To: John Mansfield who wrote (9702 ) 1/29/1998 2:25:00 AM From: John Mansfield Respond to of 31646
UK Health and Safety Executive (HSE) hsebooks.co.uk (follow up post): '<snip> The effect on safety In most engineering , production and manufacturing environments, a variety of systems are used to plan, measure, store information, control processes and to keep them safe. These systems are often referred to as 'real time' systems because data (events) are processed as they occur, the results being available immediately. Quite often such systems are linked together by communications networks which means that information is shared and used for different purposes. When such information is both time or date-dependent and important for the safe operation of a process or machine, then safety becomes an issue at year 2000. Also, the correct operation of a safety system which is itself resilient to the 'Year 2000 Problem' may still be affected by the failure of a subsidiary system to which it is linked. The unpalatable fact is that the 'Year 2000 Problem' is a failure which is potentially common to all systems. In the jargon of the control systems world, this is known as a 'common cause' failure, ie it can cause the simultaneous failure of more than one system. In the case of year 2000, the potential exists for a very great many systems to fail at the same time. In summary, the nature of the 'Year 2000 Problem' means that any programmable electronic system within a linked chain of processes may fail and so could affect any safety-related arrangements. Equipment containing embedded systems may fail or give incorrect information. The results of calculations may be erroneous and operators may take inappropriate action, or other dependent safety-related control circuits may respond inappropriately. What can you do now Complete the steps in the decision tree adjacent; the result will indicate the options open to you. Safety at Work and the Law <Picture>Suppliers, employers, the self-employed and consultants have legal obligations. These are set out in general terms in the Health and Safety at Work etc Act 1974 (HSWA) and the Supply of Machinery (Safety) Regulations 1992 as amended. Specific legislation, relating to control systems is contained in the Provision and Use of Work Equipment Regulations 1992 (PUWER). Regulation 5 requires that work equipment must be suitable, by design, construction or adaptation, for its intended purpose. Regulation 18 requires that employers ensure, so far as is reasonably practicable, that the operation of a control system does not pose any additional risk to health or safety. Any hazardous event which may result form a date discontinuity problem in a safety-related control system may therefore contravene this regulation. Duty of designers, manufacturers and suppliers Those who design, manufacture or supply articles for use at work also have a duty to those who use those articles (section 6 of HSWA). This duty extends to the information provided for use. It also extends to the revision of such information if it becomes known that anything gives rise to a risk to health or safety. In other words the law requires designers, manufacturers and suppliers to be pro-active and take reasonably practicable steps to inform their customers of potential problems once they become known. Date-discontinuity problems in the hardware or software of a safety-related control system is such a problem. Manufacturers and suppliers also have more specific duties under the Supply of Machinery (Safety) Regulations 1992 as amended, for machines that have control systems. In particular a fault in the control circuit logic such as a date discontinuity problem, should not lead to dangerous conditions. Recommendations If you use or provide your employees with PES on which you rely for safety, then the following report will provide you with one method for tackling the 'Year 2000 Problem'. Do not assume that your safety-related control systems are immune to date discontinuity problems: remember it is much better to be safe than sorry. Do not wait for someone to develop a simple 'magic method' which will solve this problem. The consensus of technical opinion is that it would have surfaced by now if it were at all possible. Act now: as far as safety is concerned this is not tomorrow's problem - time, in this case, is most definitely of the essence! Further guidanceHSE will issue guidance on this topic in March 1998. This guidance will be free and available from the Internet (address http:/www.open.gov.uk/hse/hsehome.htm) and as a leaflet. The guidance will be based on the material in this report and will give more specific advice on what HSE expects of dutyholders.