Facilities System Safety
Facilities System Safety
Facilities System Safety
Chapter 12:
Facilities System Safety
12.1 Introduction
The purpose of facility system safety is to apply system safety techniques to a facility from its initial design
through its demolition. This perspective is often referred to as the Facility Acquisition Life Cycle. The
term “facility” is used in this chapter to mean a physical structure or group of structures in a specific
geographic site, the surrounding areas near the structures, and the operational activities in or near the
structures. Some aspects that facility system safety address are: structural systems, Heating, Ventilation,
and Air-conditioning (HVAC) system, electrical systems, hydraulic systems, pressure and pneumatic
systems, fire protection systems, water treatment systems, equipment and material handling, and normal
operations (e.g. parking garage) and unique operational activities (e.g. chemical laboratories). This Life
Cycle approach also applies to all activities associated with the installation, operation, maintenance,
demolition and disposal rather than focusing only on the operator.
Facilities are major subsystems providing safety risks to system and facility operational and maintenance
staff. Control of such risks is maintained through the timely implementation of safety processes similar to
those employed for safety risk management for airborne and ground systems. MIL-STD-882, Section 4
“General Requirements” defines the minimum requirements of a safety program. These requirements define
the minimum elements of a risk management process with analysis details to be tailored to the application.
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Ž FAA Orders
Ž LessonS Learned
Structure Equipment
Ž Re-Eng. Ž Re-Eng.
Ž Renovation Ž Modify/
Upgrade
It is important to note that there is a hierarchy of safety and health directives and specifications in the FAA.
All efforts should start with FAA 3900.19, Occupational Safety and Health Program rather than other
related FAA Orders (e.g. FAA Order 6000.15, General Maintenance Handbook for Airway Facilities) and
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FAA Specifications (e.g. FAA-G-2100, Electronic Equipment, General Requirements). These related
documents contain only a small part of the safety and health requirements contained in FAA Order
3900.19, FAA Occupational Safety and Health Program and the Occupational Safety and Health
Administration (OSHA) Standards.
The methodologies as defined in MIL-STD-882 are applicable to both construction and equipment design
and re-engineering. As with all safety significant subsystems, the System Safety process for facilities
should be tailored to each project in scope and complexity. The effort expended should be commensurate
with the degree of risk involved. This objective is accomplished through a facility risk assessment process
during the mission need and/or Demonstration and Evaluation (DEMVAL) phase(s).
Facilities system safety involves the identification of the risks involving new facility construction and the
placement of physical facilities on site. The risks associated with construction operations, the placement of
hazardous facilities and materials, worker safety and facility design considerations are evaluated. Hazard
analyses are conducted to identify the risks indicated above.
Consideration should be given to physical construction hazards i.e. materials handling, heavy equipment
movement, fire protection during construction. Facility designs are also evaluated from a life safety
perspective, fire protection view, airport traffic consideration, structural integrity and other physical
hazards. The location of hazardous operations are also evaluated to determine their placement and
accessibility, i.e. high hazard operations should be constructed away from general populations.
Consideration should also be given to contingency planning, accident reconstruction, emergency
egress/ingress, emergency equipment access and aircraft traffic flow. Line of sight considerations should
be evaluated as well as factors involving electromagnetic environmental effects. Construction quality is
also an important consideration, where physical designs must minimally meet existing standards, codes and
regulations.
System safety is also concerned with the analysis of newly installed equipment. The following generic
hazards should be evaluated within formal analysis activities. Generic hazards areas are: electrical,
implosion, explosion, material handling, potential energy, fire hazards, electrostatic discharge, noise,
rotational energy, chemical energy, hazardous materials, floor loading, lighting and visual access,
electromagnetic environmental affects, walking/working surfaces, ramp access, equipment
failure/malfunction, foreign object damage, inadvertent disassembly, biological hazards, thermal non
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ionizing radiation, pinch/nip points, system hazards, entrapment, confined spaces, and material
incompatibility.
The environmental assessment and consultation process provides officials and decision makers, as well as
members of the public, with an understanding of the potential environmental impacts of the proposed
action. The final decision is to be made on the basis of a number of factors. Environmental considerations
are to be weighed as fully and as fairly as non-environmental considerations. The FAA's objective is to
enhance environmental quality and avoid or minimize adverse environmental impacts that might result from
a proposed Federal action in a manner consistent with the FAA's principal mission to provide for the safety
of aircraft operations.
