This post covers the Foreword to all Codes of Practice. In the 30-minute video, 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.
In particular, we explain the threefold significance of the statements found in the foreword.
Foreword to all Codes of Practice
“This Code of Practice on how to manage work health and safety risks is an approved code of practice under section 274 of the Work Health and Safety Act (the WHS Act).
An approved code of practice is a practical guide to achieving the standards of health, safety and welfare required under the WHS Act and the Work Health and Safety Regulations (the WHS Regulations).
A code of practice applies to anyone who has a duty of care in the circumstances described in the code. In most cases, following an approved code of practice would achieve compliance with the health and safety duties in the WHS Act, in relation to the subject matter of the code. Like regulations, codes of practice deal with particular issues and do not cover all hazards or risks that may arise. The health and safety duties require duty holders to consider all risks associated with work, not only those for which regulations and codes of practice exist.
Codes of practice are admissible in court proceedings under the WHS Act and Regulations. Courts may regard a code of practice as evidence of what is known about a hazard, risk or control and may rely on the code in determining what is reasonably practicable in the circumstances to which the code relates.
Compliance with the WHS Act and Regulations may be achieved by following another method, such as a technical or an industry standard, if it provides an equivalent or higher standard of work health and safety than the code.
An inspector may refer to an approved code of practice when issuing an improvement or prohibition notice.
This Code of Practice has been developed by Safe Work Australia as a model code of practice under the Council of Australian Governments’ Inter-Governmental Agreement for Regulatory and Operational Reform in Occupational Health and Safety for adoption by the Commonwealth, state and territory governments.
A draft of this Code of Practice was released for public consultation on 7 December 2010 and was endorsed by the Workplace Relations Ministers’ Council on 10 August 2011.
Scope and Application
This Code provides practical guidance for persons who have duties under the WHS Act and Regulations to manage risks to health and safety. The duty is placed on persons conducting a business or undertaking, including employers, self-employed, principal contractors, persons with management or control of a workplace, designers, manufacturers, importers and suppliers of plant, substances or structures that are used for work.
This Code applies to all types of work and all workplaces covered by the WHS Act. Other approved codes of practice should be referenced for guidance on managing the risk of specific hazards.
How to use this Code of Practice
In providing guidance, 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.
This Code also includes various references to sections of the WHS Act and to regulations which set out the legal requirements. These references are not exhaustive. The words ‘must’, ‘requires’ or ‘mandatory’ indicate that a legal requirement exists and must be complied with.“
This is the Transcript for Codes of Practice. In the 30-minute video, 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.
Transcript: Introduction to Codes of Practice
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.
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 the wake of an 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 SOFARP. 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, SOFARP. 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 SOFARP. 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.
Primacy of WHS & Regs
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.
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.
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.
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.
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.
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.
This is Mil-Std-882E Functional Hazard Analysis (FHA). Back to: Task 207.
The 200-series tasks fall into several natural groups. T208 requirements for Functional Hazard Analysis are reproduced (below). The full-length video is here.
T208 Requirements: Functional Hazard Analysis
208.1 Purpose. Task 208 is to perform and document a Functional Hazard Analysis (FHA) of an individual system or subsystem(s). The FHA is primarily used to identify and classify the system functions and the safety consequences of functional failure or malfunction, i.e. hazards. These consequences will be classified in terms of severity for the purpose of identifying the safety-critical functions (SCFs), safety-critical item (SCIs), safety-related functions (SRFs), and safety-related items (SRIs) of the system. SCFs, SCIs, SRFs, and SRIs will be allocated or mapped to the system design architecture in terms of hardware, software, and human interfaces to the system. The FHA is also used to identify environmental and health related consequences of functional failure or malfunction. The initial FHA should be accomplished as early as possible in the Systems Engineering (SE) process to enable the engineer to quickly account for the physical and functional elements of the system for hazard analysis purposes; identify and document SCFs, SCIs, SRFs, and SRIs; allocate and partition SCFs and SRFs in the software design architecture; and identify requirements and constraints to the design team.
208.2 Task description. The contractor shall perform and document a FHA to analyze functions associated with the proposed design. The FHA should be based on the best available data, including mishap data (if obtainable) from similar systems and other lessons learned. This effort will include inputs, outputs, critical interfaces, and the consequence of functional failure.
208.2.1 At a minimum, the FHA shall consider the following to identify and evaluate functions within a system: a. Decomposition of the system and its related subsystems to the major component level. b. A functional description of each subsystem and component identified. c. A functional description of interfaces between subsystems and components. Interfaces should be assessed in terms of connectivity and functional inputs and outputs. d. Hazards associated with loss of function, degraded function or malfunction, or functioning out of time or out of sequence for the subsystems, components, and interfaces. The list of hazards should consider the next effect in a possible mishap sequence and the final mishap outcome. e. An assessment of the risk associated with each identified failure of a function, subsystem, or component. Estimate severity, probability, and Risk Assessment Code (RAC) using the process described in Section 4 of this Standard. The definitions in Tables I and II, and the RACs in Table III shall be used, unless tailored alternative definitions and/or a tailored matrix are formally approved in accordance with Department of Defense (DoD) Component policy. f. An assessment of whether the functions identified are to be implemented in the design hardware, software, or human control interfaces. This assessment should map the functions to their implementing hardware or software components. Functions allocated to software should be mapped to the lowest level of technical design or configuration item prior to coding (e.g., implementing modules or use cases). g. An assessment of Software Control Category (SCC) for each Safety-significant Software Function (SSSF). Assign a Software Criticality Index (SwCI) for each SSSF mapped to the software design architecture. h. A list of requirements and constraints (to be included in the specifications) that, when successfully implemented, will eliminate the hazard or reduce the risk. These requirements could be in the form of fault tolerance, detection, isolation, annunciation, or recovery.
