Environmental

ct-lAp'TER 16

PREVENTION THROUGH DESIGN: SECTIONS 5.1.1 TO 5.1.4 OF 210 - This chapter, and ANSIIAIHA Z590.3-201 l, the Ameri~an National Standard titled Prevention through Design: Guidelines for Addressing Occupational Hazards and Risks in Design and Redesign Proce~ses, r~late to several provisions in ZlO: risk assessment, Section 5.1.1; hierarchy of controls, Section 5.1.2; design requirements, Section s: 1.3; and procurement, Section 5.1.4. lt 1 also pertains to the prevention of serious injuries and fatalities. ' , ' We said earlier that applying. prevention through design principles early 'in the design and redesign processes reduces the p<>lential for incidents resulting in serious harm or damage. In Chapter 3 "Inflovations in Serious Inj?ry and Fatality Prevention",

1 presented "A Socio-Technicaf Model for Ari Operational Risk Management System"

which gives prominence and Significance to preverition through Oesign. The following pnnctples are offered in support of the premise that prevention ·through design should have such importance. ·,

I. Hazards and nsks are most effectively and economically avoided, eliminated, or controlled in the clesign and redesign ·pro_cesses. .

2 · Hazard analysis i the most iinportant safety process in that, if it fails, all other

processes are likely to be ineffective (Johnson, p. 245). 3. Risk 885\'ssment should be the comerst~n~ of an operational risk management

system. -

Adva11ced Sa . . . Second Ed ' _rfery Management: Focusing on ZlO and Serious In111ry Prevention , © 201

4 Jo •tt on .. Fred A. Manuele. · ho Wiley & Sons, Inc. Published 2014 by John Wiley & Sons, Inc. 309

11111

•

310 PREVENTION THROUGH DESIGN: SECTIONS 5.1.1 TO 5.1.4 OF z10

•

Movhtg prevention upstream ht the design

. process

Business 1--:;:7 concepts l_=_J L.:::_j

Prevention - / -

through __l__ Retrofit design

Operation maintenance

Moving safety from afterthought to a forethought in ' •proc':5s, prod,~c~, and faci~ity design.

·' - Ease of safety ~lementation

FIGURE 16.1 Theoretical ideal prevention through the de~ign process. , l ..

4. If, through the hazard identificaticm and analysis and risk assessment processes ' specifications are develop~ that are applied in th~ _procurement process so~

to avoid bringing hazards and their accompanying risks into a workpjace, the potential for serious injuries is reduced ~ready. , . '

, 'I ( . J.' ,. i : '' 5. The entirety ofpprpose of th~ p~rsoni:iel re~pon~1ble for safety, re~ardless of

their titles, is to manage tpeir endeavors with respect to hazards so that the ris~ deriving from those hazar~s .are ac~eptaQle. . . .

J • (. •

6. To achieve acceptable risk levels, ~lements of a q.ierarchy of controls should be applied sequentially in the risk avoidanc~, elimi~ation, reduction, and control endeavors.

The priictice of ~afety is hazards-based. Thus, Johnson wrote approp~ately tliat hazard analysis is the most important safety process: Since all, risks ~nan operational setting derive from hazards and s1nce the intent of an operauo~al risk management system is to achie~e acceptable risk ·levels, it follows that nsk assessment should be the cornerstone of an ·operational risk' manageme?t syS!e_mk The·core of prevention through design is hazard ·identification and an·alySrs allrl ns assessment. ed

F. 16 · · is mov 1gure .1 depicts the theoretical ideal. Prevention through Design 'th in upstream in the design process. The intent is to have hazards and risks dealt wr the th . · from e conceptual and design steps but that requires unattainable perfecoon . and

• · ' · non people mvolved. Hazards and risks will also be identified in the build, opera ' maintenance steps, for which redesign is necessary in a retrofitting process .

HISTORY 311

. ·teged to be the chair of the committee that wrote the Z590 3 t d ·. d P riv1 h . h . s an ar .

1 was . us that what I ave wntten ere shows a bias in favor of its • 1 , . be obv10 . • imp emen- Jt ~111 In this chapter; we. . , . , -~· . . de a history of the safety through design/prevention through design movement.

• proVl t highlights of Z590.3, emphasizing the applicability of the provisions of • :::::Odard to all h~~ds-b~e~ init~atives: environ~ental controls, product

_t safety of the pubhc, avmdmg property damage artd business interruption siuetY, • and so on. . ..

, Discuss the cu~ture ,chang~ ,?ecessary -~~- ~ost _ orga~izations as prevention thfOUgh design concepts ar~ 1m?lemented w~thin an operation~ risk management

system. . . , Encourage safety. professionals to bC?come involved in prevention through

design fqr job satisfaction an a to b~ percf ived as providing additional vaiue in the organizations to which they give counsel. . ·

HISTORY

In the early 1990s, several safety professionals recognized through _their studies of investigation reports for occupational injuries and illne.sses that design cau~al factors were not addressed adequately. For example, a study made by this author at that time indicated that although there were implications of workplace and work method design inadequacies in over 35% percent of the· investigation reports analyzed, the corrective actions proposed did not relate to the design implications. That study is supported by a later analysis made in Australia. · · ·

In Guidance On The Principles Of Safe Design For Work, issued in 2006, com- ments are made on the "contribution that the design of machinery and equipnienrhas on the incidence of fatalities and injuries 1.n Australia."

