And I already know the comeback: “When you’re up to your ears in alligators, it’s difficult to attend to draining the swamp”. I’ll still suggest HTM leadership look at some of the safety engineering models being used for more complex systems.

A set of such models that have earned a lot of respect across many domains are laid out in Nancy Leveson’s “Engineering a Safer World” , a PDF for which can be found at https://mitpress.mit.edu/books/engineering-safer-world .

If you read nothing else from the book, at least read the first chapter, “Why Do we Need Something Different?” It’s only three pages long. Humor me. Read them.

If you then want to go further, jump right into chapter two, “Questioning the Foundation of Traditional Safety Engineering”. Forewarned: It does a pretty good job of challenging the adequacy of the Domino and Swiss Cheese models to model accidents in complex systems. It’s a much longer chapter, but a quick summary can be found in Table 2.1 on page 57, “The basis for a new foundation for safety engineering”.

Read whatever you want after that …

The models that have derived from Leveson’s work can be rather complex, and applying them to systems under the control of HTM may not always, or even generally, worth the expense. But other models exist, e.g., assurance cases, lightweight versions of which can be developed (and which Leveson has been known to criticize; this remains a developing field).

Is there a role and/or place within HTM to be aware of the palette of options for risk management? Can HTM respond with critiques grounded in formal analysis to arguably inconsistent and/or incoherent challenges from regulators like the ones laid out in this article? Or is the field destined to play a never ending game of regulatory Whack-A-Mole governed by 20th century perspectives on the nature of safe systems?