208.2.2 The contractor shall update the FHA following system design or operational changes as necessary.
208.2.3 The contractor shall document results of the analysis to include the following: a. System description. This summary describes the physical and functional characteristics of the system and its subsystems. Reference to more detailed system and subsystem descriptions, including specifications and detailed review documentation, shall be supplied when such documentation is available. b. Hazard analysis methods and techniques. Provide a description of each method and technique used in conduct of the analysis. Include a description of assumptions made for each analysis and the qualitative or quantitative data used. c. Hazard analysis results. Contents and formats may vary according to the individual requirements of the program and methods and techniques used. As applicable, analysis results should be captured in the Hazard Tracking System (HTS).
208.3 Details to be specified. The Request for Proposal (RFP) and Statement of Work (SOW) shall include the following, as applicable: a. Imposition of Task 208. (R) b. Identification of functional discipline(s) to be addressed by this task. (R) c. Desired analysis methodologies and technique(s) and any special data elements, format, or data reporting requirements (consider Task 106, Hazard Tracking System). d. Applicable requirements, specifications, and standards. e. Concept of operations. f. Other specific hazard management requirements, e.g., specific risk definitions and matrix to be used on this program.
This is Mil-Std-882E Health Hazard Analysis (HHA). Back to: Task 206.
The 200-series tasks fall into several natural groups. Task 207 addresses Health Hazard Analysis.
HEALTH HAZARD ANALYSIS
207.1 Purpose. Task 207 is to perform and document a Health Hazard Analysis (HHA) to identify human health hazards, to evaluate proposed hazardous materials and processes using such materials, and to propose measures to eliminate the hazards or reduce the associated risks when the hazards cannot be eliminated.
207.2 Task description. The contractor shall perform and document a HHA that includes evaluations of the potential effects resulting from exposure to hazards. HHAs incorporate the identification, assessment, characterization, control, and communication of hazards in the workplace or environment. Following this systems approach, evaluations should consider the total health impact of all stressors contacting the human operator or maintainer. Whenever possible, HHAs should consider the synergistic effects of all agents present. An HHA shall also evaluate the hazards and costs due to system component materials, evaluate alternative materials for those components, and recommend materials that reduce the associated risk. Materials will be evaluated if (because of their physical, chemical, or biological characteristics; quantity; or concentrations) they cause or contribute to adverse effects in organisms or offspring or pose substantial present or future danger to the environment. The analysis shall include consideration of the generation of wastes and by-products.
207.2.1 A health hazard is a condition, inherent to the operation, maintenance, storage, transport, use of materiel, or disposal, that can cause death, injury, acute or chronic illness, disability, or reduced job performance of personnel by exposure to physiological stresses. Specific health hazards and impacts that shall be considered include:
a. Chemical hazards (e.g., materials that irritate or are hazardous because of physical properties such as flammability, toxicity, carcinogenicity, or propensity to deprive an organism of oxygen).
b. Physical hazards (e.g., acoustical energy, vibration, acceleration/deceleration, barostress, heat or cold stress, finished materials, and shrapnel).
c. Biological hazards (e.g., bacteria, viruses, fungi, and mold)
d. Ergonomic hazards (e.g., hazards that occur as a consequence of engaging in activities that impose excessive physical or cognitive demands, such as assuming non-neutral postures, sustaining harsh body contacts or load-bearing stress, performing taxing muscular exertions, sustaining long duration activity, etc.).
e. Other hazardous or potentially hazardous materials that may be formed by the test, maintenance, operation, or final disposal/recycling of the system.
f. Non-ionizing radiation hazards. Provide a listing of all non-ionizing (radio frequency (RF) and laser) transmitters contained in the system. List all parameters required to determine the non-ionizing radiation hazards of the system, including RF shock and burn hazards, RF hazard distances, laser eye and skin hazard distances, etc.
g. Ionizing radiation hazards. Provide a listing of all system ionizing radiation sources (including isotopes), quantities, activities, and hazards.
207.2.2 The HHA shall provide the following categories of information:
a. Hazard identification. Identify the hazardous agents by name(s), Chemical Abstract Service (CAS) number if available, and the affected system components and processes. Hazard identification also includes:
(1) Exposure pathway description. Describe the conditions and mode by which a hazardous agent can come in contact with a living organism. Include a description of the mode by which the agent is transmitted to the organism (e.g., ingestion, inhalation, absorption, or other mode of contact), as well as evidence of environmental fate and transport. Consider components of the system which may come into contact with users.
(2) Exposure characterization. Characterize exposures by providing measurements or estimates of energy intensities or substance quantities and concentrations. Provide either a description of the assessment process or the name of the assessment tool or model used. For material hazards, estimate the expected use rate of each hazardous material for each process or component for the subsystem, total system, and program-wide impact. Consider bio-availability and biological uptake if applicable.
b. Severity and probability. Estimate severity, probability, and Risk Assessment Code (RAC) using the process described in Section 4 of this Standard. The definitions in Tables I and II, and the RACs in Table III shall be used, unless tailored alternative definitions and/or a tailored matrix are formally approved in accordance with Department of Defense (DoD) Component policy. As appropriate for each hazard, describe the potential acute and chronic health risks (e.g., carcinogenicity, flammability, and reactivity).
c. Mitigation Strategy. Recommend a mitigation strategy for each hazard. Assign a target risk assessment code for each hazard based on the degree of risk reduction achievable by the mitigation.
