Safety Concepts Part 1

In this 'Safety Concepts Part 1' Blog post, The Safety Artisan looks at the meaning of the term "safe". I look at an objective definition of safe - objective because it can be demonstrated to have been met.



This fundamental topic provides the foundation for all other safety topics, and it isn't complex. The basics are simple, but they need to be thoroughly understood and practiced consistently to achieve success.



https://youtu.be/IKAZ3KLsDW8

System Safety Concepts - highlights.



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Safety Concepts Part 1: Topics



- A practical (useful) definition of ‘safe’:



- What is risk?



- What is risk reduction?



- What are safety requirements?



- Scope:



- What is the system?



- What is the application (function)?



- What is the (operating) environment?



Safety Concepts Part 1: Transcript



Hi everyone and welcome to the Safety Artisan, where you will find professional, pragmatic, and impartial advice. Whether you want to know how safety is done or how to do it, I hope you’ll find today’s session helpful.



It’s the 21st of September 2019 as I record this. Welcome to the show. So, let’s get started. We’re going to talk today about System Safety concepts. What does it all mean?  We need to ask this question because it’s not obvious, as we will see.



If we look at a dictionary definition of the word ‘safe’, it’s an adjective: to be protected from or not exposed to danger or risk. Not likely to be harmed or lost. There are synonyms – protect, shield, shelter, guard, and keep out of harm’s way. They’re all good words, and I think we all know what we’re talking about. However, as a definition, it’s too imprecise. We can’t objectively say whether we have achieved safety or not.



A Practical Definition of ‘Safe’



What we need is a better definition, a more practical definition. I’ve taken something from an old UK Defence Standard. Forget about which standard, that’s not important. It’s just that we’re using a consistent set of definitions to work through basic safety concepts. And it’s important to do that because different standards, come from different legal systems and they have different philosophies. So, if you start mixing standards and different concepts together, that doesn’t always work.



OK so whatever you do, be consistent. That’s the key point. We’re going to use this set of definitions from the UK Defence Standard because they are consistent.



In this standard, ‘safe’ means: “Risk has been demonstrated to have been reduced to a level that is ALARP, and broadly acceptable or tolerable. And relevant prescriptive safety requirements have been met. For a system, in a given application, in a given Operating Environment.” OK, so let’s unpack that.



System Safety – Risk



So, we start with risk. We need to manage risk. We need to show that risk has been reduced to an acceptable level. As required perhaps by law, regulation, or a standard. Or just good practice in a particular industry. Whatever it is, we need to show that the risk of harm to people has been reduced. Not just any old reduction, we need to show that it’s been reduced to a particular level. Now in this standard, there are two tests for that.



And they’re both objective tests. The first one says as low as reasonably practicable. Basically, it’s asking have all reasonably practicable risk reduction measures have been taken. So that’s one test. And the second test is a bit simpler. It’s basically saying reduce the absolute level of risk to something that is tolerable or acceptable. Now don’t worry too much about precisely what these things mean. The purpose of today is to note that we’ve got an objective test to say that we’ve done enough.



System Safety – Requirements



So that’s dealt with risk. Let’s move on to safety requirements. If a requirement is relevant, then we need to apply it. If it’s prescriptive, if it says you must do this, or you must do that. Then we need to meet it. There are two separate parts to this ‘Safe’ thing: we’ve got to meet requirements; and, we’ve got to manage risk. We can’t use one as an excuse for not doing the other.



So just because we reduce risk until it’s tolerable or acceptable doesn’t mean that we can ignore safety requirements. Or vice versa. So those are the two key things that we’ve got to do. But that’s not actually quite enough to get us there. Because we’ve got to define what we’re doing, with what, and in what context. Well, we’re reducing the risk of a system. And the system might be a physical thing.



Defining the Scope: The System



It might be a vehicle, an airplane, a ship, or a submarine, it might be a car or a truck. Or it might be something a bit more intangible. It might be a computer program that we’re using to make decisions that affect the safety of human beings, maybe a medical diagnosis system. Or we’re processing some scripts or prescriptions for medicine and we’ve got to get it right. We could poison somebody. So, whether it’s a tangible or an intangible system.



We need to define it. And that’s not as easy as it sounds, because if we’re applying system safety, we’re doing it because we have a complex system. It’s not a toaster. It’s something a bit more challenging. Defining the system carefully and precisely is really important and helpful. So, we define what our system is, our thing, or our service. The system. What are we doing with it? What are we applying it to?



Defining the Scope: The Application



What are we using it for? Now, just to illustrate that no standard is perfect. Whoever wrote that defense standard didn’t bother to define the application. Which is kind of a major stuff-up to be honest, because that’s really important. So, let’s go back to an ordinary dictionary definition just to get an idea of what it means. By the way, I checked through the standard that I was referring to, and it does not explain it in this standard.



What it means by the application. Otherwise, I would use that by preference. But if we go back to the dictionary, we see application: the act of putting something into operation. OK, so, we’re putting something to use. We’re implementing, employing it, or deploying it maybe we’re utilizing it, applying it, executing it, enacting it. We’re carrying it out, putting it into operation, or putting it into practice. All useful words that help us to understand.



I think we know what we’re talking about. So, we’ve got a thing or a service. Well, what are we using it for? Quite obviously, you know a car is probably going to be quite safe on the road. Put it in water and it probably isn’t safe at all. So, it’s important to use things for their proper application, to the use to which they were designed. And then, kind of harking back to what I just said, the correct operating environment.



Defining the Scope: The Operating Environment



For this system, and the application to which we will put it to. So, we’ve got a thing that we want to use for something. What’s the operating environment in which it will be safe? What is it qualified or certified for? What’s the performance envelope that it’s been designed for? Typically, things work pretty well within the operating environment, within the envelope for which they were designed. Take them outside of that envelope and they perform not so well.



Maybe not at all. You take an airplane too high and the air is too thin, and it becomes uncontrollable. You take it too low and it smashes into the ground. Neither outcome is particularly good for the occupants of the airplane. Or whoever happens to be underneath it when it hits the ground. All of those three things:  what is the system? What are we doing with it? and where are we doing it? All those things have to be defined. Otherwise, we can’t really say that risk has been dealt with, or that safety requirements have been met.



System Safety: why Bother?



So, we’ve spent several slides just talking about what safe means, which might seem a bit over the top. But I promise you it is not, because having a solid understanding of what we’re trying to do is important in safety. Because safety is intangible. So, we need to understand what it is we’re aiming for. As some Greek bloke said, thousands of years ago: “If you don’t know to which port, you are bound, then no wind is favorable.”



It’s almost impossible to have a satisfactory Safety Program if you don’t know what you’re trying to achieve. Whereas, if you do have a precise understanding of what you’re trying to achieve, you’ve got a reasonably good chance of success. And that’s what it’s all about.



Copyright



Well, I’ve quoted you some information. From a UK government website. And I’ve done so in accordance with the terms of its Creative Commons license. More information about the terms of that can be found on this page.



End: Safety Concepts Part 1



If you want more, if you want to unpack all the Major Definitions, all the system safety concepts that we're talking about, then there's the second part of this video, which you can see here.



I hope you enjoy it. Well, that's it for the short video, for now. Please go and have a look at the longer video to get the full picture. OK, everyone, it's been a pleasure talking to you and I hope you found that useful. I'll see you again soon. Goodbye.



Back to the Start Here Page. Get the full-length Lesson as part of the FREE Triple Learning Bundle.



