Apr
03
2013

Now wash your hands

I recently visited an exhibition at the Barbican Centre in London entitled “The Bride and the Bachelors: Duchamp with Cage, Cunningham, Rauschenberg and Johns

More recently I was invited to speak to a conference entitled “Risk culture for charities” organised by the Institute for Risk Management.

I began my conference presentation with an overview of disparate risk-management cultures, offering examples of excessive risk aversion in the form of fatuous warnings of manifestly obvious directly perceptible risk. And I concluded with a cartoon that I felt made the point rather well.

brick wall

                                                                                         Guindon, Detroit Free Press, 25 September 1994

As the profusion of signs warning of obvious and/or trivial risks grows, I suggested, the likelihood increases that warnings of serious/non-obvious risks will be ignored.

After my presentation, and after tea, one of the conference participants returned to report that every urinal in the men’s toilets displayed the injunction “Now wash your hands”.*

The centrepiece of the Barbican’s Duchamp exhibition was his famous urinal – signed “R. Mutt 1917”.  I have long had trouble with Duchamp’s success in transforming it into “a work of art”.  But work of art, or no, it clearly needs updating to keep up with modern risk management practice.

duchamp hse

* He also reported that the man next to him departed without washing his hands.

 

 

 

Mar
24
2013

The BIGGEST LIE?

Last Thursday (21 March 2013) I attended a conference entitled “Lies, Damned Lies and Statistics? Understanding casualty trends and the causes”. It was sponsored by the Parliamentary Advisory Council for Transport Safety (PACTS). At the conference PACTS, the Department for Transport, and seven other organizations interested in promoting road safety launched a website called www.roadsafetyobservatory.com.

Its home page promises:

Key facts and summaries of research on road safety topics

The website proclaims:

“The Road Safety Observatory aims to provide easy access to independent road safety research and information for anyone working in road safety and for members of the public. It provides summaries and reviews of research on a wide range of road safety issues, along with links to original road safety research reports.”

Its objective, the person presenting it made clear, was to provide an authoritatively fact-checked set of statistics to inform public discussion of road safety issues. Under the heading “How is the Research Evidence Produced?” it states:

“The Programme Board commissions Research Reviews from a wide range of researchers and road safety experts. Each Review is then submitted to an independent Evidence Review Panel, who must approve it for publication on the Observatory website. The reviews are intended to be free from bias and independent of Government policies and the policies of the individual organisations on the Programme Board. They represent a summary of the best evidence readily available to the research community and will be kept under review as new evidence emerges.”

I decided to subject this new source of evidence to my standard test. Into the Home Page search bar I typed “seat belts” – do try it at home. This took me to “Road Safety Observatory Seat Belts Review, January 2013″ – bang up to date and approved by the Independent Evidence Review Panel. First up came “SEAT BELTS: KEY FACTS”.

Seven bullet points down I found this “Key Fact”: “By January 2008, 25 years after the introduction of the law, front seat belts had saved over 60,000 lives in Great Britain.”

On page 5 the claim is embellished: “By January 2008, 25 years after the introduction of the law requiring car drivers and front seat passengers to wear seat belts (if fitted), it was estimated that front seat belts had saved over 60,000 lives in Great Britain.”

On page 9 the claim is repeated – twice.

And again on page 32: “Seat belt laws increase seat belt use, and so reduce death and injury. 25 years after the first law requiring seat be to be used, it was estimated that front seat belts had saved over 60,000 lives in Great Britain.”

The claim that the seat belt law saved 60,000 lives over 25 years is reiterated five times in a document approved by the Observatory’s Independent Evidence Review Panel – without any supporting citation I could find.

Citations are no longer needed. The claim has been repeated so often that it has become a “fact” that everyone knows. Typing “seat belts 60,000 lives saved” into Google yielded, at last clicking, over one million hits.

THE CLAIM IS OUTRAGEOUS NONSENSE.  According to this claim the seat belt law is, by far, the most effective road safety measure ever implemented in Britain. 60,000 divided by 25 years would equal 2400 lives saved every year since 1983 by the seat belt law.  In 1982, the year before the seat belt law came into effect there were only 2365 driver and front seat passenger fatalities! The claim is further, if less dramatically, contradicted by other claims in the same review – indeed in the same initial bullet point: “It was estimated that the seat belt law saved the lives of 241 drivers and 147 front passengers in 1983 and 270 drivers and 181 front passengers in 1984.”   The review does not provide a citation for the estimate of lives saved in 1983 and 1984 but they are similar to those provided in a June 2008 article in Significance by Richard Allsop, Oliver Carsten, Andrew Evans, and Robert Gifford (all members of PACTS). See table below.

Significantly the Significance article did not make it into the Review’s list of key references on seat belts. A significant omission because the authors, all defenders of the seat belt law, acknowledge an effect of the law of important consequence to vulnerable road users. They say “the clear reduction in death and injury to car occupants is appreciably offset by extra deaths among pedestrians and cyclists.”

seatbelts2

This surely deserves a place in any list of “Key Facts” relating to the seat belt law.

Another Key Fact that did not make it into the review is the finding that almost all of the 1983 decrease in driver fatalities estimated by the authors of the Significance article took place between 10pm and 4am (the “drink drive hours”) and in drivers with alcohol in their blood. During the other hours of the day, and amongst alcohol-free drivers there was no detectable departure from trend (see Risk chapter 7). 1983 also happened to be the year in which evidential breath testing was introduced, and unprecedented numbers of breath tests were administered, and drink-drivers prosecuted. The modest claims (modest when compared to 2400) for lives saved in the table above can only be attributed to the seat belt law if one assumes that the measures introduced by the campaign against drink driving launched in the same year had no effect.

Who cares? Why does all this matter 30 years after the seat belt law came into effect? It matters because a new website sponsored by what might be called Britain’s road safety establishment, and promising unvarnished, unbiased, objective “Key Facts”, is telling a whopper. And not out of ignorance. The last time I looked PACTS, RoSPA and the DfT, key sponsors of the new website, all had the 60,000 claim still on their websites despite its absurdity having been called to their attention on a number of occasions.

The PACTS conference was well attended by people with a common interest in making roads safer. There was a detectable, and welcome, shift in emphasis from previous conferences I have attended from a focus on legal and engineering approaches to the problem, to an interest in changing attitudes and behaviour. As I have noted in   Managing transport risks: what works?  :

 “There are two different kinds of manager involved in the management of transport risks: there are the “official”, institutional, risk managers who strive incessantly to make the systems for which they are responsible safer, and there are the billions of individual fallible human users of the systems, each balancing the rewards of risk against the potential accident risks associated with their behaviour.”

 Understanding the attitudes of the latter to risk, and influencing their consequent behavior, represents the most important and challenging part of the institutional risk manager’s job.

