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Operational Risk Management

FAA System Safety Handbook, Chapter 15: Operational Risk Management
December 30, 2000
Chapter 15: Operational Risk Management (ORM)
15.1 DEFINING RISK AND RISK MANAGEMENT ............................................................ 2
15.2 ORM PRINCIPLES ......................................................................................................... 3
15.3 THE ORM PROCESS SUMMARY................................................................................. 4
15.4 IMPLEMENTING THE ORM PROCESS...................................................................... 6
15.5 RISK VERSUS BENEFIT................................................................................................ 6
15.6 ACCEPTABILITY OF RISK........................................................................................... 7
15.7 GENERAL RISK MANAGEMENT GUIDELINES....................................................... 8
15.8 RISK MANAGEMENT RESPONSIBILITIES............................................................... 9
15.9 SYSTEMATIC RISK MANAGEMENT: THE 5-M MODEL ........................................ 9
15.10 LEVELS OF RISK MANAGEMENT...........................................................................12
15.11 ORM PROCESS EXPANSION.....................................................................................12
15.12 CONCLUSION ..............................................................................................................23
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15.0 Operational Risk Management (ORM)
15.1 Defining Risk and Risk Management
ORM is a decision-making tool to systematically help identify operational risks and benefits and
determine the best courses of action for any given situation. In contrast to an Operational and
Support Hazard Analysis (O&SHA), which is performed during development, ORM is performed
during operational use. For example, an ORM might be performed before each flight. This risk
management process, as other safety risk management processes is designed to minimize risks in
order to reduce mishaps, preserve assets, and safeguard the health and welfare.
Risk management, as discussed throughout this handbook is pre-emptive, rather than reactive.
The approach is based on the philosophy that it is irresponsible and wasteful to wait for an
accident to happen, then figuring out how to prevent it from happening again. We manage risk
whenever we modify the way we do something to make our chances of success as great as
possible, while making our chances of failure, injury or loss as small as possible. It’s a commonsense approach to balancing the risks against the benefits to be gained in a situation and then
choosing the most effective course of action.
Often, the approach to risk management is highly dependent on individual methods and
experience levels and is usually highly reactive. It is natural to focus on those hazards that have
caused problems in the past. In the FAA's operational environment where there is a continual
chance of something going wrong, it helps to have a well-defined process for looking at tasks to
prevent problems. Operational Risk Management, or ORM, is a decision-making tool that helps
to systematically identify risks and benefits and determine the best courses of action for any given
situation. ORM is designed to minimize risks in order to reduce mishaps, preserve assets, and
safeguard the health and welfare.
Risk is defined as the probability and severity of accident or loss from exposure to various
hazards, including injury to people and loss of resources. All FAA operations in the United
States, and indeed even our personal daily activities involve risk, and require decisions that
include risk assessment and risk management. Operational Risk Management (ORM) is simply a
formalized way of thinking about these things. ORM is a simple six-step process, which
identifies operational hazards and takes reasonable measures to reduce risk to personnel,
equipment and the mission.
In FAA operations, decisions need to take into account the significance of the operation, the
timeliness of the decision required, and what level of management is empowered to make the
decision. Risk should be identified and managed using the same disciplined process that governs
other aspects of the Agency’s endeavors, with the aim of reducing risk to personnel and resources
to the lowest practical level.
Risk management must be a fully integrated part of planning and executing any operation,
routinely applied by management, not a way of reacting when some unforeseen problem occurs.
Careful determination of risks, along with analysis and control of the hazards they create results
in a plan of action that anticipates difficulties that might arise under varying conditions, and pre
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December 30, 2000
15 - 3
determines ways of dealing with these difficulties. Managers are responsible for the routine use of
risk management at every level of activity, starting with the planning of that activity and
continuing through its completion.
Figure 15-1 illustrates the objectives of the ORM process: protecting people, equipment and other
resources, while making the most effective use of them. Preventing accidents, and in turn
reducing losses, is an important aspect of meeting this objective. In turn, by minimizing the risk
of injury and loss, we ultimately reduce costs and stay on schedule. Thus, the fundamental goal of
risk management is to enhance the effectiveness of people and equipment by determining how
they are most efficiently to be used.
Figure 15-1: Risk management Goal
15.2 ORM Principles
Four principles govern all actions associated with operational risk management. These
continuously employed principles are applicable before, during and after all tasks and operations,
by individuals at all levels of responsibility.
Maximize
Operational
Capability
Conserve Personnel & Resources
Prevent or Mitigate
Losses
Advance or Optimize
Gain
Evaluate And Minimize
Risks
Evaluate And Maximize
Gain
Identify, Control, & Document
Hazards
Identify, Control, & Document
Opportunities
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Accept No Unnecessary Risk:
Unnecessary risk is that which carries no commensurate return in terms of benefits or
opportunities. Everything involves risk. The most logical choices for accomplishing an
operation are those that meet all requirements with the minimum acceptable risk. The corollary
to this axiom is “accept necessary risk,” required to successfully complete the operation or task.
