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Risk Assessment Blunders

Analysis TeamUpdated 7-Jul-2014

Recently I read a blog post writ­ten by Dav­id Cant, called, “Are You Mak­ing These Risk Assess­ment Blun­ders?”. Writ­ing in the UK, Mr. Cant spoke to some of the com­mon kinds of prob­lems that can occur when employ­ers con­duct risk assess­ments. Many his points are equally applic­able to machine build­ing:

  1. No Risk Assess­ment – This seems self evid­ent, since you can’t work to con­trol what you don’t know exists. Unfor­tu­nately, some liab­il­ity law­yers have advised cli­ents NOT to con­duct risk assess­ments, on the basis that you can’t be blamed for some­thing you knew noth­ing about. This pos­i­tion is chan­ging, since risk assess­ment has become a fun­da­ment­al piece of the machinery design pro­cess and is included in US, Cana­dian, Inter­na­tion­al, EU, and Aus­trali­an stand­ards to name a few. What remains as a liab­il­ity are poorly done risk assess­ments, and those can cer­tainly hurt a com­pany in a liab­il­ity case. See Point 3.
  2. Not Prop­erly Identi­fy­ing Haz­ards – This is anoth­er big one. Machine build­ers some­times fail to under­stand the haz­ards that are incor­por­ated into their machinery, espe­cially in the case of sys­tem integ­rat­ors. Iden­ti­fic­a­tion is the first step, ana­lys­is is the second step. Once the haz­ard has been iden­ti­fied, the assessors must ana­lyze the haz­ard to under­stand the mag­nitude of injury that can occur, e.g., a paper cut, hear­ing loss, per­man­ent mus­cu­lo­skelet­al dis­order, fatal­ity, etc.
  3. Cre­at­ing an inad­equate risk assess­ment – If you “phone it in”, any know­ledgable per­son will be able to see that, and you can be sure that pro­sec­utors will bring that to the atten­tion of the court! Any claim that is made will be refuted by a know­ledgable per­son hired by the pro­sec­u­tion.
  4. Assum­ing Safety Because You Have a Doc­u­ment – A risk assess­ment report nev­er pro­tec­ted any­one from harm. Actions based on the report are what pro­tect people from harm. Simply com­plet­ing a risk assess­ment and stick­ing the report in the design file fixes noth­ing, and going back to the liab­il­ity dis­cus­sion, will cre­ate prob­lems when it becomes clear that a) You knew about the risks, b) You thought out mit­ig­a­tion meas­ures for the risks, but c) You failed to act on your own recom­mend­a­tions.
  5. Not involving your employ­ees – I would change this to read, “Not involving the cus­tom­er or end user.” Get­ting a risk assess­ment done by an out­side indi­vidu­al is likely going to res­ult in a poor out­come, if that per­son does not work with the know­ledgable people in your organ­iz­a­tion. If this is an intern­al risk assess­ment for a pro­cess used in-house, then you need the work­ers involved with the pro­cess to be part of the risk assess­ment team. You also need the pro­cess design­ers (elec­tric­al, mech­an­ic­al, soft­ware, etc.). If this is a product devel­op­ment risk assess­ment, then you will need product design­ers, mar­ket­ing or sales people, and end-users. In all cases you may also need out­side experts to help with haz­ard ana­lys­is and mit­ig­a­tion, since you may not have the expert­ise in-house. A good example of this is the use of indus­tri­al lasers into pro­cesses.
  6. Assess­ing risk gen­er­ic­ally – this goes back to point 3 – a risk assess­ment has to be rel­ev­ant to the pro­cess, product or ser­vice that it describes. Using a risk assess­ment developed by someone else for some oth­er sim­il­ar product, pro­cess or ser­vice lim­its your think­ing to just what they decided was rel­ev­ant. Bet­ter to start with a blank sheet, and only at the end look at other’s work to see if you may have missed any­thing they included.
  7. Doing the risk assess­ment after the machine has been designed, built and put into use – This is a com­mon prob­lem, and espe­cially affects work­places that buy off-the-shelf machinery and used machinery. Many machine build­ers are not famil­i­ar with risk assess­ment or the bene­fits to their products, their liab­il­ity expos­ure, and their repu­ta­tion in the mar­ket­place, let alone the bene­fits to their cus­tom­ers. Con­duct­ing the risk assess­ment after the equip­ment is in use means that the first stage of the Hier­archy of Con­trols can­not be used. Since this is the only stage that can achieve 100% risk reduc­tion, this is a HUGE loss. In addi­tion, this means that any changes needed to mit­ig­ate risk require expens­ive changes when the machinery is already in pro­duc­tion, com­pound­ing the expense with lost pro­duc­tion. If you have no oth­er option – for instance, you’ve taken over an exist­ing busi­ness and no risk assess­ments have been done in the past, then late is bet­ter than nev­er, but it should be a last resort and not the first choice. Spe­cial thanks to Douglas Florence for sug­gest­ing this added blun­der!

All of this brings me to some import­ant stand­ards. The Cana­dian Stand­ards Asso­ci­ation released CSA Z1002, Occu­pa­tion­al health and safety – Haz­ard iden­ti­fic­a­tion and elim­in­a­tion and risk assess­ment and con­trol, in 2012. This is a land­mark stand­ard, because it addresses work­place risk assess­ment. No oth­er stand­ards devel­op­ment organ­iz­a­tion has released any­thing quite like it. There are some innov­at­ive ideas in the stand­ard, includ­ing the idea of “risk trans­fer.” This concept explains how risk is trans­ferred from the developer or sup­pli­er of a product, pro­cess or ser­vice, called the “extern­al con­text”, to the user organ­iz­a­tion, called the “intern­al con­text”, and then to the work­er. At each trans­fer point, the risk should have been reduced so that the worker’s expos­ure is as low as pos­sible, and cer­tainly no high­er than per­mit­ted by law.

In the machinery world, the “moth­er stand­ard” is ISO 12100, Safety of machinery — Gen­er­al prin­ciples for design — Risk assess­ment and risk reduc­tion. This stand­ard affects many of the machinery safety stand­ards developed world­wide, includ­ing CSA Z432 and the ANSI B11 stand­ards, and is har­mon­ized under the Machinery Dir­ect­ive as EN ISO 12100. This stand­ard lays out the pro­cess for safe machine design and provides the frame­work for machinery risk assess­ment. A com­pan­ion doc­u­ment, ISO/TR 14121 – 2, Safety of machinery – Risk assess­ment – Part 2: Prac­tic­al guid­ance and examples of meth­ods, provides guid­ance on how to con­duct a risk assess­ment, and offers up some example tools that could be used for this pur­pose. In the US, ANSI pub­lishes ANSI B11-TR3, Risk Assess­ment and Risk Reduc­tion – A Guide to Estim­ate, Eval­u­ate and Reduce Risks Asso­ci­ated with Machine Tools, provid­ing sol­ar guides to users of the B11 fam­ily of stand­ards.

Need to know more? Con­tact me for inform­a­tion train­ing and risk assess­ment work in your facil­ity!

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