 Seat belts have acquired iconic status in common parlance. “Fasten your seat belts” is a phrase commonly invoked to introduce any exciting or threatening idea into a discussion. It is routinely used as a comparator for the postulated benefits of other forms of safety legislation such as cycle helmets. It reinforces legislator hubris – “look what we have achieved!” they marvel as they pat themselves on the back. The Road Safety Observatory by virtue of its endorsement of the 60,000-lives-saved claim is further entrenching the iconic status of the seat belt law and energizing legislators keen to pass further well-meaning but misguided legislation.

 To undo this damage PACTS, RoSPA and the DfT need not just quietly remove the claim from their websites, but prominently explain why.  Likely to happen? Don’t think so.

 Recent posts and comments on this subject are on my website at http://www.john-adams.co.uk/category/seat-belts/

 

Feb
12
2013

Repeal the Seat Belt Law

Peter Bonisch  has posted a comment on my RoSPA post (11 February) that merits an answer. He asks: “would you advocate now removing the seatbelt requirement?  The world has changed since the law was introduced including having been changed by it.  Would it now be constructive to abolish the law in the knowledge that we would not simply revert to the ex ante position?”

Good questions.

I would not expect to return to the ex ante position. And yes, I would repeal the law.

Over the last 30 years road accident deaths in Great Britain have fallen from 5934 to under 2000, but the clear downward trend is not a demonstrable consequence of any government “safety” interventions over that time – see Managing transport risks: what works, Figures 1, 2 and 3.

The long-term trend in the ratio of pedestrian and cyclist fatalities to car occupant fatalities has also displayed a downward trend as car traffic has increased and the number of vulnerable road users (cyclists and pedestrians) on the road has decreased – with a significant interruption to the trend in the year that that the seat belt law was implemented – see p. 10 of what works. An important contributor to this trend has been the enormous drop in the number of children allowed on the streets on foot or on bicycle without adult supervision – see Children’s independent mobility: a comparative study in England and Germany (1971-2010) 

Bonisch notes that there have been technological advances in safety over the past 30 years, such as airbags, improved braking and anti-collision technology. But these changes appear to account for very little, if any, of the decline in road death rates with increasing levels of motorisation. Today motorists in poor countries in the early stages of motorisation are achieving kill rates per vehicle – driving  vehicles with one hundred years of safety technology built into them – as high or higher than were achieved by Model-Ts in the early 19th century. The probable reasons for this are explored in Where and when is shared space safe? 

Bonisch contends that the world has been changed by the seat belt law, and I agree. It has shifted the burden of risk on the road unfairly from the best protected in cars to the most vulnerable outside cars.

Finally, I rest my case on John Stuart Mill’s famous dictum opposing measures that would compel people to be safer than they voluntarily choose to be: “all errors which he is likely to commit against advice and warning, are far outweighed by the evil of allowing others to constrain him to what they deem his good”.

I would repeal the law.

 

Feb
11
2013

Open letter to Tom Mullarkey, CEO of the Royal Society for the Prevention of Accidents.

Dear Tom

Following our meeting at a dinner at the RSA over six years ago I sent you an email (22 February 2007).You replied the same day saying “When I have a moment, I would like to look into this in more detail and so I will follow up on the links you have kindly provided.”

I guess you’ve been busy.

In any event RoSPA’s press release on 31 January 2013 celebrating the 30th anniversary of the seat belt law, and RoSPA’s contribution to it, have given me an excuse to revisit the issue.

At dinner I had told you about RoSPA’s dubious lobbying practices in the run-up to the Parliamentary debate in 1981 and promised to send you some chapter and verse. In my 22 February email I noted that I had already detailed some of this dubious practice in my book Risk and Freedom (p152). I quoted from my book:

“On July 7 1981 The Royal Society for the Prevention of Accidents (president – Lord Nugent) sent a letter to every member of Parliament stating

‘Dr. Adams has recently published a paper advancing the thesis that the wearing of seatbelts may actually increase road accidents by encouraging a false sense of security. His paper [subsequently peer-reviewed and published unaltered by the American Society of Automotive Engineers]  presents road accident trends in several foreign countries to support his view. His paper requires detailed analysis with the aid of much background information from the countries concerned before an authoritative comment can be made upon it. RoSPA and the Transport and Road Research Laboratory are undertaking these studies, meantime it is relevant to record that Dr. Adams does unequivocally state that wearing seatbelts greatly improves the chance of avoiding injury.’ “

This last sentence, I noted, unequivocally misrepresented my position. As I said at dinner, the statistics demonstrate that a seat belt improves your chance of surviving a crash, but INCREASES your chances of being in one. I went on to say

“This letter throws a revealing light on the campaigning methods of RoSPA at the time. While publicly stating that much more work needed doing before they could comment authoritatively on my findings, privately they had been briefing selected members of Parliament for three months with a document which asserted confidently that my conclusions were ‘absurd’ and ‘without foundation’ and that I ‘exhibited, at best, a layman’s understanding of the situation.”

I wrote to you next on 30 September 2009 and again on17 October 2009 inviting your comments on my online contention that RoSPA, in celebrating the 25th anniversary of the seat belt law, was making ludicrous claims for its effect.

Having failed to elicit any response four years ago now, on the 30th anniversary, I renew my invitation in the form of an open letter. I invite your comments on my recent post “30 years in the jungle with RoSPA” .

I invite two comments in particular:

  1. Given that on the third anniversary of the law Lord Nugent, your former president, was claiming that the law was saving 200 lives a year, how do you justify RoSPA’s recent anniversary claims of 2400 lives a year – i.e. 60,000 lives saved over 25 years?  (Please note my answer at the time to the evidence on which Lord Nugent relied for his claim of 200 lives saved -     Journal of the Royal Statistical Society Series A, 149, 187-227.)
  2. In the light of the comment by Lord Nugent that RoSPA “certainly could not support any road safety measure which discriminated in favour of one section of the community rather than another” – do you think that my “Organ Harvester Lottery” is a fair characterization of the discrimination acknowledged by Allsop et al in their Significance article?

Hoping to hear from you

John

PS  This open letter is not an attempt to settle very old scores. It is an attempt to get RoSPA, an influential organization concerned with risk management, to confront the reality of risk compensation.

When I first became involved in the seat belt debate over 30 years ago the risk compensation hypothesis was jeered at in Parliament: it was “bogus”,  “spurious”, “eccentric”, “ludicrous” and, more politely, “unproven” and “new”. It now merits a Wikipedia entry:

Risk compensation (also Peltzman effect, risk homeostasis) is an observed effect in ethology whereby people tend to adjust their behavior in response to perceived level of risk, behaving less cautiously where they feel more protected and more cautiously where they feel a higher level of risk. The theory emerged out of road safety research after it was observed that many interventions failed to achieve the expected level of benefits but has since found application in many other fields.