In conducting site evaluations the following risks must be evaluated from a system safety perspective.
• Noise
• Environmental Site Characterization
• Compatible Land Use
• Emergency Access and existing infrastructure
• Water supply
• Local emergency facilitates
• Social Impacts
• Induced Socioeconomic Impacts
• Air & Water Quality
• Historic, Architectural, Archeological, and Cultural Resources.
• Biotic Communities
• Local Weather Phenomena (tornadoes, hurricanes and lighting)
• Physical Phenomena (e.g. mudslide and earth quakes)
• Endangered and Threatened Species of Flora and Fauna.
• Wetlands.
• Animal Migration
• Floodplains.
• Coastal Zone Management
• Coastal Barriers.
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• Wild and Scenic Rivers
• Farmland.
• Energy Supply and Natural Resources.
• Solid Waste
• Construction Impacts.
The final step before the user takes control of the facility is the occupancy inspection. This inspection
verifies the presence of critical safety features incorporated into the design. The use of a hazard tracking
system can facilitate the final safety assessment. This review may identify safety features that might
otherwise be overlooked during the inspection. A Hazard Tracking Log can generate a checklist for safety
items that should be part of this inspection.
The results of the occupancy inspection can serve as a measure of the effectiveness of the SSPP. Any
hazards discovered during the inspection will fall into one of two categories. A hazard that was previously
identified and the corrective action to be taken to control the determined hazard, or a hazard not previously
identified requiring further action. Items falling in this second category can be used to measure the
effectiveness of the SSPP for a particular facility.
• Ensure the application of all relevant building safety codes, including OSHA, National
Fire Protection Association, and FAA Order 3900.19B safety requirements.
• Conduct hazard analyses to determine safety requirements at all interfaces between the
facility and those systems planned for installation.
• Review equipment installation, operation, and maintenance plans to make sure all
design and procedural safety requirements have been met.
• Continue updating the hazard correction tracking begun during the design phases.
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• Evaluate accidents or other losses to determine if they were the result of safety
deficiencies or oversight.
• Update hazard analyses to identify any new hazards that may result from change
orders.
In addition, guidance for conducting a Hazardous Material Management Program (HMMP) is provided in
National Aerospace Standard (NAS) 411. The purpose of a HMMP is to provide measures for the
elimination, reduction, or control of hazardous materials. A HMMP is composed of several tasks that
complement an SSPP:
• HMMP Plan
• Cost analysis for material alternatives over the life cycle of the material
• Documented trade-off analyses
• Training
• HMMP Report
Low-risk facilities; i.e., housing, and administrative buildings. In these types of facilities, risks to building
occupants are low and limited normally to those associated with everyday life. Accident experience with
similar structures must be acceptable, and no additional hazards (e.g., flammable liquids, toxic materials,
etc.) are to be introduced by the building occupants. Except in special cases, no further system safety
hazard analysis is necessary for low risk facility programs.
Medium-risk facilities; i.e., maintenance facilities, heating plants, or benign facilities with safety critical
missions such as Air Traffic Control (ATC) buildings. This group of facilities often presents industrial
type safety risks to the building occupants and the loss of the facility's operation has an impact on the
safety of the NAS. Accidents are generally more frequent and potentially more severe. A preliminary
hazard analysis (PHA) is appropriate. System hazard Analysis (SHA) and Subsystem Hazard Analysis
(SSHA) may also be appropriate. The facility design or systems engineering team members are major
contributors to these analyses. User community participation is also important.
High-risk facilities; i.e., high-energy-related facilities, fuel storage, or aircraft maintenance. This category
usually contains unique hazards of which only an experienced user of similar facility will have detailed
knowledge. Because of this, it is appropriate for the user or someone with applicable user experience to
prepare the PHA in addition to the PHL. Additional hazard analyses (e.g., system, subsystem, operating
and support hazard analyses may be required).
Another example is presented in FAA Order 3900.19, FAA Occupational Safety and Health Program.
This Order requires that “increased risk workplaces be inspected twice a year and all general workplaces
once a year.” Increased risk workplaces are based on an evaluation by an Occupational Safety and Health
professional and include areas such as battery rooms and mechanical areas.
In facility system safety applications, there are many ways of classifying risk which are based o n
exposures, such as fire loading, or hazardous materials. The National Fire Protection Association provides
details on these various risk categorization schemes. (See page 12-34 NFPA Health (hazard) Identification
System).