Meet the Author



Learn safety engineering with me, an industry professional with 25 years of experience, I have:



•Worked on aircraft, ships, submarines, ATMS, trains, and software;



•Tiny programs to some of the biggest (Eurofighter, Future Submarine);



•In the UK and Australia, on US and European programs;



•Taught safety to hundreds of people in the classroom, and thousands online;



•Presented on safety topics at several international conferences.

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Simon Di Nucci https://www.safetyartisan.com/2019/09/22/safety-concepts-part-1/

Courses

Here are some of the courses that you can buy:



- Free Triple Bundle;



- Five Ways to Identify Hazards;



- Identify and Analyze Functional Hazards;



- Foundations of System Safety;



- Principles-of-Safe-Software; and



- System-Safety-Assessment-with-Mil-Std-882E.



Free Triple Bundle



https://youtu.be/IKAZ3KLsDW8

Highlights from one of the Triple Bundle Resources



Free Triple Bundle Resources:



- Risk Management 101 Course,



- Preliminary Hazard Identification & Analysis Guide,



- System Safety Concepts Course,



- System Safety Principles Course,



- 23 Lessons / Three hours of downloadable Video, and



- Resources: slide decks & transcripts.



get it for free



Five Ways to Identify Hazards - $45 (US)



https://youtu.be/A83QwHgHF6M

Introduction to the Bonus Webinar



In this course, learn how to perform Preliminary Hazard Identification. It includes video lessons, examples, and downloadable resources:



- Introduction,



- Preliminary Hazard Identification (Task 201 of Mil-Std-882E),



- Resources - slide decks and transcripts,



- Bonus Webinar: Five Ways to Identify Hazards, and



- Full downloadable lesson video.



- 19 Lessons / Two Hours of Video Content.



get it here



Identify and Analyze Functional Hazards - $125 (US)



https://youtu.be/RZEa18PKXcY

Introduction to the Bonus Webinar



This course has 11 lessons (2.5 hours of video content) in four major parts:



- Webinar overview - putting the Tasks together,



- Preliminary Hazard Identification (Task 201 of Mil-Std-882E),



- Functional Failure Analysis Theory & Worked Example, and



- Functional Hazard Analysis (Task 208 of Mil-Std-882E).



get it here



Foundations of System Safety - $180 (US)



https://youtu.be/Az4B4hFpVP4

Introduction to the Webinar



In this course, I pull together the three tasks that lay the foundations of every system safety program.  The contents are:



- Introduction,



- Preliminary Hazard Identification (Task 201 of Mil-Std-882E),



- Preliminary Hazard Analysis (Task 202 of Mil-Std-882E),



- System Requirements Hazard Analysis (Task 203 of Mil-Std-882E),



- Safety Analysis Techniques Overview - how to put the Tasks together,



- 18 Lessons / Four Hours of Video Content, and



- Downloads, slide decks & transcripts.



get it here



Principles of Safe Software - $245 (US)



https://youtu.be/g-5mlNIk14I

Just One of the Lessons from Principles of Safe Software.



Software safety can be a daunting subject. Software development is challenging and, as you will see, it is a very risky business. Safety is also an intangible, emergent property: how do we develop safe software? Find out here:



- Introduction,



- Software Development Facts,



- Software Safety Facts,



- Safe Software Principles,



- Overview of Software Standards,



- RTCA DO-178 (ED-12),



- IEC 61508,



- ISO 26262,



- Review of Standards,



- Lessons Learned,



- 11 Lessons / 2.5 Hours of Video Content, and



- Downloads, slide decks & transcripts.



get it here



Courses: System Safety Assessment with Mil-Std-882E - $545 (US)



https://youtu.be/nuDtDhm3i-I

Welcome to the System Safety Assessment Course.



Design a Safety Risk Assessment Program for ANY system in ANY application. This course covers all ten of the analysis tasks from the defense system safety standard Mil-Std-882E.



Whatever it is, you will learn how to tailor your risk assessment, using the analyses you need. You will be able to meet your legal and regulatory requirements. Once you’ve learned how to do this, you can apply it to almost any system.  There are thirteen lessons:



- Introduction to the Course,



- The System Safety Process,



- Tailoring your System Safety Assessment Program,



- Preliminary Hazard Identification (Task 201),



- Preliminary Hazard Analysis (Task 202),



- System Requirements Hazard Analysis (Task 203),



- Sub-system Hazard Analysis (Task 204),



- System Hazard Analysis (Task 205),



- Operating and Support Hazard Analysis (Task 206),



- Health Hazard Analysis (Task 207),



- Functional Hazard Analysis (Task 208),



- System of Systems Hazard Analysis (Task 209), and



- Environmental Hazard Analysis (Task 210).



get the complete course



You can also get all of the webinars at the Safety Engineering Academy, which gives you access to recorded webinars, a private community of like-minded people, and other resources. There are 51 videos so far, and new ones are being added every month.



Back to home.



Simon Di Nucci https://www.safetyartisan.com/courses/

Proportionality

Proportionality is about committing resources to the Safety Program that are adequate - in both quality and quantity - for the required tasks.



Introduction to Proportionality



Proportionality is a concept that should be applied to determine the allocation of resource and effort to a safety and environmental argument based on its risk.  It is a difficult concept to attempt to distil into a process as each Product, System or Service will have different risks, objectives, priorities and interfaces that make a ‘one size fits all’ approach impossible.



This section describes an approach that may be used to assist in applying the concept of proportionality; it seeks to guide you in understanding where a proportionate amount of effort can be directed, while at the same time maintaining the overriding principle that Risk to Life must be managed.  Regulators require that a proportional approach is used and there are many methods that try to achieve this.  Some focus on the amount of evidence needed to justify a safety argument; some provide more emphasis on the application of activities that are required to make a safety argument and some consider that fulfilling certain criteria can lead to an assessment of risk, but one requirement that is at the centre of any proportional approach is that safety risks are acceptable. 



A fundamental consideration of a proportional approach is considering compliance against assessment criteria.  The Health and Safety Executive’s view is that there should be some proportionality between the magnitude of the risk and the measures taken to control the risk. The phrase “all measures necessary” should be interpreted with this principle in mind. Both the likelihood of accidents occurring and the severity of the worst possible accident determine proportionality.  Application of proportionality should highlight the hazardous activities for which the Duty Holder should provide the most detailed arguments to support the demonstration .



The following considerations may affect proportionality, in a defence context:



- Type of consequence;

- Severity;

- The stage in the Life cycle;

- Intended use (CON OPS/Design Intent);

- Material state (degradation);

- Historical performance;

- Cost of safety;

- Cost of realising risk;

- Public Relations;

- Persons at Risk:- 1st,2nd,3rd Party;

- Military

- Civilian;

- Civil Servants;

- Contractors;

- General public;

- VIPs;

- Youths;

- Volume;

- Geographical spread/transboundary.



Some important points that should be noted regarding safety and environmental proportionality approach are that:



- Proportionality is inherent to safety and environmental risk assessment (i.e. use of ALARP, BPEO, etc.);

- Proportionality is explicitly linked to risk;

- Multiple factors need to be considered when deciding a proportional approach;

- ASEMS is the mandated safety and environmental framework; therefore, the framework should be applied; it is not possible to develop a proportional approach that negates any part of ASEMS.