207.2.3 In addition to the information required in 207.2.2 above, the following sections describe the HHA or part of the HHA that provides Hazardous Material (HAZMAT) evaluation, ergonomics evaluation, or describes the operational environment.
188.8.131.52 The HHA or part of the HHA providing HAZMAT evaluation, in addition to the information required in 207.2.2 above, shall:
a. Identify the HAZMAT by quantity, characteristics, and concentrations of the materials in the system. Identify source documents, such as Material Safety Data Sheets (MSDSs), and information from vendors and subvendors for components of systems and subsystems. At a minimum, if available, material identification includes material identity, common or trade names, chemical name, CAS number, national stock number (NSN), local stock number, physical state, and manufacturer and supplier names and contact information (including information from the Department of Defense HAZMAT information resource system).
b. Characterize material hazards, including hazardous waste, and determine associated risks. Examine acute health, chronic health, carcinogenic, contact, flammability, reactivity, and environmental hazards.
c. Describe how the HAZMAT is used for each process or component for the subsystem and total system.
d. Estimate the usage rate of each HAZMAT for each process or component for the subsystem, total system, and program-wide impact.
e. Recommend the disposition for each HAZMAT (to include hazardous waste) identified. Material substitution or altered processes shall be considered to reduce risks associated with the material hazards while evaluating the impact on program costs.
184.108.40.206 In addition to the information required in 207.2.2 above, the HHA or part of the HHA providing ergonomics evaluation shall:
a. Describe the purpose of the system and the mission scenarios in which the system will be used. This description should include all performance criteria established by the customer. If known, include manpower estimates that the customer anticipates will be allocated toward operating and maintaining the system. Also describe:
(1) Physical properties of all system components that personnel will manually handle or wear, and that will support personnel body weight (such as seating and bedding).
(2) A task analysis that lists the physical and cognitive actions that operators will perform during typical operations and routine maintenance.
(3) Exposures to mechanical stress encountered while performing work tasks.
b. Identify characteristics in the design of the system or work processes that could degrade performance or increase the likelihood of erroneous actions that may result in mishaps.
c. Determine manpower requirements to operate and maintain the system from the sum of the physical and cognitive demands imposed on personnel. Recommend a strategy to reduce these demands through equipment or job redesign if the determined requirements exceed the projected manpower allocation. Such recommendations may also be considered where they provide significant manpower or cost savings. Recommend methodologies to further optimize system design and control exposures to mechanical stress from load bearing, manual handling, and other physical activities through appropriate engineering and administrative controls that may include reducing load and force requirements, adding material handling aids or tools, reducing non-neutral postures, reducing frequency of repeated motion, increasing the manpower allocation, or redistributing tasks among personnel manning the system.
220.127.116.11 The HHA or part of the HHA providing the information required in 207.2.1 shall describe the operational environment, including how the equipment or system(s) will be used and maintained and the location in which it will be operated and maintained. Identify acoustic noise, vibration, acceleration, shock, blast, and impact force levels and related human exposures associated with comparable legacy systems, including personnel operating and maintaining these systems and exposures/levels in the surrounding (external) environment, particularly where exposures exceeding regulatory or recommended exposure standards have been documented or can reasonably be anticipated.
a. Assess and describe anticipated whole body movement, including whole body vibration, vehicle shock, and motions that are likely to result in musculoskeletal disorders, disorientation, or motion sickness. This information may be provided through a description of operating parameters, such as speed and vehicle loading; environment of operation and external influences, such as waves for marine vehicles; terrain conditions for land vehicles; and the position and seating characteristics of occupants.
b. Describe and quantify the potential for blast overpressure and other sudden barotrauma and the estimated pressure changes, time and rate of onset, and frequency of occurrence.
c. Identify and categorize main noise and vibration sources in the new or modified system(s). Include:
(1) The type of equipment and exposures associated with its operation in related systems. Where available or readily computed, the sound power level of relevant equipment shall be determined
(2) Octave band analysis and identification of predominant frequencies of operation.
(3) Impulse, impact, and steady-state noise sources, including anticipated intensity (dB) scale, periodicity/frequency of occurrence, and design and operational factors that may influence personnel and weapon system exposures.
d. Calculate estimated noise, blast, and vibration levels prior to final design and measurement of noise, blast, and vibration levels after construction of prototypes or initial demonstration models. If the calculated levels exceed exposure limits per Military Standard (MIL-STD)-1474 or Department of Defense (DoD) Component-specific standards, perform evaluations to include frequency analysis and estimated noise exposures to steady state and impulse noise. Describe, via calculation, the estimated resonant frequencies for occupants in seating and the effect of whole body vibration. These frequencies should be compared to known guidelines (e.g., MIL-STD-1472, International Organization for Standardization (ISO) 2631-1, ISO 2631-2, and ISO 2631-5) for whole body vibration with reference to degree of movement, frequency, and anticipated duration of exposures. Where feasible, anticipated target organ systems (e.g., back, kidneys, hands, arms, and head) should be identified and the likelihood of discordant motions should be described. Identify potential alternative processes and equipment that could reduce the adverse impacts.
e. Describe the anticipated effect of protective equipment and engineering changes, if required, for mitigating personnel exposures to noise and vibration, as well as the projected total number of individuals per platform and the total population exposed during the anticipated life of the system. Describe advanced hearing protective devices using active noise cancellation with regard to frequency and scale of noise attenuation and any frequency “trade-offs” in attenuation achieved. Use of protective equipment shall describe the optimal (design) and anticipated effective noise reduction and vibration reduction of the protective equipment. Document the methodology and assumptions made in calculations.
f. Describe the limitations of protective equipment and the burden imposed with regard to weight, comfort, visibility, and ranges of population accommodated, and quantify these parameters where feasible. Describe conformance to relevant design and performance standards for protective equipment.