Of the· 210 identified workplace fatalities~ 77 (37%) definitely or probably ·had design-related issues involved. Design c'ontributes to a(least -30% of work- related serious nonfatal injuries·. (p. 6) • ·· i · · ·

To provide the necessary education for designers, safety professionals are encour- :~ to develop their own supportive data on incidents in which-design shortcomings

2 ; 1 identified. That initiative should be followed by a major effort to have Z590.3- I 1 be accepted as a design guide. · ·

eq t was also noted in the early l 990s that designing for safety was addressed inad- uately · a£ . . terns t . in s et_y-r~lated literature, and that the safety and health management s~s-

Pro edhat organizations had in p' lace infrequently included safety through design c ures .

tof~ecisio~ makers at the National Safety Co~ncil (NSC) gave authority to this author nnaco · · 'd fh · llllnittee to study the feasibility of the Council promotmg the 1 ea o avmg

:1

312 PREVENTION THROUGH DESIGN: SECTIONS 5.1.1 TO 5.1.4 OF 210

safety and environmental needs incorporated in the design outcome was that the NSC established The Institute For ,Safet;~ess, In 1

An advisory committee for the institute was formed , whose 0 ugh be 9 . 9s, th

· d I b d th . tnernb 81&n e industry, academia, organize a ~r, an o er interested persons. . e~s repres . established by the advisory comnuttee: lnis 1s the _enteq ' ttJiss· · ion

To reduce the risk of injury, illness and environmentai • decisio~s affecting safety, health, and the environment in : by :integrati

. - ' . stage ng design process. · 8 of the

The message ~e adv~sory c~~-tte~ 'w~t~~. t~ COI}Y~y ,· .when the . through design was used 1s contamed m its defirution: · . _term ~afety

• , • ' • , • . I • The integration of hazard analysts and nsk assessment methods .

· · · d taki th l ' · early in th design and engmeenng stages an ng . e a~tions _n~cessary_ so that . e injury or damage are at an acceptable level. · , nsks of

In the literature developed by the Institute it was said that the follow· b would be obtained by applying safety through design concepts: mg enefits

• Improved productivity • Decreased operating costs· • Significant risk reduction • Avoi~ce of expensive ~etrofitting • L

' . ' Two groups were identified by the Institute, tQ be given _primary !lttention:

Academia-professor~ an<;l their students; and practicing engineers in industry and safety professionals. . , ,1 ,

Much was accomplished by the lnstjtute. S~minars, workshops, and symposia were held; proceedings were issued; presentations were made at safety conferences; and book entitled Saf~ty Through Design .w~s. publishecl. Operations of the In_s~tute were ~scontinued in ~005, ,in ac<.:ord w)th a previously establisped sunset provtswn.

In 2006, several of the participants in the flCtivities of the Institute For S~e~ Through Design, and others, received an e-mail from an executive at the Nauo~ · · auon !°5ti~~ Occupatioqal _Safety and Health (NIOSH) encouragi~g our P~::shop ID an 1rutiative for Preyent1on. through Design. In July 2007, NIOSH held a te 8

b . . . . . . . u·ve to crea

to o tam the views . of a variety of stakeholders on a maJor mitia sustainable national strategy for Prev~ntion through Design. . of the

Some of the participants expressed the yiew .that the long-term unp:~ could NIOSH initiative could be "transfonn'ative " meaning that a fi,mdamental stb Jtigher

· th · · ' • · ·ven to e occur m e practice of safc;ty, resulting in greater emphasis bemg gi · and more effective decision levels in the hierarchy of controls. "Devel0P

In 20Q8, NIOSH ,announced that on~ of its major initiatives was topreventi00 and approve a broaq, generic . voluntary consensus standard

00

HIGHLIGHTS OF ANSI/ASSE 2590.3 313

. 0

that is aligned with international design activities and practice" d .

tbfou8 d io lead that en eavor. 1 volunteere.~as obtained from the Standards Development Committee at the

su~portsociety of Safety Engineer~ .(ASSE) .. It w~ decided to develop a technical J\lllerican t for the learning experience .. that wo~ld provide. So TR-Z790.001, repOrt j·Report on Prevention Through Design, was issued in 2009. . A fech;:~ember 1, 2011, theAmeric.~ National ,Standard~ Institµte (ANSI)approved

On dafd _ANSI/ASSE Z590.3-20ll,, Preve11tion Th,:ough Design: Guid.~fines for the stan .