Waterfall Approach Process



The model that should be used to consider a proportional approach is intended to provide guidance and should only be used by competent safety and environmental practitioners.  A degree of judgement should be used when answering questions, particularly where a Product, System or Service may easily be classified in more than one category; this is why the use of competent safety and environmental practioners is required.



The waterfall approach model categorises Product, System or Service risk in accordance with factual questions, presented on the left of the diagram below, which are asked about the intended function and operation.  Each question should be used to define the cumulative potential risk, which may be presented by the Product, System or Service.  The Product, System or Service is categorised into one of three risk bands, which align to those defined in the Tolerability triangle, presented in the right of of the diagram.



During the process two initial questions are asked, where an answer of “yes” will automatically result in a categorisation of high risk, regardless of the answer to subsequent questions.  Further refinement is required for lower risk systems to ensure that the system risk is categorised appropriately.



Figure 1, Proportionality Waterfall Approach Model



The diagram above depicts the proportionality waterfall approach model used for the application of ASEMS.



Adherence to ASEMS is mandatory for DE&S.  As such, it is not possible to develop a proportional approach that negates any individual part of ASEMS and so the procedures described in ASEMS Part 2 - Instructions, Procedures and Support should be followed;  where proportionality may be applied is within each General Management Procedure, Safety Management Procedure or Environmental Management Procedure for the allocation of resource, time or effort.



Once the risk category has been established guidance is defined which prescribes the rigour which should be applied to the safety assessment process in terms of Process, Effort, Competence, Output, Assurance (PECOA):



- Process - the amount of dedicated/specific process, level of intervention in the organisational structure the Safety and Environmental Management System are established;

- Effort - How much time is afforded to the management of risk;

- Competence - the level of competence that is required to conducted appropriate assessment and management of safety and environmental;

- Output - The detail of evidence and reporting is cognisant to the level of risk;

- Assurance - The level of assurance required which shall be applied to the process.



Guidance for the application of PECOA is provided in the table below.  It should be noted that this is indicative guidance for illustrative purposes only. It is a fundamental requirement of ASEMS safety management principles that all safety decisions made should be reviewed, assessed and endorsed by a Safety and Environmental Management Committee to ensure that the Products, Systems and Services categorisation is correct. The diagram below shows the process that may be applied:



Proportionality Process



It should be remembered that using this low/medium and high categorisation could be misleading as the model takes no account of the population or rate of occurrence of the harm. A simple system that can only cause minor injury could still have a high degree of risk if there are lots of people exposed to the risk and the accident rate was high.  Moreover, acceptance of such a situation could lead to the development of an ineffective safety culture or the bypassing of safety mitigation procedures in order to avoid a high accident/minor injury position.  This is where the application of competent safety and environmental advice is essential to ensure that any proportionality model is not slavishly followed at the expense of proper rigour.   Where this model is useful is assisting those safety and environmental professionals to perform a preliminary assessment regarding what Products, Systems or Services are a priority for the allocation of resource, time or effort.



Stage One - System type and Life Cycle Phase



The first question is used to indicate, at a high level, the likely degree of risk for a project.  It should be noted that this is not a definitive assessment and that Products, Systems or Services could move within the model as the safety or environmental evidence is assessed.  There will be a degree of pre-existing assessment which accompanies a Product, System or Service and this may be used to assist with this initial question. 



The safety and environmental assessment process should be closely aligned with the Product, System or Service development process for newly developed Product, System or Services.  Where Products, Systems or Services are in the Concept, Assessment, Development or Manufacture phase of the CADMID/T cycle, they should be accompanied by a safety and environmental assessment process which utilises quantitative assessment techniques.



Where a Product, System or Service sits in the CADMID/T cycle should not influence the rigour of any safety or environmental argument; this model is provided to assist with any determination of the resource, time or effort that may be applied to the evidence to support the argument.  All Risk to Life should be ALARP, with no exception; what changes is the allocation of resources, time and effort to reach that judgement.



Those Products, Systems or Services where the expected worst credible consequence results in, at worst, a single minor injury should automatically be categorised as LOW risk and a qualitative approach may be adopted.



Commercial Off The Shelf or Military Off The Shelf systems should be accompanied by evidence which may be used in the safety and environmental assessment to demonstrate that they are acceptably safe and environmentally compliant, particularly where these are manufactured for use in the EU, where each Product, System or Service should demonstrate compliance with the applicable EU standards.  That the Product, System or Service is Commercial Off The Shelf or Military Off The Shelf is not, in itself, evidence.



Such evidence should include test evidence, trials evidence or a certificate of conformance.  Where a Commercial Off The Shelf or Military Off the Shelf system is already in the in-service phase and it is established that there is sufficient evidence to form a compelling safety argument that the Risk to Life is ALARP, then the system should be categorised as MEDIUM-LOW.  Where the system is also non-complex then it may be categorised as LOW.



Such Commercial Off The Shelf or Military Off the Shelf evidence should only be relied upon where it is established that this evidence is sufficient to demonstrate that the system is acceptably safe and environmentally compliant and already in existence.  The degree and appropriateness of evidence should be established by a Safety and Environmental Management Committee, with particular emphasis upon the quality of the evidence for high-risk systems.  This approach should be undertaken if the Product, System or Service in its entirety is categorised as Commercial Off The Shelf or Military Off the Shelf.  Where only sub-systems or components are Commercial Off The Shelf or Military Off the Shelf, the Product, System or Service should be categorised as bespoke and assessed accordingly.



Stage Two - Risk estimation and System Complexity



Any estimation of the risk that a Product, System or Service is likely to present should be used to further refine its categorisation.  If the worst credible consequence of a Product, System or Service is multiple fatalities then that Product, System or Service should automatically be categorised as HIGH risk.



If the worst credible consequence is a single fatality or multiple severe injuries then the system complexity should be considered further to refine and inform the categorisation.  Complex or novel system designs should have a higher degree of Suitably Qualified Experienced Personnel to conduct the safety and environmental assessment.  Accordingly, those Products Systems or Services which are complex and novel should also be categorised as HIGH whereas those exhibiting a lower degree of complexity might be categorised as MEDIUM.



Notwithstanding this, those Products, Systems or Services thatare in the Concept, Assessment, Development or Manufacture/Termination phase of the CADMID/T cycle should still be supported by a quantitative safety and environmental process.  The only exceptions are those Products, Systems or Services where the worst credible consequence is a single minor injury.  These should be categorised as LOW risk and may be supported by a qualitative safety and/or environmental process.



LOW risk Products, Systems or Services were the worst credible consequence is at worst a single minor injury should be categorised as LOW-MEDIUM risk where the design is complex or novel, those exhibiting a lower degree of complexity should be categorised as LOW risk.



