Re: [SystemSafety] NYTimes: The Next Accident Awaits

From: Nancy Leveson < >
Date: Sun, 2 Feb 2014 14:52:01 -0500


Tracy White wrote:

   "I am slightly confused and a little perturbed by an argument that a 'safety case' in someway replaces any regulatory control (or government interference)."

I haven't seen anyone on this list say that.

Nancy

On Sat, Feb 1, 2014 at 7:39 PM, Tracy White <tracy.white_at_xxxxxx

> I am slightly confused and a little perturbed by an argument that a
> 'safety case' in someway replaces any regulatory control (or government
> interference). Even more that a safety case would not include a subclaim to
> have conducted a 'rigorous hazard analysis' program ... or to have applied
> appropriate 'procedures and standards'.
>
> Anybody who thinks that 'safety cases' in anyway replaces some form of
> regulation is ignorant of its purpose. I work in a regulatory environment
> and the 'safety case' is the primary communications medium with that
> regulator, elements of which will talk to hazard identification and
> compliance with standards and codes considered representative of
> engineering 'good practice'. I would agree that there are good and bad
> safety cases and I think that 'industries that do not 'have a good
> historical culture in terms of safety' are as ignorant of purpose of the
> safety cases as they of the need for safety in general.
>
> Regards, Tracy
>
> On 01/02/2014, at 12:48 AM, Nancy Leveson wrote:
>
> It is very difficult to characterize the U.S. In general, the country is
> so physically large that there are extreme differences in culture and
> politics (generally but not always physically bounded). Much of the central
> government in the US and European worlds seem to be moving toward
> libertarianism, but I am probably mischaracterizing Europe based on biased
> news reports. The individual U.S. states show extreme differences. At the
> extremes, Texas and California may as well be in different worlds, let
> alone countries when it comes to safety regulations (and lots of other
> things irrelevant to this list). There are also such different cultures in
> different industries that it is difficult to make general statements.
> Mining and civil aviation are examples of such extremes.
>
> But I will make one general statement that is only my personal experience.
> Because of my paper arguing against safety cases, I am getting many calls
> from government employees and company lawyers as well as individual
> engineers. Some of the companies pushing the "safety case" in the U.S. are
> those who don't want any government interference and see the safety case as
> a way to get around the rigorous procedural standards that now exist here
> in many industries. They seem to feel that they will be able to get rid of
> the procedures and standards that exist now and can write anything they
> want in a safety case and therefore save money and time in the rigorous
> hazard analysis now widely required while using any design features they
> want. These are primarily in industries that do not have a good historical
> culture in terms of safety.
>
> Nancy.
>
>
> On Fri, Jan 31, 2014 at 4:08 AM, RICQUE Bertrand (SAGEM DEFENSE SECURITE)
> <bertrand.ricque_at_xxxxxx >
>> Hi Nancy,
>>
>>
>>
>> Concerning France you are right, and in that case I think that the
>> cultural aspect dominates. There is no safety culture in the population as
>> in UK, as acknowledged after AZF accident. The risk stops at the fence of
>> the plant and you can safely build your house on the other side ... The
>> regulations have changed since but not the cultures. The safety engineers
>> concerned by the new regulations live a nightmare as the choices are more
>> or less, dismantle the plant versus dismantle the town ... I think that the
>> safety cultures have more impact on the final result than the competence of
>> the safety community.
>>
>>
>>
>> Bertrand Ricque
>>
>> Program Manager
>>
>> Optronics and Defence Division
>>
>> Sights Program
>>
>> Mob : +33 6 87 47 84 64
>>
>> Tel : +33 1 59 11 96 82
>>
>> Bertrand.ricque_at_xxxxxx >>
>>
>>
>>
>>
>>
>>
>> *From:* systemsafety-bounces_at_xxxxxx >> systemsafety-bounces_at_xxxxxx >> Leveson
>> *Sent:* Thursday, January 30, 2014 8:59 PM
>> *To:* systemsafety_at_xxxxxx >> *Subject:* Re: [SystemSafety] NYTimes: The Next Accident Awaits
>>
>>
>>
>> It would be nice to actually introduce some data into the discussions on
>> this list. First, although it is very true that the U.K. has excellent
>> comparative occupational safety statistics, this exceptional performance
>> predated safety cases by at least 100 years and is as much a cultural
>> artifact of the U.K. as any current practices. While the rest of the world
>> was suffering the results of steam engine explosions in the late 1800s, for
>> example, Great Britain was the first to implement measures to reduce them.
>> (I wrote a paper on this once if anyone is interested.) Although the
>> British citizens on this list know more about the history of the UK HSE, I
>> believe they were the first country to require companies to have safety