118 Occupatfonµl Hazards and Risks ir,, _the Design and Redesign Processes. :

Addressist. be understood that activities at NIOSH are limited to occupational safetv and It mu · · - ~J · " th 'Ibus, the focus of Z590.3 is work-related. But, by intent, the terminology in t9() 3 was kept broad enough so thatthe guidelines could be applicable to all hazards-baSed fields: product safety, environrnental ;cqntrol,' property damage that -could result

. business·interruption, and so on. in ·the standard, the definition of prevention through :sign is work~related and identical;with .th~,.t in _the NIOSH literature. 1

Prevention-through design:: Addressing occupational safety. and .health .nee~ in fue,{lesign ffll.9 redesign process to. preve_nt or _mini.quie th.e work-related hazards and risks, associated with the construction, manufacture, use, maintenance, retrofitting, and disposal of facilities, processes, materials, and· equipment.

• . l I

Promoting the acquisition of knowledge of prevention through design concepts is in concert·with the ASSE Position Paper ,on Designing •for Safety approved by its board of directors in 1994,. the: opening paragraph of which follows.

• I • •

Design,ing For Safety (DFS) is a principle for d,~sign planning for new facilities, eq_uipmen~ a.n'd qperatio.ns (pupµc, and private) to c~nserve hum~ and natµral resources, and thereby protect people, property and the environrn~nt. DPS advo- Cfltes .systelll:~!ic proces& to ens~e st~te-of-t.Qe:-¥1 engineering and µianagement principles are used and incorporated into the design of facilities and overall

• I • ,

operations to assure safety and health of workers, as well as protection of the environment and compliance ,w,ith ~urrent cpd.es and standards.

HIGHLIGHTS OF ANSI/ASSE Z590.3 !tis n · · ·. ·. . , · ' · · '· · · i: · . • • In so!~ ~YJntention here to duplic~te the Z590_.,3 ,st,andfd; only hig~hght_s are given. the instances, number or lett~r designatiO:ns may riot be e_xactly the same as in and :ta.nd~d. It is expected that safety professionals who b~co'me involved in design

ed~sign pr~cesses will µeyelop a familiarity with Z590.3 in detail. ,

1. . Scope, Purpose, and Appllcatlon :~~::es~ope ofZ590.3: This standard provides guidance on including prevention system. ~sign. concepts within an occupational safety and health management

ough the application of these concepts, decisions pertaining to occupational

314 PREVENT! · ON THROUGH DESIGN· SECTIONS 5.1.1 TO 5.1.4 OF 210

h zards and risks can be incorporated into the process of design and a h" b redesj th ork Premises tools, equipment, mac mery, su stances, and Work &n of ew , . Proc

including their construction, manufacture, use: mamtenance, and ultimate dis esses, reuse. This standard provides guidance fo~ a hfe-cycle assessment and desi~0sa1 or that balances environmental and occupational sa[ety and health goals ov ill0de1 span of a facility, process, or product. l!C . er the 1:,

Although the Purpose statement indicates that the standard pertains Prine· 11,e a,oidance, elimination, reduction, or "'.'•trol of occupational safety .. ~~Yto hazards and risks in the design and redesign processes, this important ext ~th

ens1on follows the purpose statement.

Note: Incidents that have the potential to result in occupational injuries and •u. nesses can also result in damag~ to prol":rty and .business i?te~ption, and darn~e to the environment. Reference 1s made m several places m this standard to those additional loss potentials which may require evaluation and resultant action . .

Largely, this slandard is applicable to all hazard-based operational risks, Panicul,dy it relates directly to all of the four major stages of occupational risk management. '

a Pre-operatiQnal stage:.in the initial planning, design, specification, prototYPing, and construction processes, where the opportunities are greatest and the costs are lowest for hazard and risk .avoidance, elimination, reduction; or control.

b. Operational stage: where •hazards and risks are identified and evaluated and mitigation actions are taken throµgh redesign initiatives or changes in work methods before incidents or exposures occur.

c. Post-incident stage: where investigations are made of incidents and exposures to determine the causal factors that will lead to appropriate interventions and acceptable risk levels.

d. Post-operational stage: where demolition, decommissioning, or reusing/retiuilding operations are undertaken:

The application goals of utilizing prevention , through design concepts in an occupational setting are to:

a. Achieve acceptable risk levels.

b. Prevent or reduce occupationally related injuries, illnesses, and fatalities. c. Reduce the cost of retrofitting necessary to mitigate hazards and risks

th at were

not addressed sufficiently in the design or redesign processes.

Adde?dum A outlines the risk assessment process, and Addendum B gives tbe progress10n of occupational hygiene issues flow.

2. Referenced and Related Standards

· · • • that per· Relative Amencan National Standards and other standards and guidebnes tain to the purpose of the standard are listed.

HIGHLIGHTS OF ANSI/ASSE 2590.3

oet1n1t1ons . ; 315

3, ·t· 00 list grew to 27 in response · to suggestions mad b defilll

1 d' · · al al · . e Y commenters fbe of the standar s pnnc1p go s ts to achieve acce'ptaole risk 1 1 thr .

Since onde i·gn and redesign processes, the definitions relative to th teve sl ough- out the es · . · . a goa only are listed here.