18.104.22.168. The HHA or part of the HHA providing non-ionizing radiation evaluation, in addition to the information required in 207.2 above, shall refer to [N.B. may not be applicable in your jurisdiction] MIL-STD-464, MIL-STD1425, and Military Handbook (MIL-HDBK)-454 [N.B. may not be applicable in your jurisdiction] for further guidance and clarification on associated tasks. Ionizing and non-ionizing radiation should be evaluated in accordance with [N.B. may not be applicable in your jurisdiction] DoD Military Standards consistent with Department of Defense Instruction (DoDI) 6055.11, Protection of DoD Personnel from Electromagnetic Fields and DoDI 6055.15, DoD Laser Protection Program [N.B. may not be applicable in your jurisdiction].
207.2.4 Include a list of source materials used in conducting the analysis. It may include Government and contractor reports, standards, criteria, technical manuals, and specifications.
207.3 Details to be specified. The Request for Proposal (RFP) and Statement of Work (SOW) shall include the following, as applicable:
a. Imposition of Task 207 and identification of related tasks in the SOW or other contract requirements. (R)
b. Selected hazards, hazardous areas, hazardous materials, or other specific items to be examined or excluded.
c. Desired analysis methodologies and technique(s) and any special data elements, format, or data reporting requirements (consider Task 106, Hazard Tracking System).
d. Sources of information that will be made available and should be utilized. For example, DoD Service-specific HAZMAT policies may apply for in-Service maintenance, testing, and disposal.
e. Standards and criteria for acceptable exposures and controls.
f. A list of mandatory references, including specific issue dates. The following list of references represents a starting point for information to support this task, but is not intended to be comprehensive.
[N.B. may not be applicable in your jurisdiction]
(1) 29 Code of Federal Regulations (CFR) 1910, U.S. Department of Labor, Occupational Safety and Health Administration (OSHA), General Industry Regulations.
(2) 29 CFR 1910.1200, OSHA Hazard Communication.
(3) DODI 6055.12, DoD Hearing Conservation Program.
(4) DoD Handbook 743, Anthropometry of U.S. Military Personnel (Metric).
(5) MIL-STD-464, Electromagnetic Environmental Effects Requirements for Systems.
(6) MIL-STD-1425, Safety Design Requirements for Military Lasers and Associated Support Equipment.
(7) MIL-STD-1472, DoD Design Criteria Standard for Human Engineering.
(8) MIL-STD-1474, DoD Design Criteria Limit Noise Limits.
(9) MIL-HDBK-454, General Guidelines for Electronic Equipment.
(10) MIL-HDBK-1908, Definitions of Human Factors Terms.
(11) MIL-STD-46855, Human Engineering Requirements for Military Systems, Equipment, and Facilities.
(12) U.S. Army Health Hazard Assessors Guide, U.S. Army Center for Health Promotion and Preventive Medicine.
(13) U.S. Army Manpower and Personnel Integration (MANPRINT) Program.
(14) U.S. Army Regulation 40-10, Health Hazard Assessment Program in Support of the Army Acquisition Process.
(15) Department of the Army Pamphlet 40-501, Hearing Conservation Program.
(16) Navy and Marine Corps (NAVMC) Directive 5100.8, Marine Corps Occupational Safety and Health (OSH) Program Manual
(17) NAVMC Public Health Center Technical Manual 6260.51.99-2.
(18) Navy Bureau of Medicine and Surgery Instruction 6270.8A, Obtaining Health Hazard Assessments.
(19) Marine Corps Order 6260.1E, Marine Corps Hearing Conservation Program.
(20) U.S. Air Force Manual 48-153, Health Risk Assessment.
(21) Air Force Occupational Safety and Health (AFOSH) STD 48-9, Radio Frequency Radiation (RFR) Safety Program.
(22) AFOSH STD 91-501, Air Force Consolidated Occupational Safety Standard.
(23) General Services Administration Federal Standard 313, Material Safety Data, Transportation Data, and Disposal Data for Hazardous Materials Furnished to Government Activities.
(24) ISO 2631-1:1997, Mechanical Vibration and Shock – Evaluation of Human Exposure to Whole Body Vibration and Shock. Part 1: General Requirements.
(25) ISO 2631-2, Mechanical Vibration and Shock – Evaluation of Human Exposure to Whole Body Vibration. Part 2: Vibration in Buildings (1 Hz to 80 Hz).
(26) ISO 2631-5, Mechanical Vibration and Shock – Evaluation of Human Exposure to Whole Body Vibration and Shock. Part 5: Method for Evaluation of Vibration Containing Multiple Shocks.
(27) ISO 5349, Guide for the Measurement and the Assessment of Human Exposure to Hand Transmitted Vibration.
(28) American National Standards Institute (ANSI) S2.70, Guide for Measurement and Evaluation of Human Exposure to Vibration Transmitted to the Hand.
(29) Institute of Electrical and Electronics Engineers (IEEE) Standard for Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 KHz to 300 GHz, IEEE Standards Coordinating Committee on Non-Ionizing Radiation Hazards.
(30) Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, American Conference of Governmental Industrial Hygienists.
(31) American Society for Testing and Materials (ASTM) E2552 – Standard Guide for Assessing the Environmental and Human Health Impacts of New Energetic Compounds.
[N.B. may not be applicable in your jurisdiction]
g. Concept of operations.
h. Projected manpower allocation in support of 22.214.171.124.
i. Other specific hazard management requirements, e.g., specific risk definitions and matrix to be used on this program.
In the full-length video (55 minutes long), 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.)
Task 207: Health Hazard Analysis Transcript
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 defence 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.
