18 November 1998Pollution Prevention Planning, Inc. 1 Fire Protection Risk Management “A DoD Program Manager’s Perspective” Carmen DiGiandomenico Pollution Prevention Planning, Inc Harpoon Drive Stafford, Virginia (540)

18 November 1998Pollution Prevention Planning, Inc. 2 OUTLINE Purpose Organizations & Functions Decision-making Process Summary

18 November 1998Pollution Prevention Planning, Inc. 3 PURPOSE Help you understand how DoD Program Managers (PMs) conduct fire protection risk management by providing: –An organizational & functional overview –Approaches to fire protection risk management –Insight into differences among services

18 November 1998Pollution Prevention Planning, Inc. 4 ORGANIZATIONS & FUNCTIONS

18 November 1998Pollution Prevention Planning, Inc. 5 Organizational Overview External Regulators & General Accounting Office Laboratories Systems & Materiel Commands Program Manager (PM) Offices Operational Organizations Depot/Repair Organizations Internal Regulators, Inspectors General & Advisors

18 November 1998Pollution Prevention Planning, Inc. 6 Internal Regulators - USD(A&T) DoD Regulation R - All PMs must: –Integrate environmental, safety, & health (ESH) issues into the systems engineering process –Develop a system safety & health program that: manages risks from - death- injury - acute/chronic illness - disability - reduced job performance covers personnel involved with the system who - produce- test - operate- maintain - provide support –ESH decisions based on lowest life cycle cost to protect human life and the environment

18 November 1998Pollution Prevention Planning, Inc. 7 Internal Inspectors General DoD & each service Audit & review compliance to regulations Conduct investigations into –Fraud, Waste & Abuse Examples of reports: –HazWaste Minimization 80% of DoD’s HazWastes come from weapon systems –Comanche (RAH-66) $18B-$30B in HAZMAT-related life cycle costs

18 November 1998Pollution Prevention Planning, Inc. 8 “Internal” Advisory Boards DoD & service independent Science Boards Examples of reports: –Defense Science Board Report on Aviation Safety Decline in DoD accident rate has leveled off Programs address basic causes only to a limited extent Life Cycle Cost of accidents is rarely addressed –Naval Studies Board (NRC/Academy of Science) Halon replacement efforts are being studied effectively, the body of knowledge is being developed & no gaps in the effort Unlikely a drop-in replacement will be discovered Effective alternatives have been identified & are being incorporated in new ships & aircraft Promising agents, in addition to chemical replacement agents, are being considered (e.g., water-mist & inert gas generators)

18 November 1998Pollution Prevention Planning, Inc. 9 External Regulators Environmental Protection Agency –Clean Air Act (CAA) Section 612(c) prohibits replacing Class I & II substances w/substitutes that may present adverse effects to human health & the environment –Significant New Alternatives Policy (SNAP) Requires toxicity data (e.g., cardiotoxicity study in dogs) EPA defers to OSHA for regulating workplace safety EPA expects users to conduct thorough technical investigations Acceptability not to be construed as endorsement of any given fire or explosion scenario - users should consult fire protection specialists –National Environmental Policy Act (NEPA) Federal agencies (e.g., EPA, DoD, FAA) must consider the impact of policies & actions on the human environment as a part of their decision-making process Occupational Safety & Health Administration –Occupational Safety & Health Standards (29 CFR 1910) 29 CFR governs use of all gaseous agents in fixed extinguishing systems

18 November 1998Pollution Prevention Planning, Inc. 10 General Accounting Office (GAO) Congressional investigative office Audits & reviews federal agencies Example of reports: –Best Practices Commercial firms gain more knowledge of a product’s technology, performance, & producibility much earlier in the product development than DoD DoD increases risks by allowing more technology development to continue into product development

18 November 1998Pollution Prevention Planning, Inc. 11 Laboratories Basic & applied research –Typically non-system specific Examples: –US Air Force Research Laboratory (AFRL) Performance evaluation tests Toxicity tests –US Army Center for Health Promotion & Preventative Medicine (CHPPM) Toxicity Profiles Health Hazards Analyses –US Naval Research Laboratory (NRL) Performance evaluation tests

18 November 1998Pollution Prevention Planning, Inc. 12 System & Materiel Commands Provide PMs with engineering infrastructure Examples –Air Force Materiel Command Product Centers Eliminated Fire Protection Office in early 1990s Process Action Committees (PACs) concluded Air Force lacked sufficient infrastructure support –Naval Air Systems Command Naval Air Warfare Centers –Army Materiel Command Major Subordinate Commands

18 November 1998Pollution Prevention Planning, Inc. 13 Program Managers (PMs) Responsible for all aspects of program –Cost –Schedule –Performance Operational requirements (e.g., survivability) Technical requirements (e.g., ESH integration) Develop & control maintenance procedures Decide on system fire protection –Passive (e.g., isolate hot surfaces, quick shut-off) –Active (e.g., agent, distribution, detectors)

