Product Safety Management
Ten Principles of Safety Management
- Establish and observe a written corporate safety policy.
- Create an independent safety review process.
- Identify and evaluate the severity and foreseeability of product hazards.
- Conduct a design review assessing the risk of injury by considering the hazards, the environment, and foreseeable use.
- First attempt to eliminate hazards. If not possible, then reduce the opportunity for injury by guarding against the hazards.
- Warn users of product dangers and motivate them to avoid injury.
- Promote only the safe use of a product.
- Maintain safety-related records during the useful life of the product.
- Continuously monitor safety performance of the product in the hands of users.
- Promptly notify product users and institute recall procedures where necessary to substantially reduce or eliminate injury.
Kitzes, Wm. F., "Safety Management and the Consumer Product Safety Commission" in Professional Safety, American Society of Safety Engineers, April 1991.
1. Establish and observe a written corporate safety policy.
A written corporate safety policy is the ultimate responsibility of top management. The document is designed to detail executive commitment, both statutory and voluntary, to the concept of system safety; a before-the-fact management system designed to insure the production and distribution of reasonably safe products. Oral direction such as "safety is everyone's responsibility" provides inadequate instructions to the organization. The policy must describe management commitment to clear identification of the responsible corporate units for the tasks of hazard identification, risk assessment and injury control. The primary goal of a written safety policy is the creation of a management system to substantially reduce of eliminate injury to consumers.
2. Create an independent safety review process.
The independence of the safety function within the management structure is crucial to successful analysis of potential product dangers. Corporate Safety Director is an advisory role, with authority to interact with technical functions such as product design, engineering, epidemiology, human factors, communications and legal. The safety manager must be able to order safety-related analyses by the various technical divisions and have the authority to integrate the results for presentation directly to top management for decisions on injury control. It is critical that the safety management office be independent of production and distribution. Giving a production manager primary responsibility for safety will divide his or her loyalties and compromise injury control before management review. The safety director often will preside over a safety review board is compromised of members from the technical divisions.
3. Identify and evaluate the severity and foreseeability of product hazards.
A hazard is the inherent capability of a product to do harm. It is most often the result of an energy transfer or release, with such transfer creating impact to the product user. Appropriate analysis must include a focus on whether the hazard is latent to the user while foreseeable to the producer and the impact on certain vulnerable population groups. The vast majority of homeowners in rural areas do not understand that pilot outage in an LP gas water heater can create dangerous conditions when the safety valve fails to operate. Turning on a light bulb or attempting to relight the pilot can create a catastrophic explosion. Some hay balers can entangle a farmer's arm faster than they can let go of a piece of string caught in the feed rollers. Children cannot recognize strangulation hazards in and around cribs. Manufacturers and distributors must proceed with extra caution where the hazard is not immediately apparent to the user.
4. Conduct a design review assessing the risk of injury by considering the hazards, the environment, and foreseeable use.
A risk of injury is the opportunity for a specific set of conditions to create harm: Under what circumstances can the user be injured? An examination of the identified hazards, the environment in which it is intended to be used and foreseeable use and misuse of the product by the user population must be considered. An all terrain vehicle, or ATV, can be an inherently unstable 300-pound machine that can throw a rider. Crushing injuries can occur in addition to the impact by overturning. ATVs are intended to be used in uncontrolled, wilderness environments, such as mountainous paths, sand dunes and over obstacles. By creating a recreational, sometimes uninhibited setting, ATV riders can foreseeable use the product by going fast, racing with friends, or even by partaking in alcoholic beverages. While not always appropriate behavior to a safety analyst, it is foreseeable that these situations will occur and must be considered to effect reasonable safeguards to prevent injury.
5. First attempt to eliminate hazards. If not possible, then reduce the opportunity for injury by guarding against the hazards.