Make Risk Decisions at the Appropriate Level:
Anyone can make a risk decision. However, the appropriate decision-maker is the person who can
allocate the resources to reduce or eliminate the risk and implement controls. The decision-maker
must be authorized to accept levels of risk typical of the planned operation (i.e., loss of
operational effectiveness, normal wear and tear on materiel). He should elevate decisions to the
next level in the chain of management upon determining that those controls available to him will
not reduce residual risk to an acceptable level.
Accept Risk When Benefits Outweigh the Costs:
All identified benefits should be compared against all identified costs. Even high-risk endeavors
may be undertaken when there is clear knowledge that the sum of the benefits exceeds the sum of
the costs. Balancing costs and benefits is a subjective process, and ultimately the balance may
have to be arbitrarily determined by the appropriate decision-maker.
Integrate ORM into Planning at all Levels:
Risks are more easily assessed and managed in the planning stages of an operation. The later
changes are made in the process of planning and executing an operation, the more expensive and
time-consuming they will become.
15.3 The ORM Process Summary
The ORM process comprises six steps, each of which is equally important. Figure 15-2 illustrates
the process.
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1. Identify
the Hazards
2. Assess
the Risks
3. Analyze
Risk Control
Measures
4. Make
Control
Decisions
5. Implement Risk
Controls
6. Supervise
and Review
Figure 15-2: ORM's 6 Process Steps
Step 1: Identify the Hazard
A hazard is defined as any real or potential condition that can cause degradation, injury, illness,
death or damage to or loss of equipment or property. Experience, common sense, and specific
analytical tools help identify risks.
Step 2: Assess the Risk
The assessment step is the application of quantitative and qualitative measures to determine the
level of risk associated with specific hazards. This process defines the probability and severity of
an accident that could result from the hazards based upon the exposure of humans or assets to the
hazards.
Step 3: Analyze Risk Control Measures
Investigate specific strategies and tools that reduce, mitigate, or eliminate the risk. All risks have
three components: probability of occurrence, severity of the hazard, and the exposure of people
and equipment to the risk. Effective control measures reduce or eliminate at least one of these.
The analysis must take into account the overall costs and benefits of remedial actions, providing
alternative choices if possible.
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Step 4: Make Control Decisions
Identify the appropriate decision-maker. That decision-maker must choose the best control or
combination of controls, based on the analysis of step 3.
Step 5: Implement Risk Controls
Management must formulate a plan for applying the controls that have been selected, then
provide the time, materials and personnel needed to put these measures in place.
Step 6: Supervise and Review
Once controls are in place, the process must be periodically reevaluated to ensure their
effectiveness. Workers and managers at every level must fulfill their respective roles to assure
that the controls are maintained over time. The risk management process continues throughout the
life cycle of the system, mission or activity.
15.4 Implementing the ORM Process
To derive maximum benefit from this powerful tool, it must be used properly. The following
principles are essential.
Apply the steps in sequence
Each step is a building block for the next, and must be completed before proceeding to the next. If
a hazard identification step is interrupted to focus upon the control of a particular hazard, other,
more important hazards may be overlooked. Until all hazards are identified, the remainder of the
process is not effective.
Maintain a balance in the process
All six steps are important. Allocate the time and resources to perform them all.
Apply the process in a cycle
The “supervise and review” step should include a brand-new look at the operation being
analyzed, to see whether new hazards can be identified.
Involve people in the process
Be sure that the risk controls are mission supportive, and that the people who must do the work
see them as positive actions. The people who are actually exposed to risks usually know best
what works and what does not.
15.5 Risk versus Benefit
Risk management is the logical process of weighing the potential costs of risks against the
possible benefits of allowing those risks to stand uncontrolled.
15.5.1 Types of Risk Defined
Identified risk: That risk that has been determined to exist using analytical tools. The time and
costs of analysis efforts, the quality of the risk management program, and the state of the
technology involved affect the amount of risk that can be identified.
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Unidentified risk: That risk that has not yet been identified. Some risk is not identifiable or
measurable, but is no less important for that. Mishap investigations may reveal some previously
unidentified risks.
Total risk: The sum of identified and unidentified risk. Ideally, identified risk will comprise the
larger proportion of the two.
Acceptable risk: The part of identified risk that is allowed to persist after controls are applied.
Risk can be determined acceptable when further efforts to reduce it would cause degradation of
the probability of success of the operation, or when a point of diminishing returns has been
reached.
Unacceptable risk: That portion of identified risk that cannot be tolerated, but must be either
eliminated or controlled.
Residual risk: The portion of total risk that remains after management efforts have been
employed. Residual risk comprises acceptable risk and unidentified risk.
Figure 15-3: Types of Risk
15.5.2 Benefits Defined
Benefits are not limited to reduced mishap rates or decreased injuries, but may also be realized as
increases in efficiency or mission effectiveness. Benefits are realized through prudent risk-taking.