That people adjust their behavior in response to changes in perceived levels of risk has now become a commonplace. Where (if) there is debate about the phenomenon it now usually focuses on whether compensation is partial, complete, or more than complete – except in the case of seat belts legislation where, for campaigners such as RoSPA, it apparently still does not exist.

Acknowledgement of the phenomenon is essential to an intelligent civilized discussion of any risk management problem. A quick Google search will show that it features in discussions ranging from flood control, anti-lock brakes, cycle helmets, sexual behavior, skydiving, and sub-prime mortgages to shared space and warship safety – amongst many others.

RoSPA’s continuing repetition of its nonsense claims for the efficacy of Britain’s seat belt law is in danger of undermining its credibility in other areas where it undertakes useful work.

Feb
08
2013

30 years in the jungle with the Royal Society for the Prevention of Accidents

 31 January marked the 30th anniversary of the implementation of Britain’s seat belt law. A television interviewer sent to quiz me about my opposition to the law said I reminded him of Hiroo Onoda, the Japanese soldier who spent 30 years in the jungle, fighting on, unaware that the war had been lost. The interview was not broadcast; I assume that when he got back to the office his boss decided that after 30 years the story was no longer newsworthy.

I have actually been in the jungle for more that 30 years. In 1981 I produced a paper entitled The Efficacy of Seat Belt Legislation (published in 1982 by the Society of Automotive Engineers). The paper earned me a gratifying number of column inches in the Hansard report of the 1981 Parliamentary debate that resulted in the passage of the law that was finally implemented in January 1983. The column inches were reasonably equally divided between those who were persuaded by my evidence and those who weren’t.

The debate was introduced by Conservative MP Ivan Lawrence whose opposition to the law was essentially libertarian. But he welcomed my evidence that the law would not save lives.

Mr. Lawrence This is one of those subjects which stir feelings deeply and genuinely, regardless of party politics. It touches upon freedom, and all of us have been sent to this place to protect, as far as we might, the individual liberties of our constituents against the remorseless hunger of a State and bureaucratic machine trying to gobble it up. …..    ……  we now have some solid evidence that we have never had before. In earlier debates we have heard talk of some figures from Australia that were airily waved about as supporting the compulsion case, but we were never given any statistics from the many other countries experiencing compulsion. Now we have just that. We have a comparative study of road fatality statistics in no fewer than 18 countries, covering about 80 per cent of the world’s car population.

Examining the national statistics which have not been available earlier, Mr. John Adams of University College, London, in January this year published his findings.

Mr. Austin Mitchell (Grimsby) The only one that the hon. and learned Gentleman can dredge up.

Mr. Lawrence It is a darned sight more than anything that has ever been dredged up by the arguers for compulsion on the Opposition Benches, who have never presented this House with a comprehensive analysis of the statistics.

Mr. Mitchell rose—

Mr. Lawrence I hope that the hon. Gentleman will be able to catch your eye later, Mr. Speaker. However, I am conscious that many hon. Members wish to speak. Therefore, I hope that the hon. Gentleman will forgive me if I continue.

Mr. Mitchell rose—

Mr. Lawrence Mr. John Adams of University College, London, compared Belgium, Denmark, Finland, France, Germany, Holland, Norway, Spain, Switzerland, Sweden, Israel, Australia and New Zealand—all countries with a compulsory seat belt law that is enforced—with Italy, the United States of America, Japan and Great Britain, where there is either no compulsory seat belt law or it is not enforced.

Mr. Adams’ findings are astonishing and unexpected. Although most of the countries experienced a substantial decrease in road accident fatalities in the years following the 1973 oil crisis, the decrease was greater in those countries without a compulsory seat belt law than in those countries with one.

Mr Mitchell rose—

Mr. Lawrence The hon. Gentleman will have to carry on—

Mr. Deputy Speaker (Mr. Bernard Weatherill) Order. The hon. and learned Gentleman is not giving way.

Mr. Mitchell I wondered whether the hon. and learned Gentleman was giving way.

Mr. Lawrence The hon. Gentleman can carry oil wondering. I should like to complete my case. The promise of massive reductions in the number of deaths because of compulsion simply has not materialised. There is no evidence to show that seat belt compulsion—taking accidents overall—saves lives; nor does it reduce the overall number of injuries. However, the inherent unreliability of comparative statistics makes any positive conclusion about injuries impossible.

That survey has put the cat among the pigeons. Those who have stood up publicly for compulsion have some understandable reluctance to stand on their heads in public, whatever the evidence may be. Others, less publicly committed, will want to stop and reconsider the matter. The first attack made on Mr. Adams’ inconvenient findings was that he had not substantiated his tentative hypothesis that the reason why there seemed to he no reduction in the death rate, and probably an increase after compulsion, was that “protecting car occupants from the consequences of bad driving encourages bad driving.” As a rock climber may take more risks when wearing a harness, so a car driver may do so. That attack was irrelevant. Mr. Adams was only describing the statistics. He did not set out to explain them and still less to prove an explanation. It is for all of us to consider why those statistics produce that astonishing result. However, it is beyond argument that they produce it.

The next attack came from Lord Nugent, who proposed the amendment in the other place. On 11 June—only six weeks ago—he said that Mr. Adams’ mistake was to muddle up pedestrians, cyclists, motor cyclists and so on with the only relevant victims—drivers and front seat passengers. I hear notes of assent and support for that criticism from Opposition Members.

Mr. George Foulkes (South Ayrshire) Nonsense!

Mr. Lawrence I hope that we shall hear some constructive speeches from Opposition Members, rather than “Nonsense!”

Lord Nugent’s criticism of Mr. Adams was patent rubbish since the survey and its appendix contained three graphs, giving information about car occupant fatalities in Sweden and in seven EEC countries. Nevertheless, the criticism was repeated by Dr. Murray MacKay in a letter to The Times on 11 June. Mr. Adams replied, pointing out the error of his critics in The Times in a letter of 16 June. That seems to have made no difference. Once some people have made up their minds, they will not change them, whatever the facts.

On 26 June, the motoring correspondent of The Times repeated the error. Once again, the patient Mr. Adams drew the attention of The Times to the error and once again, the correction was ignored. The leader in The Times stated: “Dr. Adams fails to distinguish sufficiently between all road user casualties and those among car occupants.”

Mr. Austin Mitchell rose—

Mr. Lawrence Mr. Adams has produced 57 graphs. He concludes: “Nowhere in all this data can there be found any evidence of the enormous beneficial effect promised by the advocates of legislation. On the contrary the data persistently suggests that the effect of the legislation, if there is one, is perverse.” There, for the moment, the evidence rests.

