Welcome to the Universal Verification newsletter – Universally Speaking.
Issue number 004 – Five acronyms you need to understand.
We’ve received a number of questions since our last newsletter. Therefore, I thought it would be helpful to provide some information and clarification for you.
Here are five fundamentally important acronyms
- DRA.
- OURA.
- PUI
- MRA
- UKAS
DRA – Design Risk Assessment
Both EN13814:2019 and HS(G)175 place a duty and obligation on the designer (i.e. ride manufacturer) of a new amusement device to produce a DRA which serves to ensure that the design caters for the safety requirements of the EN standard.
HS(G)175 says that the DRA is, “The process of assessing the hazards that the design of a piece of fairground equipment may pose, the likelihood of those hazards posing a risk and the control measures that are necessary to adequately control those risks. Designers should assess the significant risks that arise from its subsequent assembly/dismantling, transport, inspection, maintenance and operation.”
EN13814-1:2019 states that the DRA is a document, “produced by the designer as a tool for the safe design, within the agreed scope of supply”.
It states in 13814-1 (clause 4.1.1 if you’re interested) that, “The design documents include all the documents required for the assessment of the stability and operational safety of the amusement device, including the Design Risk Assessment (DRA). They shall be available for any subsequent approval by the independent inspection bodies. These documents shall encompass all the design conditions pertaining to the operation of the amusement devices or structures. A description of the construction, operation and operational safety, design drawings and a comprehensive stress, fatigue and stability analysis are required for this purpose.”
Did you notice the section that I highlighted? The DRA shall be available for any subsequent approval by the independent inspection bodies
It is a requirement of both 13814 and HS(G)175 that the DRA forms part of the Design Review process.
The DRA process will never close out every issue. Therefore, the residual risks which remain need to be considered by the controllers when completing their OURA.
This means that you, as the controller, need a copy of the DRA. Most controllers do not have this, so how are you going to perform a suitable and sufficient OURA?
OURA – Operation and Use Risk Assessment.
We spoke about this in the last newsletter, but her is a brief recap.
When EN13814 was updated in 2019, it introduced a requirement for controllers of new and existing amusement rides/devices to undertake an OURA.
The OURA is a document whose purpose is to guide the controller into making the correct decisions in terms of ensuring the safe operation and maintenance of the device, based upon the residual risks arising from the design of the device and information provided by the ride designer/manufacturer.
EN13814-1:2019 states that the OURA is a document, “produced by the controller, that details all of the considered risks inherent during all modes of the amusement device operation and the means taken to mitigate against them”.
It is safe to say that most controllers have never heard of, yet alone performed an OURA. There are significant gaps in the knowledge of the requirements.
The DRA and OURA are fundamentally important. EN 13814-1:2019 (section 5.1.2.1 if you’re interested) states that:
“The DRA and OURA are regarded as keystone documents, paramount to the total safety management of the amusement device and as such shall be regarded as dynamic. The documents require review periodically and following any relevant change to the design or operation of the amusement device.”
The DRA and OURA are therefore inextricably linked and should ideally form part of an iterative process as shown below.
PUI – Pre-Use Inspection
This refers to the first three inspections performed by the inspection body before the device’s first use. It is the device’s initial approval.
I was going to title this section DRACDIT (Design Review, Assessment of Conformity to Design, Initial Test) but the terminology of EN 13814 is a little different.
The principle is, however, the same. The PUI process is what you need in order to demonstrate that the ride is safe to operate and, in the UK, this is how you get your initial DOC (Declaration of Operational Compliance).
If you’re in the UK, check out HS(G)175 paragraphs 105 to 141 for what this entails.
For EN 13814, please see EN13814 part 3 for details.
EN 13814 states that, “The results of the various inspections and reviews [of the PUI process] shall become an integral part of the amusement device log.”
For clarification:
- EN 13814-1 section 5.7.1.2 (Content of the amusement device log) lists the record and report of initial acceptance tests. This is the PUI documentation.