A ceptable risk. That risk for which the probability of an incident or , a. c th •·t f h . .• d . . exposure

occurring an~ e seven yRPo or a~age t?at may result are as low as rea- sonably practicable (ALA ) m the settmg bemg considered. ,

b. As lo~ ds reas~nably Pract!cable (~~). 'That level of risk which can be lowered further only by an increase m resource experlditu,re 'that is dispropor- tionate in relation to the resulting decrease ip 'risk ' ' ,,. \' . ' I

c. Hazard. ·The' potential for harm. . . \' ; . I Note : Hazards include all aspects of technology and activity that produce risk. Hazards include the characteristics of things (e.g., equipment, tech- nology, processes, dusts, fibers, gases, matetjals? ~henµcals) ~d th.e .. actions or inactions of people.

d. Hiera rchy ' of 'controls. A systematic· approach to avoiding, . eliminating, reducing, and coritr~lling risks, considering steps fo ''a ranked and sequenti.al order, beginning with' avoidance, elimination.', and substitution. . .

e. Probability. An estimate of the likelih~od of ~n incident or exposure ~c~ng that could result in harm or damage for a selected unit of time, events, population, ite~~. or,. activiJ~ ~.eJng CQnsidered. , ;

1 f. Residual risk. The risk remaining aftei: risk r~duction measures have been

' • I • • • " • • taken: ' ' · · · ,,, · · " · ' · ' · '. f • • ' J . i , : • > ' ', , • •, I > ' ; , • ' ' > :

g. Risk. An estimate of the probability of a ·hazard-relat~ inc1c!e~t ~r expos~e occurring and the severity of harm or damage that could result.

h. Safety. Freedom from unacceptable risk. ,~-. 1

: . . . : .,

1. Severity. An estimate of the magnitude of harm or d~ag~ ~a~ ~?~ld_ re~~:m~bly result from a hazard-related incident or exposure

4 • Roles and Reaponslbllltles

• I I ' To J ' • • ff t· P management shall provide the leadership to institute and m~~ 1 tam e ec ~ive

s~sksterns for the design and redesign processes.' Key p~ints: · anticiP;~te ha_zards and ns · ·, 1 t bl nsk levels 1n . ' assess risks; apply the hierarchy of controls to achieve accep e ·

o]]oWing note> is significant iii the ro1eS• and responsibilities seelion. . . k · ote: 1'he processes of identifying and analyzing hazards • nd assesf.:;8 ns ltnpr~ve if management establishes a culture where ·emplo7e~ know ge an f expene . 1 b t . s1gmficant aspects o th nee Is valued and respected and they col .a ora e,Ul · · al bl

e design d h do the work can make v ua e contrib . an redesign activities. Employees w O • • k · ssments and in p ~hons in identifying and evaluating hazardS, m ns asse ' roposing risk reduction measures.

•

id

316 PREVENTION TH ECTIONS 5.1.1 TO 5.1.4 OF Z10

ROUGH DESIGN: S

Ith suppliers 5 Relations W . were received that commenters wa • gesuons · . th ntect h apparent as sug . ·b . ging hazards mto e workplace 'l'L elp i It became avoid nn t th . ... nat h I n . procedures . to . di cussions and arrangemen s at organizati e p ls creaung . The s th -6 th ons sh 'ded in this section. , . i d guidance on e spec1 cs at should b . ou1d prov1 ith suppliers are outime d ans recommended and the related addendu e expected hfav~pwpliers is provided. PrOCe •~ments in ZlO. Addendum C provides prrn Pertains 0 S urement reqi.iµv 'th li . , , 0Cllren, directly to the proc · . . · aking arrangements w1 supp ers. ••1en1 . to assist m m . d th . guidelines. that are . . . this section recommen s at supp hers of, eq .

One of the provisions 1 dn m' aterials provide documentation establishing thuiprnent,

I • processes, an · bl . k 1 • atari k techno ogies, , ~onducted and that an accepta e ns evel, as outlinea b s assessment has ~?- ·achieved. . , y the . aruzauon has been ., . . procunng org . I ample of 'a basic risk assessment report that can be u·

Addendum D 1s an ex · , sed as a guide for that purpo~e. ,· t. . ,

6. Design Safety Reviews I '

In the design proces$, ri~k assessments _~ould be made as ?fien as needed, on a con- tinuum. In addition, a formal design safety review proc~dur~ should be put in.place. This section is supported by ~ddendum E, a safety desi~1,1 revi~w guide: Chapter 15 of this book is devoted entirely to design reviews. ·

7. The Hazard Analysis and Risk 'Assessment Process ' This is the longest section in the stand~d. First, an outlin~ of the hazard analysis and risk assessment process is given. Th~t is followed by the "how" for each element in the outline. The tiutline follows .' · · 1 · • • • • ' · ·

' .. _ • Select.a risk ~sessmeQt matrix. • Establish the analysis -~ar~~ters. • Identify the hazards.

,, r . \'1

• !

• Consider failure modes.

• Assess the severity of consequences. • Deternu·ne .

occurrence probabilit ·. • Define initiaf risk. y . . • Select ·a d · , ·

n implement hazard . . d ontrol methods. avoidance, elimination, reduction, an .. c

• A_ssess the residual risk. • Risk acceptance d . . • ec1s1on makin

Document the results. g. • Follow-up on a t·

c ions taken .