Once the risk category has been established the rigour which should be applied to the safety assessment process in terms of Process, Effort, Competence, Output, Assurance (PECOA) should be defined.  This is summarised below:



Program ScaleLifecycle StageSmall scale or no Critical FunctionCADMID/TCADMID/TCADMID/TLarge Scale Capital,Critical Function or bespokeCADMID/TCADMID/TCADMID/TAssessmentHighMediumLowProcessA rigorous quantitative safety and environmental assessment process should be applied.Consideration should be given to the application of a qualitative safety and environmental assessment process.  Functional safety/environmental assessment may be required, if identified as a risk control measure.A qualitative safety and environmental assessment process should be appropriate for low risk, low complexity systems.EffortSignificant effort should be expended developing the safety and environmental case.A medium level of effort should apportioned to development of the safety and environmental case, increasing for newly developed systems.A medium level of effort should be apportioned to development of the safety and environmental case.CompetenceThe safety and environmental assessment and assurance programme should be led by individuals who are experts.  Remaining personnel should be at least Practitioners who should be provided with oversight where appropriate.Personnel engaged in the safety and environmental assessment and approval should be at least practitioners.Personnel engaged in the safety and environmental assessment and approval should be at least supervised practitioners who should be provided with oversight where appropriate.OutputA safety and environmental case should be developed which includes a safety argument.  The safety assessment process should be substantiated by quantitative evidence.A safety and environmental case should be developed, which should include a safety and environmental argument for all by simplex low risk systems.  The safety assessment process should be substantiated by quantitative evidence for newly developed systems.A safety and environmental statement may be considered for systems, which are low risk and complexity.AssuranceThe safety and environmental assessment should be independently assured.Independent assurance should be considered and applied to those projects which are considered to be novel or complex.  Assurance may be conducted at Committee level. Independent assurance is not required.ASEMS GuidanceSafety and Environmental   Dedicated tailored and full implementation of all Clauses, articulated through adherence to all GMPs, SMPs and EMPs.Safety and Environmental   Apply full implementation of all Clauses, in line with guidance provided for the Functional safety/environmental assessment, as required, if identified as a risk control measure and application of GMPs, SMPs and EMPs.Where Project Teams have an overarching Safety and Environmental Management Systems in place:   Safety Gather sufficient evidence to support safety argument and document in a Safety Case/Assessment in accordance with SMP 04, 05, 06, 09 and 12     Environmental Gather sufficient information in order to produce Environmental Impact Statement in accordance with EMP 07 - Environmental Reporting.



Process



The type of safety and environmental process which should be applied is dependent both upon the Product System or Service categorisation and the phase of the CADMID/T cycle that the project is in.  Newly developed MEDIUM-LOW to HIGH category Products, Systems or Services which are in the Concept, Assessment, Development or Manufacture phase of the cycle should have a quantitative safety and environmental assessment process applied, the depth and rigour of the assessment should be proportionate to its classification.  LOW risk Products, Systems or Services where the worst credible consequence is anticipated to be no greater than one minor injury may be assessed qualitatively.



A qualitative safety and environmental assessment process should be applied to Products, Systems or Services, which are in the In-Service, Disposal/Termination phase where it is deemed that there is sufficient evidence already in existence to demonstrate that it is acceptably safe.  In these circumstances a qualitative safety and environmental process should be applied to assess the in-service risks.



The approach uses a systematic and logical approach to categorise the resource, time and effort required to support any argument that a Product, System or Service is acceeptably safe or provides no significant damage to teh environment.  It also advocates the application of ASEMS in its entirety, prescribing the level of rigour, which should be applied in terms of process, effort, competence, output and assurance.



Effort



The effort apportioned to the safety and environmental process should be proportionate to the classification of the system.  A significant amount of rigour should be applied to those projects requiring quantitative assessment processes, particularly those with the highest degree of risk and complexity.



If a Product System or Service is assessed to be in a particularly low category and is simple it may not be necessary to undertake the full scope of risk management procedures.  In these circumstances a certificate of conformance may be sufficient, which may be supported by statement to that effect from the Safety and Environmental Management Committee.



All decisions made regarding the evidence required to justify a safety argument (regardless of risk) should be endorsed by a Safety and Environmental Management Committee.  If this is decision is delegated further for those Products, Systems or Services that are low risk is for the Duty Holder to determine as all decisions regarding to Risk to Life are made on their behalf.



Competence



The safety and environmental lead should be an expert for HIGH category projects or for MEDIUM category projects where the Product System or Service is particularly complex or a novel design.  The remaining personnel engaged on such projects should be at least practitioner level.  A competency assessment should be undertaken which should be endorsed by a Safety and Environmental Management Committee.



The safety and environmental lead for MEDIUM category projects should be at least practitioner level.  The remaining personnel engaged on such projects should be practitioner or supervised practitioner where appropriate supervision is in place.  A competency assessment should be undertaken which should be endorsed by a Safety and Environmental Management Committee.



The safety and environmental lead for LOW category projects should be at least practitioner level or a supervised practitioner with appropriate supervision in place.



Competency requirements relating to specific safety and environmental processes defined in ASEMS should be applied where those processes are undertaken.



Output



A safety and environmental case should be developed for HIGH category projects which includes a safety and environmental argument, developed using Claims Arguments Evidence (CAE) or Goal Structuring Notation (GSN).  The argument should be substantiated by quantitative evidence such as reliability data or the output from quantitative safety assessment processes.



A safety and environmental case should be developed for MEDIUM category projects which includes a CAE or GSN safety argument.  The quality and depth of evidence required to substantiate the safety and environmental argument should be proportionate to the classification of the Product System or Service.   Products, Systems or Services with increased complexity or higher degrees of risk should be substantiated by quantitative evidence



A Safety and environmental case should be developed for MEDIUM-LOW category Products, Systems or Services. 

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Simon Di Nucci https://www.safetyartisan.com/2022/09/14/proportionality/

Sub-System Hazard Analysis with Mil-Std-882E
In this video lesson, I look at Sub-System Hazard Analysis with Mil-Std-882E (SSHA, which is Task 204). I teach the mechanics of the task, but not just that. I'm using my long experience with this Standard to teach a pragmatic approach to getting the work done.

Task 204 is one of three tasks that integrate tightly in a Systems Engineering framework. (The others are System Hazard Analysis, Task 205, and System of Systems Hazard Analysis, Task 209.)

SSHA is designed to be used where a formal Sub-System Specification (SSS) has been created. However, an SSS is not essential to perform this Task. The need for SSHA is usually driven by the complexity of the system and/or that sub-system development is contracted out.

Together, we will explore Task 204's aim, description, scope, and contracting requirements. There's value-adding commentary, and I explain the issues with SSHA - how to do it well and avoid the pitfalls.

https://youtu.be/VUreppOMyiQ
This is the seven-minute demo, the full video is 40-minutes' long.

buy the course here

Topics: Sub-System Hazard Analysis

- Preamble: Sub-system & System HA.

- Task 204 Purpose:

- Verify subsystem compliance;

- Identify (new) hazards; and

- Recommend necessary actions.

- Task Description (six slides);

- Reporting;

- Contracting; and

- Commentary.

Transcript: Sub-System Hazard Analysis

Introduction

Hello, everyone, and welcome to the Safety Artisan, where you will find professional, pragmatic, and impartial instruction on all things system safety. I'm Simon – I’m your host for today, as always and it's the fourth of April 22. With everything that's going on in the world, I hope that this video finds you safe and well.

Sub-System Hazard Analysis

Let's move straight on to what we're going to be doing. We're going to be talking today about subsystem hazard analysis and this is task 204 under the military standard 882E. Previously we've done 201, which was preliminary hazard identification, 202, which is preliminary hazard analysis, and 203, which is safety requirements hazard analysis. And with task 204 and task 205, which is system has analysis, we're now moving into getting stuck into particular systems that we're thinking about, whether they be physical systems or intangible. We’re thinking about the system under consideration and I'm really getting into that analysis.

Topics for this Session

So, the topics that we're going to cover today, I've got a little preamble to set things in perspective. We then get into the three purposes of task 204. First, to verify compliance. Secondly, to identify new hazards. And thirdly, to recommend necessary actions. That would be recommended control measures for hazards and risks. We've got six slides of task description, a couple of slides on reporting, one on contracting, and then a few slides on some commentary where I put in my tuppence worth and I'll hopefully add some value to the basic bones of the standard.