Risk management provides a reasoned and repeatable process that reduces the reliance on
intuition.
15.6 Acceptability of Risk
Risk management requires a clear understanding of what constitutes unnecessary risk, i.e., when
benefits actually outweigh costs. Accepting risk is a function of both risk assessment and risk
management, and is not as simple a matter as it may first appear. Several principles apply:
Unacceptable/Eliminate
Unacceptable/Control
Residual
Unidentified
Acceptable
Total Risk Residual Risk
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·  Some degree of risk is a fundamental reality
·  Risk management is a process of tradeoffs
·  Quantifying risk does not in itself ensure safety
·  Risk is often a matter of perspective
·  Realistically, some risk must be accepted. How much is accepted, or not accepted, is
the prerogative of the defined decision authority. That decision is affected by many
inputs. As tradeoffs are considered and operation planning progresses, it may become
evident that some of the safety parameters are forcing higher risk to successful
operation completion. When a manager decides to accept risk, the decision should be
coordinated whenever practical with the affected personnel and organizations, and
then documented so that in the future everyone will know and understand the
elements of the decision and why it was made.
15.7 General Risk Management Guidelines
·  All human activity involving technical devices or complex processes entails some
element of risk.
·  Hazards can be controlled; they are not a cause for panic.
·  Problems should be kept in perspective.
·  Judgments should be based upon knowledge, experience and mission requirements.
·  Encouraging all participants in an operation to adopt risk management principles both
reduces risk and makes the task of reducing it easier.
·  Good analysis tilts the odds in favor of safe and successful operation.
·  Hazard analysis and risk assessment do not replace good judgment: they improve it.
·  Establishing clear objectives and parameters in risk management works better than
using a cookbook approach.
·  No one best solution may exist. Normally, there are a variety of alternatives, each of
which may produce a different degree of risk reduction.
·  Tact is essential. It is more productive to show a mission planner how he can better
manage risk than to condemn his approach as unworkable, risky, unsafe or unsound.
·  Seldom can complete safety be achieved.
·  There are no “safety problems” in planning or design, only management problems
that may cause accidents, if left unresolved.
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15.8 Risk Management Responsibilities
15.8.1 Managers
·  Are responsible for effective management of risk.
·  Select from risk reduction options recommended by staff.
·  Accept or reject risk based upon the benefit to be derived.
·  Train and motivate personnel to use risk management techniques.
·  Elevate decisions to a higher level when it is appropriate.
15.8.2 Staff
·  Assess risks and develop risk reduction alternatives.
·  Integrate risk controls into plans and orders.
·  Identify unnecessary risk controls.
15.8.3 Supervisors
·  Apply the risk management process
·  Consistently apply effective risk management concepts and methods to operations
and tasks.
·  Elevate risk issues beyond their control or authority to superiors for resolution.
15.8.4 Individuals
·  Understand, accept and implement risk management processes.
·  Maintain a constant awareness of the changing risks associated with the operation or
task.
·  Make supervisors immediately aware of any unrealistic risk reduction measures or
high-risk procedures.
15.9 Systematic Risk Management: The 5-M Model
Successful operations do not just happen; they are indicators of how well a system is functioning.
The basic cause factors for accidents fall into the same categories as the contributors to successful
operations—Human, Media, Machine, Mission, and Management.
Risk management is the systematic application of management and engineering principles,
criteria and tools to optimize all aspects of safety within the constraints of operational
effectiveness, time, and cost throughout all operational phases. To apply the systematic risk
management process, the composite of hardware, procedures, and people that accomplish the
objective, must be viewed as a system.
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The 5-M model, depicted in Figure 15-4, is adapted from military ORM. In this model, “Man” is
used to indicate the human participation in the activity, irrespective of the gender of the human
involved. “Mission” is the military term that corresponds to what we in civil aviation call
“operation.” This model provides a framework for analyzing systems and determining the
relationships between the elements that work together to perform the task.
The 5-M's are Man, Machine, Media, Management, and Mission. Man, Machine, and Media
interact to produce a successful Mission (or, sometimes, an unsuccessful one). The amount of
overlap or interaction between the individual components is a characteristic of each system and
evolves as the system develops. Management provides the procedures and rules governing the
interactions between the other elements.
When an operation is unsuccessful or an accident occurs, the system must be analyzed; the inputs
and interaction among the 5-Ms must be thoroughly reassessed. Management is often the
controlling factor in operational success or failure. The National Safety Council cites the
management processes in as many as 80 percent of reported accidents.
15.9.1 Man
The human factor is the area of greatest variability, and thus the source of the majority of risks.
Selection: The right person psychologically and physically, trained in event proficiency,
procedures and habit patterns.
Performance: Awareness, perceptions, task saturation, distraction, channeled attention, stress,
peer pressure, confidence, insight, adaptive skills, pressure/workload, fatigue (physical,
motivational, sleep deprivation, circadian rhythm).
