You left off arguably the biggest reason,

-          What’s a risk assessment?; they don’t know they should be doing one.

-Dave

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday, March 06, 2015 2:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

Good evening

My “ three pennyth” / “few cents worth” – for what they are worth ☺:

Regardless of what product or system is under discussion, there is rarely (if 
ever?) a rationale for not doing relevant risk assessments  - what may put some 
people off doing it, or doing it properly, could be (in no particular order, 
and there are probably many more!) any or all of the following:

-       They don’t know which risk assessment standard/methodology to apply

-       They don’t believe it is necessary or would help

-       They don’t actually know what it involves in respect of their product

-       They believe the product already complies with a “standard” and that is 
“good enough” – even if that standard has no overt risk assessment requirements

-       They think they already know what the risks are, and what they have 
already done to mitigate them is “good enough”, and so any chance of a real 
accident is remote to “impossible”

-       They don’t think wider than their own “box” in terms of the effects it 
could have on other “boxes” with which it might be, or conceivably be used, 
and/or by whom

-       They think risk assessment only applies to basic occupational safety 
(health & hygiene, climbing ladders, manual handling, etc.) within their 
premises or domain – and that’s someone else’s responsibility

-       They don’t want to risk finding out something that they really won’t 
like

-       The “guy at the top” believes one or more of the above will cause him 
more harm than good, and cost him a lot of time and money in the process, and 
won’t sanction it even when his employees state clearly that it is necessary

-       The “guy at the top” is working to tight time/cost targets and means to 
“get the job done” regardless of anything else – and then deal with any 
“consequences” later

-       The “guy at the top” has no concept of risk assessment, and what can 
result if you don’t do (and properly)

-       The “guy at the top” believes that “the insurance will cover any 
consequences”

-       The “guy at the top” has no understanding failure to take the right 
actions could result in criminal prosecutions – including of himself

-       The “guy at the top” is a “cowboy”, pure and simple (and I’ve met a few 
of those in my time!)

Why have I said all these “obvious” things that I think we have all encountered 
some time / somewhere?

Because I think they encompass many of the reasons given in the earlier posts 
as to why risk assessments are not done, or are not done appropriately (and I 
have avoided the word “correctly” because I don’t think there could ever be a 
“correct” risk assessment in absolute terms!).

Therefore if you made up a checklist something like the above, then maybe you 
could begin to identify why some companies do, or don’t do, the appropriate 
risk assessments, see where the drop-offs could be fixed, and try to overcome 
any opposition to doing them as/where/how appropriate.

John Allen
W.London, UK

From: dward [mailto:dw...@pctestlab.com]
Sent: 06 March 2015 18:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

“Risk Assessment” or in plain English – How many people have to get injured or 
killed before anything is done that should have been done in the beginning 
anyway.


​​​​​
Dennis Ward
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From: Douglas Powell [mailto:doug...@gmail.com]
Sent: Friday, March 6, 2015 10:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Safety standards versus safety engineering

Mike,

"...dismissal of identifiable risks..."

Isn't this the main problem with Risk Assessment in general.   The people 
assigned to identify risks and catalog their risk values are almost always the 
same ones who design and built the product. The same goes for FMEA, and PFMEA.  
The assignment of risk values is very subjective, allowing those involved to 
say "the chances of that happening are ____".  And the team agrees to set the  
likelihood of occurrence very low.

I watched exactly this scenario occur in real life when through a chain of 
events a 7,000 CFM cooling fan was activated while a worker had his hands in 
the exhaust duct.   1) He should not have been working in there with power 
applied, 2) Communications to the Xylinx fan controller had been established 
through the company ethernet, 3) The default IP address of the controller had 
not been changed, 4) The digital engineer was working on a similar proto board, 
in another office building, with the same default IP address configured on his 
board, 5) The proto board was connected to the same network, as is their usual 
practice,  6) The digital engineer enabled the fan on his proto board and 
simultaneously enabled the fan in the unit on the manufacturing floor to full 
speed.

Risk Assessment said this was very unlikely event and the technician nearly 
paid for it.   The mitigation was to simply reassign the IP address for every 
circuit board on receipt at incoming inspection and to reinforce LOTO safety 
procedures on the shop floor.

Oh, and by the way, this product was already fully certified to applicable 
standards.

Thanks, - doug

Douglas Powell
Skype: doug.powell52
http://www.linkedin.com/in/dougp01



From: Mike Sherman ----- Original Message -----
Sent: Friday, March 6, 2015 10:17 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Reply To: msherma...@comcast.net<mailto:msherma...@comcast.net>
Subject: Re: [PSES] Safety standards versus safety engineering


Re "...and dismissal of identifiable risks deemed conveniently unlikely to 
occur."

This is a real issue in organizations, and was a key contributor to the 
Columbia space shuttle disaster.

NASA's Columbia Accident Investigation Board's final report explores this 
contributor a lot. The report is easy to find on the web.

As safety professionals, we are more effective if we understand the psychology 
that makes such dismissal attractive and learn to counteract it.

Mike Sherman
Graco Inc.

________________________________
From: "CR" <k...@earthlink.net<mailto:k...@earthlink.net>>
To: "EMC-PSTC" <EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Sent: Friday, March 6, 2015 6:46:33 AM
Subject: Re: [PSES] Safety standards versus safety engineering

On 3/6/2015 2:56 AM, John Woodgate wrote:
> Making the designers responsible for the safety of the design (as
> opposed to the safety of what is shipped, over which they have no
> control) immediately eliminates any claim that it's not their problem
> and/or cramps their style.
I'm not a Safety Engineer; my work is in EMC but...

Some years ago, after the EU tripled the immunity requirement for
medical equipment, I had occasion to speak with a management type
complaining that a test plan I'd written required them to do tests no
other firm did, and would place them at a competitive disadvantage.
Asked why, I said: "Because I don't want you to kill people whose lives
you're trying to save." *

End of discussion.

* For an example of what I was thinking about, see number 3 Banana Skin
at /http://www.compliance-club.com/archive/old_archive/Bananaskins.htm/
.  In any event no one had HAD to test to those levels before, and he
didn't want to start.

It seems to me that many firms waste and disparage the pride its own
engineering staff takes in work they do, binding it in a web of Six
Sigma process control inapplicable to creative work, and grinding it
away with a wheel made equally of cost cutting and dismissal of
identifiable risks deemed conveniently unlikely to occur. That may be
another topic.


Cortland Richmond

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