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Control of Common OSH Hazards in Military Systems Acquisition

Several categories of occupational safety and health hazards, nominally under jurisdiction of OSHA regulations, have often been inconsistently addressed in defense acquisition programs. These include control of falls from elevated work locations (the second most common source of occupational fatalities); noise associated hearing loss (the most common occupational medical problem and a special concern within defense systems) and control of physical and atmospheric hazards within confined spaces.

The regulatory approach has tended to describe measures that must be taken in existing facilities and equipment. It has often been applied in a manner stressing procedural and design compliance without consistent identification of relative risk. Additionally, there has often been a misunderstanding and related over-estimation of the effectiveness and economy of using protective equipment to manage potential exposures. The continued incidence of hearing loss despite aggressive DOD hearing conservation programs demonstrates the limitations of primary reliance on protective equipment for risk management. Use of personal fall arrest systems and respiratory protection, among other measures; have demonstrated similar inconsistencies in effectiveness and many incompletely documented costs. Use of protective equipment as the main approach to hazard management is inconsistent with the hierarchy of controls applied by system safety and good systems engineering practice. Primary reliance on protective equipment for hazard mitigation is also nominally inconsistent with regulatory requirements. However, the likelihood of receiving a significant violation on the basis of this approach is minimal.

Application of risk-based system safety versus regulatory compliance approaches provides the most effective method for early identification of critical occupational safety hazards in system design. Identification of risk in the Preliminary Hazard List (PHL), management as part of the design process and mitigation through the conventional hierarchy of controls provides the most cost-effective methodology for hazard management. The existence of potential hazards and technological risks should not be delineated by regulatory compliance. Instead, reference to regulatory or guidance criteria may be used as an indication or threshold for including a specific physical agent or chemical agent in the PHL.

Work at elevated locations poses a fairly obvious risk of injury from falling to a lower level that should be considered in development of the PHL. Potentially affected systems include facilities, ships, aircraft (maintenance operations), communication towers and certain large vehicles. The severity of this risk is clearly related to the potential fall distance and type of surface below. The regulatory threshold for implementation of "fall protection" programs varies with industry between 4 and 15 feet and represents a "legal compromise" between technical feasibility, cost and human risk. These criteria may also be influenced by the relative strength and effectiveness of varied stakeholder. They clearly do not represent a fine line between "safe and unsafe". Therefore, an initial risk-based evaluation must be based on hazard identification. Final engineering control measures need to provide for regulatory compliance within the context of good design.

There is a concurrent DoD and Navy focus upon strengthening system engineering and the application of human engineering and human systems integration during the acquisition process. Combining these approaches provides a methodology to ensure design for users and coordination of developmental efforts. The result should be lowered life-cycle costs and risks associated with improved process description, risk evaluation, hazard management and operational controls.

As an example, entry into deep storage tanks on aircraft carriers is both hazardous and difficult because of the space configuration and the limited dimensions of access pathways. Major risks include potential falls of up to 50 feet, entrapment in confined spaces and atmospheric hazards. Necessary precautions contribute significantly to life-cycle maintenance costs. Design alternatives were reviewed by application of human engineering criteria and process flow evaluation. Minor configuration changes were suggested for new vessels. It is estimated that application of these guidelines could enhance the safety and efficiency of entry while reducing maintenance costs by approximately 35%, or in the range of $250,000 per shipyard availability period. Implementation costs are estimated to be relatively low for new construction.

Ergonomic injuries are the fastest growing category of occupational injuries and illness. Application of human engineering principles in design and modeling to ensure effective user interface markedly increases efficiency and reduces risk and injury to users. Proactive design approach and early identification of potential risk factors should be integrated into the systems engineering process. Management of identified risk factors such as material handling, potential entry into restricted locations, repetitive motion can be potentially related to specific process, work tasks and designs inconsistent with known human engineering criteria. System safety offers the most effective approach to management of risks related to design interface when such factors can be related to a risk and severity matrix.

The Chief of Naval Operations, CNO Safety Liaison Office (Code N09FB) has worked to ensure management of commonly understood risks through enhancing the risk management requirements in acquisition capabilities documents. We have also developed eTools and related website information for communication of common categories of occupational safety hazards in format and language relevant to acquisition. Case studies will be discussed. It is anticipated that these efforts and identification of occupational safety risks in the PHL and their risk-based evaluation in the hazard matrix of Military Standard 882 will support improved cost and risk management. Application of human factors engineering into the design of new military systems should enhance safety, economy and efficiency over the products life cycle.

Abstract for International System Safety Conference, August 2005

Mark Geiger, M.S., CIH, CSP 9 February 2005

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