Personal Factors: Expectancies, job satisfaction, values, families/friends, command/control,
perceived pressure (over tasking) and communication skills.
15.9.2 Media
Media are defined as external, and largely environmental and operational conditions. For
example:
Climatic: Ceiling, visibility, temperature, humidity, wind, precipitation.
Operational: Terrain, wildlife, vegetation, human made obstructions, daylight, and darkness.
Hygienic: Ventilation/air quality, noise/vibration, dust, and contaminants.
Vehicular/Pedestrian: Pavement, gravel, dirt, ice, mud, dust, snow, sand, hills, curves.
15.9.3 Machine
Hardware and software used as intended, limitations interface with man.
Design: Engineering reliability and performance, ergonomics.
Maintenance: Availability of time, tools, and parts, ease of access.
Logistics: Supply, upkeep, and repair.
Technical data: Clear, accurate, useable, and available.
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15.9.4 Management
Directs the process by defining standards, procedures, and controls. Although management
provides procedures and rules to govern interactions, it cannot completely control the system
elements. For example: weather is not under management control and individual decisions affect
personnel far more than management policies.
Standards: FAA Policy and Orders.
Procedures: Checklists, work cards, and manuals.
Controls: Crew rest, altitude/airspeed/speed limits, restrictions, training rules/limitations.
Operation. The desired outcome.
15.9.5 Mission (Operation)
Objectives: Complexity understood, well defined, obtainable. The results of the interactions of
the other -M’s (Man, Media, Machine, and Management).
Figure 15-4: The 5-M Model
5M model of System Engineering
• Msn - Mission: central
purpose or functions
• Man - Human element
• Mach - Machine: hardware
and software
• Media - Environment:
ambient and operational
environment
• Mgt- Management:
procedures, policies, and
regulations
Man
Mach.
Msn
Mgt
Media
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15.10 Levels of Risk Management
The risk management process operates on three levels. Although it would be preferable to
perform an in-depth application of risk management for every operation or task, the time and
resources may not always be available. The three levels are as follow:
15.10.1 Time-Critical
Time-critical risk management is an "on the run" mental or verbal review of the situation using
the basic risk management process without necessarily recording the information. This timecritical process of risk management is employed by personnel to consider risk while making
decisions in a time-compressed situation. This level of risk management is used during the
execution phase of training or operations as well as in planning and execution during crisis
responses. It is also the most easily applied level of risk management in off-duty situations. It is
particularly helpful for choosing the appropriate course of action when an unplanned event occurs
during execution of a planned operation or daily routine.
15.10.2 Deliberate
Deliberate Risk Management is the application of the complete process. It primarily uses
experience and brainstorming to identify risks, hazards and develops controls and is therefore
most effective when done in a group. Examples of deliberate applications include the planning of
upcoming operations, review of standard operating, maintenance, or training procedures, and
damage control or disaster response planning.
15.10.3 Strategic
This is the deliberate process with more thorough hazard identification and risk assessment
involving research of available data, use of diagram and analysis tools, formal testing, or long
term tracking of the risks associated with the system or operation (normally with assistance from
technical experts). It is used to study the hazards and their associated risks in a complex operation
or system, or one in which the hazards are not well understood. Examples of strategic
applications include the long-term planning of complex operations, introduction of new
equipment, materials and operational, development of tactics and training curricula, high risk
facility construction, and major system overhaul or repair. Strategic risk management should be
used on high priority or high visibility risks.
15.11 ORM Process Expansion
Many aspects of the ORM process utilize the same risk management tools described throughout
this handbook. There are some unique contributions and issues in the ORM process which are
expanded in this section.
15.11.1 Hazard identification expansion
Hazard identification, the foundation of the entire ORM process, and ans analysis of control
measures require further expansion. Figure 15-3 depicts the actions necessary to identify hazards.
Specifically, identify hazards associated with these three categories:
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Operational or System Degradation.
Injury or Death.
Property Damage.
Action 1—Task Analysis
The 5-M’s are examined. This is accomplished by reviewing current and planned operations.
Management defines requirements and conditions to accomplish the tasks. Construct a list or
chart depicting the major phases of the operation or steps in the job process, normally in time
sequence. Break the operation down into ’bite size’ chunks.
Some tools that will help perform operation/task analysis are:
Operations Analysis/Flow Diagram
Preliminary Hazard Analysis (PHA)
Multi-linear Events Sequence (MES)
Action 2—List Hazards
Hazards are identified based on the deficiency to be corrected and the definition of the operation
and system requirements. The output of the identification phase is a listing of inherent hazards or
adverse conditions and the accidents, which could result. Examples of inherent hazards in any one
of the elements include fire, explosion, and collision with ground, wind, or electrocution. The
analysis must also search for factors that can lead to hazards such as alertness, ambiguity, or
escape route. In addition to a hazard list for the elements above, interfaces between or among
these elements should be investigated for hazards. Make a list of the hazards associated with each
phase of the operation or step in the job process. Stay focused on the specific steps in the
operation being analyzed. Try to limit your list to "big picture" hazards. Hazards should be
tracked on paper or in a computer spreadsheet/database system to organize ideas and serve as a
record of the analysis for future use. Tools that help list hazards are:
Preliminary Hazard Analysis
“What if” Tool
Scenario Process Tool
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Logic Diagram
Change Analysis Tool
Opportunity Assessment
Training Realism Assessment.
