

So, that is the end of the lesson and it just remains for me to say thank you very much for your time and for listening. And I look forward to seeing you again soon. Cheers.