Hi Rich,

I have to admit that I’ve been thinking about your reply all weekend.

As you know, I teach machinery risk assessment and consult in this area 
regularly. I want to stipulate that there are some significant issues with risk 
assessment the way it is most commonly applied in industry, see my list of 
references on this topic at the end of my message.

The inherent subjectivity of risk assessments that are performed without 
empirical data is unquestioned. The difficulty is that for many areas of human 
endeavour we have no empirical data, and try as we might we cannot calculate 
without numeric data. Nevertheless, we must be able to make risk-based 
decisions when designing products and equipment, and so we muddle along with 
the best tools that we have, hopefully while recognizing their flaws.

The HBSE model is a good one, and it fits machinery applications as readily as 
does risk assessment, however, the risk assessment methods that are used today 
have a history that stretches back to the 1960s, while the HBSE model is much 
younger. This doesn’t take away from HBSE in any way for me, but it does have 
an impact on the broader acceptance of the method since it is not yet as widely 
known as “conventional” risk assessment. None of the the standards in the 
machinery safety sector recognize the method as yet, so getting regulators and 
users to consider the method is a challenge.

HBSE also suffers from issues with lack of data when it comes to characterizing 
some hazards, leaving the user to estimate the characteristics. This brings in 
the biases of the person(s) doing the estimating just as surely as conventional 
risk assessment methods.

The absence of a probability parameter in the HBSE model is an interesting one, 
since the probability aspect is the one most subject to error in conventional 
risk assessment. Humans are notoriously bad at estimating probability. It 
appears to me that the absence of that parameter implies that the presence of a 
hazard will inevitably lead to harm, which I don’t disagree with. CSA Z1002, 
OHS risk assessment, actually states that this is the case, and recommends that 
hazards are eliminated on this basis whenever possible.

So we’re left with this situation, I think:

1) Risk assessment, when done quantitatively using sound statistical techniques 
and valid data is a useful and relatively objective method to provide data to 
decision makers,
2) Conventional risk assessment using subjective opinions and risk matrices or 
decision trees are unrepeatable and therefore unscientific, however. despite 
their flaws, they provide a means to help guide decision makers,
3) HBSE improves on some aspects of conventional risk assessment by eliminating 
the probability parameters, but is still subject to some subjectivity, and is 
still not widely accepted enough for some decision makers.

I wish there was a more utopian perspective to take on the topic, but I have 
yet to find my way to it.

References
[1] E. S. Levine, “Improving risk matrices: The advantages of logarithmically 
scaled axes,” J. Risk Res., vol. 15, no. 2, pp. 209–222, 2012.

[2] R. Long, “Calculators , Matrices and Mumbo Jumbo Risk Assessment,” 
Safetyrisk.net, 2016. [Online]. Available: 
http://www.safetyrisk.net/calculators-matrices-and-mumbo-jumbo-risk-assessment/.
 [Accessed: 03-Feb-2016].

[3] D. J. Ball and J. Watt, “Further Thoughts on the Utility of Risk Matrices,” 
Risk Anal., vol. 33, no. 11, pp. 2068–2078, 2013.

[4] C. Bao, D. Wu, J. Wan, J. Li, and J. Chen, “Comparison of Different Methods 
to Design Risk Matrices from the Perspective of Applicability,” Procedia 
Comput. Sci., vol. 122, pp. 455–462, 2017.

[5] C. Peace, “The risk matrix : uncertain results?,” Policy Pract. Heal. Saf., 
vol. 0, no. 0, pp. 1–14, 2017.

[6] B. Ale and D. Slater, “Risk Matrix Basics,” 2012.

[7] P. Gardoni and C. Murphy, “A Scale of Risk,” Risk Anal., vol. 34, no. 7, 
pp. 1208–1227, 2014.

[8] P. Baybutt, “Guidelines for Designing Risk Matrices,” Process Saf. Prog., 
vol. 00, no. 0, p. 7, 2017.

[9] H. J. Pasman, W. J. Rogers, and M. S. Mannan, “Risk assessment: What is it 
worth? Shall we just do away with it, or can it do a better job?,” Saf. Sci., 
vol. 99, pp. 140–155, 2017.

[10] X. Ruan, Z. Yin, and D. M. Frangopol, “Risk Matrix Integrating Risk 
Attitudes Based on Utility Theory,” Risk Anal., vol. 35, no. 8, pp. 1437–1447, 
2015.

[11] S. Albery, D. Borys, and S. Tepe, “Advantages for risk assessment: 
Evaluating learnings from question sets inspired by the FRAM and the risk 
matrix in a manufacturing environment,” Saf. Sci., vol. 89, pp. 180–189, 2016.

[12] P. Thomas, R. B. Bratvold, and J. E. Bickel, “The Risk of Using Risk 
Matrices,” SPE Annu. Tech. Conf. Exhib., no. April 2015, 2013.

