GCI TECH NOTES ©
This author, since the early 1980s, has been
involved in developing systems to protect the environment, corporate
interest, employee health and safety, and the public. This paper
provides an introduction for companies to consider how, when, and what
type of hazard analysis is performed to limit corporate liability,
control costs, improve quality control and protect people.
“Hazard Analysis for System Safety”1
by Ericson is an excellent comprehensive text that delves into the
details of over 20 different hazard analysis techniques. It is highly
recommended by the author who has used this text as a foundation for
teaching hazard analysis classes internationally. There are
pre-operation techniques, job or task based methods, post incident or
near miss processes and even specialty techniques such as those used for
software risk assessments.
System safety has, at its core, an eight
element process as established in the military standard MIL-STD-882E,2
shown in Table 1. This DOD document outlines the process of risk
assessments for a variety of situations and systems required by the
military. It is another excellent resource for performing any of a
variety of risk assessments. MIL-STD-882F, the latest update of this
standard issued as a draft, does a more comprehensive job of integrating
risk assessments of the software systems into the overall process.
Table 1 Risk Assessment
Process
Element 1:
Document the System Safety Approach |
Element 5:
Reduce Risk |
Element 2:
Identify and
Document Hazards |
Element 6:
Verify, Validate and Document Risk Reduction |
Element 3:
Assess and
Document Risk |
Element 7:
Accept Risk
and Document |
Element 4:
Identify and Document
Risk Mitigation Measures |
Element 8:
Manage Life-Cycle
Risk |
NFPA 551: Guide for the Evaluation of Fire
Risk Assessments applies when fire risks are of concern. A significant
portion of this guide is based on the previously mentioned military
standard.
Part of determining which type of risk
assessment is appropriate is looking at the circumstances of when and
why the assessment is being performed. Many of the available techniques
are used at different stages during project development such as
preplanning, design, construction and pre-operation. Others are best
used in an ongoing operation or just prior to/during a change in
operations. Other techniques are more frequently used as a result of an
incident or “near-miss.” Commonly used in the latter is the Root Cause
Analysis.
A number of risk assessment techniques are
well suited to target the protection of worker health and safety. These
include Hazard and Operability Analysis (HAZOP),3 Health
Hazard Assessments, and other forms of risk assessments that focus on
identifying and mitigating risks for worker tasks.
Generally, risk assessments that are focused
on workers and/or protecting facilities do an excellent job of
protecting off-site members of the public. That said, there are some
special areas that may require a more detailed look at off-site risks.
One of those would be emissions or releases
from a facility. EPA often requires some form of air quality modeling
and risk assessment during the initial permitting stage of a facility
and often requires updates of this information once a facility is in
operation and/or periodically based on actual emission tests.
Another off-site risk is based on a
theoretical or actual on-site incident that results in a sudden release.
Again, this may require modeling to determine the extent of the off-site
risk. For certain hazardous materials, notification, and even training,
may be needed for local fire departments and other emergency response
personnel.
Finally, the off-site transport of both
products and byproducts of a process may need a risk assessment. The
off-site transport of products is often an issue that is overlooked.
Production is dealt with and end consumer communications are dealt with,
but not the intermediate step(s) of moving the product from the
production facility to the ultimate marketplace.
Food safety is an especially important
concern for risk assessments and the FDA has a number of programs
designed around this concept.
Insurance companies in particular may look at
a facility’s active safety and risk assessment programs and find fault
in the lack of attention to protecting facility physical assets and
ongoing operations. For this reason, and just good business practice, it
is important to consider risks and incident scenarios that do not
necessarily endanger employees, but could damage equipment and/or result
in significant downtime for an operation.
For example, perhaps a change in raw
materials is missed that results in bad product that is caught in the
process quality control program prior to leaving the facility but does
not control that risk adequately prior to the raw materials entering the
process. This is an especially good reason to have personnel who have a
clear understanding of the process involved in performing the risk
assessment, not just a corporate safety engineer who may not have the
needed experience to identify these types of risks.
For certain operations handling highly
hazardous materials, EPA may require risk assessments for personnel, the
public and the environment. However it need not be a highly hazardous
material to have the potential for serious environmental impacts. For
example, something that is not a significant risk for people can be a
real risk to aquatic species in a nearby body of water. Further,
incidents that damage the environment often create huge monetary
liabilities via fines and remediation as well as damage to a business's
reputation and, from there, their market. For these reasons, at every
temporal stage in the risk assessment process, make sure that
environmental risks are evaluated and appropriately mitigated.
There are over 100 different types of risk
assessments currently published and in potential use. This has come
about as a result of a growing awareness over the last 60+ years of the
real hazards associated with numerous activities, from riding a bike or
horse, to running a large industrial plant, to sending rockets into
space. Identifying and mitigating those risks in advance of an incident
is clearly the preferred option over learning something “the hard way.”
David Gossman started his career on the
engineering staff at a nuclear particle accelerator laboratory where it
was often said that the engineers spent half their time working to
prevent the physicists from killing themselves. Since then he provided
early leadership to develop safe and secure systems for recycling wastes
including hazardous wastes. He has designed, operated and built
laboratories for quality testing designed to control and mitigate
hazards to people, processes and the environment. He is a Certified Fire
and Explosion Investigator and has performed many investigations of
fires, explosions and incidents of chemical exposure and developed a
comprehensive under-standing of what can go wrong and just how bad the
end result of such incidents can be. He can bring that experience to
bear on the needs of your operations
1Ericson, Clifton A.,
Hazard analysis techniques for system safety, John Wiley & Sons,
Hoboken, NJ, 2005.
2Department of
Defense Standard of Practice – System Safety, United
States Department of Defense, May 2012, p. 9.
3https://gcisolutions.com/library/gci_tech_notes/gcitn199808.html
Please contact David Gossman at 563-652-2822
or by e-mail at
dgossman@gcisolutions.com for additional information.