By eliminating a specific hazard, certain injury cannot occur. For many years cribs were designed with finials, or cornerposts, extending above the top edge of the crib. Children would become entangled on the finials through clothing or other articles and strangle. Redesigning the crib with a smooth top edge with no protrusions eliminates the danger. But in other cases this is often not possible. Gasoline creates toxic and explosive fumes. It is not possible to eliminate them without destroying its usefulness. Gasoline can however, be stored in an appropriate canister to prevent the fumes from leaking into a water heater closet in the garage causing an explosion and severe burn injuries. A power mower employs a steel blade rotating at over 200 mph, but lawn mowers can incorporate devices to shut down the blade when the operator releases the controls and can shield user access to the rotating blades.
6. Warn users of product dangers and motivate them to avoid injury.
In addition to elimination of hazards, product warnings and instructions must assist the user to avoid dangers, including those that remain after thorough attempts to eliminate or guard. An explicit warning including a signal word, statement of the hazard, appropriate behavior and a description of the consequences of the danger are required. A pictogram illustrating the consequences is often needed to communicate the danger, especially to those who cannot read the words. This communication of the consequences is particularly important in motivating the user to avoid the danger. Ten years ago, the CPSC required a warning on certain power lawn mowers signaling Danger, to keep hands and feet away from the mower, and included a pictogram depicting a blade cutting a hand. A warning not to go in the kitchen without knowing why may be quickly disobeyed. Informing the chef not to enter the kitchen because of a fire spreading from the oven will often cause him or her to go elsewhere to eat.
7. Promote only the safe use of a product.
Advertising and product promotion sometimes subtly and deceptively promote consumer misuse. Motorcycles promoting speeds up to 150 mph certainly encourage users to go fast, if not to the limit. Some chain saw manufacturers for years promoted the "macho" image to outdoorsmen. When they began distributing smaller, homeowner saws to the general population, injuries more than doubled. In the early years of sales, ATVs were advertised as safe, family fun. Print advertisements said the ATVs could traverse "an astonishing array of terrain", over "rocks, boulders and fallen logs" and "where some animals can't go." Small, instantly removed disclaimers are insufficient to warn users of the dangers of actions depicted in advertisements. Positive statements providing safe use instructions with sufficeint frequency to influence behavior is necessary to reinforce safe activity.
8. Maintain safety-related records during the useful life of the product.
An effective product safety system requires records in sufficient detail to allow for timely detection of safety hazards and trends, and for tracing product defects in assembly, components and overall design. Records necessary to provide sufficient data for management decisions include safety-related product changes, test results, consumer complaints, product liability lawsuits, location of products within the distribution chain, government injury data, and engineering reports. An integral part of the corporate safety policy is establishment of a system of records and a directive concerning retention of those documents. A document destruction policy of three years concerning a product with a useful life of seven years deprives the organization for the opportunity to protect product users from danger.
9. Continuously monitor the safety performance of the product in the hands of users.
Once a manufacturer/distributor has concluded that a product is reasonably safe based on pre-production review and analysis, the product is ready for distribution to users. Feedback from product users is critical to determining whether subsequent corrective action is necessary. Government injury data such as the National Electronic Injury Surveillance System (NEISS) is a primary resource for management safety data. A major producer of furnace valves distributed approximately 15,000 valves to furnace manufacturers. Reports from the field indicated the seals were not properly chlorinated, thus allowing the gasket to tear and leak gas. The company notified the Consumer Product Safety Commission under section 15(b) that the product possibly "contained a defect which could create a substantial product hazard". An appropriate corrective action plan including the recall of the valve and notification to consumers was taken to protect consumers from the dangers of gas explosions.
10. Promptly notify product users and institute recall procedures where necessary to substantially reduce or eliminate injury.
Upon discovery of a product hazard after distribution to the public, immediate notification of the danger and quick steps to protect users from injury are critical. Time is of the essence. Knowledgeable product users can help reduce both injuries and claims. Efficient recall procedures can remove hazardous products from the stream of commerce. A number of years ago a major producer and distributor of telephones in the United States discovered that the transformers used to power the lighted dial on certain phones would catch fire. Four incidents of minor property damage were reported. Although no injuries were reported, the company embarked on a major notification and recall campaign which included "bill stuffers" to tens of millions of consumers of the fire damage and offered a free replacement, along with compensation for damage caused by the transformer. Few additional incidents were reported.