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12.4 Facility System Safety Program
Preparation of a facility system safety program involves the same tasks detailed in Chapter 5. However,
there are unique applications and facility attributes which are discussed in this section.
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The concept of operational risk management is the application of operational safety and facility system
safety. More explicit information on Operational Risk management is found in Chapter 15.
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Other factors influencing the SSPP are overall project time constraints, manpower availability, and
monetary resources. The degree of system safety effort expended depends on whether the project replaces
an existing facility, creates a new facility, involves new technology, or is based on standard designs. A
more detailed discussion of each of the elements of a System Safety Program Plan is in Chapter 5.
ORMG Process
The ORMG process consists of nine major elements, which are depicted in Figure 12-3.
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Hazard Update
Identification SER
(Master M atrix)
Requirements Document in
Cross-Check Initial
SER (iterative)
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• Existing Human Factors Review documents
• Existing Computer-Human Interface Evaluations
• Safety Assessment Review documents
• Site Transition & Activation Plan (STAP)
• System Technical Manuals
• Site Transition and Activation Management Plan (STAMP)
• System/Subsystem Specification (SSS)
The basis of the analysis relates to generic hazards and controls to specific maintenance steps required for
maintaining and repairing the system. The maintenance steps identified during the review should be
integrated into a matrix. In evaluating hazards associated with the maintenance procedures, the specific
procedures could fall into generic maintenance categories, which are characterized for example as listed
below:
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1
12.5.1 Change Analysis
Change analysis examines the potential affects of modifications to existing systems from a starting point or
baseline. The change analysis systematically hypothesizes worse case effects from each modification from
that baseline. Consider existing, known system as a baseline. Examine the nature of all contemplated
changes and analyze the potential effects of each change (singularly) and all changes (collectively) upon
system risks. The process often requires the use of a system walk down, which is the method of physically
examining the system or facility to identify the current configuration.
Alternatively, a change analysis could be initiated on an existing facility by comparing “as designed” with
the “as built” configuration. In order to accomplish this, there would first be the need to physically identify
the differences from the “as designed” configuration. The process steps are:
This PHL effort serves several important functions. It provides the FAA with an early vehicle for
identifying safety, health, and environmental concerns. The results of this determination are used to size
the scope of the necessary safety effort for the specification, design and construction activities. It provides
the Associate Administrator with the data necessary to assess the cost of the safety effort and include it in
requests for funding. By requiring the PHL to accompany the funding documentation, funding for system
safety tasks becomes an integral part of the budget process.
Generation of the initial PHL includes identification of safety critical areas. Areas that need special safety
emphasis (e.g., walk-through risk analysis) are identified. The process for identifying hazards can be
accomplished through the use of checklists, lessons learned, compliance inspections/audits, accidents/near
1
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misses, regulatory developments, and brainstorming sessions. For existing facilities, the PHL can be
created using information contained in the Environment and Safety Information System (ESIS). All
available sources should be used for identifying, characterizing, and controlling safety risks. Examples of
such inputs that may be found are in Figure 12-3. The availability of this information permits the FAA to
incorporate special requirements into the detailed functional requirements and specifications. This input
may be in the form of specific design features, test requirements, of SSP tasks. The resulting contract
integrates system safety into the design of a facility starting with the concept exploration phase.
PHL
PHA
User-defined unacceptable or Safety Risk
undesirable events Identification and
Design Reviews Characterization
Hazard Analysis Outputs
Health Hazard Reports
Figure 12-3 Sample Inputs for Safety Risk Identification and Characterization
The PHL also generates an initial list of risks that should initiate a Hazard Tracking Log, a database of
risks, their severity and probability of occurrence, hazard mitigation, and status. New risks are identified
throughout the design process, entered into and tracked by the log. As the design progresses, corrective
actions are included and risks are eliminated or controlled using the system safety order of precedence (See
Chapter 3, Table 3-1). Status is tracked throughout the design and construction process.
Safety risks may be logged closed in one of three ways. Those: (1) eliminated or controlled by design are
simply “closed.” (2) that are to be controlled by procedures or a combination of design and procedures are
marked closed but annotated to ensure that standard and operating procedures (SOPs) are developed to
reduce the risk. A list of operation and maintenance procedures to be developed is generated and turned
over to the user. (3) that are to be accepted as is, or with partial controls, are closed and risk acceptance
documentation prepared. This process documents all risks, their status, and highlights any additional
needed actions required. Thus, the hazard tracking system documents the status of safety risks throughout
the life of the facility's life cycle.