It's worth saying that you'll notice that subsystem is highlighted in yellow and the reason for that is that the subsystem and system hazard analysis tasks are very, very similar. They're identical except for certain passages and I've highlighted those in yellow. Normally I use a yellow highlighter to emphasize something I want to talk about. This time around, I'm using underlining for that and the yellow is showing you what these are different for subsystem analysis as opposed to system . And when you've watched both sessions on 204 and 205, I think you'll see the significance of what I've done.

Preamble – Sub-system & System HA

Before we get started, we need to explain the system model that the 882 is assuming. If we look at the left-hand side of the hexagons, we've got our system in the center, which we're considering. Maybe that interfaces with other systems. They work within the operating environment; hence we have the icon of the world, and the system and maybe other systems are there for a purpose. They’re performing some task; they’re doing some function and that's indicated by the tools. We're using the system to do something, whatever it might be.

Then as we move to the right-hand side, the system is itself broken down into subsystems. We’ve got a couple here. We've got sub-systems A and B and then A further broken down into A1 and A2, for example. There's some sort of hierarchy of subsystems that are coming together and being integrated to form the overall system. That is the overall picture that I'd like to bear in mind while we're talking about this. The assumption in the 882, is we're going to be looking at this subsystem hierarchy bottom upwards, largely. We'll come on to that.

Sub-System Hazard Analysis (T204)

The purpose of the task, as I've said before, it's threefold. We must verify subsystem compliance with requirements. Requirements to deal with risk and hazards. We must identify previously unidentified hazards that may emerge as we're working at a lower level now. And we must recommend actions as necessary. Those are further requirements to eliminate all hazards or mitigate associated risks. We'll keep those three things in mind and that will keep coming up.

End: Sub-System Hazard Analysis

My name’s Simon Di Nucci. I’m a practicing system safety engineer, and I have been, for the last 25 years; I’ve worked in all kinds of domains, aircraft, ships, submarines, sensors, and command and control systems, and some work on rail air traffic management systems, and lots of software safety. So, I’ve done a lot of different things!

You can find a free pdf of the System Safety Engineering Standard, Mil-Std-882E, here.
#hazardanalysistraining #hazardanalysistutorial #Milstd882Technique #Milstd882Training #Milstd882tutorial #Milstd882Video #MilStd882E #Milstd882eTechnique #Milstd882eTraining #Milstd882etutorial #Milstd882eVideo #safetyengineertraining #SafetystandardTechnique #SafetystandardTraining #Safetystandardtutorial #SafetystandardVideo #SSHA #subsystemhazardanalysis #SubsystemhazardanalysisTechnique #SubsystemhazardanalysisTraining #Subsystemhazardanalysistutorial #SubsystemhazardanalysisVideo #SystemsafetyengineeringTechnique #systemsafetyengineeringtraining #Systemsafetyengineeringtutorial #SystemsafetyengineeringVideo #Task204
Simon Di Nucci https://www.safetyartisan.com/?p=547

Sub-System Hazard Analysis with Mil-Std-882E
In this video lesson, I look at Sub-System Hazard Analysis with Mil-Std-882E (SSHA, which is Task 204). I teach the mechanics of the task, but not just that. I'm using my long experience with this Standard to teach a pragmatic approach to getting the work done.

Task 204 is one of three tasks that integrate tightly in a Systems Engineering framework. (The others are System Hazard Analysis, Task 205, and System of Systems Hazard Analysis, Task 209.)

SSHA is designed to be used where a formal Sub-System Specification (SSS) has been created. However, an SSS is not essential to perform this Task. The need for SSHA is usually driven by the complexity of the system and/or that sub-system development is contracted out.

Together, we will explore Task 204's aim, description, scope, and contracting requirements. There's value-adding commentary, and I explain the issues with SSHA - how to do it well and avoid the pitfalls.

https://youtu.be/VUreppOMyiQ
This is the seven-minute demo, the full video is 40-minutes' long.

buy the course here

Topics: Sub-System Hazard Analysis

- Preamble: Sub-system & System HA.

- Task 204 Purpose:

- Verify subsystem compliance;

- Identify (new) hazards; and

- Recommend necessary actions.

- Task Description (six slides);

- Reporting;

- Contracting; and

- Commentary.

Transcript: Sub-System Hazard Analysis

Introduction

Hello, everyone, and welcome to the Safety Artisan, where you will find professional, pragmatic, and impartial instruction on all things system safety. I'm Simon – I’m your host for today, as always and it's the fourth of April 22. With everything that's going on in the world, I hope that this video finds you safe and well.

Sub-System Hazard Analysis

Let's move straight on to what we're going to be doing. We're going to be talking today about subsystem hazard analysis and this is task 204 under the military standard 882E. Previously we've done 201, which was preliminary hazard identification, 202, which is preliminary hazard analysis, and 203, which is safety requirements hazard analysis. And with task 204 and task 205, which is system has analysis, we're now moving into getting stuck into particular systems that we're thinking about, whether they be physical systems or intangible. We’re thinking about the system under consideration and I'm really getting into that analysis.

Topics for this Session

So, the topics that we're going to cover today, I've got a little preamble to set things in perspective. We then get into the three purposes of task 204. First, to verify compliance. Secondly, to identify new hazards. And thirdly, to recommend necessary actions. That would be recommended control measures for hazards and risks. We've got six slides of task description, a couple of slides on reporting, one on contracting, and then a few slides on some commentary where I put in my tuppence worth and I'll hopefully add some value to the basic bones of the standard.

It's worth saying that you'll notice that subsystem is highlighted in yellow and the reason for that is that the subsystem and system hazard analysis tasks are very, very similar. They're identical except for certain passages and I've highlighted those in yellow. Normally I use a yellow highlighter to emphasize something I want to talk about. This time around, I'm using underlining for that and the yellow is showing you what these are different for subsystem analysis as opposed to system . And when you've watched both sessions on 204 and 205, I think you'll see the significance of what I've done.

Preamble – Sub-system & System HA

Before we get started, we need to explain the system model that the 882 is assuming. If we look at the left-hand side of the hexagons, we've got our system in the center, which we're considering. Maybe that interfaces with other systems. They work within the operating environment; hence we have the icon of the world, and the system and maybe other systems are there for a purpose. They’re performing some task; they’re doing some function and that's indicated by the tools. We're using the system to do something, whatever it might be.

Then as we move to the right-hand side, the system is itself broken down into subsystems. We’ve got a couple here. We've got sub-systems A and B and then A further broken down into A1 and A2, for example. There's some sort of hierarchy of subsystems that are coming together and being integrated to form the overall system. That is the overall picture that I'd like to bear in mind while we're talking about this. The assumption in the 882, is we're going to be looking at this subsystem hierarchy bottom upwards, largely. We'll come on to that.

Sub-System Hazard Analysis (T204)

The purpose of the task, as I've said before, it's threefold. We must verify subsystem compliance with requirements. Requirements to deal with risk and hazards. We must identify previously unidentified hazards that may emerge as we're working at a lower level now. And we must recommend actions as necessary. Those are further requirements to eliminate all hazards or mitigate associated risks. We'll keep those three things in mind and that will keep coming up.