Figure 15-3. Identify Hazards Actions
ACTIONS FOR STEP 1 – IDENTIFY THE HAZARDS
Action 3—List Causes
Make a list of the causes associated with each hazard identified in the hazard list. A hazard may
have multiple causes related to each of the 5-M’s. In each case, try to identify the root cause (the
first link in the chain of events leading to operational degradation, personnel injury, death, or
property damage). Risk controls can be effectively applied to root causes. Causes should be
annotated with the associated hazards in the same paper or computer record mentioned in the
previous action. The same tools for Action 2 can be used here.
Strategic Tools
If time and resources permit, and additional hazard information is required, use strategic hazard
analysis tools. These are normally used for medium and long term planning, complex operations,
or operations in which the hazards are not well understood.
The first step of in-depth analysis should be to examine existing databases or available historical
and hazard information regarding the operation. Suggested tools are:
Accident analysis
Cause and effect diagrams
The following tools are particularly useful for complex, coordinated operations in which multiple
units, participants, and system components and simultaneous events are involved:
Multi-linear event sequence (MES).
Interface analysis.
Failure mode and effect analysis.
ACTION 1:
TASK
ACTION 2:
LIST HAZARDS
ACTION 3:
LIST CAUSES
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The following tools are particularly useful for analyzing the hazards associated with physical
position and movement of assets:
Mapping tool.
Energy trace and barrier analysis.
Interface analysis.
SEVEN PRIMARY HAZARD
IDENTIFICATION TOOLS
• THE OPERATIONS ANALISIS
•THE PRELIMINARY HAZARD ANALYSIS
•THE WHAT IF TOOL
•THE SENARIO PROCESS TOOL
•THE LOGIC DIAGRAM
•THE CHANGE ANALYSIS
•THE CAUSE AND EFFECT TOOL
Figure 15-4: The Primary Family of Hazard Identification Tools
There are many additional tools that can help identify hazards. One of the best is through a group
process involving representatives directly from the workplace. Most people want to talk about
their jobs, therefore a simple brainstorming process with a facilitator is often very productive. The
following is a partial list of other sources of hazard identification information:
Accident/Incident Reports: These can come from within the organization, for it represents
memory applicable to the local workplace, cockpit, flight, etc. Other sources might be NTSB
reports, medical reports, maintenance records, and fire and police reports.
Operational Personnel: Relevant experience is arguably the best source of hazard identification.
Reinventing the wheel each time an operation is proposed is neither desired nor efficient. Seek
out those with whom you work who have participated in similar operations and solicit their input.
Outside Experts: Look to those outside your organization for expert opinions or advice.
Current Guidance: A wealth of relevant direction can always be found in the guidance that
governs our operations. Consider regulations, operating instructions, checklists, briefing guides,
SOPs, NOTAMs, and policy letters.
Surveys: The survey can be a powerful tool because it pinpoints people in the operation with first
hand knowledge. Often, first line supervisors in the same facility do not have as good an
understanding of risk as those who confront it every day.
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Inspections: Inspections can consist of spot checks, walk-through, checklist inspections, site
surveys, and mandatory inspections. Utilize staff personnel to provide input beyond the standard
third-party inspection.
15.11.2 Analyze Control Measures
Hazard control is accomplished in several ways. Figure 15-5 depicts the actions necessary to
analyze the alternatives.
Figure 15-5. Analyze Control Measures Actions
ACTIONS FOR STEP 3 – ANALYZE CONTROL MEASURES
Action 1—Identify Control Options
Starting with the highest-risk assessed, identify as many risk control options as possible for all
hazards. Refer to the list of possible causes from Step 1 for control ideas. The Control Options
Matrix and “What-If” analyses are excellent tools to identify control options. Risk control options
include: rejection, avoidance, delay, transference, spreading, compensation, and
reduction.
Action 2—Determine Control Effects
Determine the effect of each control on the risk associated with the hazards. A computer spread
sheet or data form may be used to list control ideas and indicate control effects. The estimated
value(s) for severity and/or probability after implementation of control measures and the change
in overall risk assessed from the Risk Assessment Matrix should be recorded. Scenario building
and next accident assessment provides the greatest ability to determine control effects.
Action 3—Prioritize Risk Controls/ Measures
For each risk, prioritize those risk controls that will reduce the risk to an acceptable level. The
best controls will be consistent with objectives and optimize use of available resources
(manpower, material, and equipment, money, time). Priorities should be recorded in some
standardized format for future reference. Opportunity assessment, cost versus benefit analysis and
computer modeling provide excellent aids to prioritize risk controls. If the control is already
implemented in an established instruction, document, or procedure, that too should be
documented.