HIGHLIGHTS OF ANSI/ASSE 2590.3 317

hazards the proper level of acceptable risk can be attained without for JJJanY ther complex teams of people. Safety and health professionals and design

bringing tog_~ the proper experience and education can reach the proper conclusions of engineers V:1 t 5 acceptable risk. For more complex risk situations, management should wbatc00stJtue: in place to seek the counsel of experienced personnel who are partic- have pro~!~: in risk assessment for the category of the situation being considered. uJarlY ski_ group consensus is a highly desirable goal. Sometimes, for what an

ReacJung · hi · . ·11 d . bl h b . . . . . ual considers obvious, ac evmg consensus 1s stl esrra e, sot at uy-m 1s 1ndi~1~ for the actions taken. Addenda A and B serve as examples of suggested obtaln h s to the risk assessment processes. appro_acs;ongly urged that an appropriate risk assessment matrix be selected for the

Ins d · k t A . k . "d hazard analysis an ns ~se~smen proces~. . ns assessment matnx. prov1 es a thod to categorize combmatlons of probab1hty of occurrence and seventy of harm,

:e 5 establishing risk levels. A matrix helps in communicating with decision makers on .:k reduction actions to be taken. Also, risk assessment matrices assist in comparing ~d prioritizing risks, and in effectively allocating mitigation resources. Addendum F provides several examples of risk assessment matrices and descriptions of terms to serve as a base for an organization to develop a matrix suitable for its operations.

e. Hazard Analysis and Risk Assessment Techniques Top management shall adopt and apply the hazard analysis and risk assessment tech- niques suitable to the organization's needs and provide the training necessary to employees who will be involved in the process. Descriptions of eight selected tech- niques are presented in Addendum G. Addendum H is a failure mode and effects analysis form.

As a practical matter, having knowledge of three risk assessment concepts will be sufficient to address most, but not all, risk situations: preliminary hazard analysis and risk assessment, what-if/checklist analysis methods, and failure mod~ and effects analysis. .

9· Hierarchy of Controls

m~~gement shall achieve acceptable risk levels by adopting, implementing, and p atntaining a process to avoid, eliminate, reduce, and control hazards.and risks. The rocess shall be based on the hierarchy of controls outlined in this standard, which is:

a. Risk avoidance b. Elilllination c. Substitution d. Engin · eermg controls e. War ·

ning systems f. A.ct . .

mtn1strative controls g. Personal .

protective equipment

318 "'THROUGH DESl~N: SECTIONS 5.1.1 TO 5.1.4 OF 210 PREVENTIO, i

Thi . "prevention" standard. Research w~ done to develop a v:i..: . . s 1s a th . f .. r ,, E -•ation . hierarchy of controls to adapt to e_ meanhit~g of pretrveln tdo~. linunation Whi1_n the

firs ti. to be taken in many hierarc es o con o s, 1d not seem t 6 , ch is the t ac on . o t With

meaning of prevention. · the

• Elimination means removal; purging; talcing away; to get rid of somethj eliminate, there has to. be something in place to rempve. . ng. 1o

• Avoidance means to prevent something from happening; keeping aw . avemng. ,

Designers start with a blank sheet of paper or an empty screen in,a computer. 'd . . "d h d . ai ed design system. Designers have ,opportumttes to av?• azar s tn all design sta .

conceptual, preliminary, and final. In the early design phases, there are not Yet ges. hazards to be eliminated, reduced,. or controlled, so .av.oidance is a better match r:! hierarchy of controls for a prevention standard.

Addendum I includes extensive comments on .each of the elements in the hierarchy. Addendum J is the Bibliography. ,

GOALS TO BE ACHIEVED

2590.3 says that insofar as is practicable, the goal shall be to assure that for the design selected:

• An acceptable risk level is achieved, as defined in this standard. < ' ' • I t ' '

• The probability of personnel making human errors because of design inade- quacies is as. low as is reasonably practi,cable. .

• The ability. of perso~nel ,tq defeat the . work. sys.tern and the work methods prescf!bed is as low as is r~asonably pr~ticable.

• The work processes prescribed take into consideration human factors ( ergonomics )-the capabilities and limitations of the work population.

• Hazards and risks with respect to access and the means for maintenance are at as low as is reasonably practical. " '

• The need for personal protective equipment is as low as is reasonably practi:~ 1 ' d 'd · · · · t for uu an at IS1)rov1ded for its use where it is necessary (e.g., anchor pom s protection).

• Applicable laws, codes, regulations, and standards have been met. • Any r · ed d • 'dered. ecogmz co e of practice, internal or external, has been const

GETTING INVOLVED

It is recommended th t c . . hich theY a.red . a saiety professionals use actual cases· m w · nan tnvolved to support th • . the des1g

. e premise that addressing hazards and risks m but also redesign processes will result not only in achieving acceptable risk levels

PATIENCE AND UNDERSTANDING 319

uctivity and operational_ efficiency. That may be done easier in the rede- higber prod I say to safety professionals: , JV rocess, 5ignP • . .

