Safety Strategies For Emerging Technologies At Work
Introducing an emerging technology into the work environment can be challenging from a health & safety perspective. This is due to the presence of new risks and lagging government regulations surrounding them. In this article we outline a process organisations can adopt to ensure they protect workers exposed to new technologies, while demonstrating due-diligence in the face of legislative uncertainty.
Today’s workplaces are undergoing fundamental change due to the rapid adoption of emergent technologies. Because of the complexity of the emerging technology process, there is a gap in the organisations ability to recognise harmful risks in the early stages of adoption.
The sheer speed and depth of technological advancement has led to an ongoing situation where governments cannot produce legislation fast enough for the labour market
For the risk assessor this has created a shift away from retrospective analysis of probable risks to prospective analysis of unknown risks. As the digital revolution advances more and more organisations are being forced to create prospective risk management strategies for adopting products and systems driven by industry 4.0 technologies.
Safety Strategy For Adopting New Technologies
The following steps set out a foundation for identifying, discovering, and managing hazards relating to new products and technologies. This strategy can be initiated before or after procurement:
1. Create a multidisciplinary team
From the start of the process it is advisable that a multidisciplinary team is convened to discuss various requirements. The involvement of different in-house departments ensures that both building and organisational needs are factored into costs, and the suitability of the technology for that organisation. Initial discussions may take the form of brainstorming exercises and other exploratory methods. Useful tip: first establish whether the product is indeed an emerging technology
2. Consult reliable resources
There is a high likelihood that research information already exists from regulatory bodies on the technology. Governments will have begun the initial stages of creating legislation at the request of the labour market. In the absence of formal risk information within a jurisdiction it is advisable to seek guidance from countries within that global region. Reliable sources include:
- The National Institute for Occupational Safety and Health (NIOSH), United States
- Canadian Centre for Occupational Health & Safety (CCOHS), Canada
- Occupational Safety & Health Administration (OSHA), United States
- European Agency for Safety & Health at Work (EU-OSHA), Europe
- Health & Safety Executive UK (HSE), Britain
3. Identify and challenge knowledge gaps
Whether it be a Material Safety Data Sheet (MSDS) or an Operators Manual the product manufacturer has a duty to provide safety information on the health & safety risks associated with the product itself. It is important to note that the manufacturer’s main objective is sell their product and they will rarely volunteer detailed information on workplace or training requirements required to manage lifecycle risks. It is at this point that the assessor needs to question the depth of information being provided by the manufacturer and identify any gaps or uncertainties within. Useful tip: pre-procurement is the optimal time to approach the manufacturer for further information on risks.
4. Categorise collected information
All accrued risk information on the product should be categorised based on the level of information available at that time. These categories should include:
Known Knowns – These are familiar risks. It is clearly understood what the hazards are, what can go wrong, and how the risks can be controlled. This level of certainty is usually attributed to established regulations and guidance.
Known Unknowns – These are gaps in information where the risk is known but clear details on the harmful effects are not. An example would include an Occupational Exposure Limits (OEL) for a new substance. If an OEL has not been established for a substance it is difficult to select effective control measures to mitigate the risks presented.
Unknown Unknowns – Many emerging technologies have unintended consequences and some have the potential to be catastrophic. These types of hidden or “latent risks” present themselves after the product has been released into the labour market. Past examples of unknown unknown risks include tobacco, DDT, and asbestos. All three were available to consumer and industrial markets long before the health effects were formally recognised.
Useful tip: consult with local academic institutions to identify relevant subject-matter experts in the region.
5. Establish compliance status
When it comes to emerging technologies it is best not to depend on legislation when exercising due-diligence. Organisations should instead addressing the legislative status for components of the technology under the following headings:
Legislation exists – identify standards and regulations that relate to the technology, or parts of the technology. Examples include electrical standards, conformity markings, and machinery standards.
No legislation – identify standards and regulations that do not exist for the technology. Examples may include OELs, fire standards, and training requirements.
Legislation pending – acknowledge where regulations and standards that are in the process of being created for the technology. It is important to record when these statutes are due for enactment.
6. Develop an iterative risk assessment
While alternative processes exist a risk assessment is the most accepted framework for systematically analysing and presenting accrued health & safety information. An iterative type assessment allows the assessor to integrate new information into the risk management process throughout its lifecycle . New information may include updated regulations, software updates, and incidents recorded on the “factory floor”. This process forces the risk assessor to adapt and bolster risk controls based on the most up-to-date information.
Selected control measures must always err on the side of caution and should overcompensate as long as gaps in risk information exist
The effectiveness of an iterative risk assessment is heavily dependant on operator and user feedback. Involving technology users in the risk management process not only ensures access to hands-on knowledge but also ensures that the occupational risks are transparent to the worker. This is key to the feedback loop and subsequent adjustments to the risk management strategy. Useful tip: addressing compliance aspects within the risk assessment ensures that recently enacted regulations are not overlooked.
7. Learning throughout the lifecycle
Ongoing surveillance throughout the technologies lifecycle is needed to identify emergent risks. Collecting and reviewing information each quarter may signal new hazards which will initiate timely course-corrections. These changes may come about on foot of measurement, testing, formal observations, health surveillance, and feedback from users.
Because the potential for latent risks is always present employers must continually prompt the question during the review process; have any health or safety concerns arisen since the introduction of this technology? In this context assessors should give attention to near-miss incidents, ill-health, absenteeism and up-to-date information from the manufacturer and legislators. Feedback on new hazards not only applies to the employee management dynamic, but also from the customer back to the manufacturer. Customer feedback enables the manufacturer design team to eliminate inherent risks in future upgrades to the technology.
Garry McGauran is author and editor at Emerging Tech Safety. He has 17 years experience as a prototype risk assessor, design safety consultant and academic research advisor, as well as heading up his own drone inspection service. He is a freelance safety consultant serving the tech and utility sectors in Ireland and the UK.
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