ACTION 1:
IDENTIFY
CONTROL
OPTIONS
ACTION 2:
DETERMINE
CONTROL
EFFECTS
ACTION 3:
PRIORITIZE RISK
CONTROL
MEASURES
ACTION 4:
IMPLEMENT
RISK
CONTROL
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The "standard order of precedence" indicates that the ideal action is to “plan or design for
minimum risk” with less desirable options being, in order, to add safety devices, add warning
devices, or change procedures and training. This order of preference makes perfect sense while
the system is still being designed, but once the system is fielded this approach is frequently not
cost effective. Redesigning to eliminate a risk or add safety or warning devices is both expensive
and time consuming and, until the retrofit is completes, the risk remains unabated.
Normally, revising operational or support procedures may be the lowest cost alternative. While
this does not eliminate the risk, it may significantly reduce the likelihood of an accident or the
severity of the outcome (risk) and the change can usually be implemented quickly. Even when a
redesign is planned, interim changes in procedures or maintenance requirements are usually
required. In general, these changes may be as simple as improving training, posting warnings, or
improving operator or technician qualifications. Other options include preferred parts substitutes,
instituting or changing time change requirements, or increased inspections.
The feasible alternatives must be evaluated, balancing their costs and expected benefits in terms
of operational performance, dollars and continued risk exposure during implementation. A
completed risk assessment should clearly define these tradeoffs for the decision-maker.
Some Special Considerations in Risk Control. The following factors should be considered
when applying the third step of ORM.
Try to apply risk controls only in those activities and to those who are actually at risk. Too often
risk controls are applied indiscriminately across an organization leading to wasted resources and
unnecessary irritation of busy operational personnel.
Apply redundant risk controls when practical and cost effective. If the first line of defense fails,
the back up risk control(s) may prevent loss.
Involve operational personnel, especially those likely to be directly impacted by a risk control, in
the selection and development of risk controls whenever possible. This involvement will result in
better risk controls and in general a more positive risk control process.
Benchmark (find best practices in other organizations) as extensively as possible to reduce the
cost associated with the development of risk controls. Why expend the time and resources
necessary to develop a risk control and then have to test it in application when you may be able to
find an already complete, validated approach in another organization?
Establish a timeline to guide the integration of the risk control into operational processes.
Action 4 — Implement Risk Controls
Once the risk control decision is made, assets must be made available to implement the specific
controls. Part of implementing control measures is informing the personnel in the system of the
risk management process results and subsequent decisions. If there is a disagreement, then the
decision-makers should provide a rational explanation. Careful documentation of each step in the
risk management process facilitates risk communication and the rational processes behind
risk management decisions. Figure 15-6 depicts the actions necessary to complete this step.
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15 - 18
Figure 15-6: Actions to Implement Risk Controls
ACTIONS FOR STEP 4—IMPLEMENT RISK CONTROLS
STEP 1:
MAKE IMPLEMENTATION CLEAR
STEP 2:
ESTABLISH ACCOUNTABILITY
STEP 3:
PROVIDE SUPPORT
Step 1—Make Implementation Clear
To make the implementation directive clear, consider using examples, providing pictures or
charts, including job aids, etc. Provide a roadmap for implementation, a vision of the end-state,
and describe successful implementation. The control measure must be deployed in a method that
insures it will be received positively by the intended audience. This can best be achieved by
designing in user ownership.
Step 2—Establish Accountability
Accountability is an important area of ORM. The accountable person is the one who makes the
decision (approves the control measures), and hence, the right person (appropriate level) must
make the decision. Also, be clear on who is responsible at the unit level for implementation of the
risk control.
Step 3—Provide Support
To be successful, management must be behind the control measures put in place. Prior to
implementing a control measure, get approval at the appropriate level. Then, explore appropriate
ways to demonstrate commitment Provide the personnel and resources necessary to implement
the control measures. Design in sustainability from the beginning and be sure to deploy the
control measure along with a feedback mechanism that will provide information on whether the
control measure is achieving the intended purpose.
Common Problems in Implementing Risk Controls
A review of the historical record of risk controls indicates that many never achieve their full
potential. The primary reason for shortfalls is failure to effectively involve the personnel who are
actually impacted by a risk control. Note that virtually all these factors are driven by the failure to
properly involve personnel impacted by risk controls in the development and implementation of
the risk controls. Shortfalls include:
·  The control is inappropriate for the problem.
·  Operators dislike it.
·  Managers dislike it.
·  It turns out to be too costly (unsustainable).
·  It is overmatched by other priorities.
·  It is misunderstood.
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·  Nobody measures progress until it is too late.
Procedures for Implementing Risk Controls within an Organizational Culture
The following procedures provide useful guidance for shaping a risk control within an
organizational culture. Followed carefully they will significantly improve the impact and duration
of the effectiveness of risk controls.