18 November 1998Pollution Prevention Planning, Inc. 14 Operational Organizations Establish operational requirements for PMs Primary input for funding prioritization Conduct “day-to-day” maintenance Include “Users” of weapon systems, e.g., –Air Force User Major Commands –Army - User Major Commands –Navy - Fleet Commanders in Chief

18 November 1998Pollution Prevention Planning, Inc. 15 Depot/Repair Organizations Conduct major overhauls, rebuilds, & repairs Follow PMs’ maintenance procedures Include: –Air Force Logistic Centers –Naval/Marine Corps Air Rework Facilities –Army Depots

18 November 1998Pollution Prevention Planning, Inc. 16 Decision-making Process

18 November 1998Pollution Prevention Planning, Inc. 17 How Do PMs Make Decisions? “Risk Management” decisions based on available data that are: –Accurate Based on accepted technical & management standards –Complete Balanced across all critical parameters Systems engineering (“holistic”) solutions –Objective Provided/reviewed by “honest brokers” (e.g., input from agencies who have no vested interest in the outcome of the decision) PMs place trust in agencies who provide data that are accurate, complete, & objective

18 November 1998Pollution Prevention Planning, Inc. 18 Accepted Technical Standards Data based on universally accepted standards, e.g., –Fire suppression NFPA –Materials Compatibility ASTM, NIST –Toxicity & Exposure AMES Screening DuPont, et. al. Cardiac Sensitization OSHA Standards

18 November 1998Pollution Prevention Planning, Inc. 19 Accepted Management Standards MIL-STD-882C “System Safety Program” –Accepted by both industry & government –Proven & used by services in managing ESH risks –For system hazards, requires all PMs to: Identify in terms of their specific system Assess in severity and probability of occurrence Categorize in terms of high, medium/serious, and low Prioritize in terms of importance & mitigation effectiveness Mitigate in terms of how and when Obtain acceptance in terms of the correct level of authority

18 November 1998Pollution Prevention Planning, Inc. 20 HIGH LOWHIGH SEVERITY OF AN OCCURRENCE PROBABILITY OF AN OCCURRENCE These don’t happen often and when they do, they’re not bad. They don’t pass the “so-what” test! These don’t happen too often but when they do, they’re bad. FIX THESE. These happen often but when they do, they’re not too bad. FIX THESE. These happen often and they’re always bad.FIX THESE. System Risk Management Analysis

18 November 1998Pollution Prevention Planning, Inc. 21 Risk Management Analysis Comparison of Two Agents During Accidental Discharges HIGH LOWHIGH SEVERITY OF AN OCCURRENCE ( chemical & exposure related) PROBABILITY OF AN OCCURRENCE (system related) B2 B1 A1A2 A2-Exposure > Cardiac Sensitization & Infrequent Accidental Discharges B1-Exposure permanent lung damage & Frequent Accidental Discharges B2-Exposure permanent lung damage & Infrequent Accidental Discharges A1-Exposure > Cardiac Sensitization & Frequent Accidental Discharges

18 November 1998Pollution Prevention Planning, Inc. 22 Critical Parameters Identified by PMs Varies from system to system based on requirements Must include life cycle issues A common list has been developed by Army Common list effectively used by PMs in other services

18 November 1998Pollution Prevention Planning, Inc. 23 Critical Parameters Common List Class A Effectiveness Class B Effectiveness Class C Effectiveness Class D Effectiveness Complete Volume Fill Quick Response Time Persistence Cooling Effect Throwing Characteristics Neat Agent Health Effects Pyrolysis Health Effects Visual Acuity Clean Agent Shelf Life Stability in Bottle Environmental Impact of Production Environmental Impact of Neat Agent Environmental Impact of Pyrolysis Products Electrically non-conductive Neat Agent Compatibility w/Protected System Pyrolysis Products Compatibility w/Protected System Neat Agent Compatibility w/Fire Suppression System Availability of a Viable Production Base Refill Capability Handling, Transportation, Maintenance Impacts Testing Hardware Availability Space & weight Impacts Costs

18 November 1998Pollution Prevention Planning, Inc. 24 Systems Engineering Approach Seeks “holistic” solution Avoids “drop-in” euphoria Involves much more than “chemists” Considers all practical aspects –Passive as well as active techniques –Agent effectiveness –Distribution aspects –Detection sensitivity/reliability

18 November 1998Pollution Prevention Planning, Inc. 25 Objective Information PMs don’t like being given “half-truths” PMs rely on internal “honest brokers” PMs are inundated with “sales pitches” PMs are wary of “drop-in” solutions

18 November 1998Pollution Prevention Planning, Inc. 26 Summary PMs –Are key to system-related fire protection decisions within DoD –Respond to Military Operators’ requirements –Attempt to make informed “risk management” decisions –Approach issues from a systems engineering perspective –Rely on accurate, complete, & objective data –Use accepted standards –Don’t like “surprises” Researchers can be most effective when they –Understand the system(s) that their technology/agent may support –Understand PM’s “risk management” decision process –Understand the life cycle issues involved with their technology –Provide accurate, complete, & objective data early in process