Now, more than 30 years on, the Royal Society for the Prevention of Accidents has issued a press release to celebrate the implementation of the law and to celebrate the role of Lord Nugent (their then president) in its passage. The press release also adds to the “patent rubbish” of which Ivan Lawrence complained:

31 January 2013

ACTION STILL NEEDED TO SAVE LIVES 30 YEARS AFTER SEATBELT LAW, WARNS RoSPA

Greater compliance with seatbelt legislation could help save lives in road crashes says RoSPA, as it marks the 30th anniversary of the law coming into force.

Well over 60,000 lives have been saved by seatbelts since January 31, 1983, when the Royal Society for the Prevention of Accidents’ then-President, Lord Nugent of Guildford, won the day for compulsory wearing in the front seat of cars by introducing an amendment to the Transport Bill in the House of Lords. A law making it compulsory to wear seatbelts in the back of cars was introduced in 1991.

RoSPA is shameless. On the 20th anniversary of the law they claimed it had saved 50,000 lives. On the 25th anniversary they claimed 60,000 – or 2400 lives a year. Now, on the 30th anniversary, using the scientific method called hand-waving extrapolation they claim “well over 60,000”.

The nonsense of RoSPA’s 60,000 claim was exposed in a number of postings at the time of the 25th anniversary. It was a claim also made in a Department for Transport press release and in a press release by PACTS (the Parliamentary Advisory Council on Transport Safety). The 25th anniversary claims can still be found on the DfT and PACTS websites. PACTS was especially proud of it contribution to the achievement:

On the 31st January 2008, the 25th anniversary of the law change which made front seatbelt wearing compulsory was celebrated. PACTS itself was set up by Barry Sheerman MP as part of the fight to get mandatory seatbelt wearing turned into legislation. Eight years later it became compulsory for all backseat passengers to use seatbelts and it is estimated that since the introduction of the first law change in 1983, seatbelts have prevented 60,000 deaths and over 670,000 serious injuries.

Intriguingly, a few months after this press release four prominent road safety experts who describe themselves as being “among the leadership of the Pacts” – Richard Allsop, Oliver Carsten, Andrew Evans, and Robert Gifford – published an article in Significance, a journal of the Royal Statistical Society, in which they advanced a much more modest claim for the number of lives saved by the seat belt law: not 2400 per year but 164.

Also intriguingly, for the first time of which I am aware, serious, statistically-qualified, advocates of seat-belt legislation acknowledged a risk transfer effect:

“The clear reduction in death and injury to car occupants is appreciably offset by extra deaths among pedestrians and cyclists”.

and

“the best estimates from both the analyses summarised here are that extra deaths to vulnerable road users did accompany the introduction of mandatory wearing of seat belts.”

Table 1 from Allsop et al summarizes the risk transfer effect for vulnerable road users – cyclists, pedestrians and rear sear passengers who were not covered by the seat belt law.

TABLE 1

The seat belt law, they explained, has

“two potential unintended effects. First, the affected group may have more collisions, perhaps through taking greater risks, realizing that the likely consequences of collision have been reduced. Second, there may be an increased risk to other road users not protected by the safety measure. In these ways, the reduction in death and injury in the protected group may be partly offset by extra death and injury caused to others.”

Dedicated readers of this website will recognize that these two unintended consequences are what for some decades I have been calling “the risk compensation effect”.

Allsop et al went on to observe that

“Whether belts are worn by choice or by law, these unintended effects could lead to the number of deaths to belted car occupants falling by less than the amount one would expect if they were unbelted, and to extra death and injury among pedestrians, cyclists and unbelted occupants. This applies equally to legislating for belt-wearing and to simply encouraging it: it should rule out neither, but be taken into account when considering either.”

For 30 years the common response to this argument has been that of David Ennals (above), a supporter of the law, who referred in the parliamentary debate to “the extraordinary argument by Dr. John Adams of University College, London that the wearing of seat belts could lead to a false sense of complacency.”  He went on to assert that “the hypothesis is that ‘protecting an occupant from the consequences of bad driving encourages bad driving’,” adding “there is no evidence of that.” He went on to thank RoSPA for producing evidence that proved me wrong – yes RoSPA and I go back a long way.

RoSPA never got round to publishing the evidence. Mine passed peer review and was published in the Transactions of the Society of Automotive Engineers as The efficacy of seat belt legislation.

Other comments on my paper made during the debate will convey the flavour

  • “that [Adams’]piece of research was, as I have said before, bogus.”
  • “the so-called new evidence of Mr. Adams.”
  • “Mr. John Adams is a lecturer in geography.”
  • “He has produced an eccentric paper and has made the preposterous suggestion that the wearing of seat belts encourages people to drive more dangerously.”
  • “Is it seriously argued that safety devices make people behave more dangerously? I think that the majority of people would consider that a ludicrous proposition.”
  • “Those of us who have attempted to look at the problem seriously find the evidence in Dr. Adams’s paper highly spurious and bogus.”
  • “Professor Adams’s thesis is unproven. It is new.”

Lord Nugent does indeed deserve much of the credit that RoSPA bestows upon him for the passage of the law. Shortly before the debate he sent a letter on behalf of RoSPA to every MP stating:

“Dr Adams has recently published a paper advancing the thesis that wearing seat belts may actually increase road accidents by encouraging a false sense of security. … His paper requires detailed analysis with the aid of much background information from the countries concerned before authoritative comment can be made upon it. RoSPA and the Transport and Road Research Laboratory are undertaking these studies, meantime it is relevant to record that Dr Adams does unequivocally state that wearing seatbelts greatly improves the chance of avoiding injury.”

The immediate objection to the letter that I made at the time was that it was disingenuous. I had stated that seat belts improve a car occupant’s chances of avoiding an injury in a crash. The fact that fatalities and injuries, to occupants and others, had not fallen with the implementation of the law was my principal evidence for risk compensation.

A second objection can now be raised. After 30 years, the results of the RoSPA studies commissioned by Lord Nugent have yet to be published, nor has its preposterous contention that the seat belt law is saving 2400 lives a year been justified.

While RoSPA’s contribution to the seat belt debate over the last three decades can be dismissed as hand-waving statistical nonsense, the argument of Allsop et al deserves further consideration, if only because its authors have established track records as serious transport safety researchers

Despite having accepted that lives of vulnerable road users have been lost as a result of the seat belt law – 268 according to their Table 1 – they still argue that seat belt laws should be retained because they save more lives – 432 car occupants – than they cost. Here is their justification for keeping a law that – by their estimation kills 268 “vulnerable road users” a year

“road safety is made up of many individual safety measures and equity among road user  groups across road safety policy as a whole in no way implies that each individual safety measure should in itself benefit all road user groups equitably. Nor does each road safety measure necessarily act only to reduce death and injury: many measures reduce aggregate death and injury by reducing them in incidents of certain kinds by more than they increase them in other kinds. A case in point is installing central barriers on motorways. These prevent many deaths and injuries by preventing errant vehicles on one carriageway crossing onto the other and then having very injurious head-on collisions.