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As an expanded version of the PHL, the PHA contains greater detail in three areas. First, hazard control
information is added to identified hazards. Second, a more comprehensive and systematic analysis to
identify additional hazards is performed. Third, greater detail on hazards previously identified in the PHL
is provided.
Detailed knowledge of all operations to be conducted within the facility and any hazards presented by
nearby operations is required. Based on the best available data, including lessons learned, hazards
associated with the proposed facility design or functions are evaluated for risk severity and probability,
together with operational constraints.
If the PHA indicates that the facility is a “low-risk” building and no further analysis is necessary, a list of
applicable safety standards and codes are still required. If the facility is “medium” or “high” risk, methods
to control risk must be instituted.
For existing systems the O&SHA is intended to address changing conditions through an iterative process
that can include subject matter expert (SME) participation and a review of installed systems. This
information could be documented in subsequent Safety Engineering Reports.
O&SHA is limited to the evaluation of risks associated with the operation and support of the system. The
materials normally available to perform an O&SHA include the following:
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Operating and Support Hazard Analysis Approach
This approach is based on the guidance of MIL-STD-882, System Safety Program Plan Requirements and
the International System Safety Society, Hazard Analysis Handbook. The O&SHA evaluates hazards
resulting from the implementation of operations or tasks performed by persons and considers the following:
Throughout the process, the human is considered an element of the total system, receiving inputs and
initiating outputs during the conduct of operations and support. The O&SHA methodology identifies the
safety-related requirements needed to eliminate hazards or mitigate them to an acceptable level of risk using
established safety order of precedence. This precedence involves initial consideration of the elimination of
the particular risk via a concept of substitution. If this is not possible, the risk should be eliminated by the
application of engineering design. Further, if it is not possible to design out the risk, safety devices should
be utilized. The order of progression continues and considers that if safety devices are not appropriate,
design should include automatic warning capabilities. If warning devices are not possible, the risks are to
be controlled via formal administrative procedures, including training.
The O&SHA is a more formal system safety engineering method that is designed to go beyond a JSA.
System safety is concerned with any possible risk associated with the system. This includes consideration
of the human/hardware/software/environmental exposures of the system. The analysis considers human
factors and all associated interfaces and interactions. As an additional outcome of the O&SHA, different
JSAs could be developed and presented depending on exposure and need. It is anticipated that JSAs will be
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utilized to conduct training associated with new systems. Specific JSAs addressing particular maintenance
tasks, specific operations, and design considerations can be developed.
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For further information concerning operating and support hazards and risks associated with aviation,
contact the FAA Office of System Safety.
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An example of a risk assessment matrix is provided in Table 12-1. This matrix indicates the related hazard
code, hazard or scenario description, and scenario code. Both initial risk and final risk associated with the
specific scenario is also indicated. There is also a section for supportive comments.
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Table 12-2 Hazard Tracking Log Example: LOCATION: Building 5 Paint Booth
ITEM/FUNCTION PHASE HAZARD CONTROL CORRECTIVE ACTION
& STATUS
Cranes Lifting Loads exceed crane hoist Rated capacity painted on both Closed.
(2) 1000 LB capacity. sides if Figures readable from Use of cranes limited by
(top of paint booth frame) the floor level. Ref. Operating procedure to loads less
Manual.... than 600 lbs.
Crane Lifting Loads exceed crane hoist All bridge cranes proof loaded Closed.
(1) 10,000 LB bridge capacity. every 4 years. Certification tag No anticipated loads
(In front of paint booth) containing date of proof load, exceed 5000 lbs.
capacity, and retest date located
near grip.
Lifting Loss of control through All crane operators qualified Closed.
operator error. and authorized by floor
supervisor.
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The requirement cross check analysis is a technique that relates the hazard description or risk to specific
controls and related requirements. TABLE 12.-3 is an example of a requirement cross check analysis
matrix. It is comprised of the following elements: hazard description code, hazard description, or accident
scenario, the hazard rationale, associated with a specific exposure or piece of equipment. The matrix also
displays a control code, hazard controls, and it also provides reference columns for appropriate requirement
cross check. For this example, OSHA requirements, FAA requirements and National Fire Protection
Association requirements are referenced.
