Re: [SystemSafety] FMEA draft international standard

From: Andrew Rae < >
Date: Wed, 16 Jul 2014 11:10:38 +0100


Don't hold back, Matthew! Say what you really think.

What bugs me most is that one reason the standards process has got like this is proliferation of useless standards.

FMEA is a broad-brush name for a family of techniques. What is the benefit of locking the practice of those techniques into a standard?

You can't tell if FMEA has been performed well by auditing it against a standard, so it is useless for quality control or contract management, if not downright counter-productive. Use of a standard implies that someone is spending time checking that it meets the standard instead of meets its actual objectives. If the standard is intended instead to teach people how to do FMEA properly, then the standardisation process is not the way to go about it.

Worse, the name "FMEA" is often used to cover functional failure analysis type activities that have different purposes to bottom-up component FMEA. Whichever direction the standard jumps (covering both, or restricting to one) it is going to contribute to confused people applying techniques at the wrong stage in the lifecycle for them to do any good. We'll get people performing FMEA in a particular way at a particular time because "it's in the contract, and the contract calls up the standard" instead of "because I think it will help make a safer system".

Standards processes seldom have an easy way for people outside the immediate process to say "You're whole approach to this is wrong". They're much more suited to complaining about how specific bits are expressed, on the assumption that the overall framework makes sense.

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On 16 July 2014 10:59, Matthew Squair <mattsquair_at_xxxxxx