But there are some incidents in which injury or death result from a vehicle striking the barrier and bouncing back onto its own carriageway when the opposing carriageway was fortuitously clear of traffic; had there been no barrier, there would have been no injuries. That is no reason to do away with motorway barriers. The barrier is justified when the deaths and injuries prevented outweigh appreciably the extra deaths and injuries that result from its presence.

It would therefore be a severe constraint on the use of safety measures if any measure were to be ruled out for which the larger number of deaths and injuries saved were differently distributed among road user groups from the smaller number resulting from the measure—the more so because most of us at different times belong to different user groups.

The wearing of seat belts is therefore not exceptional among safety measures in that extra deaths and injuries that may arise from wearing occur in part (only in part because, if wearers drive more riskily, some of the extra deaths and injuries will occur to vehicle occupants) to different road user groups than those among which deaths and injuries are prevented—though the difference is perhaps sharper for belt wearing than for many other measures

Any increase in death and injury to pedestrians and cyclists that stems from wearing of seat belts should be borne in mind in the formulation of road safety policy as a whole and contribute to prioritising safety measures benefitting pedestrians and cyclists. But so long as wearing of belts saves substantially more death and injury among vehicle occupants than the increase among pedestrians and cyclists, the latter does not rule out the provision and wearing of belts. Nor, therefore, does it rule out laws requiring the wearing of belts.”

When I first encountered this sophistry (both seat belts and central barriers are measures designed to protect vehicle occupants) justifying the killing of the vulnerable to save the lives of the best protected I put it to one of the authors, Rob Gifford, that the same argument would justify an “organ harvester lottery”:

“In the light of that argument I would welcome your comment on this analogy: an Organ Harvester Lottery in which healthy people will be selected at random (not unlike road accidents) to “donate” organs to people in need of them. One heart and one liver could save two lives at the cost of one – slightly better than the ratio that you argue justifies keeping the seat belt law. Throw in two kidneys and you get a four to one ratio of lives saved to lives lost. This is a gruesome but not wholly inappropriate analogy given the myth circulating at the time (and still) that the success of the seat law was responsible for increasing the shortage of donor organs.”

I have yet to receive a challenge from the PACTS authors to the appropriateness of this analogy.

Let us conclude with an examination of the appropriateness of the analogy comparing me to Hiroo Onoda with which we began. According to this analogy my war against seat belt laws was lost over thirty years ago with the passage of Britain’s first seat belt law.

In one sense the war has indeed been lost. The myth of the efficacy of seat belts and seat belt laws is now so deeply entrenched that it appears to be immune to evidence. It is routinely advanced in support of other safety regulation, such as compulsory cycle helmets, as an example of the efficacy of measures that compel people to be safer than they voluntarily choose to be.

An acceptance of the myth leads to its routine insertion into all sorts of other arguments. I offer a recent example from the New York Times – an article by a Cambridge philosopher, Huw Price, explaining why he was working to establish in Cambridge “the Centre for the Study of Existential Risk (C.S.E.R.).”

His project he likens to a societal seat belt. He elaborates the analogy:

“our fate is in the hands, if that’s the word, of what might charitably be called a very large and poorly organized committee – collectively short-sighted, if not actually reckless, but responsible for guiding our fast-moving vehicle through some hazardous and yet completely unfamiliar terrain.”

and

“Second, remember that all the children – all of them – are in the back. We thrill-seeking grandparents may have little to lose, but shouldn’t we be encouraging the kids to buckle up?”

A fact not widely known to those who might be persuaded by this analogy is that, when Britain passed a law in 1989 requiring children in back seats to belt up, the number of children killed in back seats increased (see Risk, pp 126-127). My provisional explanation, pending a more convincing one: when the children were secure in their government approved safety harnesses, parents reverted to their customary, vigorous, style of braking, cornering, and accelerating.

So common is the deployment of the efficacious-seat-belt analogy that I, for peace of mind, have learned, to let it pass.  But in this case, sensitised by the impending 30th anniversary celebrations, I ventured a comment.

The myth of the efficacy of seat belt legislation

Why should the belief in the efficacy of the law have persisted for so long in the face of so much evidence that it hasn’t worked? Myth has been called  ”ideology in narrative form”.

The narrative. Before the passage of the law in 1981 there had been numerous parliamentary debates about a seat belt law. Over this period the evidence, and popular support, appeared to grow stronger. Experiments with crash test dummies provided convincing graphic evidence of the protection afforded by seat belts in crashes. And in the early 1970s all the Australian states passed seat belt laws that appeared to arrest a long established rising trend of road accident deaths. The belief in the potential road safety legislation to save lives gained momentum.

By the time of the 1981 debate the law had acquired a large number of influential champions – practically any organisation with an interest in road safety – including the British Medical Association, the Royal society for the Prevention of Accidents, the Royal College of Surgeons, the Royal College of Nursing, the Society of Automotive Manufacturers and Traders, and the Automobile Association. Lord Avebury offered this list in a House of Lords debate as compelling evidence for legislation: “Why”, he asked, “would all these institutions seek to mislead the public?”

But none of these organisations, and none of the countries that followed the lead of Australia, produced any compelling evidence that legislation had saved lives. They all cited the original, misconstrued, Australian evidence, or other people citing the Australian evidence, or other people citing other people citing the Australian evidence.

Ever since, the champions of the law have felt free to assert its effectiveness with impunity. Five years ago I pointed out to the Department for Transport, the Parliamentary Council for Transport Safety and the Royal Society for the Prevention of Accidents that their 25th Anniversary claim that the law had saved 60,000 lives was preposterous. But the claim can still be found on their websites. Echoing Lord Averbury one might well ask, “why would these institutions seek to mislead the public?”

 

 

 

 

Aug
01
2012

Is ISO 31000 fit for purpose?

The debate

“Is ISO 31000 fit for purpose” is the headline above a debate published in the June edition of Risk Management Professional – for online version click here. The “debate” consisted of an abbreviated version of my blog – “ISO 31 000: Dr Rorschach meets Humpty Dumpty” -­‐ and a “rebuttal” by Grant Purdy, one of the principal authors of the ISO Standard.

“Debate” and “rebuttal” have been enclosed in quotation marks because a serious debate did not take place. The rebuttal is entitled “Never perfect, but inclusionary, practical and widely accepted”, and consists mostly of an explanation of (and excuse for) any imperfections that it might have.

It observes that:

  • “standards may not reflect the ‘best available’ practices and leadingthinking.”
  • “a standard can be biased because of prevailing influences in the committeethat prepared it.
  • “significant compromises are often required to obtain consensus in acommittee.” and concedes that

• “it would be naïve to think that ISO 31000 could not suffer from any of the problems described above.”