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Table 12-4 Hazard Tracking Log Example: LOCATION: Building 5 Paint Booth
ITEM/FUNCTION PHASE HAZARD CONTROL CORRECTIVE ACTION
& STATUS
Cranes Lifting Loads exceed crane hoist Rated capacity painted on both Closed.
(2) 1000 LB capacity. sides if Figures readable from Use of cranes limited by
(top of paint booth frame) the floor level. Ref. Operating procedure to loads less
Manual.... than 600 lbs.
Crane Lifting Loads exceed crane hoist All bridge cranes proof loaded Closed.
(1) 10,000 LB bridge capacity. every 4 years. Certification tag No anticipated loads
(In front of paint booth) containing date of proof load, exceed 5000 lbs.
capacity, and retest date located
near grip.
Lifting Loss of control through All crane operators qualified Closed.
operator error. and authorized by floor
supervisor.
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Listing by an NRTL such as UL, does not automatically ensure that an item can be used at an acceptable
level of risk. These listings are only indications that the item has been tested and listed according to the
laboratory’s criteria. These criteria may not reflect the actual risks associated with the particular
application of the component or its use in a system. Hazard analysis techniques should be employed to
identify these risks and implement controls to reduce them to acceptable levels. The hazard is related to the
actual application of the product. A computer powered by 110 VAC might be very dangerous if not used
as intended. For example, if it were used by a swimming pool, it would be dangerous regardless of the UL
standard that it was manufactured to comply with. Therefore, the use of products manufactured to product
manufacturing standards require the same system safety analysis as developmental items to ensure that they
are manufactured to the correct standard and used in an acceptable manner.
Conformance to codes, requirements, and standards is no assurance of acceptable levels of risk when
performing tasks. Risks should be diagnosed by hazard analysis techniques like the O&SHA. When risks
are identified, they are either eliminated or controlled to an acceptable level by the application of hazard
controls.
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Commercial-off-the-shelf, non-developmental items (COTS NDI) pose risks that must be isolated by
formal hazard analysis methods. The use of COTS-NDI does not ensure that the components or systems
that they are used in are OSHA compliant. COTS NDI components cannot be considered as having been
manufactured to any specific standards unless they have been tested by an NRTL. Therefore, the use of
COTS-NDI requires the same system safety analysis as developmental items to ensure that they are
manufactured and used in an acceptable manner.
The identification of hazardous materials in facilities and equipment that have been designated for
disposition. Failure to comply with these regulations can lead to fines, penalties, and other regulatory
actions. As per the Federal Facilities Compliance Act of 1992, states and local authorities may fine and/or
penalize federal officials for not complying with state and local environmental requirements.
Improper disposal of equipment containing hazardous materials would expose the FAA to liability in terms
of regulatory actions and lawsuits (e.g. fines, penalties, and cleanup of waste sites)
There are many regulatory drivers when dealing with hazardous materials disposition. These include:
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• National Environmental Policy Act (NEPA)
• Toxic Substance Control Act (TSCA)
• Federal Facilities Compliance Act of 1992 (FFCA)
• Community Environmental Response Facilitation Act (CERFA)
• DOT Shipping Regulations - Hazardous Materials Regulation
• OSHA Regulations (HAZCOM)
• State, local, and tribal laws
• FAA Orders
• Disposal guidance provided in FAA Order 4660.8, Real Property Management and
Disposal
• Disposition guidance contained in FAA Order 4800.2C, Utilization and Disposal of
Excess and Surplus Personal Property
• Material that on exposure under fire conditions would offer no hazard beyond that of
ordinary combustible material. (Example: peanut oil)
• Material that on exposure would cause irritation but only minor residual injury.
(Example: turpentine)
• Material that on intense or continued but not chronic exposure could cause temporary
incapacitation or possible residual injury. (Example: ammonia gas)
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• Material that on very short exposure could cause death or major residual injury.
(Example: hydrogen cyanide)
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FAA Order 1600.46, Physical Security Review of New Facilities, Office Space or Operating Areas
Human Factors Design Guide. Daniel Wagner, U.S. Dept of Transportation, FAA, January 15, 1996.
Public Law 91-596; Executive Order 12196, Occupational Safety and Health Programs for Federal
Employees
System Safety 2000, A Practical Guide for Planning, Managing, and Conducting System Safety
Programs, J. Stephenson, 1991.
System Safety Analysis Handbook, System Safety Society (SSS), July 1993.
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