Journal of System Safety article for 1st qtr 2011

Once again I find myself sitting at my computer to compose TBD only to realize that I have forgotten the topic that sprang to mind a few weeks ago.  I guess I need to sit down and write them when that happens, rather then waiting for them to mature before setting them to print.  Luckily, I ran into an interesting topic while having a cup of tea with my morning Buddhist meditation group.  I belong to a small group of people in Davis, California (home of the University of California, Davis) who sit together from 6:00 am to 7:00 am.  We then go to a little restaurant for a cup of tea and a little chat.  Since it is a university town, several members of the group are PhD students studying various sciences, including the life sciences (microbiology, stem cell research and similar topics).  This background leads our discussions off on some pretty wild, and interesting, tangents.

Yesterday one of them brought up that she had used me, and my work, as an example in a microbiology presentation.  She kind of giggled and suggested that our work (system safety) is similar to the work of something called “micro-RNA” within cells.  Apparently a couple of them in our little group of scientists have been referring to me as “the” micro-RNA!)

She went on to explain that these micro-RNA things are a newly discovered part of the cell.  They are different from most of the rest of the RNA because they don’t really “do” anything.  The DNA is used as a template to make RNA, which in turn makes many other elements of the cell that do the work – most of the RNA particles manufacture the proteins that are required to make the cell work, but they do so rather blindly.  Apparently the RNA gets turned on to produce a product or chemical, without much control.   Basically, they just start turning out various types of protein.   

The micro-RNA things act as a kind of safety engineer.  They monitor the amounts and rates of activities from the “doing” parts and adjust them by telling them to stop, to create other materials, to speed up or slow down – basically they are the “system” guys, looking after the overall health and safety of the cell – while allowing the other parts of the cell to make all that is needed for life.   If they fail to work properly, many bad things can happen, including illness, cancer or cell death (or death of the entire organism!).  Hence, they are the system safety engineers of the cell world in that they make sure that the cell manufacturing elements don’t produce dangerous or toxic products.

She said that it is turning out that this kind of activity is extremely common in nature at the cell level.  The doers just get to doing, but need subtle control to do so safely and effectively.  Hence her analogy of our role as the micro-RNA of the industrial world.  Apparently this approach of some elements being focused on doing things and making things as fast and furiously as possible extends to the macro-world in the projects that we are working on.

I found this to be kind of humorous, but also enlightening because it gave me a slightly different perspective on our role within a product development team.  Over the years, I have noticed a definite lack of respect for the importance of our work by not only the rest of the team, but as a feeling of “self-worth” by the system safety engineer as well.  There is a feeling that the value is to be had in being creative in the design. If you don’t design something, then you are just an added cost.

The problem that I have observed is a desire by the system safety professional to “do something.”  They want to get involved in the process of creation rather than “merely” being regulators.  The problem with this is two fold.  First, they tend to become vested in their own design ideas – breaking their position of independence which is so critical to their effectiveness in identifying problems and recognizing good solutions.  The second problem is that the attempt to create “good” design ideas tends to create conflicts with the design team – causing jealousy and a barrier between the safety engineer and the design team.  The design team usually doesn’t want to share the glory with others.

 I rather like the analogy of our work to that of the micro-RNA.  We don’t actually “do” much in that we don’t design or build anything.  However, without a process such as ours to guide and control the process, the designers are not likely to be successful or the final product safe to make or use.  The work of the system safety engineer is necessary to achieve success of the enterprise – just as the work of the micro-RNA is necessary for the success of the cell and ultimately of life.  Of course, in many situations that work is performed informally by the designers themselves either by following existing codes and standards, or by using “common sense.”

The problems with the use of these informal approaches are many, not the least of which are that the existing standards usually do not completely cover the scope of the potential hazards and are therefore incomplete, the fact that “common sense” doesn’t seem to be all that common.  An additional problem is the fact that the designers are influenced by the same type of vested interest as mentioned above.  They become “blind” to glaring safety problems in their designs.

I have always found it to be most satisfactory (and satisfying) to keep my role as an assistant in mind while working on a project.  I am there to assist in the identification of potential hazards and potential types of solutions.  However, it is not my place to actually do the designing.  Of course, sometimes I make suggestions about design solutions if I happen to know of them, realizing that I am treading on thin ice when I do so.  I find it best to make sure that others actually do the design, and I provide“behind the scenes” assistance – leading them to a better and safer design, but not doing the designing for them.  I freely give my knowledge to the designers to help them to be successful and do not take credit for the design.  I make sure that they maintain ownership and credit for the design.   That approach prevents the formation of jealousy and other problems where my knowledge is not sought after.  As far as I am concerned, they can do the designing and get the glory – I get to do the extremely important work of directing the design toward a safe solution.     