- HS(G)175 paragraph 141 says the “The IB should prepare a report for inclusion in the operations manual.“
As a controller, you need these documents. However, some controllers do not have access to them. Please speak to your Inspection Body to obtain this information.
MRA – Maturity Risk Assessment
(Yep, I went there!)
When HS(G)175 was introduced in 1997, it was recognised that there would be devices in use that had not been subject to PUI and did not have complete design documentation, but which were, nevertheless, demonstrably well designed and maintained.
An arrangement was therefore reached to allow such devices to continue to operate. The controllers of these devices were given until 2004 to prepare a documented risk assessment that could be used to demonstrate safety through the maturity of a device. Ergo, the Maturity Risk Assessment.
This only applied to devices that had operated in Great Britain before 1997.
However, with the 3rd edition of HSG175 in 2017, the HSE changed the requirement. They stated that the MRA was intended to be a one-time, stand-alone assessment of the design, safety and fitness for use of an amusement device based on its condition at the time of the assessment and on its operational history.
The MRA was designed to be in addition to, and separate from, the operational risk assessment. The operational risk assessment, of which the MRA would be a part, would still need to be kept in date but the MRA itself would become a historical document.
In various stakeholder meetings, the HSE basically told controllers to burn them. Some did.
We advised all our clients to keep them. Some did.
With the 4th edition of HSG 175 due imminently, the use of a machinery standard is set to be included. The standard is BS 14200:2023 (Maintenance of machinery – specification).
BS 14200 requires the Maturity Assessment of Ageing Machinery. This requires the ongoing maturity risk assessment of machinery.
This states that, “towards the end of the predicted operating life of the machine, the user shall undertake (or have commissioned a suitably qualified person to undertake) a systematic technical review of the machine’s structural, fixed and moving parts, obtaining evidence to support the machine’s ongoing safe use.”
This is working on the assumption that you as a controller know the predicted operating life of each of your rides and devices. And this is a pretty large assumption.
if you want a starter for 10, this information is rarely in the DRA or PUI documentation.
There will be an implementation period for the HS(G)175 update. However, you need to start working on this now. At Universal Verification Ltd we are already supporting our clients with this.
UKAS – United Kingdom Accreditation Service
Accreditation is the process of formal recognition of a person, organisation, or program’s competence and quality against set standards.
UKAS are the sole national accreditation body for the UK.
You may have heard of Inspection Bodies being accredited to a standard ISO 17020:2012 (Conformity assessment – Requirements for the operation of various types of bodies performing inspection). Whilst it is not mandatory in the UK for an Inspection Body to have UKAS accreditation, a few Inspection Bodies do have it and the ADIPS scheme and Inspection Bodies work in accordance with the requirements of ISO 17020.
However, with the 4th edition of HSG 175 due imminently, the requirement for the scheme (not the inspection body) to have UKAS accreditation is set to be included.
This is likely to mean UKAS accreditation of the scheme (ADIPS, LEAPS, etc) to the standard ISO 17065:2012 (Conformity assessment – Requirements for bodies certifying products, processes and services).
UKAS accreditation is not new, and it was first muted in the Roberts report in 2001, but this was aimed at individual inspectors, not the Inspection Body or scheme. It’s just taken a while to get around to it.
For you as a controller, for UKAS accreditation, nothing much will change apart from the cost, which will probably increase due to the cost to administer the scheme. This will most likely be included in the DOC levy.
Again, there will be an implementation period for the HS(G)175 update. Please speak to your Inspection Body or scheme regarding this.
How can we assist?
The team at Universal Verification have been involved with all the above.
We work with manufacturers, designers, inspection bodies and controllers in the UK and overseas.
We’ve helped controllers obtain their DRA and PUI documentation, and we’ve authored and provided OURA’s and MRA’s to numerous controllers.
We can assist you too.
For more information on the above acronyms, or to discuss audits, training and our range of consultancy services, please contact the team
Email the team at enquiries@universal-verification.com
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