Electrical Product Safety in Ontario Risk Assessment Methodology

Transcription

1 Electrical Product Safety in Ontario Risk Assessment Methodology presented on behalf of Working Group 1 Peter Jackson CA, ORMP peter.jackson@riskwaves.com

2 WG purpose To develop draft guidelines for the consideration of ESA concerning a risk assessment methodology to be used in complying with the requirements under Part VIII of the Electricity Act, 1998 and the Product Safety Regulations for reporting and responding to serious electrical accidents, incidents and defects 2

3 WG 1 members & participants Daniel Tiburcio, Safe Kids Canada Derwyn Reuber, Intertek Testing Services NA Inc. Ed Gulbinas, Office of the Fire Marshal Jeffrey Troutt, U.S. Attorney Joseph Neu, Electro Federation Canada Mark Chmielewski, Canadian Tire Corp Mel Fruitman, Consumers Association of Canada Michael Ng, Office of the Fire Marshal Nancy Chambers, Sears Canada Inc Neeraj Gupta, HBC Nick Maalouf, QPS Evaluation Services Paul Schlote, Canadian Standards Association Robert Pollock, Underwriters Laboratories Inc (alt Dan Ackerman) Ron Bergeron, Bergeron Electric Whipple Steinkrauss, Consumers Council of Canada Maria Iafano, Ted Olechna, Steve Smith, ESA 3

4 The Guideline (draft of December 17) Part 1 reporting thresholds Based on severity of actual impacts Based on potential to cause death, injury or damage Part 2 ESA case prioritization methodology Guides response strategy and urgency Applies to uncertified/unapproved; counterfeit; certified/approved but unsafe Four steps: Understand defect Assess severity of potential impact Assess likelihood of potential impact Make a priority rating 4

5 Reporting thresholds actual harm A death Injury requiring hospitalization or professional medical treatment Flame or fire outside the product 5

6 Reporting thresholds potential harm Flame or fire outside the product Failing (as a product or a component in the product) to perform its primary safety and/or protective function (e.g. smoke detector, CO detector) Overheating causing actual or potential property damage Causing actual or potential personal injury or electrical shock Are you aware of other similar incidents involving the product that may be a warning sign of more serious problems? 6

7 Definitions Accident Incident Defect An event that results in death, injury or property damage An event that could have resulted in death, injury or property damage A fault, flaw or irregularity that causes weakness, failure, or inadequacy in form or function 7

8 Issues Defining the thresholds for actual harm Drawing the lines on injury and property damage Defining the thresholds for potential harm By nature of incident or defect Addressing trends in small incidents Getting to grips with forseeable use 8

9 Forseeable use (WIP) Consumers may use a product for purposes other than those for which the product is intended, even though usage instructions are clearly understandable and even though they contain warnings against unintended use. Consideration must therefore be given to whether foreseeable use is likely to affect the safety of any person or cause damage to property. 9

10 Forseeable use (continued) Forseeable use (whether reasonable or unreasonable or somewhere in between) has a greater likelihood of affecting the safety of a person or cause property damage in cases such as the following; Dangerous use is invited Users are not equipped to use the product safely There is a trend of unsafe behaviour. 10

11 ESA Case Prioritization Methodology Guides response strategy and urgency Based on rating of Priority 1, 2 or 3 Rating based on severity of future harm and its likelihood Applies to uncertified/unapproved; counterfeit; certified/approved but unsafe Responses differ accordingly 11

12 Making the ratings The risk rating is arrived at by plotting where the risk falls on the following table. The likelihood of injury or damage is plotted against the vertical axis, and the severity of impact on the horizontal axis. Likelihood of Injury or Damage Very High High Medium Low Very low Severity of impact Insignificant Minor Moderate Major Priority 1 Priority 2 Priority 3 12

13 Assessing severity of potential impact Loss Severity Impact on People Impact on Property Major Death, need for permanent life support, permanent impairment of a body function, permanent damage to a body structure, chronic health effect or long term psychological trauma. Loss attributed to flame emitted from product, or failure to contain an ignition source or hazardous material. Partial or total loss of contents accompanied by structural damage to or total loss of building. Moderate Minor Recoverable injury requiring hospitalization or professional medical treatment. Recoverable injury requiring only first-aid treatment. Loss attributed to flame emitted from product, or failure to contain an ignition source or hazardous material. Partial loss to contents without structural damage to building. Superficial damage to building and contents e.g. smoke 1 and / or heat emitted from product causing discolouration of adjacent surface or material but without ignition. No evidence that flame, a potential ignition source or hazardous material escapes from product. Insignificant Startle reaction or momentary fright without physical injury. Product fails without external consequence. No evidence that flame, a potential ignition source or hazardous material escapes from product. Note 1: Smoke emitted from product in sufficient volume to threaten life is covered by the Impact on People column. 13

14 Assessing likelihood 14

15 Estimating the likelihood of defect 15

16 Estimating likelihood of serious negative effect 16

17 Issues Understanding the ESA context: Many reports Little information Need to prioritize The judgments involved in the prioritization process 17

18 Issues and recommendations foreseeable use material is a work in process; ESA should consider what consideration should be given, as part of considering foreseeable use, to usage of products by users unable to read warnings or instructions critical to safe use because of language; ESA should review the ratings matrix (in section 15 of the draft) in light of past and future experience and adjust as appropriate (this is seen as an important element of the ongoing review of the Guideline during the first year of application). 18

19 Questions? Comments? 19