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 COSH, 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 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 to 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 characterisation 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 is 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?
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.
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. Then 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. We may have to go – 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.
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.
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. An 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.
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, for example, but this is a good example of how we’re going to you might have to do it in another country, 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.
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 that. 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 HAZ CHEM 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.
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 so 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 analysing 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 analysing 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 afterwards? 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 afterwards? 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.
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.
And for more information on this topic and others, and for more resources, do please visit www.safetyartisan.com or you can also go to www.patreon.com and look at the Safety Artisan page. Now the two are linked together. So, if you go to one and you want to click on a video that you need to subscribe via Patreon, it’ll sort all of that out for you. But also, there are lots of free resources on the website as well, and there’s plenty of free videos to look at.
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.
In this 40-minute video, ‘Introduction to Human Factors’, I am pleased to welcome Peter Benda to The Safety Artisan.
Peter is a colleague and Human Factors specialist, who has 23 years’ experience in applying Human Factors to large projects in all kinds of domains. In this session we look at some fundamentals: what does Human Factors engineering aim to achieve? Why do it? And what sort of tools and techniques are useful? As this is The Safety Artisan, we also discuss some real-world examples of how erroneous human actions can contribute to accidents, and how Human Factors discipline can help to prevent them.
This post is the Transcript: Intro to Human Factors.
In the 40-minute video, I’m joined by a friend, colleague and Human Factors specialist, Peter Benda. Peter has 23 years of experience in applying Human Factors to large projects in all kinds of domains. In this session we look at some fundamentals: what does Human Factors engineering aim to achieve? Why do it? And what sort of tools and techniques are useful? As this is The Safety Artisan, we also discuss some real-world examples of how Human Factors can contribute to accidents or help to prevent them.
Transcript: Intro to Human Factors
Simon: Hello, everyone, and welcome to the Safety Artisan: Home of Safety Engineering Training. I’m Simon and I’m your host, as always. But today we are going to be joined by a guest, a Human Factors specialist, a colleague, and a friend of mine called Peter Benda. Now, Peter started as one of us, an ordinary engineer, but unusually, perhaps for an engineer, he decided he didn’t like engineering without people in it. He liked the social aspects and the human aspects and so he began to specialize in that area. And today, after twenty-three years in the business, and first degree and a master’s degree in engineering with a Human Factors speciality. He’s going to join us and share his expertise with us.
So that’s how you got into it then, Peter. For those of us who aren’t really familiar with Human Factors, how would you describe it to a beginner?
Peter: Well, I would say it’s The Joint Optimization Of Human-Machine Systems. So it’s really focusing on designing systems, perhaps help holistically would be a term that could be used, where we’re looking at optimizing the human element as well as the machine element. And the interaction between the two. So that’s really the key to Human Factors. And, of course, there are many dimensions from there; environmental, organizational, job factors, human and individual characteristics. All of these influence behaviour at work and health and safety. Another way to think about it is the application of scientific information concerning humans to the design of systems. Systems are for human use, which I think most systems are.
Simon: Indeed. Otherwise, why would humans build them?
Peter: That’s right. Generally speaking, sure.
Simon: So, given that this is a thing that people do then. Perhaps we’re not so good at including the human unless we think about it specifically?
Peter: I think that’s fairly accurate. I would say that if you look across industries, and industries are perhaps better at integrating Human Factors, considerations or Human Factors into the design lifecycle, that they have had to do so because of the accidents that have occurred in the past. You could probably say this about safety engineering as well, right?
Simon: And this is true, yes.
Peter: In a sense, you do it because you have to because the implications of not doing it are quite significant. However, I would say the upshot, if you look at some of the evidence –and you see this also across software design and non-safety critical industries or systems –that taking into account human considerations early in the design process typically ends up in better system performance. You might have more usable systems, for example. Apple would be an example of a company that puts a lot of focus into human-computer interaction and optimizing the interface between humans and their technologies and ensuring that you can walk up and use it fairly easily. Now as time goes on, one can argue how out how well Apple is doing something like that, but they were certainly very well known for taking that approach.
Simon: And reaped the benefits accordingly and became, I think, they were the world’s number one company for a while.
Peter: That’s right. That’s right.
Simon: So, thinking about the, “So why do it?” What is one of the benefits of doing Human Factors well?
Peter: Multiple benefits, I would say. Clearly, safety and safety-critical systems, like health and safety; Performance, so system performance; Efficiency and so forth. Job satisfaction and that has repercussions that go back into, broadly speaking, that society. If you have meaningful work that has other repercussions and that’s sort of the angle I originally came into all of this from. But, you know, you could be looking at just the safety and efficiency aspects.
Simon: You mentioned meaningful work: is that what attracted you to it?
Peter: Absolutely. Absolutely. Yes. Yes, like I said I had a keen interest in the sociology of work and looking at work organization. Then, for my master’s degree, I looked at lean production, which is the Toyota approach to producing vehicles. I looked at multiskilled teams and multiskilling and job satisfaction. Then looking at stress indicators and so forth versus mass production systems. So that’s really the angle I came into this. If you look at it, mass production lines where a person is doing the same job over and over, it’s quite repetitive and very narrow, versus the more Japanese style lean production. There are certainly repercussions, both socially and individually, from a psychological health perspective.
Simon: So, you get happy workers and more contented workers-
Peter: –And better quality, yeah.
Simon: And again, you mentioned Toyota. Another giant company that’s presumably grown partly through applying these principles.
Peter: Well, they’re famous for quality, aren’t they? Famous for reliable, high-quality cars that go on forever. I mean, when I moved from Canada to Australia, Toyota has a very, very strong history here with the Land Cruiser, and the high locks, and so forth.