>> policies, etc., after the Flixborough explosion. Safety cases, I believe,
>> came into being only after the more recent Piper Alpha explosion.
>>
>>
>>
>> Trying to tie accident rates in different countries to particular ways of
>> regulating safety is dicey at best. First, there are significant
>> differences between the engineering, agricultural, industry, and service
>> rates of accidents in countries, often related to technical differences.
>> Some have high agricultural accident rates but low service accident rates.
>> For example, accident rates are going to be very different in a country
>> with high tech agricultural techniques compared to those still plowing
>> fields with a pair of oxen. Politics plays an even more important role. For
>> example, western countries often put very dangerous processes and plants in
>> third world countries or governments in these countries do not have laws
>> that require manufacturers to use even minimal safety practices in
>> manufacturing, for example, and they will not as long as they need the
>> revenue and jobs. The safety culture in these countries will not change
>> magically by using one type of regulatory regime.
>>
>>
>>
>> Note also, that there are vast differences in industries. Those with the
>> very safest records, such as the U.S. SUBSAFE program, do not use safety
>> cases. (And they have managed to have an incredible safety record despite
>> being in the U.S. :-)). If we want to compare the effectiveness of
>> different regulatory regimes, then we need to provide scientific
>> evaluations and not just misuse statistics (which may involve factors that
>> have nothing to do with the actual regulatory regime used).
>>
>>
>>
>> Also, as Michael Holloway noted, culture differences will make different
>> types of regulation more or less different in different countries and
>> industries.
>>
>>
>>
>> Finally, I would like to point out to those who are making some national
>> comparisons and putting down the U.S. in comparison with France, for
>> example, that the fatal occupational accident rate in the U.S. is less than
>> that of France. Perhaps we can avoid mixing politics and chauvinism with
>> science on this list.
>>
>>
>>
>> Nancy
>>
>>
>>
>> On Thu, Jan 30, 2014 at 8:50 AM, Martyn Thomas <
>> martyn_at_xxxxxx >>
>> I'm a non-exec Director at the UK's Health and Safety Laboratory (
>> www.hsl.gov.uk). We carry out the basic research that underpins the UK's
>> regulation of occupational health and safety, ranging from reducing
>> accidents on construction sites and improving the tethering of loads on
>> lorries, through to reproducing and analysing major explosions (such as
>> Buncefield - http://www.buncefieldinvestigation.gov.uk/) and
>> destruction-testing the physical integrity of tankers and rolling-stock.
>>
>> We also undertake commercial work that uses our unusual experimental and
>> analysis capabilities and very strong science base.
>>
>> The UK is unusual in having a goal-based, safety-case regulatory regime
>> and a regulator (HSE) with its own expert research establishment (HSL). We
>> are getting an increasing number of approaches from Governments in the Far
>> and Middle East who see the UK's good performance in occupational Health
>> and Safety and who want to investigate setting up similar goal-based
>> regulation.
>>
>> Maybe there is something in the HSE/HSL approach that the US chemical
>> industry could benefit from.
>>
>> Regards
>>
>> Martyn
>> Martyn Thomas CBE FREng
>>
>>
>>
>>
>> On 29/01/2014 22:05, Peter Bernard Ladkin wrote:
>>
>> A worthy opinion piece from the Chair of the US Chemical Safety Board. Note his suggestion that identifying hazards and mitigation is just well-established best practice. I can say from experience that it is not yet in Europe in all industries with safety aspects, even though he holds Europe up as having a factor of three fewer chemical accidents as the US.
>>
>>
>>
>>
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>>
>>
>> --
>> Prof. Nancy Leveson
>> Aeronautics and Astronautics and Engineering Systems
>> MIT, Room 33-334
>> 77 Massachusetts Ave.
>> Cambridge, MA 02142
>>
>> Telephone: 617-258-0505
>> Email: leveson_at_xxxxxx >> URL: http://sunnyday.mit.edu
>>
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>
>
> --
> Prof. Nancy Leveson
> Aeronautics and Astronautics and Engineering Systems
> MIT, Room 33-334
> 77 Massachusetts Ave.
> Cambridge, MA 02142
>
> Telephone: 617-258-0505
> Email: leveson_at_xxxxxx > URL: http://sunnyday.mit.edu
> _______________________________________________
> The System Safety Mailing List
> systemsafety_at_xxxxxx >
>
>
> _______________________________________________
> The System Safety Mailing List
> systemsafety_at_xxxxxx >
>

-- 
Prof. Nancy Leveson
Aeronautics and Astronautics and Engineering Systems
MIT, Room 33-334
77 Massachusetts Ave.
Cambridge, MA 02142

Telephone: 617-258-0505
Email: leveson_at_xxxxxx
URL: http://sunnyday.mit.edu



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Received on Sun Feb 02 2014 - 20:52:15 CET

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