Develop the risk control within the organization’s culture. Every organization has a style or a
culture. While the culture changes over time due to the impact of managers and other
modifications, the personnel in the organization know the culture at any given time. It is
important to develop risk controls, which are consistent with this culture. For example, a rigid,
centrally directed risk control would be incompatible with an organizational culture that
emphasizes decentralized flexibility. Conversely, a decentralized risk control may not be effective
in an organization accustomed to top down direction and control. If you have any doubts about
the compatibility of a risk control within your organization, ask some personnel in the
organization what they think. People are the culture and their reactions will tell you what you
need to know.
Generate maximum possible involvement of personnel impacted by a risk control in the
implementation of the risk control. Figure 15-7 provides a tool to assist in assessing this
“involvement factor.” The key to making ORM a fully integrated part of the organization culture,
is to achieve user ownership in a significant percentage of all risk controls that are developed and
implemented by the personnel directly impacted by the risk..
Figure 15-7: Levels of User Involvement in Risk Controls
STRONGER
WEAKER
User Ownership: Operators are empowered to develop the risk control
Co-Ownership: Operators share leadership of the risk control development team
Team Member: Operators are active members of the team that developed the risk control
Input: Operators are allowed to comment and have input before the risk control is developed
Coordination: Operators are allowed to coordinate on an already developed idea
Comment and Feedback: Operators are given the opportunity to express ideas
Robot: Operators are ordered to apply the risk control
Develop the best possible supporting tools and guides (infrastructure) to aid operating personnel
in implementing the risk control. Examples include standard operating procedures (SOPs), model
applications, job aids, checklists, training materials, decision guides, help lines, and similar items.
The more support that is provided, the easier the task for the affected personnel. The easier the
task, the greater the chances for success.
Develop a time line for implementing the risk control. Identify major milestones, being careful to
allow reasonable timeframes and assuring that plans are compatible with the realities of
organizational resource constraints.
Procedures for Generating Management Involvement in Implementing Risk Controls
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15 - 20
Manager and supervisor’s influence behind a risk control can greatly increase its chances of
success. It is usually a good idea to signal clearly to an organization that there is interest in a risk
control if the manager in fact has some interest. Figure 15-8 illustrates actions in order of priority
that can be taken to signal leader support. Most managers are interested in risk control and are
willing to do anything reasonable to support the process. Take the time as you develop a risk
control to visualize a role for organization leaders.
STRONGER
WEAKER
Sustained consistent behavior
On-going personal participation
Accountability actions and follow up
Follow up inquiries by phone & during visits
Verbal support in staff meetings
Sign directives
Figure 15-8. Levels of Command Involvement
Procedures for Sustaining Risk Control Effectiveness
To be fully effective, risk controls must be sustained. This means maintaining the responsibility
and accountability for the long haul. If the risk control has been well designed for compatibility
with the organization operation and culture this should not be difficult. Managers must maintain
accountability and yet provide a reasonable level of positive reinforcement as appropriate.
Supervise and Review
The sixth step of ORM, Supervise and Review, involves the determination of the effectiveness of
risk controls throughout the operation. This step involves three aspects. The first is monitoring the
effectiveness of risk controls. The second is determining the need for further assessment of either
all or a portion of the operation due to an unanticipated change as an example. The last is the need
to capture lessons-learned, both positive and negative, so that they may be a part of future
activities of the same or similar type. Figure 15-9 depicts the actions necessary to complete this
step.
Figure 15-9: Supervise and Review Actions
ACTION 1:
SUPERVISE
ACTION 2:
REVIEW
ACTION 3:
FEEDBACK
ACTIONS FOR STEP 6 - SUPERVISE AND REVIEW
Action 1—Supervise
Monitor the operation to ensure:
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·  The controls are effective and remain in place.
·  Changes, which require further risk management, are identified.
·  Action is taken when necessary to correct ineffective risk controls and reinitiate the
·  Risk management steps in response to new hazards.
Any time the personnel, equipment, or tasking change or new operations are anticipated in an
environment not covered in the initial risk management analysis, the risks and control measures
should be reevaluated. The best tool for accomplishing this is change analysis.
Successful performance is achieved by shifting the cost versus benefit balance more in favor of
benefit through controlling risks. By using ORM whenever anything changes, we consistently
control risks, those known before an operation and those that develop during an operation. Being
proactive and addressing the risks before they get in the way of operation accomplishment saves
resources, enhances operational performance, and prevents the accident chain from ever forming.
Action 2—Review
The process review must be systematic. After assets are expended to control risks, then a cost
benefit review must be accomplished to see if risk and cost are in balance. Any changes in the
system (the 5-M model, and the flow charts from the earlier steps provide convenient benchmarks
to compare the present system to the original) are recognized and appropriate risk management
controls are applied.
To accomplish an effective review, supervisors need to identify whether the actual cost is in line
with expectations. Also the supervisor will need to see what effect the control measure has had on
operational performance. It will be difficult to evaluate the control measure by itself so focus on
the aspect of operational performance the control measure was designed to improve.
