18 November 1998Pollution Prevention Planning, Inc. 1 Fire Protection Risk Management “A DoD...

18 November 1998 Pollution Prevention Planning, Inc.

1

Fire Protection

Risk Management“A DoD Program Manager’s Perspective”

Carmen DiGiandomenico

Pollution Prevention Planning, Inc.

2185 Harpoon Drive

Stafford, Virginia 22552

(540) 659-5077


2

OUTLINE

• Purpose

• Organizations & Functions

• Decision-making Process

• Summary


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PURPOSE

• Help you understand how DoD Program Managers (PMs) conduct fire protection risk management by providing:

– An organizational & functional overview

– Approaches to fire protection risk management

– Insight into differences among services


4

ORGANIZATIONS &

FUNCTIONS


5

Organizational OverviewE

xternal R

egu

lators &

Gen

eral Acco

un

ting

Office

Laboratories

Systems & Materiel Commands

Program Manager (PM) Offices

Operational Organizations

Depot/Repair Organizations

Inte

rnal

Reg

ula

tors

, In

spec

tors

Gen

eral

& A

dvi

sors


6

Internal Regulators - USD(A&T)• DoD Regulation 5000.2-R - All PMs must:

– Integrate environmental, safety, & health (ESH) issues into the systems engineering process

– Develop a system safety & health program that:• manages risks from

- death - injury

- acute/chronic illness - disability

- reduced job performance

• covers personnel involved with the system who- produce - test

- operate - maintain

- provide support

– ESH decisions based on lowest life cycle cost to protect human life and the environment


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Internal Inspectors General• DoD & each service

• Audit & review compliance to regulations

• Conduct investigations into – Fraud, Waste & Abuse

• Examples of reports:– HazWaste Minimization

• 80% of DoD’s HazWastes come from weapon systems

– Comanche (RAH-66) • $18B-$30B in HAZMAT-related life cycle costs


8

“Internal” Advisory Boards• DoD & service independent Science Boards

• Examples of reports:

– Defense Science Board Report on Aviation Safety • Decline in DoD accident rate has leveled off

• Programs address basic causes only to a limited extent

• Life Cycle Cost of accidents is rarely addressed

– Naval Studies Board (NRC/Academy of Science)• Halon replacement efforts are being studied effectively, the

body of knowledge is being developed & no gaps in the effort

• Unlikely a drop-in replacement will be discovered

• Effective alternatives have been identified & are being incorporated in new ships & aircraft

• Promising agents, in addition to chemical replacement agents, are being considered (e.g., water-mist & inert gas generators)


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External Regulators• Environmental Protection Agency

– Clean Air Act (CAA)• Section 612(c) prohibits replacing Class I & II substances w/substitutes that

may present adverse effects to human health & the environment

– Significant New Alternatives Policy (SNAP)• Requires toxicity data (e.g., cardiotoxicity study in dogs) • EPA defers to OSHA for regulating workplace safety • EPA expects users to conduct thorough technical investigations • Acceptability not to be construed as endorsement of any given fire or

explosion scenario - users should consult fire protection specialists

– National Environmental Policy Act (NEPA)• Federal agencies (e.g., EPA, DoD, FAA) must consider the impact of policies

& actions on the human environment as a part of their decision-making process

• Occupational Safety & Health Administration– Occupational Safety & Health Standards (29 CFR 1910)

• 29 CFR 1910.162 governs use of all gaseous agents in fixed extinguishing systems


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General Accounting Office (GAO)• Congressional investigative office

• Audits & reviews federal agencies

• Example of reports:– Best Practices

• Commercial firms gain more knowledge of a product’s technology, performance, & producibility much earlier in the product development than DoD

• DoD increases risks by allowing more technology development to continue into product development


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Laboratories• Basic & applied research

– Typically non-system specific

• Examples:– US Air Force Research Laboratory (AFRL)

• Performance evaluation tests• Toxicity tests

– US Army Center for Health Promotion & Preventative Medicine (CHPPM)

• Toxicity Profiles

• Health Hazards Analyses

– US Naval Research Laboratory (NRL)• Performance evaluation tests


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System & Materiel Commands• Provide PMs with engineering infrastructure

• Examples– Air Force Materiel Command

• Product Centers• Eliminated Fire Protection Office in early 1990s• Process Action Committees (PACs) concluded Air Force

lacked sufficient infrastructure support

– Naval Air Systems Command• Naval Air Warfare Centers

– Army Materiel Command• Major Subordinate Commands


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Program Managers (PMs)• Responsible for all aspects of program

– Cost– Schedule – Performance

• Operational requirements (e.g., survivability)• Technical requirements (e.g., ESH integration)

• Develop & control maintenance procedures

• Decide on system fire protection– Passive (e.g., isolate hot surfaces, quick shut-off)– Active (e.g., agent, distribution, detectors)