Simon: All very well-known brands here. Household names.
Peter: Are known to be bombproof and can outlast any other vehicle. And the lean production system certainly has, I would say, quite a bit of responsibility for the production of these high-quality cars.
Simon: So, we’ve spoken about how you got into it and “What is it?” and “Why do it?” I suppose, as we’ve said, what it is in very general terms but I suspect a lot of people listening will want to know to define what it is, what Human Factors is, based on doing it. On how you do it. It’s a long, long time since I did my Human Factors training. Just one module in my masters, so could you take me through what Human Factors involves these days in broad terms.
Peter: Sure, I actually have a few slides that might be useful –
Simon: – Oh terrific! –
Peter: –maybe I should present that. So, let me see how well I can share this. And of course, sometimes the problem is I’ll make sure that – maybe screen two is the best way to share it. Can you see that OK?
Simon: Yeah, that’s great.
Introduction to Human Factors
Peter: Intro to Human Factor. So, as Stewart Dickinson, who I work with at human risk solutions and I have prepared some material for some courses we taught to industry. I’ve some other material and I’ll just flip to some of the key slides going through “What is Human Factors”. So, let me try to get this working and I’ll just flip through quickly.
Definitions of Human Factors
Peter: So, as I’ve mentioned already, broadly speaking, environmental, organizational, and job factors, and human individual characteristics which influence behaviour at work in a way that can which can affect health and safety. That’s a focus of Human Factors. Or the application of scientific information concerning humans to the design of objects, systems and environments for human use. You see a pattern here, fitting work to the worker. The term ergonomics is used interchangeably with Human Factors. It also depends on the country you learn this in or applied in.
Simon: Yes. In the U.K., I would be used to using the term ergonomics to describe something much narrower than Human Factors but in Australia, we seem to use the two terms as though they are the same.
Peter: It does vary. You can say physical ergonomics and I think that would typically represent when people think of ergonomics, they think of the workstation design. So, sitting at their desk, heights of tables or desks, and reach, and so on. And particularly given the COVID situation, there are so many people sitting at their desks are probably getting some repetitive strain –
Simon: –As we are now in our COVID 19 [wo]man caves.
Peter: That’s right! So that’s certainly an aspect of Human Factors work because that’s looking at the interaction between the human and the desk/workstation system, so to speak, on a very physical level.
But of course, you have cognitive ergonomics as well, which looks of perceptual and cognitive aspects of that work. So Human Factors or ergonomics, broadly speaking, would be looking at these multi-dimensional facets of human interaction with systems.
Definitions of Human Factors (2)
Peter: Some other examples might be the application of knowledge of human capabilities and limitations to design, operation and maintenance of technological systems, and I’ve got a little distilled –or summarized- bit on the right here. The Human Factors apply scientific knowledge to the development and management of the interfaces between humans and rail systems. So, this is obviously in the rail context so you’re, broadly speaking, talking in terms of technological systems. That covers all of the people issues. We need to consider to assure safe and effective systems or organizations.
Again, this is very broad. Engineers often don’t like these broad topics or broad approaches. I’m an engineer, I learned this through engineering which is a bit different than how some people get into Human Factors.
Simon: Yeah, I’ve met a lot of human factor specialists who come in from a first degree in psychology.
Peter: That’s right. I’d say that’s fairly common, particularly in Australia and the UK. Although, I know that you could take it here in Australia in some of the engineering schools, but it’s fairly rare. There’s an aviation Human Factors program, I think, at Swinburne University. They used to teach it through mechanical engineering there as well. I did a bit of teaching into that and I’m not across all of the universities in Australia, but there are a few. I think the University of the Sunshine Coast has quite a significant group at the moment that’s come from, or, had some connection to Monash before that. Well, I think about, when I’m doing this work, of “What existing evidence do we have?” Or existing knowledge base with respect to the human interactions with the system. For example, working with a rail transport operator, they will already have a history of incidents or history of issues and we’d be looking to improve perhaps performance or reduce the risk associated with the use of certain systems. Really focusing on some of the evidence that exists either already in the organization or that’s out there in the public domain, through research papers and studies and accident analyses and so forth. I think much like safety engineering, there would be some or quite a few similarities in terms of the evidence base –
Simon: – Indeed.
Peter: – Or creating that evidence through analysis. So, using some analytical techniques, various Human Factors methods and that’s where Human Factors sort of comes into its own. It’s a suite of methods that are very different from what you would find in other disciplines.
Simon: Sure, sure. So, can you give us an overview of these methods, Peter?
Peter: There are trying to think of a slide for this. Hopefully, I do.
Simon: Oh, sorry. Have I taken you out of sequence?
Peter: No, no. Not out of sequence. Let me just flip through, and take a look at –
The Long Arm of Human Factors
Peter: This is probably a good sort of overview of the span of Human Factors, and then we can talk about the sorts of methods that are used for each of these – let’s call them –dimensions. So, we have what’s called the long arm of Human Factors. It’s a large range of activities from the very sort of, as we’re talking about, physical ergonomics, e.g. sitting at a desk and so on, manual handling, workplace design, and moving to interface design with respect to human-machine interfaces- HMIs, as they’re called, or user interfaces. There are techniques, manual handling techniques and analysis techniques – You might be using something like a task analysis combined with a NIOSH lifting equation and so on. Workplace design, you’d be looking at anthropocentric data. So, you would have a dataset that’s hopefully representative of the population you’re designing for, and you may have quite specific populations. So Human Factors, engineering is fairly extensively used, I would say, in military projects –in the military context-
Simon: – Yes.