End: Sub-System Hazard Analysis

My name’s Simon Di Nucci. I’m a practicing system safety engineer, and I have been, for the last 25 years; I’ve worked in all kinds of domains, aircraft, ships, submarines, sensors, and command and control systems, and some work on rail air traffic management systems, and lots of software safety. So, I’ve done a lot of different things!

You can find a free pdf of the System Safety Engineering Standard, Mil-Std-882E, here.
#hazardanalysistraining #hazardanalysistutorial #Milstd882Technique #Milstd882Training #Milstd882tutorial #Milstd882Video #MilStd882E #Milstd882eTechnique #Milstd882eTraining #Milstd882etutorial #Milstd882eVideo #safetyengineertraining #SafetystandardTechnique #SafetystandardTraining #Safetystandardtutorial #SafetystandardVideo #SSHA #subsystemhazardanalysis #SubsystemhazardanalysisTechnique #SubsystemhazardanalysisTraining #Subsystemhazardanalysistutorial #SubsystemhazardanalysisVideo #SystemsafetyengineeringTechnique #systemsafetyengineeringtraining #Systemsafetyengineeringtutorial #SystemsafetyengineeringVideo #Task204
Simon Di Nucci https://www.safetyartisan.com/?p=547

System Hazard Analysis with Mil-Std-882E
In this 45-minute session, I look at System Hazard Analysis with Mil-Std-882E. SHA is Task 205 in the Standard. I explore Task 205's aim, description, scope, and contracting requirements.

I also provide commentary, based on working with this Standard since 1996, which explains SHA. How to use it to complement Sub-System Hazard Analysis (SSHA, Task 204). How to get the maximum benefits from your System Safety Program.

Using Task 205 effectively is not just a matter of applying it in number order with the other Tasks. We need to use it within the Systems Engineering framework. That means using it top-down, to set requirements, and bottom-up to verify that they are met.

https://youtu.be/F70fhSGsyLk
This is the seven-minute-long demo. The full video is 47 minutes long.

get the course 'system hazard analysis': click here

System Hazard Analysis: Topics

- Task 205 Purpose ;

- Verify subsystem compliance;

- ID hazards (subsystem interfaces and faults);

- ID hazards (integrated system design); and

- Recommend necessary actions.

- Task Description (five slides);

- Reporting;

- Contracting; and

- Commentary.

Transcript: System Hazard Analysis with Mil-Std-882E

Introduction

Hello, everyone, and welcome to the Safety Artisan, where you will find professional, pragmatic, and impartial safety training resources and videos. I’m Simon, your host, and I’m recording this on the 13th of April 2020. And given the circumstances when I record this, I hope this finds you all well.

System Hazard Analysis Task 205

Let's get on to our topic for today, which is System Hazard Analysis. Now, system hazard analysis is, as you may know, Task 205 in the Mil-Std-882E system safety standard.

Topics for this Session

What we're going to cover in this session is purpose, task description, reporting, contracting, and some commentary – although I'll be making commentary all the way through. Going back to the top, the yellow highlighting with this (and with Task 204), I'm using the yellow highlighting to indicate differences between 205 and 204 because they are superficially quite similar. And then I'm using underlining to emphasize those things that I want to bring to your attention and emphasize.

Within Task 205, Purpose. We've got four purpose slides for this one. Verify subsistent compliance and recommend necessary actions – fourth one there. And then in the middle of the sandwich, we've got the identification of hazards, both between the subsystem interfaces and faults from the subsystem propagating upwards to the overall system and identifying hazards in the integrated system design. So, quite a different emphasis to 204, which was thinking about subsystems in isolation. We’ve got five slides of task description, a couple on reporting, one on contracting – nothing new there – and several commentaries.

System Requirements Hazard Analysis (T205)

Let's get straight on with it. The purpose, as we've already said, there is a three-fold purpose here; Verify system compliance, hazard identification, and recommended actions, and then, as we can see in the yellow, the identifying previously unidentified hazards is split into two. Looking at subsystem interfaces and faults and the integration of the overall system design. And you can see the yellow bit, that's different from 204 where we are taking this much higher-level view, taking an inter-subsystem view and then an integrated view.

Task Description (T205) #1

On to the task description. The contract has got to do it and document, as usual, looking at hazards and mitigations, or controls, in the integrated system design, including software and human interface. We must come onto that later.

All the usual stuff about we've got to include COTS, GOTS, GFE, and NDI. So, even if stuff is not being developed, if we're putting together a jigsaw system from existing pieces, we've still got to look at the overall thing. And as with 204, we go down to the underlined text at the bottom of the slide, areas to consider. Think about performance, and degradation of performance, functional failures, timing and design errors, defects, inadvertent functioning – that classic functional failure analysis that we've seen before.

Again, while conducting this analysis, we’ve got to include human beings as an integral component of the system, receiving inputs, and initiating outputs.  Human factors were included in this standard from long ago...

The End

You can find a free pdf of the System Safety Engineering Standard, Mil-Std-882E, here.

Learn safety engineering with me, an industry professional with 25 years of experience, I have:

•Worked on aircraft, ships, submarines, ATMS, trains, and software;

•Tiny programs to some of the biggest (Eurofighter, Future Submarine);

•In the UK and Australia, on US and European programs;

•Taught safety to hundreds of people in the classroom, and thousands online;

•Presented on safety topics at several international conferences.
#Milstd882Technique #Milstd882Training #Milstd882tutorial #Milstd882Video #MilStd882E #Milstd882eTechnique #Milstd882eTraining #Milstd882etutorial #Milstd882eVideo #SafetystandardTechnique #SafetystandardTraining #Safetystandardtutorial #SafetystandardVideo #SHA #systemhazardanalysis #systemhazardanalysisTechnique #systemhazardanalysisTraining #systemhazardanalysistutorial #systemhazardanalysisVideo #SystemsafetyengineeringTechnique #systemsafetyengineeringtraining #Systemsafetyengineeringtutorial #SystemsafetyengineeringVideo #Task205
Simon Di Nucci https://www.safetyartisan.com/?p=480

Australian vs. UK Safety Law

This post, Australian vs. UK Safety Law compares the two approaches, based on my long experience of working on both sides.



Are you a safety professional thinking of emigrating from the UK to Australia?  Well, I've done it, and here's my BREXIT special guide!  In this 45-minute video, The Safety Artisan looks at the similarities and differences between British and Australian safety practices.  This should also help Aussies thinking of heading over to work in the UK and even, dare I say it, to the EU...



https://youtu.be/lrRmSf5K2U4

"It's beginning to look a lot like BREXIT! La, La-la, la, la..."



Australian vs. UK Safety Law, Key Points



- Introduction. With BREXIT looming, British and Australian professionals may be thinking of working in each other's countries;



- Legislation. Our laws, regulations and codes of practice are quite similar;



- Guidance. Try the UK Health and Safety Executive (HSE) or the Safe Work Australia websites - both are excellent;



- Jurisdictions. This is complex in a federated state like Australia, so Brits need to do their homework;



- Regulators. This varies by industry/domain - many are very similar, while some are quite different;



- Cultural Issues: Australia vs. the UK. Brits and Aussies are likely to feel quite comfortable working in each other's countries; and



- Cultural Issues: Australia vs. the EU. There are some commonalities across the EU, but also dramatic differences.



