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As we move through stage two of the meaningful use program and with the effective date having come and gone for compliance with the new HIPAA Omnibus Mega Rule, it is critical to take a strong look at your security posture.
The key areas that need to be reviewed to ensure that your practice has the best possible security posture include the technical, administrative and physical safeguards your practice has in place to protect PHI.  A thorough and comprehensive assessment of risk following NIST guidance will allow you to gain a true understanding of your security posture. Conducting and reviewing these assessments annually as part of your Risk Management Plan are not only important for meeting the regulatory requirements for Meaningful Use and HIPAA Compliance, they will assure that you are putting your practice in the most secure environment possible. As you prepare to meet the requirements listed above, please keep the following in mind.  The more thorough you are will put your practice in a better posture. Here are some things to keep in mind as you review your physical, administrative and technical safeguards as part of your risk assessment. Approved Document A of the Building Regulations requires that a systematic risk assessment is carried out for Class 3 buildings. It must be kept in mind that the Building Regulations only require that buildings are designed to avoid disproportionate collapse not designed to resist all possible hazards. The subject of risk is complex with numerous techniques and approaches for analysing, assessing and reducing risk.
As explained in this article and identified in Reference 4, the application of engineering judgement will play a major role in the risk assessment procedure due to the lack of guidance and the levels of uncertainty regarding likelihood and consequence of hazards.
Approved Document A states that the risk assessment should include; normal hazards that may reasonably be foreseen and any abnormal hazards. Certain buildings may have additional specific hazards that may also need to be considered.
The risk assessment methodology which is used should be of sufficient detail to enable the hazard related risks to be ranked in order for the subsequent consideration of what risk reduction measures may be required. Guidance on selecting an appropriate risk assessment method is provided by the HSE in Reference 5.
For a qualitative method, the likelihood of each hazard occurring needs to be estimated and assigned to one of the predetermined categories of likelihood.
For a quantified risk assessment various techniques can be used to obtain a probability of occurrence for many of the foreseeable hazards. Predicting the likelihood of hazards is likely to include a significant degree of uncertainty. For a qualitative method the consequences of hazards are dealt with in a similar manner to likelihood of each hazard in that they are assigned to a category reflecting their severity.
For a quantified risk assessment the consequences of hazards can be measured in various units.
The performance of the damaged structure then needs to be assessed to determine if further collapse will occur. For a qualitative assessment, a risk matrix (Figure 2) is a convenient method of ranking the risks. For a quantitative assessment the level of risk can be calculated by multiplying the likelihood with the severity.


For Class 3 buildings where the risks are not greater than those for Class 2B buildings the structural provisions required for robustness will be the same as those for Class 2B buildings. There are many options available to you regarding encryption, look into the options that best meet your practices needs and financial considerations. CISSP® is a registered certification mark and (ISC)? is a service mark of the International Information Systems Security Certification Consortium, Inc. Our risk assessment process centers on an evaluation of current decision-making from key leaders, plus an analysis of the technology, personnel and procedures that are currently used in crisis situations.Our team then synthesizes these observations into a comprehensive look at disaster preparedness. Moreover, our comprehensive TRA methodology will ensure that your application, network, and computing infrastructure are thoroughly scrutinized in order to reduce risk and exposure. Requirement A3 (Disproportionate Collapse) now applies to all buildings regardless of the number of storeys. The discussion in this article provides simple guidance that can be applied to ‘ordinary’ Class 3 buildings. Risk is a function of the likelihood of a hazard occurring and the magnitude of the consequences of that hazard.
Hazards in general terms are events that have unwanted consequences, which for buildings is structural damage (and the consequential harm to people). The rigour of assessment should be proportionate to the complexity of the problem and the magnitude of risks. Although the HSE document is for offshore installations the principles can be applied to Class 3 buildings. A quantified assessment may be required for certain hazards if further detail is required to assess the acceptability of the risk. The number of categories needs to be sufficient to differentiate between hazards with significantly different probabilities.
As examples, accidental impacts can be calculated based on historical data and scientific predictive modelling can be used to determine the likelihood of natural events. Some published data is available but the data tends to be widespread and based on historical statistics.
The number of categories can vary but four or five categories are usually appropriate for a qualitative risk assessment. The amount of structural damage is often the most appropriate measure for buildings; alternatively the number of casualties can be used but this is a more subjective measure.
Each hazard is plotted on the risk matrix according the appropriate severity and likelihood category. Indicative information on what levels of risk may be acceptable can be obtained from various sources. The report should include all the hazards and their associated level of risk with explanations of why the risks are acceptable and what reduction measures have been necessary to achieve acceptable levels.
Where there are increased risks from hazards, additional structural provisions are likely to be required to reduce the consequences of the hazards.


This serves as the foundation for our strategic efforts to identify gaps and implement a strategy throughout our clients’ entire organization. Approved Document A (2004 Edition)[2] defines four classes of building; Class 1, 2A, 2B and 3, and recommends that to comply with Requirement A3, a systematic risk assessment is required for Class 3 buildings.
There will be buildings and other structures where advanced risk assessment procedures (such as those used in the off-shore and nuclear industries) are appropriate but these are outside the scope of this guidance. The distinction between normal and abnormal hazards is unclear but the important point is that all reasonably foreseeable (accidental) hazards are included.
The level of risk assessment should be sufficient to enable the decision making process to be conducted and those responsible for the decision making should be suitably qualified, experienced and of sufficient seniority to be competent. However, a lack of accurate data on the likelihood of hazards may mean that a quantitative assessment is not always possible.
However, the likelihood of some hazards like terrorist attack is difficult to predict and will depend on the political and social significance of the building and its occupants.
Engineering judgement, experience and approximate calculations can be used to estimate the consequences of hazards for a qualitative assessment. For example, the nuclear[6] and the offshore[5] industries have guidance regarding acceptable levels of risk but these are generally expressed in terms of risk of death per individual per year. The types of structural provisions that may be appropriate include: designing members to resist specific accidental actions or generic accidental loading and enhancing redundancy within the structure so that alternative load paths can be utilised in the event of a hazard occurring and thereby avoiding disproportionate collapse. Guidance regarding the calculation of impact forces and explosion loads due to various causes is given in EN 1991-1-7[8]. The findings of the risk assessment will feed back into the decision making process of the design and operation of the building.
This article presents the SCI’s interim guidance on risk assessments for Class 3 buildings.
The building regulations are intended to guard against accidental events and therefore on this basis it would seem reasonable to exclude deliberate or malicious events from the scope of the risk assessment.
A paper on gas explosions[7] includes useful information (albeit slightly out of date) on yearly probabilities of explosions in dwellings in the UK (1 in 500,000 probability of causing structural damage) and the average number of occurrences of other hazards. All the sources of data, assumptions and uncertainties in the assessment should be included in the report. If the building is required to be designed to resist malicious events such as terrorist attack this should be addressed separately.
The SCI recommends that Class 3 buildings should have at least the same structural provisions for robustness as required for Class 2B buildings. Designing buildings to avoid disproportionate collapse due to accidental hazards can provide some robustness to deliberate hazards.



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