Peter: – And there’s this set of standards, the Mil standard, 1472G, for example, from the United States. It’s a great example that gives not only manual handling standards or guidelines, workplace design guidelines in the workplace, in a military sense, can be a vehicle or on a ship and so on. Or on a base and so forth.
Interface design- So, if you’re looking at from a methods perspective, you might have usability evaluations, for example. You might do workload’s studies and so forth, looking at how well the interface supports particular tasks or achieving certain goals.
Human error –There are human error methods that typically leverage off of task models. So, you’d have a task model and you would look at for that particular task, what sorts of errors could occur and the structured methods for that?
Simon: Yes, I remember human task analysis –seeing colleagues use that on a project I was working on. It seemed quite powerful for capturing these things.
Peter: It is and you have to pragmatically choose the level of analysis because you could go down to a very granular level of detail. But that may not be useful, depending on the sort of system design you’re doing, the amount of money you have, and how critical the task is. So, you might have a significantly safety-critical task, and that might need quite a detailed analysis. An example there would be – there was a … I think it’s the … You can look up the accident analysis online, I believe it’s the Virgin Galactic test flight. So this is one of these test flights in the U.S. – I have somewhere in my archive of accident analyses – where the FAA had approved the test flights to go ahead and there was a task where – I hope I don’t get this completely wrong – where one of the pilots (there are two pilots, a pilot and a co-pilot) and this test aeroplane where they had to go into high-altitude in this near-space vehicle. They were moving at quite a high speed and there was a particular task where they had to do something with – I think they had to slow down and then you could … slow down their aeroplane, I guess, by reducing the throttle and then at a certain point/a certain speed, you could deploy, or control, the ailerons or some such, wing-based device, and the task order was very important. And what had happened was a pilot or the co-pilot had performed the task slightly out of order. As a matter of doing one thing first before they did another thing that led to the plane breaking up. And fortunately, one of the pilots survived, unfortunately, one didn’t.
Simon: So, very severe results from making a relatively small mistake.
Peter: So that’s a task order error, which is very easy to do. And if the system had been designed in a way to prevent that sort of capability to execute that action at that point. That would have been a safer design. At that level, you might be going down to that level of analysis and kind of you get called keystroke level analysis and so on
Simon: – Where it’s justified, yes.
Peter: Task analysis is, I think, probably one of the most common tools used. You also have workload analysis, so looking at, for example, interface design. I know some of the projects we were working on together, Simon, workload was a consideration. There are different ways to measure workload. There’s a NASA TLX, which is a subjective workload. Questionnaire essentially, that’s done post-task but it’s been shown to be quite reliable and valid as well. So, that instrument is used and there are a few others that are used. It depends on the sort of study you’re doing, the amount of time you have and so forth. Let me think, that’s workload analysis.
Safety culture- I wouldn’t say that’s my forte. I’ve done a bit of work on safety culture, but that’s more organizational and the methods there tend to be more around culpability models and implementing those into the organizational culture.
Simon: So, more governance type issues? That type of thing?
Peter: Yes. Governance and – whoops! Sorry, I didn’t mean to do that. I’m just looking at the systems and procedure design. The ‘e’ is white so it looks like it’s a misspelling there. So it’s annoying me …
Simon: – No problem!
Peter: Yes. So, there are models I’ve worked with at organization such as some rail organizations where they look at governance, but also in terms of appropriate interventions. So, if there’s an incident, what sort of intervention is appropriate? So, essentially use sort of a model of culpability and human error and then overlay that or use that as a lens upon which to analyse the incident. Then appropriately either train employees or management and so on. Or perhaps it was a form of violation, a willful violation, as it may be –
Simon: – Of procedure?
Peter: Yeah, of procedure and so on versus a human error that was encouraged by the system’s design. So, you shouldn’t be punishing, let’s say, a train driver for a SPAD if the –
Simon: – Sorry, that’s a Signal Passed At Danger, isn’t it?
Peter: That’s right. Signal Passed At Danger. So, it’s certainly possible that the way the signalling is set up leads to a higher chance of human error. You might have multiple signals at a location and it’s confusing to figure out which one to attend to and you may misread and then you end up SPADing and so on. So, there are, for example, clusters of SPADs that will be analysed and then the appropriate analysis will be done. And you wouldn’t want to be punishing drivers if it seemed to be a systems design issue.
Simon: Yes. I saw a vivid illustration of that on the news, I think, last night. There was a news article where there was an air crash that tragically killed three people a few months ago here in South Australia. And the newsies report today is saying it was human error but when they actually got in to reporting what had happened, it was pointed out that the pilot being tested was doing – It was a twin-engine aeroplane and they were doing an engine failure after take-off drill. And the accident report said that the procedure that they were using allowed them to do that engine failure drill at too low an altitude. So, if the pilot failed to take the correct action very quickly – bearing in mind this is a pilot being tested because they are undergoing training – there was no time to recover. So, therefore, the aircraft crashed. So, I thought, ”Well, it’s a little bit unfair just to say it’s a human error when they were doing something that was in intrinsically inappropriate for a person of that skill level.”
Peter: That’s an excellent example and you hear this in the news a lot. Human error, human error and human error. The cause of this, I think, with the recent Boeing problems with the flight control system for the new 737s. And of course, there will be reports. Some of the interim reports already talk about some of these Human Factors, issues inherent in that, and I would encourage people to look up the publicly available documentation on that-
Simon: – This is the Boeing 737 Max accidents in Indonesia and in Ethiopia, I think.