The rebuttal further acknowledges “some fudging” and “some unnecessary complexity”. None of these admissions of possible imperfection are related to any specific parts of ISO 31000; readers are left to work out for themselves where within the document they might be found.

Is it fit?

But let’s move on to the purpose of ISO 31000. … read the full essay here  

May
07
2012

ISO 31000: the debate warms up

Until recently most online discussion of ISO 31000 has been confined to a friendly Linkedin site for supporters: two quotations – “I know the ISO 31000 and think it’s almost perfect” and “I think the ISO 31000 definition of risk is great” – will convey the flavor of the critical discussion to be found on the site.

The discussion is frequently ad hominem – in a nice way. Participants who agree with each other declare their mutual respect warmly – “I value your connection/friendship dearly.” But when skeptics or heretics attempt to join the discussion it can turn ad hominem in a nasty way.

Indeed outsiders do not even have to attempt to join the Linkedin forum; they can be dragged in. This happened recently to Robert Kaplan of the Harvard Business School. After speaking at a conference he was approached by one of the audience and asked his opinion about ISO 31000: “When I personally asked him afterwards to clarify how he saw ISO 31000 fitting in, he put it in the same basket as any other standard and ‘not relevant’ (implying not relevant to the future advancement of ERM).”

When asked, he said something that implied something. This was sufficient to involve him (in absentia} in a heated discussion on the ISO Linkedin site that degenerated into personal abuse.

One participant described him as “another arrogant potion peddling merchant that really should be treated as such although, this one seems to hide behind the curtain and title of a university doctrine [sic] to make the whole experience feel authentic for the next manager that is about to be ripped off.”

The convenor of the discussion declared at one point, “it is really upsetting that Dr. Kaplan’s team’s research is limited [sic] with LinkedIn ISO 31000 group. They did not asked [sic] permission for that and the legal rights are belongs [sic] to us not to him. We need to sue him for this.” It is not clear what this means or what “that” is. But we need to sue him!

The tone is consistently ad hominem, varying between nasty and nice depending on the participant’s perspective: “these people are a liability for the progression of risk management”, “excellent comments”, “I have no desire to waste my time with charlatans”, “100% agree” … etc. etc.

At one point in the discussion the ubiquitous Arnold Schanfield of Manhattanville College denounces Peter Bonisch of Paradigm Risk as “dishonourable”. He elaborates “We [i.e. the ISO fan club] are all offended by your remarks most of which cannot be supported and defended and your intentions are indeed dishonorable. If they were honorable you would be taking part in a discussion on what we need to do to move the discipline forward. Instead you have chosen to attack those individuals/professionals with very strong risk management backgrounds in a non stop barrage of $50,000 words [sic].” As with much else on this Linkedin site it is not entirely clear what this is intended to mean (or how the price of words was calculated) – other than that Schanfield stands by his view that Bonisch is dishonourable.

Bonisch has now retreated to the calmer, more dignified and coherent environment of his own blog and published an essay worth reading.

He begins by quoting a statement by Kaplan that I find difficult to argue with. It suggests that his (Kaplan’s) position is more nuanced than that attributed to him following an oral conversation:

“Standards and innovation have an inherent tension between each other, in some cases they can be mortal enemies. We standardize when we understand a process very well and want to ensure that everyone follows the same processes and measurements because they have been proven to yield superior results. But in an environment with limited knowledge and experience, premature standard setting will inhibit innovation, exploration and learning. We can standardize around preventable risks because managers do understand them well, and have developed excellent processes to prevent them from occurring. But we are just learning about the management of strategy risks and external, non-preventable risks. To think we can standardize the “best practices” for managing these two risk categories through an ISO-based process seems like a highly risky proposition for risk professionals to be engaged in with our present body of knowledge.”

Skipping to the end, Bonisch concludes, tellingly, by calling attention to an ISO 31000 injunction that I touched upon in my last blog on this subject: the risk manager should “generate a comprehensive list of risks”. ISO 31000 leaves the reader in no doubt about the importance of comprehensiveness:
 Management’s framework should be “comprehensive”
 “Comprehensive identification is critical”
 The organization should have a “comprehensive understanding of its risks”
 Enhanced risk management includes comprehensive, fully defined and fully accepted accountability for risks, controls and risk treatment tasks
 “Enhanced risk management includes … comprehensive and frequent reporting of risk management performance”
 There is a “need for risk treatment against properly established and comprehensive risk criteria” and
 “Comprehensive and frequent external and internal reporting … contributes substantially to effective governance within an organization.”

“In the face of irreducible uncertainty”, Bonisch asks, “how can analysis of its effects ever be comprehensive?”

Consider the “comprehensive” challenge through the eyes of a project manager tasked with producing a “comprehensive” event tree. It would be a strange tree, unknown to nature. It would have an infinite number of branches of varying lengths and numbers of branching points.

The branching points on some branches, let’s call these branches “probabilistically-known knowns”, can be assigned probabilities with relatively small error bands. This is the realm of someone, such as an actuary in a motor insurance company, working with large and stable actuarial databases.

Other branches, let’s call them “known unknowns” because the branching points represent imaginable possibilities, and the probabilities assigned to them are speculative; they have such wide error bands that they are effectively quantified expressions of ignorance. The fire that closed the Channel Tunnel for six months shortly after it opened had been assigned a probability in an event tree of somewhere between zero and 2.8 per billion journeys.

But the largest number of branches and branching points, a number that renders my contention of “infinite” unchallengeable, is the number of the unknown unknowns. We now live in a world inhabited by more than seven billion risk managers interacting reflexively with each other, and with natural hazards. The computer required to manage such a system is unimaginable, because once it started managing, it too would get caught up in myriad infinitely reflexive loops.

If one wants certainty one must turn to the fault tree. The event tree is a map of infinite possible futures. The engineer’s fault tree is a map of the post-accident past, and it commonly has only one branch called “culpable negligence”. (see dangerous trees)

So, what hope of demonstrating the (in)effectiveness of ISO 31000 or COSO or any other risk management standard? Concorde, before it crashed, could claim to be the safest airliner in the world – zero fatalities. After it crashed it became the airliner with the highest fatality rate per mile flown – because it had flown so few miles.

Good luck to those who hope to demonstrate the superiority of their risk management standards. Enron and Concorde had lots of fans – until they crashed – comprehensively. The ISO 31000 standard says that the risk manager “should allocate appropriate resources for risk management”. What it does not say is how, with finite resources and infinite uncertainty, one should define “appropriate”.

Apr
13
2012

Post hoc, trees are dangerous

Last night (11/4/2012) I took part in an interesting Radio 3 discussion programme called Night Waves . The first contributor, Jonathan Haidt, was fascinating and I’ve just ordered his new book The Righteous Mind.