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Operational Organizations

• Establish operational requirements for PMs

• Primary input for funding prioritization

• Conduct “day-to-day” maintenance

• Include “Users” of weapon systems, e.g., – Air Force User Major Commands– Army - User Major Commands– Navy - Fleet Commanders in Chief


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Depot/Repair Organizations

• Conduct major overhauls, rebuilds, & repairs

• Follow PMs’ maintenance procedures

• Include:– Air Force Logistic Centers– Naval/Marine Corps Air Rework Facilities– Army Depots


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Decision-making Process


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How Do PMs Make Decisions? • “Risk Management” decisions based on available

data that are:– Accurate

• Based on accepted technical & management standards – Complete

• Balanced across all critical parameters• Systems engineering (“holistic”) solutions

– Objective• Provided/reviewed by “honest brokers” (e.g., input from

agencies who have no vested interest in the outcome of the decision)

• PMs place trust in agencies who provide data that are accurate, complete, & objective


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Accepted Technical Standards• Data based on universally accepted

standards, e.g., – Fire suppression

• NFPA

– Materials Compatibility• ASTM, NIST

– Toxicity & Exposure • AMES Screening• DuPont, et. al. Cardiac Sensitization• OSHA Standards


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Accepted Management Standards • MIL-STD-882C “System Safety Program”

– Accepted by both industry & government– Proven & used by services in managing ESH risks– For system hazards, requires all PMs to:

• Identify in terms of their specific system

• Assess in severity and probability of occurrence

• Categorize in terms of high, medium/serious, and low

• Prioritize in terms of importance & mitigation effectiveness

• Mitigate in terms of how and when

• Obtain acceptance in terms of the correct level of authority


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HIGH

LOW HIGH

SE

VE

RIT

Y O

F A

N O

CC

UR

RE

NC

E

PROBABILITY OF AN OCCURRENCE

These don’t happenoften and when theydo, they’re not bad.They don’t pass the“so-what” test!

These don’t happentoo often but whenthey do, they’re bad.FIX THESE.

These happen oftenbut when they do,they’re not too bad.FIX THESE.

These happen oftenand they’re alwaysbad. FIX THESE.

System Risk Management Analysis


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Risk Management AnalysisComparison of Two Agents During Accidental Discharges

HIGH

LOW HIGH

SE

VE

RIT

Y O

F A

N O

CC

UR

RE

NC

E(

chem

ical

& e

xpo

sure

rel

ated

)

PROBABILITY OF AN OCCURRENCE(system related)

B2 B1

A1A2A2-Exposure > Cardiac Sensitization & Infrequent Accidental Discharges

B1-Exposure < Cardiac Sensitization but > permanent lung damage & Frequent Accidental Discharges

B2-Exposure < Cardiac Sensitization and > permanent lung damage & Infrequent Accidental Discharges

A1-Exposure > Cardiac Sensitization & Frequent Accidental Discharges


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Critical Parameters

• Identified by PMs

• Varies from system to system based on requirements

• Must include life cycle issues

• A common list has been developed by Army

• Common list effectively used by PMs in other services


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Critical Parameters Common List

• Class A Effectiveness• Class B Effectiveness• Class C Effectiveness• Class D Effectiveness• Complete Volume Fill• Quick Response Time• Persistence • Cooling Effect• Throwing Characteristics• Neat Agent Health Effects• Pyrolysis Health Effects• Visual Acuity• Clean Agent• Shelf Life

• Stability in Bottle• Environmental Impact of Production• Environmental Impact of Neat Agent• Environmental Impact of Pyrolysis Products• Electrically non-conductive• Neat Agent Compatibility w/Protected System• Pyrolysis Products Compatibility w/Protected System• Neat Agent Compatibility w/Fire Suppression System• Availability of a Viable Production Base• Refill Capability • Handling, Transportation, Maintenance Impacts• Testing Hardware Availability• Space & weight Impacts• Costs


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Systems Engineering Approach

• Seeks “holistic” solution• Avoids “drop-in” euphoria• Involves much more than “chemists”• Considers all practical aspects

– Passive as well as active techniques– Agent effectiveness– Distribution aspects– Detection sensitivity/reliability


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Objective Information

• PMs don’t like being given “half-truths”

• PMs rely on internal “honest brokers”

• PMs are inundated with “sales pitches”

• PMs are wary of “drop-in” solutions


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Summary• PMs

– Are key to system-related fire protection decisions within DoD

– Respond to Military Operators’ requirements

– Attempt to make informed “risk management” decisions

– Approach issues from a systems engineering perspective

– Rely on accurate, complete, & objective data

– Use accepted standards

– Don’t like “surprises”

• Researchers can be most effective when they– Understand the system(s) that their technology/agent may support

– Understand PM’s “risk management” decision process

– Understand the life cycle issues involved with their technology

– Provide accurate, complete, & objective data early in process

18 November 1998Pollution Prevention Planning, Inc. 1 Fire Protection Risk Management “A DoD...

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