IPod Risks

I was driving home yesterday listening to Pete Wilson on KGO.  He was talking about a lawsuit that somewhere in the country concerning the IPOD devices.  Apparently, the lawsuit claims that the IPOD is “defective” because it allows the user to adjust the volume to 115 db – which is high enough to cause permanent degradation of hearing after something like38 seconds.  
Mr. Wilson’s position, which was agreed to by all of the callers, is that this is a frivolous lawsuit and that it is not the place of the legal system to protect people from themselves.  His point is that the device has a volume control and you can always turn the volume down and not damage your hearing.  He used a number of examples of his thesis such as the ability of some cars to go 150 miles per hour, the extremely load volume used at rock concerts, and the volume control on your car radio (actually I don’t think my car radio can get close to 115 db).  
He made an interesting point that for sales to France, Apple has elected to limit the maximum volume to 100 db.  He also pointed out that as a news person he has worn very loud earphones for so many years that it has damaged his hearing, and that this was his choice and therefore somehow acceptable.
I find all of this to be interesting.  First off, if his employer has been providing him with earphones that have caused permanent hearing damage, they have been breaking the law because OSHA prohibits exposure to noise levels that will result in such injuries.  Actually, my guess is that he is getting older and probably was exposed to excessive noise levels in other ways – but he might be correct, his employer might well have been breaking the law.
My guess the reason that Apple limits the noise levels for sales to France is that they are complying with the European Union law which protects people from excessive risks from products.  The United States doesn’t seem to think this is very important and has very few laws or regulations designed to protect people from injury from products.  The recourse in the USA is to sue the manufacturer, rather than implement safety requirements as part of our law.  We end up having a lot of excessively dangerous products until enough people have been injured, or killed, to make a lawsuit worthwhile.  Personally, I consider this to be a barbaric approach to product safety, but that is the way that it is.  Luckily for us, the European Union is influencing many products on a global scale and we all get additional protection.
Now to the specific issue of whether or not the IPOD is “defective” because of excessive noise levels.  I can’t really say one way or another because that is a legal term that can only be decided in court.  However, it is my personal opinion that it is defective.  My reasoning includes (but is not limited to) the ideas that the manufacturer knows that many of the users will be children, and that children do not necessarily have the ability to make decisions that protect their future health – especially if there is no means available for determining that harm is being done.  Parents can’t effective monitor the noise levels being used by their children because the noise is personal in nature, it fills the ear but not the room.  From a few feet away the noise is not detectable even if it is turned up full blast.   Even if parents happen to discover that they are playing the thing too loud, they can only monitor while the child is in the area – once the kid is away from the parent they can, and do, turn the volume up to full blast.  Apple knows this, and knows (or should know) that many children and young people play the device at, or near, full volume most of the time.
There are warnings to not play the device too loud for too long, but there is no way for a person to know what that means.  There is no indication that the volume is too loud and dangerous.  In fact, there is no immediate way for a person to know that they have damaged their hearing.  It takes time, and tests, to determine that one’s hearing has degraded.  It is one of those things that sneaks up on you without warning.
So, as it stands millions of young people are potentially exposed to sound levels that are known to cause permanent, and serious, hearing damage.  There is no means available for those persons to know the extent of the injuries, or the extent of the risk that they are exposing themselves to.  The manufacturer knows all about this, but has elected to take the position that it is better to enhance sales and injury millions of people than to back off a bit and injure none.  It appears to be a sales decision, one that is good for them but bad for their customers.
By the way, it isn’t just Apple that is doing this kind of thing, there are other personal music systems (using hear phones) that are every bit as dangerous as the IPOD.  It seems to be the norm in the industry to take the position of “let the buyer beware,” but that doesn’t make it right.  
Oh yes, I almost forgot to address the issue of the fast cars.  It turns out that we do not assume that it is alright for people to drive as fast as they want and take whatever risks they want.  We have lots of laws that limit speeds to what is considered “safe enough.”  Speeding is not okay, and is actively regulated throughout the country.  I personally think building cars that are capable of 150 mph is crazy since there is no place to legally drive them except on a race track.  Race tracks are an entirely different issue, and in fact are heavily regulated themselves, including special vehicle designs, special driver training, and self-regulations by the industry.  Building a fast car in an environment where speed is highly regulated and the risks are relatively easy to judge is not at all the same thing as handing a dangerous device to a child and hoping that they don’t harm themselves – especially when neither the child nor the supervising parent can determine what is risky and what is not.