Australian vs. UK Safety Law: The Transcript



Click Here for the Transcript

Comparing Australian & UK Safety Law: Topics



This is a free full-length show. I think it’s going to be about 30 minutes just to let you know; in those 30 minutes, we’re going to compare the British and Australian approaches to safety. We’re going to talk about the similarities and differences between Australian and British legislation. On the safety guidance that’s available from the various authorities the different jurisdictions in the UK and Australia. Jurisdiction is not really an issue in the UK but certainly is in Australia, so that’s something we really need to go through.



We’ll talk about regulators and the different approaches to regulation. And, finally, some cultural issues. I may mention the dreaded EU. It’s worth talking a little bit about that too because there are still significant links between the EU and the UK on how safety is done which Australians might find helpful.



Introduction



Now, where’s Michael Bublé when I need him to sing the song? It says it’s looking a lot like Brexit. With the Conservatives winning in the UK they’ve passed the Brexit act. It looks like it’s finally going to happen. Now whether you think that’s a good idea or not I’m not going to debate that, you’ll be pleased to hear – you’re sick of that, I’m sure.



There are going to be some safety professionals and other engineering professionals who were working in the EU. And who maybe won’t be able to do so easily anymore, and there might be some Brits thinking well maybe this is an opportunity. This is a prompt for me to think about moving to Australia and seeing what life is like there. Conversely, there may be Aussies seeking opportunities in the UK because if the flow of professionally qualified Engineers and so forth from the EU countries dries up or slows down then there might be more opportunity for Aussies. Indeed, the UK has been talking about introducing an Australian-style points-based immigration system. And I think we might see a favourable treaty between UK and Australia before too long.



What have I got to contribute here? I spent quite a few years in the UK as a safety engineer and safety consultant and I worked on a lot of international projects. I worked on a lot of UK procurements of American equipment. And I also worked very closely with German, Italian and Spanish colleagues on the Eurofighter Typhoon for thirteen years on and off. And I have quite a bit of experience of working in Germany and some of working with the French. I’ve got I think quite a reasonable view of different approaches to safety and how the UK differs from and is like our European counterparts.



Also, seven years ago I emigrated to Australia. I went through that points-based process, fortunately with a firm to back me up. I made the transition from doing UK-style safety to Australian-style safety.



Let’s get on with it.



Legislation #1



There are very many similarities between Australian and UK approaches to safety. Australia has learned a lot from the UK and continues to be very close to the UK in many ways, particularly in our style of law and legislation. But there are differences and I’m mainly going to talk about the differences.



First of all in the UK we’ve had the Health And Safety At Work (HSAW) Act around since 1974. That’s the executive Act that sets up the Health and Safety Executive the HSE as a regulator, gives it teeth and enables further legislation and regulations. Now if I was still in the UK, the next thing we would talk about would be in any discussion about health and safety at work would be the ‘six-pack’.



Now, these were six EU directives that the UK converted into UK regulations, as indeed all EU member states were required to. Incidentally, the UK was very successful in influencing EU safety policy, so it’s a bit ironic that their turning their back on that.  What will you find in the six-pack?



First of all, the regulations on management of health and safety at work otherwise known as HSG65 and there’s a lot of good advice in there on how to do risk management that is broadly equivalent, for an Aussie audience, to the Risk Management Code Of Practice: similar things in there that it’s trying to achieve. Then we’ve got the Provision and Use of Work Equipment Regulations or PUWER for short. That says if you provide equipment for workers it’s got to be fit for purpose. Then there are regulations on manual handling, on workplace health safety and welfare, on personal protective equipment at work, and on the health and safety of display screen equipment of the kind that I’m using here and now (I’m sat in my EU-standard computer chair with five legs and certain mandatory adjustable settings).



Now Aussies will be sat there looking at this list thinking it looks awfully familiar. We just package them up slightly differently.



There’s also, it should be said, a separate act called the Control Of Major Accident Hazards or COMAH as it’s known. And that was introduced after the Piper Alpha disaster in the North Sea which claimed 167 lives in a single accident. That covers big installations that could cause a mass-casualty accident. So that’s the UK approach.



Legislation #2



Now the Australian approach is much simpler. The Aussies have had time to look at UK legislation, take the essentials from it and boil it down in into its essence quite cleverly. There is a single Work Health and Safety (WHS) Act, which was signed up in 2011 and came into force on the 1st of January 2012. And there are a single set of WHS Regulations that go hand in hand with the Act.



And they cover a wide spectrum of stuff. A lot of the things in the UK that you would see covered in different acts and different regulations are all covered in one place. Not only does it address, as you would expect, the workplace responsibilities of employers and employees etc., but there are also upstream duties on designers and manufacturers and suppliers and importers and so forth. The WHS act pulls all these things together quite elegantly into one.



It’s a very readable act. I have to say it’s one of the few pieces of legislation that I think a non-lawyer can read and make sense of. But you’ve got to read what it says not what you think it says (just a word of caution).  The regulations cover Major Hazard Facilities, rather like the COMAH regulations, so they’re all included as well.



It’s worth noting that Australian WHS, unlike the UK, does not differentiate between safety and security. If somebody gets hurt, then it doesn’t matter whether it is an accident or whether it was a malicious act. If it happens to a worker, then WHS covers it. And that puts obligations on employers to look after the security of workers, which is an interesting difference, as the UK law generally does not do that. We’re seeing more prosecutions (I’m told by the lawyers) for harm caused by criminal acts than we are yet seeing for safety accidents.



And that’s the act and regulations. And it’s also worth saying that Australia has a system of Codes Of Practice just as the UK has Approved Codes Of Practice. Now that’s all I’m going to say for now. There are other videos and resources on the website that go into the Act and Regulations and COP. I’m going to do a whole series on all those things, unpacking them one by one.



Legislation #3



Let’s think about exceptions for a moment because the way that the UK and Australia do exceptions in their Health and Safety legislation is slightly different. In the UK, the Health and Safety at Work Act explicitly does not apply to ships and aircraft moving under their own power. That’s quite clear. That kind of division does not occur in Australia.



Also, the UK Health and Safety Act does not apply to special forces, or to combat operations by the armed forces, or to the work up to combat operations. Again, those exclusions do not exist in Australia. And then it’s also worth saying there are many other acts enforced by the UK HSE. It’s not just about HSAW, the six-pack and COMAH. There’s a lot of regs and stuff on mining and offshore, etc., you name it. The UK is a complex economy and there are lots of historical laws. Going back up to 100 years. I think the Explosives Act was in 1898, which is still being enforced.



Now Australia has a different approach. They’ve made a clean sweep; taken a very different approach as we’ll see later. And there are only really three explicit exclusions to the Act. It says that WHS doesn’t apply to merchant ships, which are covered by the Occupational Health and Safety (Maritime Industry) Act. So, merchant ships aren’t covered, and WHS doesn’t apply to offshore petroleum installations either. More on that later.



There is a separate act that deals with radiation protection, and that is enforced by the ARPANSA, the Australian Radiation and Nuclear Safety Protection Agency. So, a slightly different approach to what is covered and what is not; but very similar in the essentials.



Legislation #4



One of those essentials is the determination of how much safety is enough. In the UK the HSE talks about ALARP and in Australia the Act talks about SFARP. This quote here is directly from the UK HSE website. Basically, it says that ALARP and SFARP are essentially the same things. And the core concept, what is reasonably practicable, is what’s defined in the WHS Act.