> I detest the 'walled garden' approach of these organisations, what they're
> doing is simply rent sitting on a social good. And their bureaucratic
> processes have become an end in themselves.
>
> Also, now Peters riled me up, speaking as an antipodean there's about the
> same likelihood of the snow dog catching the cinder cat in the furnaces of
> hell as there is of my being able to contribute to the development of the
> FMEA standard. Which won't stop our national standards body from adopting
> it, mainly because they can make a profit on the exercise.
>
> Oh and IMHO writing standards without any reference to what the thinking
> and evidence that they are based on is inherently a flawed process,
> irretrievably so in my opinion.
>
> I say a plague on all their houses. Somewhere along the line we seem to
> have completely lost the point about all this.
>
>
> Matthew Squair
>
> MIEAust, CPEng
> Mob: +61 488770655
> Email; Mattsquair_at_xxxxxx > Web: http://criticaluncertainties.com
>
> On 16 Jul 2014, at 5:53 pm, Peter Bernard Ladkin <
> ladkin_at_xxxxxx >
>
>
> On 2014-07-15 21:16 , Barrie Reynolds wrote:
>
> PBL said
>
> But getting such a process underway is not trivial. First, people have to
> obtain a copy of the CD.
>
>
> The UK committee is BSI DS/1
>
> Members of the supporting organisations should obtain a copy direct from
> their representative on DS/1
>
> The Supporting organisations are at the bottom of the page at:
>
> https://standardsdevelopment.bsigroup.com/Home/Committee/50001626
>
>
> If I may take the opportunity to use Barrie's helpful message for a
> purpose for which it was not
> intended.....
>
> I am very concerned, as are other colleagues, about the restrictive
> practices involved in standards
> development. There are two sides to it.
>
> One is that some form of organisation is required, resources for any
> activity have to be sourced,
> especially an activity such as codifying the state of the art in a
> specific technology while
> controlling as far as possible for special interests, and the world is a
> very complicated place.
>
> Another is that the sum total of practices discourage much participation
> in the endeavor, and the
> results suffer technically. Many standards in some areas are unnecessarily
> technically poor.
>
> For example, John Knight has complained publicly that he cannot obtain
> copies of standards to which
> he has himself contributed as a committee member without paying out large
> sums of money to which he
> does not have access in his academic role. And his students thereby cannot
> study them. He is right.
> Almost all academia is hindered from using actual - even past - standards
> in their teaching, at
> least in the area in which I work. That seems to be absurd if the
> standards' claim to codify current
> state of the art is true.
>
> Some national standards organisations do make provision for this. In
> Germany, a flat-rate
> subscription somewhat less than the current cost of a leading journal buys
> an organisation access to
> any German standards relevant to its area of interest. So I could get
> anything produced by IEC SC
> 65A (the functional system safety people) or IEC TC 56 (the Dependability
> people, which in the IEC
> definition does not include safety, although in the IFIP glossary -
> Laprie, Randell and co - it
> does) - but only in its German translation (to which the responsible
> national standards organisation
> DKE has copyright - the official German standard is the translation of the
> IEC one).
>
> Then there is the business of soliciting input and commentary from those
> with expertise who are not
> involved in development.
>
> BSI appears to distinguish two phases, a Committee Draft and a Draft for
> Public Comment. The
> proposed IEC 60812 is not available as a Draft for Public Comment on the
> BSI WWW site. The German
> DKE does not distinguish such phases, as far as I know. A Committee Draft
> is made available to any
> who have registered a legitimate interest in the work of a given committee
> (the German correspondent
> to BSI DS/1 is DKE K132). Registering an interest is open to anyone, and
> you will be accepted if it
> looks as if you work in the field or a related field, and often even if
> you don't.
>
> For example, I imagine any member of the VDE (the German electrotechnical
> engineering organisation)
> would be enabled to register an interest in any standards area for which
> DKE is responsible. Whereas
> I note that the British equivalent, the IET, is not a supporting
> organisation of DS/1, so you don't
> get to comment on the 60812 CD merely through being an IET member with an
> interest. (Incidentally, I
> find it very odd that the IET is not. I think we should fix that. HAZOP
> and FMEA and FTA and ETA,
> let alone Markov modelling and so on are important to electrotechnical
> engineers!)
>
> IEC CDs, NWIPs and so on are distributed, and comments are requested -
> commentary is expected to be
> solicited by those who have registered an interest. So for example I gave
> a recent CD of another
> standard to a particularly talented student for commentary; he sent in
> extensive (and worthwhile)
> comments, which were forwarded to the IEC MT (though had not been
> addressed by the time I resigned
> my MT membership, which was at the time that the subsequent CD was being
> distributed - one
> procedural anomaly amongst many, which is why I resigned) and he was
> invited to participate in the
> subsequent K 132 meeting. Comments are sent direct to the named German
> Representative on the IEC
> Technical Committee (each participating country has just one
> Representative on a TC; this is a
> different role from that of participating in a specific Project Team or
> Maintenance Team, which is
> nominally not tied to nationality).
>
> So I regard the German regime as appropriately technically liberal in this
> regard; the British and
> US ones much less so.
>
> Then there is the matter of affordances/hindrances, to use the
> Nielsen/Norman terminology.
>
> As I mentioned, the IEC (and by transitivity the national standards
> organisations) only accept
> comments on their comments form. This is commendably targeted in that it
> requires not only a general
> comment (usually expressing a criticism) but also a specific proposed
> change, and has a column for
> committee response. Formally, a committee response to each comment is
> required. The "committee" of
> first instance here will often be the national committee, which will
> decide which comments to
> forward to the IEC PT/MT. The affordance here is that comments get logged
> and responded to in a
> traceable manner.
>
> *But* the form is in a proprietary document-preparation format, and is not
> formatted for easy use on
> the screens of computers which most of us use. I just got a brand-new
> Apple MacBook Pro, which
> renders the file automatically using its own doc-prep SW Pages, and it is
> as usual all over the
> place. I can of course deal with that and will. But I am involved in
> standardisation work, and many
> people whom we hope will comment are not. Many of them are not going to
> take the half-hour to couple
> of hours to configure their computers just to use a form. It's a hindrance.
>
> What happens in Germany is that free-form comments are de facto accepted,
> and someone usually
> volunteers to wedge them into the IEC format for further consideration,
> all very informal. As far as
> I know, that doesn't seem to happen in Britain.
>
> All in all, a reverse of the usual cultural stereotypes. :-)
>
> John is concerned about access to standards and standards development for
> engineering students, as
> am I (but as I mentioned, we have some sort of a solution, at least for
> IEC and ISO although not for
> RTCA or EUROCAE, in Germany). I am very concerned about the technical
> quality of published standards
> in our area, as is John, because it so often is poor. I think FDISs (the
> final draft standard)
> should be subject to eminent-peer review. I think the EU project regime
> here is quite effective.
> Named outside reviewers who engage face-to-face with representatives of
> the Project Team and who
> have final say on whether Deliverables (documents and SW) are accepted.
> (It is more effective than
> academic-style anonymous reviewing, because *everybody's* reputation is
> publicly on the line at
> every step. For reviewers to miss things is just as consequential as for
> the PT to miss things.)
> Resourcing this is an issue, but one imagines that the IEC could find a
> way from the kinds of
> four-figure sums it charges for the likes of IEC 61508.
>
> John's paper at SSS2014 is available at
> http://scsc.org.uk/paper_126/protect_reg_01-Knight.pdf?pap=933 . I have a
> White Paper on it from a
> year ago at
> http://www.rvs.uni-bielefeld.de/publications/WhitePapers/RVSsfssPrinciples.pdf
>
> PBL
>
> Prof. Peter Bernard Ladkin, Faculty of Technology, University of
> Bielefeld, 33594 Bielefeld, Germany
> Tel+msg +49 (0)521 880 7319 www.rvs.uni-bielefeld.de
>
>
>
>
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