In the discussion he made a point that resonated with a problem that I have been wrestling with: discussing the relationship between reason and emotion he said, “reason is mostly post hoc”. Risk management decisions are taken pre hoc. They are decisions taken with insufficient information. They are decisions about an uncertain future. Post hoc, after the event/accident, there is usually much more information to which one can apply cause and effect reasoning. Before the event the links between causes and effects are either unknown or shrouded in estimates of probability, with large error bands attached. The information gap confronting a risk manager is readily filled by “emotion” – the natural instinctive state of mind deriving from one’s circumstances, mood, or relationships with others.

Event Trees, beloved of engineers and project managers as a method for describing the risks associated with big projects, represent a denial of this reality (see Dangerous Trees?). All of the branching points on each limb of their trees must be assigned probabilities, usually with large error bands. By the time one reaches the tip ends of the branches the compound error bands are too large to fit on the page, so the magnitude of the uncertainty is ignored.

In the dangerous trees example just referred to an actual tree blew down and killed some one. In Britain, averaged over the whole country, the statistical risk of such a thing happening in a given year is about 1 in 10 million. Britain’s Health and Safety Executive describes risks of 1 in 1 million as “adequately controlled”. But after the event different sorts of reasoning are brought to bear. The police, who are predisposed to allocate blame in such circumstances, arrested the head estate warden and the estate manager on suspicion of negligent manslaughter. The coroner declared, a year and a half later, that all mature trees on the estate’s land adjacent to paths should be inspected and logged – a requirement that, if applied to all the National Trust’s properties (whose estate it was) might have bankrupted the institution.

Post hoc Event Trees are often transformed into Fault Trees that, with the aid of clear facts and “reason”, are transformed into trees with only one branch called “culpable negligence”. What pre hoc appeared a risk of 1 in 10 million, post hoc becomes a risk of 1 in 1.

After a year and a half the Crown Prosecution Service, dropped the case for lack of evidence, but a threat of dire consequence still hangs over the National Trust. Given the many millions of mature trees in Britain, the risk assessment and risk management implications of the coroner’s judgment, pursued to their logical conclusion would require the diversion of enormous resources to inspection and/or the execution of countless mature trees that could not be guaranteed 100 percent safe – and who would offer that assurance in our litigious times? This experience is now colouring the (emotional?) judgment of Britain’s tree managers. In deciding what trees must be executed the legal risk now far outweighs the physical risk.

Feb
22
2012

ISO 31000: Dr Rorschach meets Humpty Dumpty

Much advice is proffered in cyberspace about how to manage risk: at the time of writing, tapping “risk management” into Google yielded 72 million hits. Do you sometimes (frequently?) on reading risk management guidance get to the end without a clue as to what the guide expects you, the risk manager, to actually do?

I am currently having this problem with ISO 31000 – Risk management — Principles and Guidelines. The International Standards Organization published these guidelines in 2009 and with them appears to aspire to global leadership, if not domination, of the risk management industry. According to Kevin Knight, leader of the group that produced the document, it is comprehensive and global in reach – it “provides principles and practical guidance to the risk management process” and it applies to everyone everywhere – it is “applicable to all organizations, regardless of type, size, activities and location and should apply to all types of risk.”

A game anyone can play
I have now read it many times and still do not know what is expected of me. And I think I have worked out why. It repeatedly tells me to do what is “appropriate”: it tells me that my involvement with stakeholders should be “appropriate and timely”; that I should consider “the most appropriate ways to communicate with [stakeholders]”; that I “should allocate appropriate resources for risk management”; and that I should “communicate and consult with stakeholders to ensure that [my] risk management framework remains appropriate.” The guidance to do the “appropriate” thing appears 34 times in 26 pages.

What is “appropriate”? Those deploying the word appear to assume that all readers will share its meaning. But anyone plugged into discussions about the influence of disparate cultural perceptions of risk will appreciate that this is a facile assumption. All these “appropriates” are Rorschach inkblots. The famous Rorschach test is known as a projective test. Subjects are shown ambiguous stimuli (inkblots) and asked to say what they see. Although psychologist have failed to reach a consensus on the interpretation of the answers it is clear that different people project very different meanings onto ambiguous stimuli.

“Appropriate” is not the only inkblot in ISO 31000. There are 33 “effectives” (“this International Standard establishes a number of principles that need to be satisfied to make risk management effective.”); 13 “culture/culturals” (“Risk management takes human and cultural factors into account.”); 9 “relevants” (I should ensure that “risk management remains relevant and up-to-date”); 8 “comprehensives” (I need “to generate a comprehensive list of risks”); plus 4 “acceptables” and 4 “tolerables”.

Using this (incomplete) list of inkblots I divide 105 inkblots by 26 pages and award ISO 31000 an inkblot score of 4.03. It is a game that anyone can play and I offer it as a way of quantifying the sense of vague dissatisfaction generated by so much of the current risk management literature.

Humpty Dumpty
Humpty famously told Alice “When I use a word it means just what I choose it to mean — neither more nor less.”

One word in ISO 31000 is most definitely not an inkblot. “Risk” is defined as “the effect of uncertainty on objectives – positive and/or negative”.

The document is forcefully determined that the meaning of the word should be absolutely clear to all readers. Section 2 contains 29 terms and definitions elaborating on the meaning of “risk” and its use in the document – supplemented by 44 explanatory notes. Section 3 contains eleven “principles” that turn out to be further definitions, e.g. “d) Risk management explicitly addresses uncertainty.”

But all this is not sufficient. To be absolutely confident that one is on the ISO 31000 wavelength one must master Risk management – Vocabulary (ISO Guide 73:2009). This is a 15-page dictionary further elaborating the terms and definitions of ISO 31000. An example: ISO 31000 refers to “stakeholders”, but one needs the ISO vocabulary to be confident of knowing what this word means – “a person or organization that can affect, be affected by, or perceive themselves to be affected by a decision or activity”. The Guide provides 49 such examples (supplemented by 56 more notes).

The ISO definition of risk – “the effect of uncertainty on objectives – and/or negative” – is described by the leader of the group that produced it, as “pivotal”. Certainly it is the pivot, the authors are determined, around which all discussion of risk management should rotate. But they have a couple of problems.

The first is that their definition of risk as something “positive and/or negative” is shared by no other dictionary. “Risk” as the rest of the world uses the word is negative. It is
• · “the possibility that something unpleasant or unwelcome will happen (http://oxforddictionaries.com/definition/risk) , or

• · “A probability or threat of a damage, injury, liability, loss, or other negative occurrence that is caused by external or internal vulnerabilities, and that may be neutralized through preemptive action” (http://www.businessdictionary.com/definition/risk.html ), or

• · “possibility of loss or injury : peril, someone or something that creates or suggests a hazard” (http://www.merriam-webster.com/dictionary/risk)

The established dictionaries have the merit of defining words as most people use them. With its idiosyncratic definition the ISO appears to aspire to establish itself as a priestly caste with a private vocabulary inaccessible to the vulgar horde.