Peter: That’s correct. That’s correct. Yes, absolutely. And pilot error was used as the general explanation but under further analysis, you started looking at that error. That so to speak error perhaps has other causes which are systems design causes, perhaps. So these things are being investigated but have been written about quite extensively. And you can look at, of course, any number of aeroplane accidents and so on. There’s a famous Air France one flying from Brazil to Paris, from what I recall. It might have been Rio de Janeiro to Paris. Where the pitot –
Simon: – Yeah, pitot probes got iced up.
Peter: Probes, they iced up and it was dark. So, the pilots didn’t have any ability to gauge by looking outside. I believe it was dark or it might have been a storm. There’s some difficulty in engaging what was going on outside of the aeroplane and there again misreads. So, stall alarms going off and so off, I believe. There were some mis-readings on the airspeed coming from the sensors, essentially. And then the pilots acted according to that information, but that information was incorrect. So, you could say there were probably a cascade of issues that occurred there and there’s a fairly good analysis one can look up that looks at the design. I believe it was an Airbus. It was the design of the Airbus. So, we had one pilot providing an input in one direction to the control yoke and the other pilot in the other direction. There are a number of things that broke down. And typically, you’ll see this in accidents. You’ll have a cascade as they’re trying to troubleshoot and can’t figure out what’s going on they’ll start applying various approaches to try and remedy the situation and people begin to panic and so on.
And you have training techniques, a crew resource management, which certainly has a strong Human Factors element or comes out of the Human Factors world, which looks at how to have teams and cockpits. And in other situations working effectively in emergency situations And that’s sort of after analysing, of course, failures.
Simon: Yes, and I think CRM, crew resource management, has been adopted not just in the airline industry, but in many other places as well, hasn’t it?
Peter: Operating theatres, for example. There’s quite a bit of work in the 90s that started with I think it was David Gaba who I think was at Stanford – this is all from memory. That then look at operating theatres. In fact, the Monash Medical Centre in Clayton had a simulation centre for operating theatres where they were applying these techniques to training operating theatre personnel. So, surgeons, anaesthetists, nurses and so forth.
Simon: Well, thanks, Peter. I think and I’m sorry, I think I hijacked you’ll the presentation, but –
Peter: It’s not really a presentation anyway. It was more a sort of better guidance there. We’re talking about methods, weren’t we? And it’s easy to go then from methods to talking about accidents. Because then we talk about the application of some of these methods or if these methods are applied to prevent accidents from occurring.
Simon: Cool. Well, thanks very much, Peter. I think maybe I’ll let the next time we have a chat I’ll let you talk through your slides and we’ll have a more in-depth look across the whole breadth of Human Factors.
Peter: So that’s probably a good little intro at the moment anyway. Perhaps I might pull up one slide on Human Factors integration before we end.
Simon: Of course.
Peter: I’ll go back a few slides here.
What is Human Factors Integration?
Peter: And so what is Human Factors integration? I was thinking about this quite a bit recently because I’m working on some complex projects that are very, well, not only complex but quite large engineering projects with lots of people, lots of different groups involved, different contracts and so forth. And the integration issues that occur. They’re not only Human Factors integration issues there are larger-scale integration issues, engineering integration issues. Generally speaking, this is something I think that projects often struggle with. And I was really thinking about the Human Factors angle and Human Factors integration. That’s about ensuring that all of the HF issues, so HF in Human Factors, in a project are considered in control throughout the project and deliver the desired performance and safety improvements. So, three functions of Human Factors integration
confirm the intendant system performance objectives and criteria
guide and manage the Human Factors, aspects and design cycles so that negative aspects don’t arise and prevent the system reaching its optimum performance level
and identify and evaluate any additional Human Factors safety aspect now or we found in the safety case.
You’ll find, particularly in these complex projects, that the interfaces between the – you might have quite a large project and have some projects working on particular components. Let’s say one is working on more of a civil/structural elements and maybe space provisioning and so on versus another one is working more on control systems. And the integration between those becomes quite difficult because you don’t really have that Human Factors integration function working to integrate those two large components. Typically, it’s within those focused project groupings –that’s the way to call them. Does that make sense?
Simon: Yeah. Yeah, absolutely.
Peter: I think that’s one of the big challenges that I’m seeing at the moment, is where you have a certain amount of time and money and resource. This would be common for other engineering disciplines and the integration work often falls by the wayside, I think. And that’s where I think a number of the ongoing Human Factors issues are going to be cropping up some of these large-scale projects for the next 10 to 20 years. Both operationally and perhaps safety as well. Of course, we want to avoid –
Simon: –Yes. I mean, what you’re describing sounds very familiar to me as a safety engineer and I suspect to a lot of engineers of all disciplines who work on large projects. They’re going to recognize that as it is a familiar problem.
Peter: Sure. You can think about if you’ve got the civil and space provisioning sort of aspect of a project and another group is doing what goes into, let’s say, a room into a control room or into a maintenance room and so on. It may be that things are constrained in such a way that the design of the racks in the room has to be done in a way that makes the work more difficult for maintainers. And it’s hard to optimize these things because these are complex projects and complex considerations. And a lot of people are involved in them. The nature of engineering work is typically to break things down into little elements, optimize those elements and bring them all together.
Peter: Human Factors tends to –Well, you can do them Human Factors as well but I would argue that certainly what attracted me to it, is that you tend to have to take a more holistic approach to human behaviour and performance in a system.
Peter: Which is hard.
Simon: Yes, but rewarding. And on that note, thanks very much, Peter. That’s been terrific. Very helpful. And I look forward to our next chat.
Peter: For sure. Me too. Okay, thanks!
Simon: Well, that was our first chat with Peter on the Safety Artisan and I’m looking forward to many more. So, it just remains for me to say thanks very much for watching and supporting the work of what we’re doing and what we’re trying to achieve. I look forward to seeing you all next time. Okay, goodbye.