1. Risk Assessment: A Practical Guide to Assessing Operational Risk Chapter 10: Design Safety Reviews

2. Risk Assessments: Design Safety Reviews Objectives Introduce Design Safety Reviews Review Challenges and Obstacles Examine Elements within Design Reviews Provide Guidance on Conducting Design Safety Reviews

3. Introduction Arguably the greatest missed opportunity for organizations to reduce risk is the failure to adequately identify, assess and control risks during the design and redesign phase. At first glance, a safety design review seems like a fairly easy enough process that would be universally practiced within organizations and engineering circles. In reality, there are obstacles that must be overcome to be successful in putting this concept into practice.

4. Design for Safety Designing for Safety (DFS) is a principle for design planning for new facilities, equipment, and operations (public and private) to conserve human and natural resources, and thereby protect people, property and the environment. DFS advocates systematic process to ensure state-of-the-art engineering and management principles are used and incorporated into the design of facilities and overall operations to assure safety and health of workers, as well as protection of the environment and compliance with current codes and standards. ASSE

5. Challenges and Obstacles to Overcome The lack of design safety reviews can lead to embedded problems in facilities, processes, equipment, workstations and products. Reasons that these obstacles exist include: Tradition Turf Training Time

6. Challenges and Obstacles to Overcome Tradition An organization’s culture and traditions are deeply embedded and difficult to change. Within those cultures and traditions are organizational structures and operating systems. Many organizations operate in highly compartmentalized departments (or silos) with a strict chain of command making it difficult for information to flow "horizontally" (from department to department) or "vertically" (around a particular manager). Documented procedures often leave out the critically important step of communicating with other departments. These interdepartmental barriers can prevent open sharing and collaborating among departments in many cases.

7. Challenges and Obstacles to Overcome Training Formal education and training provided to engineers has typically not included occupational safety and health principles. Many engineers have little to no experience in anticipating or recognizing hazards, and are not familiar with the concept of the Hierarchy of Controls. However, this is not a one-way street. Safety professionals need to better understand their organization’s cost drivers and internal protocols for engineering and design as well.

8. Challenges and Obstacles to Overcome Turf Design engineers are responsible for designing systems/products according to established design criteria, within set time and budget constraints. Their primary goal is to design things to work. Understandably, it is not in an engineer’s nature to deviate from their formal education and training or established protocols. As a result, there is often reluctance to seek input from non-engineering departments. This presents an opportunity for safety professionals to prove their worth to engineers (and management) by facilitating pre-operational risk assessments that enable the organization to create safer designs that are more cost effective. Financial measures such as cost/benefit analysis and return of investment (ROI) will aid in communicating the value of design safety reviews.

9. Challenges and Obstacles to Overcome Time The critical path from design concept to production is time limited. Engineers are on a tight schedule and expected to meet their deadlines. Lack of fore-thought or time allotted for safety reviews at the design phase is common. Risk assessments take time to conduct effectively, typically more time than can occur within a design review session. As pointed out by Bruce Main, risk assessments may need to be performed separately from the engineering design review, and should be incorporated into the design process as early as possible.

10. To Overcome Barriers 1.Safety needs to be addressed at the earliest possible point in a project, preferably at the scoping and specification phase. 2.Safety-focused events are needed to give proper attention to hazard identification and elimination. 3.Engineers need a model for understanding their role in preventing incidents. 4.Engineers need to be trained on the process for designing safe systems.

11. Standards Requiring Design Safety 1.ANSI Z10 Occupational Health and Safety Management Systems originally released in 2005. 2.ANSI Z590.3 Prevention through Design Guidelines for Addressing Occupational Hazards and Risks in Design and Redesign Processes in 2011. 3.ANSI B11.0-2015, Safety of Machinery - General Requirements and Risk Assessments standard lists design safety requirements and responsibilities for both the supplier and user of machines

12. The Review of Designs As described by Main, a design review is typically a formal evaluation of a design to ensure that the design meets specified criteria. Safety is only one element to consider in a design review, and the complexity and criticality of the design will dictate the level of hazard analysis and risk assessment needed. Many design reviews include a compliance review aspect.

13. Hazardous Energy Control Haddon’s “Energy Release Theory” is based on an engineering approach that establishes a relationship between incident causation and risk control methods and should be considered in design safety reviews since it relates well to engineers and can be applied systematically.

14. Mandated PHAs What-If Hazard Analysis is one of several process hazard analysis methodologies referred to in the OSHA Process Safety Management standard and EPA Risk Management Plan Rule as an acceptable method.

15. Haddon’s Energy Release Theory Prevent Stored Energy Prevent Energy Release Reduce Rate of Release Separate Energy Release from Humans and Assets by Space and Time Separate Energy Release from humans and assets by physical barriers Modify Contact Surfaces Strengthen Susceptible Structures Increase Detectability and Prevention of Harm Prevent Further Damage

16. Ergonomic Review of Designs The concept of designing in ergonomic principles into the workplace is supported by recent standards such as ANSI/ASSE Z590.3-2011, Prevention through Design Guidelines for Addressing Occupational Hazards and Risks in Design and Redesign Processes standard, and ANSI/AIHA/ASSE Z10-2012, the Occupational Health and Safety Management Systems standard. Certain industries such automotive, aviation and technology have incorporated ergonomic standards and guidelines within their products and systems design specifications and procurement requirements to a certain degree.

17. Ergonomic Review of Designs Three critical elements: 1.Use a formal ergonomic design review process that incorporates a phase-gate review and approval process during design 2.Adherence to ergonomic design standards and guidelines (i.e., reach, force, work height, weight limits, etc.) 3.System for holding engineers accountable for the risk level of their designs (level of musculoskeletal disorder risk factors)

18. Risk Assessments within the Life-cycle of a System

19. Design Review Process To be successful: Top management commitment an established process for design safety reviews within the organization’s operational risk management system potential hazards must be anticipated, identified, eliminated and controlled prior to being introduced to the workplace

20. Design Review Process

21. Hazard Analysis and Risk Assessment in Design

22. Integrating Safety into the Design Process Thorough study and identification of hazards and their control begins in the preliminary design phase and proceeds through final design and testing. 1.Initial design safety review of available data and literature 2.Questions and suggestions generated for further study 3.Second design review by SH&E stakeholders 4.New elements or changes incorporated into the design are reviewed 5.Final design review is made to determine if all parameters have been met 6.Approval – move to implementation phase

23. Conclusion The greatest opportunity for reducing risk and improving safety within systems and products lies within the design phase. SH&E professionals must find ways to actively participate in the design and redesign process if progress is to be made.