I don't entirely agree, but the term is certainly vague and subjective.  The trouble is, it's embedded in step 4 of your procedure.  I think we have moved on from it now, but you will surely remember the requirement for two layers of plastic film or insulation, in case one layer had a pinhole.  It was 'considered' that the probability of two coinciding pinholes was acceptably low. If that isn't a risk assessment, I'm not writing this message. This is just an example of 'test the adequacy of the safeguards'. Many others spring to mind rather readily; how do you test *objectively* the adequacy of a symbol like the ! in a triangle, meaning, well, I think it has had more than one meaning over the years?

I do wish there was a way of eliminating it, but I don't see one.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-04-16 21:47, Richard Nute wrote:

I don’t like “risk assessment.”  It is highly subjective and not scientific.  Read ISO 14971 or any treatise on risk assessment.

I use the “energy transfer model.”   This is not subjective and highly scientific.

It was first proposed by James J. Gibson in 1961:

“Injuries to a living organism can be produced only by some energy interchange.”

The first step is to identify the energy sources within a product.  The second step is to class the energy sources as capable of causing injury or not.  The third step is to provide the energy sources capable of causing injury with one or more safeguards to prevent the transfer of energy to a body part.  The fourth step is to test the adequacy of the safeguards.

Easy and straight-forward.  Not subjective.

Rich

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