Now it’s worth mentioning that the HSE say, this because it was the HSE who invented the term ALARP. If you look in UK legislation you will see the term SFARP, and you’ll see other terms like ‘all measures necessary’. There are various phrases in UK laws to say how much is enough, and the HSE said it doesn’t matter what it says in the law, the test we will use is ALARP and it covers all these things. It was always intended to be essentially the same as SFARP.



Now there is some controversy in Australia about that, and some people think that ALARP and SFARP are different. The truth is that in Australia, as in the UK, some people did ALARP badly. They did it wrong. If you do ALARP wrong, it’s not the same as SFARP, it’s different. But if you’re doing ALARP properly it is the same. Now, there are some people who will die in a ditch in order to disagree with me over that but I’m quoting you from the HSE, who invented the term to describe SFARP.



It’s also worth noting that WHS uses the term SFARP, but the offshore regulator, which is the National Offshore Petroleum Safety and Environmental Management Agency (NOPSEMA), they use the term ALARP, because they’ve got a separate act from WHS for enforcing safety on offshore platforms. But again, even though they’re using ALARP, it’s the same as SFARP, if you look at the way that NOPSEMA explain ALARP.  They do it properly. And it matches up with SFARP, in fact, that NOPSEMA guidance is very good.



Guidance



We’ll talk more on regulators, but first a little aside and you’ll see why in a moment. Before we can get to talking about regulators, I need to tell you about where you can get guidance in Australia.



Now in the UK, you’ve got the HSE, who is the regulator and they also provide a lot of guidance. Any safety Engineer in the UK will immediately think of a document called R2P2, which is short for ‘Reducing Risk, Protecting People’. That’s an 80-something page document, in which the HSE explain their rationale for how they will enforce safety law and safety regulations and what they mean by ALARP and so on. There’s also a lot of guidance on their website as well, which is excellent and available under a Creative Commons licence so you can do an awful lot with it.



In Australia, it’s a little bit more complex than that. The WHS act was drafted by Safe Work Australia, which is a statutory agency of the government. It’s not a regulator, but it was the SWA who developed the Model WHS Act, the Model Regulations and the Model Codes Of Practice. (More on that in just a second.) It’s Safe Work Australia that provides a lot of good guidance on their website.



Most Australian regulators will refer you to legislation . We’ve got a bit of an American approach in that respect in Australia, in that you can’t do anything without a lawyer to tell you what you can and can’t do. Well, that’s the way that some government agencies seem to approach it. Sadly, they’ve lost the idea that the regulator is there to bridge the gap and explain safety to ordinary people so they can just get on with it.



Now some regulators in Australia, particularly say the New South Wales state regulator or Victorian state regulator do provide good guidance for use within their jurisdiction. The red flashing lights and the sirens should be going off at this point because we have a jurisdiction issue in Australia, and we’ll come onto that now.



Jurisdictions



In the UK, it’s reasonably simple. You’ve got the HSE for England and Wales, you’ve got the HSE for Scotland and you’ve got the HSE for Northern Ireland. They are enforcing essentially the same acts and the same regulations, right across the United Kingdom. Now there are differences in law: England and Wales have a legal system; Scotland has a slightly different legal system; then Northern Ireland has peculiarities of its own. But they’re all related. There are historical reasons why the law is different, but, from a safety point of view, all those three regulators do the same thing. And work consistently.



In Australia, it’s a bit different. Australia is a Federated Nation. We have States and Territories as you can see, we’ve got Queensland, New South Wales and Victoria. Within New South Wales we’ve got the ACT, that’s the Australian Capital Territory, and Canberra is the Australian Federal capital.



Most Australians live on that East Coast, down the coast of Queensland NSW and Victoria. Then we’ve got Tasmania, South Australia, the Northern Territory and Western Australia. All those states and territories have and enforce their own Safety Law and Regulations.



On top of that, you’ve got a Federal approach to safety as well. Now, this will be a bit of a puzzle to Brits, but in Australia, we call the national government in Canberra ‘the Commonwealth’. Brits are used to the Commonwealth being 100+ countries that used to belong to the UK, but now they’re a club. But in Australia, the Commonwealth is the national government, the Federal Government.



Regulators #1



Let’s talk about regulators, starting at the national level. If you look at the bottom right-hand corner, we have got Comcare. They are the national regulator, who enforce WHS for The Commonwealth of Australia, all Federal workplaces, Defence, any land that’s owned by The Commonwealth, and anything where you’ve got a national system. You’ve also got some nationalised or semi-nationalised industries that effectively belong to the Commonwealth, or are set up by national regulations, and they operate to the Commonwealth version of WHS



Then you’ve got the Northern Territory, Tasmania, South Australia, Queensland, New South Wales and the Australian Capital Territory. All those states and territories have their own versions of the Model WHS Act, Regulations and COP. They’re not all identical but they’re pretty much the same. There are slight differences in the way that things are enforced, for example in South Australia there’s a couple of Codes Of Practice that Work Safe SA have said they will not enforce.



These differences don’t change the price of fish. All these regulators have their own jurisdiction, and they’re all doing more or less the same thing as Commonwealth WHS. If you start with the Model WHS Act or the Commonwealth version, then you won’t be far off what’s going on in those states and territories. However, you do have to remember that if you’re doing non-Commonwealth work in those states and territories, you’re going to be under the jurisdiction of the local state or territory regulator.



That’s the easy bit!



Unfortunately, not all states have adopted WHS yet. Western Australia (bottom left-hand corner) they are going to implement WHS but it’s not there yet. Currently, in December 2019 they’re heading towards WHS, but they’re still using their old Occupational Health and Safety (OS&H) Legislation from about 1999, I think.



Victoria has decided that they’re not going to implement WHS. Even though everybody agreed they would , they’re going to stick with their Occupational Health and Safety at work Act, which again I think dates from something like 1999. (These acts are amended and kept up to date.)  Victoria has no plans to implement WHS.



You, like me, might be thinking what a ridiculous way this is to organise yourself. We’re a nation of less than twenty-five million people, and we’ve got all this complexity about regulators and how we regulate and yes: it is daft! Model WHS was an attempt to get away from that stupidity. I have to say it’s mostly been successful, and I think we will get there one day, but that’s the situation we’ve got in Australia.



Regulators #2



Now, a quick little sample of regulators in the UK and Australia just to compare. I can’t go through them all, because there are a lot. I wanted to illustrate the similarities and differences; there are many similarities for Brits coming to Australia or Aussies going to the UK. You will find a regulatory system that in most part looks and feels familiar.



In the UK, for example, you’ve got the Civil Aviation Authority, who regulate non-military flying, airports etc; in Australia, you’ve got the Civil Aviation Safety Authority, which does almost the same thing. In the UK you’ve got the Air Accident Investigation Branch, who do what their name implies; in Australia, you’ve got the Australian Transportation Safety Bureau, who also investigates air accidents (they do maritime accidents as well). By the way, the ATSB in Australia is somewhat modelled on the American ATSB, with a very similar approach to the way they do business.



Now when we get onto the maritime side, it’s quite different. In the UK, you’ve got the Maritime and Coastguard Agency or MCGA. They regulate Civil Maritime Traffic and health and safety on merchant ships; they also investigate accidents. In Australia, don’t forget we’ve got the ATSB looking at maritime accidents and publishing statistics. We’ve then got the Australian Maritime Safety Authority, the AMSA, who look at the design aspects of safety of ships. (These are all national / Federal / Commonwealth regulators, by the way.)

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Simon Di Nucci https://www.safetyartisan.com/2022/09/07/brexit-special/