O nvince designers to. allow you to work with them on a proiect so th t

frY to c b'li d al J a ' demonstrate your capa i ty, an v ue. you can . . . ,

w the value you bnng to the discussion. . , ShO 'd . . d . When teams are consi ermg a given es1gn or redesign situation, try to ' courage input from all present who have knowledge of the process.

~1r a holistic, macro view; include all ·hazard~based subjects if you can. 'l!U'e . , 'frY to involve operations personnel at al~ levels. Assume respectfully that those

ho do the work have knowle~ge and skill that can contribute to workplace and :ork method redesign and encourage their input. . . ·

, Do yow; homework; includ~ alternative solutions al).d costs if that can be done. , Understand . that you are proposing a culture change-that designers may

presume that you are intruding into their territory aµ,d will r~ist your involvement to maintain their territorial prerogative.

, Do not play down the fact that implementing a new program can be challenging and frustrating. Be patient. Utilize change management concepts. Be a good listener. Be open to comment and criticism.

, Study the incident history in the entity to which counsel is being given and that of its industry for support data showing that design shortcomings were among the contributing factors for incidents t\lat have occurred.

A goal is to achieve buy-in by those who are involved, particularly at the senior executive level. Training programs should be consid.ered for th~,value tq.ey provide. Also, ask if it will be advantageous in a particular situation, for a prevention through design system to be written. ,

PATIENCE AND UNDERSTANDING

~ple~enting the concepts of risk assessment and risk avoidance or reduction in , e des1gn and redesign proce~ses is a long-term effort. On that point, Bruce Main is eloq · . d 0

uent, as m the Introduction to his book -Risk Assessment: Challenges an PPortunities, reproduced here with his permission. . ·

This is an · · · • · ·· hi u· ro ce exciting tlme in risk .assessment. Whether mac · nery ·up me, P - Or

ss_throughput, cost savings -• new ideas for features, patentable innovations, sun 1 •· · 'th ac P Y documenting that a company makes really good products wi

ceptable · k d dri irnpro ns s, the opportunities abound to apply the process an ve '1'L ve~ents. The opportunities exist because risk assessment works. 1ue n k · that .8 assessment process is a .journey rather, than an event. Comparu~s

requ~e JUSl starting to complete risk assessmen~~ find their first efforts will ire more ti' · 1 &e A nnel . m~ anq •wjll. be less complete than later euorts. s perso

320 PREVENTION THAO UGH DESIGN: SECTIONS 5.1.1 TO 5.1.4 OF z10

. trai"ning and become more familiar with the risk a · olved receive . d • k d . ssesstn mv h ards will be identtfie , more ns re uction methods d en1 process, ?1kore az ment process will improve and hasten in pace. epioYed and the ns assess . . . d . k

are learned and expenence 1s game , ns assessment be As lessons . d • . cotn fi ed However some ttme an expenence is required for th es

more re nt ~ess to ~come fully integrated into a company. How m he risk assessmen p . b . . uc tun depends on the company and its crrcumstances, u~ it typically takes rnonthse

ks Eventually the risk assessment process will become a Part of , not wee . . d . nonna1 business procedures. Until then, ip~ustry nee s time to fully and fortnally implement these concepts (Introduction).

For safety professionals who are interested in well-written dissertati~ " f · k t h non "Implementing and D~plo~.ment o a ns ashses

11 s men system t at affects all design

decisions, Chapter 16 m Risk Assessment: C a enges and Opportunities is rec mended. Bruce Main has given permission to duplicate the following key Points 0:; of which should be considered in relation to procedures in place and the culture of an organiz.ation.

1. Leadership is a key and critical factor in successfully implementing and deploying the risk assessment process.

2. Integrating risk assessment in an organization is a process that generally follows a sequence of phases. (Three frameworks are discussed.)

3. Engineering design needs to change to include the risk assessment process to more effectively move safety into design. Only by changing the design process will risk assessment efforts succeed.

4. Introducing the risk assessment process will explicitly change the design pro- cess, allowing hazards 'to be identified and risk reduction methods to be incor- porated early in the design process. As with any new process or substantial change, people may resist.

5· To be effective, the company culture must _be willing to embrace the ri_sk assessment process, and cultural acceptance stems from management leadership,

6 In· d ·al · dusers · m UStri pr~uct or process applications,, fx?th equipment suppliers an ss. should perform nsk assessments and be jnvolved in the risk assessment proee .