A review by itself is not enough, a feedback system must be established to ensure that the
corrective or preventative action taken was effective and that any newly discovered hazards
identified during the operation are analyzed and corrective action taken. When a decision is made
to assume risk, the factors (cost versus benefit information) involved in this decision should be
recorded. When an accident or negative consequences occur, proper documentation allows for the
review of the risk decision process to see where errors might have occurred or if changes in the
procedures and tools lead to the consequences. Secondly, it is unlikely that every risk analysis
will be perfect the first time. When risk analyses contain errors of omission or commission, it is
important that those errors be identified and corrected. Without this feedback loop, we lack the
benefit of knowing if the previous forecasts were accurate, contained minor errors, or were
completely incorrect.
Measurements are necessary to ensure accurate evaluations of how effectively controls eliminated
hazards or reduced risks. After action reports, surveys, and in progress reviews provide great
starting places for measurements. To be meaningful, measurements must quantitatively or
qualitatively identify reductions of risk, improvements in operational success, or enhancement of
capabilities.
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Action 3—Feedback
A review by itself is not enough: a feedback system must be established to ensure that the
corrective or preventative action taken was effective and that any newly discovered hazards
identified during the operation are analyzed and corrective action taken. Feedback informs all
involved as to how the implementation process is working, and whether or not the controls were
effective. Whenever a control process is changed without providing the reasons, co-ownership at
the lower levels is lost. The overall effectiveness of these implemented controls must also be
shared with other organizations that might have similar risks to ensure the greatest possible
number of people benefit. Feedback can be in the form of briefings, lessons learned, cross-tell
reports, benchmarking, database reports, etc. Without this feedback loop, we lack the benefit of
knowing if the previous forecasts were accurate, contained minor errors, or were completely
incorrect.
Monitoring the Effectiveness of Implementation
This aspect of the supervise and review step should be routine. Periodically monitor the progress
of implementation against the planned implementation schedule that should have been developed
during the third and fifth ORM steps. Take action as necessary to maintain the planned
implementation schedule or make adjustments as necessary.
Monitoring the Effectiveness of Risk Controls
If the risk control has been well designed, it will favorably change either physical conditions or
personnel behavior during the conduct of an operation. The challenge is to determine the extent to
which this change is taking place. If there has been no change or only minor change, the risk
control is possibly not worth the resources expended on it. It may be necessary to modify it or
even rescind it. At first thought it may seem obvious that we need only determine if the number
of accidents or other losses has decreased. This is only practical at higher levels of management.
Even at those levels of management where we have sufficient exposure to validly assess actual
losses, it may be a year or more before significant changes actually occur. This is too long to wait
to assess the effectiveness of risk controls. Too much effort may have been invested before we
can determine the impact of our proposals. We need to know how we are doing much sooner. If
we can’t efficiently measure effectiveness using accident rates, how can we do it? The answer is
to directly measure the degree of risk present in the system.
Direct Measures of Behavior. When the target of a risk control is behavior, it is possible to
actually sample behavior changes in the target group. Making a number of observations of the use
of restraints before initiating the seat belt program and a similar sample after, for example, can
assess the results of an effort to get personnel to wear seat belts. The change, if any, is a direct
measure of the effectiveness of the risk control. The sample would establish the percent of
personnel using belts as a percentage of total observations. Subsequent samples would indicate
our success in sustaining the impact of the risk control.
Direct Measures of Conditions. It is possible to assess the changes in physical conditions in the
workplace. For example, the amount of foreign objects found on the flight line can be assessed
before and after a risk control initiative aimed at reducing foreign object damage.
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Measures of Attitudes. Surveys can also assess the attitudes of personnel toward risk-related
issues. While constructing survey questions is technical and must be done right, the FAA often
conducts surveys and it may be possible to integrate questions in these surveys, taking advantage
of the experts who manage these survey processes. Nevertheless, even informal surveys taken
verbally in very small organizations will quickly indicate the views of personnel.
Measures of Knowledge. Some risk controls are designed to increase knowledge of some hazard
or of hazard control procedures. A short quiz, perhaps administered during a safety meeting
before and after a training risk control is initiated.
Safety and Other Loss Control Reviews Procedures. Programmatic and procedural risk control
initiatives (such as revisions to standard operating procedures) can be assessed through various
kinds of reviews. The typical review involves a standard set of questions or statements reflecting
desirable standards of performance against which actual operating situations are compared.
15.12 Conclusion
Operational risk management provides a logical and systematic means of identifying and
controlling risk. Operational risk management is not a complex process, but does require
individuals to support and implement the basic principles on a continuing basis. Operational risk
management offers individuals and organizations a powerful tool for increasing effectiveness and
reducing accidents. The ORM process is accessible to and usable by everyone in every
conceivable setting or scenario. It ensures that all FAA personnel will have a voice in the critical
decisions that determine success or failure in all our operations and activities. Properly
implemented, ORM will always enhance performance.
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