[13] F. Gauthier, Y. Chinniah, D. Burlet-Vienney, B. Aucourt, and S. Larouche, 
“Risk assessment in safety of machinery: Impact of construction flaws in risk 
estimation parameters,” Saf. Sci., vol. 109, no. June, pp. 421–433, 2018.

[14] O. Amundrud and T. Aven, “On how to understand and acknowledge risk,” 
Reliab. Eng. Syst. Saf., vol. 142, pp. 42–47, 2015.

[15] S. O. Hansson and T. Aven, “Is Risk Analysis Scientific?,” Risk Anal., 
vol. 34, no. 7, pp. 1173–1183, 2014.

[16] J. Li, C. Bao, and D. Wu, “How to Design Rating Schemes of Risk Matrices: 
A Sequential Updating Approach,” Risk Anal., 2018.

[17] L. A. Cox, D. Babayev, and W. Huber, “Some limitations of qualitative risk 
rating systems,” Risk Analysis, vol. 25. pp. 651–662, 2005.

[18] L. A. Cox, “What’s wrong with risk matrices?,” Risk Anal., vol. 28, no. 2, 
pp. 497–512, Apr. 2008.

[19] A. Quintino, “What’s Wrong with Risk Matrices? Decoding a Louis Anthony 
Cox paper Reshaping dowsntream configuration View project An integrated risk 
management model for an oil and gas company View project,” no. March 2011, 2016.

--
Doug Nix
[email protected]

“If there are no dogs in Heaven, then when I die I want to go where they went.” 
-Will Rogers



> On 12-Feb-22, at 16:59, Richard Nute <[email protected]> wrote:
> 
> 
> 
> I don’t like the Risk Assessment process because it is highly subjective and 
> not very repeatable.
> 
> When I was with Hewlett Packard, three of us developed “Hazard Based Safety 
> Engineering,” HBSE.  The basis for HBSE was James J. Gibson’s (Cornell 
> University) research into child injury from auto accidents.  Gibson said:
> 
> “Injuries to a living organism can be produced only by some energy 
> interchange. Consequently, a most effective way of classifying sources of 
> injury is according to the forms of physical energy involved. The analysis 
> can thus be exhaustive and conceptually clear. Physical energy is either 
> mechanical, thermal, radiant, chemical, or electrical.”
> 
> In a moving automobile, the automobile and its passengers have kinetic 
> (mechanical) energy.  In an accident, the kinetic energy of the automobile is 
> dissipated in crumpling parts.  The kinetic energy of the passengers is 
> dissipated in injuries to the body.  Seat belts transfer the passenger 
> kinetic energy to the automobile.  Air bags slow the rate of kinetic energy 
> transfer to the automobile.
> 
> HBSE identified the magnitudes each kind of physical energy necessary to 
> cause injury.  We called this “hazardous” energy.  Then, HBSE went on to 
> specify safeguards that would attenuate or prohibit hazardous energy 
> interchange.
> 
> When I evaluate a product, I look for the physical energy sources, and then 
> determine if the energy sources are hazardous or not.  Unlike Risk 
> Assessment, this is easy and repeatable and not subjective.  For example, all 
> primary circuits are hazardous energy circuits that can cause injury 
> (electric shock, thermal, fire, and maybe more) and safeguards must be 
> provided.
> 
> Best regards,
> Rich
> 
> 
> From: Douglas E Powell <[email protected] <mailto:[email protected]>>
> Sent: Friday, February 11, 2022 11:37 AM
> To: [email protected] <mailto:[email protected]>
> Subject: Re: [PSES] EN 62368-1 : 2020 Ed 3
> 
> In my view, the Risk Assessment should never be treated as a 'get out of 
> jail' card or panacea. Instead, it is only a starting point for a safe design 
> and should be done near the beginning of a project, not the end. I agree with 
> what Rich says, I've seen a lot of subjective assessments by cross-functional 
> teams, with variability based on personal risk tolerance or risk aversion.  
> There are any number of articles pointing to why humans are not very good at 
> assessing risk (Google search 
> <https://www.google.com/search?q=humans+are+not+very+good+at+assessing+risk>).
> 
> When using FMEA for risk assessment, I always stress that the RPN factors of 
> probability of occurrence, severity, and detection be quantified separately 
> without regard to the other factors, not an easy task. There is also the 
> problem of RPN vs Criticality (severity x occurrence).  If using the RPN, 
> there is the possibility that Detection can dilute the RPN number to a point 
> below the threshold for action. So in my view, Criticality alone should be 
> used to trigger action.
> 
> Kenneth Ross wrote a very good article last month on Navigating the Safety 
> Hierarchy; for me, it was an excellent refresher on how I should use risk 
> assessment more effectively 
> (https://incompliancemag.com/article/navigating-the-safety-hierarchy/ 
> <https://incompliancemag.com/article/navigating-the-safety-hierarchy/>).
> 
> -Doug
> 
> Douglas E Powell
> Laporte, Colorado USA
> -
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