7 • In consumer p d d · 0

&acturer 15 · . ro uct an component product applications, the man 1' responsible for c d • . . Pr duct users

. on uctmg the nsk assessment if• applicable. 0 d I

in ~;;ally have ~o risk assessment responsibilitie~ beyond using the pro uc

8 Pr ~nnanc~ wi th the product information. . gress

. actical guidance is h d d ake pro in the risk s are to help companies get started an rn toP risk ·as asses~ment process. Topics addressed include: when 10. s what

sessment, the time to 1 . racuces; to do 1• • comp ete an assessment leaders m best P 55men1, n cross •industry • tu . • . . • k asse making h si ations, when to revise an existing ns

9. To integrc t~~eks to the method, results of risk assessment, a. nd otherli~k-el" need a e ns assessm t · . will '

education and tr . . en_ into the design process, engineers aming on nsk assessment in some form. (p. 230)

REVIEW OF ACTIVITIES AT NIOSH ON PREVENTION THROUGH DESIGN 321

F ACTIVITIES AT NIOSH ON PREVENTION Rev1euWG~ DESIGN . . . ~flO , n . , . , f k I is the coordinator of preventibn though design at NIOSH. ·Z590.3 painela flee .:; if personnel at NIOSH had not concluded that orie of its goals ,was to would not eJUntion through Design (PtD) standard. Heckel was asked to provide a have 8 rre;ethe relative activities at NIOSH '. which are ·extensive. This is what was

approved at NIOSH for inclusion in this chapter. wntten .• . .

, , tion , through Design (PtD) was initiated · by the National Institute for

Prevenational Safety and Health in 2007 to' eliminate hazards through the occup f 'f1 ·1· . 1 . d d d . gn and redesign o · act tties, processes, too s, equtpment, pro ucts, an ;:iorgahlzation of work.' Strategic partners included the American Industrial Hygiene Association (AIHA), the. _American ~ociety of Safety Eng~~:ers (ASSE), CPWR.:.,_ The Center for Construction · Research and_ Trammg, Kaiser Permanente, Liberty Mutual, the National Safety Council (NSC), the Occupational Safety 'and Health Administratiori (OSHA), ORC World-wide, and the Regenstrief Center for Healthcare Engineering. · . -· ·

Toe first PtD workshop was held in July-2007. Attenclees included representa- tives from industry, labor, government, and academia. Proceedings were published in 2008 in a dedicated· issue of the Journal of Safety Research. A PtD' Council was· formed to guide the new • initiative. Council members were specialists in occupational ·safety and health and arranged strategic goals around the themes of Research, Education, Practice, and , Policy; The Plan for the National Initiative (http://www.cdc:gov/niosh/docs/20H-12l/) was publishedin 2009.

In 2010/ the PtD t ole of the •designer/engineer was investigated by -bench- marking PtD regulations of designers in the• construction industry in the United Kingdom (UK) to further understand the potential impacts and opportunities for implementation of the PtD concept in the US. · The Education and Information Division of NIOSH coordinated a workshop, titled "Making Green Jobs Safe," ~hich developed 48 compelling activities· for including worker ·safety and health ~to green jobs and sustainable design. A summary of the workshop was published inZOll : http://www.cdc.gov/niosh/docs/2011-201/pdfs/2011-201 '.pdf' •

"Prevention through Design: A New Way of Doing Business," was held in ~:~st !0l 1, included supportive business leaders, noted safety experts, and or u~c researchers. At this stage, PtD concepts were included in 12 drafts peep t~hed consensus standards. 1Two booklets, three textbooks, and 50 ate~·:ev~ewed papers had been published. Four case studies had been cre- learne~ fr:monstrate t?e business value of PtD. ' Prese~ters_ shared lessons Bil'lnih h ma Masters-level degree program at the University of Alabama- offeredg am and a PtD course at Virginia · Tech. Half a dozen universities

courses co t . . . . highlight d n ammg PtD content. The·se and -other success stones were I e at the conference · n 2011 h . . · . . .

approved fr t e Amencan Society of Safety Engineers (ASSE) obtained om the American National Standards Institute (ANSI) for ANSI/

a

322 PREVENTION THROUGH DESIGN: SECTIONS 5.1.1 TO 5.1.4 OF z1o

ASSE 2590.3-th~ stand,ard titled "Preventiqn through Design· 0 . for Addressing Occupational _Hazar~s and Ris_ks in Design ~d : 1deU?es Processes." This standard provides gwdance on mcluding Prevent' ~design Design concepts within an pccupational safety and health manage~on through

. d . . al . Th entsyste and can be applie IQ any occupation setting. e standard focus _Ill, cally on the avoidance, elimination,,reduction, and control of occupatioes~J>ecifi. and health hazards and risks ii! the design process. n ,Safety

In 2011, NIOSH met with the US Green Building Council (USGBC) to collaborate on the inclusion of worker health and safety into Leade' ?~ Energy and Environmental Design (LEED) credits for certification. ~s 2[ 1

10

~OSH repre~~ntatives.met with_ the Con~~ction User's Roundtable to ide;: tify opportumties f~r collaboration: Additional emphasis was placed on the development of business case. studies. Three papers summarizing the 20l 1 conference presentations in the areas of practice, p.olicy, and research we p_ublished in the January 2013 issue of Professional Safety. Three mo;: were published in the Marcb 2013 issue, including one focused on business value, one pertftining to OSH management system~. and the third, education. PtD has been the topic_ at more tban 55 , professional development courses, webinars, and roundtable.presentations since 2008.