There has been an attempt by ISO supporters to gain a foothold in other dictionaries. The Wikipedia definition of risk is in agreement with the established dictionaries: “Risk is the potential that a chosen action or activity (including the choice of inaction) will lead to a loss (an undesirable outcome).” (http://en.wikipedia.org/wiki/Risk).

But then an ISO enthusiast took advantage of Wikipedia’s open-editing facility to add the following: “The ISO 31000 (2009) /ISO Guide 73 definition of risk is the ‘effect of uncertainty on objectives’. In this definition, uncertainties include events (which may or not happen) and uncertainties caused by a lack of information or ambiguity. It also includes both negative and positive impacts on objectives. Many definitions of risk exist in common usage, however this definition was developed by an international committee representing over 30 countries and is based on the input of several thousand subject matter experts [my emphasis added].”

The ISO definition may well be now shared by several thousand linkedin “experts”, but the problem is that they are vastly outnumbered by the hundreds of millions of other lay and expert risk managers who share the dictionary meaning – who understand risk to be something negative. From Britain’s Health and Safety Executive (mantra “Reducing Risks, Protecting People”) to the quants who calculate Value at Risk, most risk experts still side with the dictionaries. The consoling mantra of day traders after a bad day is “No risk, No Reward”. Outside the ISO club risk means what the dictionaries say it means.

A second problem encountered by the “expert” advocates of ISO 31000 is that their job as risk managers involves communicating with non-experts. Their definition of the key word “risk” that will be central to these communications is not only not in the dictionaries that most of the non-experts are likely to consult, but can be found only in ISO 31000 and the supplementary vocabulary ISO Guide 73. These documents cost CHF 112 ($104) and CHF 86 ($80) respectively.

When Alice questioned the meaning of a word that Humpty Dumpty had used he replied, “The question is which is to be master — that’s all.” In attempting to assert its mastery over the word risk, a word requiring 178 expensive terms, definitions and notes before those deploying it can be confident that they know what they mean by it, the ISO experts face a challenge. “When I make a word do a lot of work like that, said Humpty Dumpty, I always pay it extra.” Payment is likely to take the form of tears of frustration.

ISO 31000 and the IRM
In 2010 the IRM published an endorsement of ISO 31000 in a document entitled A structured approach to Enterprise Risk Management (ERM) and the requirements of ISO 31000. It says “this guide [the IRM Guide] provides a structured approach to implementing risk management on an enterprisewide basis that is compatible with both COSO ERM and ISO 31000.”

It runs into an immediate problem. ISO and COSO cannot agree on the meaning of the word at the centre of the exercise – “risk”. COSO sides with the dictionaries and views it as negative – “the possibility that an event will occur and adversely affect the achievement of objectives” while ISO defines it as “positive and/or negative”. Humpty Dumpty has yet to pronounce.

The IRM document shares with ISO 31000 an impressively high inkblot count – words onto which readers will project variable subjective meanings. In 17 pages it has 21 “appropriates”, 16 “significants”, 14 “effectives”, 14 “culture/culturals”, 13 “effectives”, 7 “comprehensives” and 4 “sufficients” – yielding an inkblot score of 5.3 – or 36 if you add the 523 occurrences of “risk” which, thanks to the ISO/COSO definitional conflict, has itself become an inkblot. The sentence “Achieving a good risk aware culture is ensured by establishing an appropriate risk architecture” conveys the flavour of the difficulty confronting those seeking to standardize risk management guidance. Which definition of risk will the health and safety officer, investment banker, compliance manager, financial regulator, or teacher producing a risk assessment for a school trip, have in mind when reading this sentence?

Although “culture” appears liberally in both documents it is used without content. There is no apparent awareness, acknowledgement or application of the substantial literature by behavioural economists, psychologists, anthropologists and members of other academic disciplines on the influence of cultural biases. The subtitle of the seminal work Risk and Culture, by Douglas and Wildavsky almost 30 years ago is “An Essay on the Selection of Technological and Environmental Dangers”. Ever since then cultural influences on the threats that people select to worry about, or choose to ignore, have generated an impressive literature. Why are GMOs shunned in Europe while planted over millions of acres in the United States? Why do middle-aged women have much lower road accident rates than young men? Who worries about global warming, and why? And what induced some derivative traders to place bank-busting bets? ISO 31000 appears oblivious to such questions. Why?

In an article in Risk Analysis Grant Purdy, one of the principal architects of ISO 31000 describes it as “a new globally accepted standard for risk management”. Accepted globally? Accepted by whom? Most, the vast majority, of the people around the globe interested in risk management have never been asked. They have never read it, and probably never heard of it. The academic world is comprehensively ignorant of it because it can be found in no libraries. If it, and its associated vocabulary, were to be made available in libraries sales of these documents at CHF 198 would be severely compromised.

No academics I know are likely to pay such a sum for the privilege of reading them. For a start they would not be interested in writing about something almost none of their colleagues had heard of – I have only been able to join this discussion because an anonymous friend sent me bootleg copies.

The academic world depends on open access to sources. The IRM is so sensitive to ISO’s aggressive protection of its copyright that it declares in its introduction that “Permission to reproduce extracts from ISO 31000 ‘Risk management – Code of practice’ is granted by the BSI.” Academics are not in the habit of seeking permission to reproduce extracts from sources that they are commenting upon.

Purdy acknowledges that ISO 31000 creates “challenges for those who use language and approaches that are unique to their area of work but different from the new standard and guide. The need for compromise and change is” he insists “the inevitable consequence of standardization.” In a world where the vast majority use approaches that are free, and communicate in the language of the standard dictionaries, the unique approach and language of the ISO “new standard” appear unlikely catch on.

Jan
13
2012

What is risk?

A new book from Cambridge University Press – Successful Science communication, (Bennett and Jennings eds.) – contains 26 chapters with helpful things to say to people concerned to communicate complex ideas to “the public”. Plus a chapter by me entitled Not 100% sure? The “public” understanding of risk; the reader is left to judge whether it too is helpful.

It begins: “Where knowledge (belief) relates to potential future harms or benefits, as it usually does in situations where science communication is seen as problematic or contentious, the issue can be framed as one of risk communication.”

And concludes: “The problem for science communicators is that we, scientist and non-scientist alike, do not respond blankly to uncertainty. We impose meaning upon it. The greater the uncertainty the greater becomes the influence of perceptual biases. These biases have deep cosmological roots and are not easily shifted. Perhaps the best that a science communicator can hope for is that introspection might assist recognition of one’s own biases, and an awareness of the inevitability of different biases in others. Self-knowledge and an ability to stand metaphorically in the shoes of others are key ingredients of the empathy essential to effective communication.”

And the first section is headed “What is risk?”

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