Electrical Safety and Compliance: A Perspective on Risk-Based Approach and Assessment in South Africa
Electrical Safety and Compliance: A Perspective on Risk-Based Approach and Safety Risk Assessment.
With the South African market’s globalisation and the enactment of the WTO Technical Barrier to Trade Agreement, the industry expressed a requirement for safety regulations through compulsory product specifications.
This resulted in the inclusion of numerous voluntary SABS standards and adopted international standards for electrical products into compulsory specifications, often referred to as VC’s (Verplig-Compulsory).
Risk Assessment of Products
Both regulatory agencies and manufacturers utilise product risk assessments during the standards and product development processes. This involves formulating requirements and test methods for products to mitigate potential risks of harm or injury to users. Risk assessment procedures or models have been published by various regulatory bodies and are widely used to follow a structured approach based on reliable evidence in developing safety standards.
While the ultimate responsibility for product safety sits with manufacturers/suppliers, product risk assessments are regularly performed by manufacturers during their product design and engineering change processes.
The potential safety risk of products during their use depends on various factors such as:
- The nature of the hazard (such as burning, fire, electric shock, etc.)
- The likelihood of the potential hazard/injury occurring (statistical probability)
- The severity of the expected injury/harm
- Accessibility and the exposure time of users to the product
- Use by ordinary or skilled persons, elderly persons, or children?
- Expected end-of-life condition of the product (does it fail safely?)
Factual evidence of incidents and/or technical expertise, combined with the experience of the team of evaluators usually determines whether safety regulation is warranted.
Both national and international product standards encompass safety, interchangeability, and compatibility requirements for various products. These standards establish a foundation for compliance, ensuring that competitive settings uphold acceptable levels of quality and safety. In cases where products pose a tolerable safety risk, mandatory regulations might not be necessary. Instead, acceptable product quality and equitable trade conditions can be attained through voluntary standards or specifications.
NRCS Risk Assessment Methodology
Despite various risk assessment models available internationally, the NRCS chose to develop a unique Risk Assessment Methodology for the development of compulsory specifications that is based on standard ISO 31000. This Risk-Based Approach is being applied by the NRCS to evaluate the need and justification for new compulsory specifications.
The validity of the NRCS methodology has been queried by stakeholders and members of the industry as it is not based on factual evidence and statistics, resulting in outcomes that seem to be at variance with actual practice.
During stakeholder meetings addressing the safety and performance specifications (VC9109 and VC9110) of General Service lamps, a safety risk assessment was conducted. However, stakeholders encountered difficulty in reconciling the resulting risk rating score of 30 from the NRCS model. This score suggests a moderate risk, implying a need for pre-approval and regulation, which contradicts common experience. General Service lamps, having been in use for over 100 years, don’t present a safety risk that justifies the proposed level of regulation.
This discrepancy in the NRCS model’s outcome can be attributed to the lack of statistical evidence and a comprehensive evaluation of the various factors influencing the risk level. As a response to formal objections raised by stakeholders to NRCS management, there are indications that the NRCS methodology is currently under review.
What is a Risk-Based Approach based on ISO 31000?
The ISO 31000 risk management guideline provides principles, a framework and a process for managing risk. It can be used by any organization regardless of its size, activity or sector.
Using ISO 31000 can help organisations increase the likelihood of achieving objectives, improve the identification of opportunities and threats and effectively allocate and use resources for risk treatment.
However, ISO 31000 cannot be used for certification purposes, but does provide guidance for internal or external audit programmes. Organizations using it can compare their risk management practices with an internationally recognized benchmark, providing sound principles for effective management and corporate governance.
Although there may be common concepts, the objective of ISO 31000 Risk Management is to increase the effectiveness of the organisation’s processes and corporate governance, while Product Safety Risk assessment is aimed at developing product specifications to protect the public and environment against unsafe products.
While there seems to be an overwhelming urge to increase product regulation, it is critical that a sound, well-structured Risk Assessment model and procedure is developed. Even more critical is that it is based on statistical evidence and experience from local and international sources.
The implementation of structured surveillance testing processes are essential to collect factual evidence and to prevent personal preferences and assumptions to influence the development and implementation of new unwarranted compulsory specifications.
Impact on Industry and the Consumer
A flawed risk assessment model may result in levels of over-regulation and implementation of compulsory specifications for products that pose no more than a tolerable risk at the expense of the public and the economy.
Such over-regulation causes wasteful expenditure to suppliers and deprives the consumers of affordable cost-effective products.
Manufacturers and suppliers, who hold the ultimate responsibility for distributing safe products, are driven to employ risk assessment procedures during both product development and engineering changes.
This is done to uphold ongoing product safety by conducting thorough root cause analyses of customer complaints and internal test outcomes. The accumulation of this valuable information further reinforces the commitment to maintaining product safety and performance over time.
Safehouse remains committed to promoting electrical safety awareness and public education.
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