In August 2012, PtD -and .. the NIOSH -Nanotechnology .Research Center (NTRC) collaboratecj with the State University New-York at Albany, College of Nanos.cale Science & Engineering, to hold a Safe NanQ-Design workshop. The purpose was to discuss the value pf. applying .PtD to safely synthesize engineered nanoparticles and safely .commercialize nano-enabled products, Applying PtD concepts in organizations handling engineered nanomaterials assures that worker health and safety is considered at each step in the supply chain, resulting in sustainable health and safety performance.

By the spring of 2013, two additional textbooks were published. A total of93 first generation publications were cited by 721 second generation public~tions, Fifteen consensus standards containing PtD concepts have been publish_ed. More than two dozen universities have expressed interest in the PtD Education Modules for existing undergraduate classes. The first to be published was tbe Architectural Design and Construction Instructor's Manual (http://www.cdc. gov/niosh/docs/2013-133). PtD

NIOSH is encouraging research in developing the business case for_ . The focus is now on developing the process and related tools for de~ernu~:f business value. Areas of interest include the methods to measure the impac PtD concepts on actually reducing injury and illness. . roach

NIOSH i~ currently developing a systematic Health Hazard Banding :~cals to assist safety and .health professionals in providing guidance for~ ~azard without authoritative occupational exposure limits (OELs). The NIOS d can be Banding process can be used with limited information and resources 8;ety spe· performed quickly by in-house industrial hygienists and health and s pational cialists. The outcome of the Health Hazard Banding process is an occu exposure band (OEB).

REFEREN9ES 323

d Banding can be used to supplement and support OEL geaitb I-lazal" facilitating a more rapid evaluation of health risks, providing

d veloPJllent bhy roicals without . OELs, identifying hazards to evaluated for e for c e 'di th 'th ,,idallce ubstitution, prov1 ng e user wi recommendations when S"' • n or s 1:Jlljnatt0 . ,.,lable andatoolforthedevelopmentqfNIOSHRecommended

e~ . a1data1sav... • . (llJniJll Lunits, . . ~p05ure . ctivities focus on-providing educational materials for students r,,1ucation a . . •

r:,c, d designers. The impact of these tools must be assessed. Most engine:• :ngineering students. ha:e Uttl~ practical experience wit:4 hazarli grad~a · n risk assessment, and nsk avoidance or control methods. NIOSH 'd nuficauo • . . h ed' . . 1 e ki' with ABET, the orgamzation t at acer its engmeenng and tech-. wor ng 1 • is urricula, to encourage facu ty to consider the safety and health of nologytscand staff during the discovery phase of cutting-edge research. stu:re are several areas where the incorporation of Prevention through Design

Pts into the curriculum dovetails with ABET objectives to improve student conce d c· · 3 I · PtD · th 1 omes, specifically un er ntenon c. ncorporating concepts mto e OU c . . . "- c l d curriculum shows a comm1tment to continuous improvement uom 1acu ty an

the learning community. Practice activities focus on stakeholder ability to access, share, and apply

successful PtD practices. In addition to our continued dialog with USGBC and CURf, NIOSH is collaborating with industry to identify Best Practices so these can be front loaded into the Capital Design Process.

When a root cause analysis uncovers a design-related hazard, the design solution should be documented for future reference during the conceptual design phase of similar facilities or equipment.

Policy activities are focused on developing a PtD culture in industry. Including PtD into consensus standards is the first step in the development of a PtD culture.

CONCLUSION

: 1 :m~nt of safety professionals in the design processes is hugely more extensive

thro~ h n it 20_ ye8:s ago. There is opportunity here for professional satisfaction COntrit P~•cipation m the design processes and for being perceived as a valued

utor m support of operational efficiency as well as risk management.

REl=ERENCEs

ANSIJASSE ZS Guidelines fi 90-3-20l 1. American National Standard, Prevention through Design: Processes DorpAd~ressing Occupational Hazards and Risks in Design and Redesign

Chr· · es lam IL 18tensen W es, : American Society of Safety Engineers, 2011. Nar ' ayne C and F 10nat Sat ty C · red A. Manuele, Editors. Safety Through Design. Itasca, IL:

e ouncil, 1999.

324 PREVENTION THROUGH DESIGN: SECTIONS 5.1.1 TO 5.1.4 OF 210

"Designing for Safety." A position paper approved by the board of direct Society of Safety Engineers, Des Plaines, 11, 1994. · ors, of the Arnen

Guidance On The Principles' Of Safe Design For Work. Canberra, Austral{ . can and Compensation Council,'an entity of the Australian government, 2~tu

straJian Sat I , , · . , ety

Johnson, William. ·MORT Safety Assurance Systems. Itasca,· IL: National S 1980. (Also published by Marcel Dekker, New York.) afety Couneil

Main, •Bruce w.i Risk' Assessment: Challenges and Opportunities. Ann Arb ' Safety Engineering, Inc., 2012. · · or, MI: Design

TR•Z790.001.' A Technical1Report on Ptevention ·Through Design. Des Plain , ' Society of Safety Engineers, 2009. . es, D.... Arnencan

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