< Previous10 NEWS 10 bmta.co.uk 10 BMTA has written to UKAS asking them to propose that in light of trade sanctions by the UK Government, the Russian Federation should be expelled from the International Co- operation on Laboratory Accreditation (ILAC) and the International Accreditation Forum (IAF). UKAS has already suspended accreditation of two Russian organisations. BMTA has also written to the Office of Product Safety and Standards (OPS&S) proposing that the Russian Federation should be suspended from the International Bureau of Weights and Measures (BIPM) and the International Organisation of Legal Metrology (OIML). OPS&S has contacted both organisations but as yet has not had encouraging responses. UKAS UKAS has reminded all UKAS accredited bodies to monitor relevant sanctions imposed by the UK Government with the following letter: You are without doubt monitoring the ongoing situation in Ukraine and its impact upon your people, activities, and customers. For that same reason, we are contacting you regarding the expanding range of international sanctions placed upon Russia and Belarus and its impact on UKAS accreditation. At UKAS we believe in the need for democratic cooperation and respectful partnerships to build mutual recognition across borders. We join with our partners in EA, ILAC and IAF to convey our support to our colleagues from the National Accreditation Agency of Ukraine (NAAU). We back all efforts undertaken by the international community to protect people and reach a solution restoring security and compliance with international law. Consequently, UKAS requires that all its accredited conformity assessment bodies operate in full compliance with relevant sanctions imposed by the UK Government. It is our expectation that you will take appropriate and timely action to ensure that you are operating in full compliance with relevant sanctions and ensure no UKAS accredited conformity assessment activities are provided to persons or bodies covered by relevant sanctions. We appreciate that this is an emerging situation, and the sanctions (from multiple jurisdictions) are evolving. Hence, this will require careful ongoing review and consideration, on your behalf, to ensure compliance whilst also avoiding non-sanctioned persons or bodies from being unduly affected. To find more about UK Government sanctions please visit: https://www.gov.uk/government/publications/the-uk-sanctions- list#full-publication-update-history See https://www.ukas.com/resources/latest-news/impact-of- international-sanctions-on-ukas-accredited-services/ for more information. Government advice In addition, this page on the Government website provides guidance on the UK’s sanctions regime relating to Russia. https://www.gov.uk/government/collections/uk-sanctions-on- russia OFSI The Office of Financial Sanctions Implementation (OFSI) helps to ensure that financial sanctions are properly understood, implemented and enforced in the United Kingdom. In this blog, OFSI sets out some of the changes that have been put in place, and where stakeholders can find more information. https://ofsi.blog.gov.uk/2022/03/10/russia-what-has-changed- and-what-do-i-need-to-do/ BMTA members are reminded that they must comply with UK Government trade sanctions. The situation remains dynamic and as a result the information published here is subject to change. SANCTIONS ON RUSSIAN FEDERATION In response to the Russian invasion of Ukraine on 24 February 2022, the UK, alongside allies across the world, swiftly executed the biggest package of sanctions ever imposed against a G20 nation. Jeff Llewellyn, President, BMTA, provides us with the latest information from BMTA on UK sanctions and what it means to our members.11 NEWS 11 bmta.co.uk 11 MY GREEN LAB SUMMIT 2022 My Green Lab Summit 2022 will gather scientists, lab and facility managers, designers, manufacturers, and corporate sustainability leaders to unite the industry, sharing best practices and expertise. Taking place virtually on 26 May 2022, starting at 17:00h CEST, the event will feature interactive sessions and technical talks covering waste, energy, water and chemicals, as well as panels about community engagement around lab sustainability. To find out more about the event and registration, access the link here: https://mygreenlab.regfox.com/my-green-lab- summit-2022 EUROLAB is a marketing partner of the My Green Lab Summit 2022. CIM 2023 – LIMITLESS METROLOGY AT YOUR FINGERTIPS CIM2023 is an innovative Congress, where metrology meets science, industry and quality infrastructure bodies! To be held from 7th to 10th March 2023, the 21st International Metrology Congress and the metrology community, support the development of solutions ensuring we can trust in measurements. Composed of 200 presentations sorted by technical topics, and six round table sessions responding to the world’s challenges, the congress will involve participants in measurement and innovation and will provide the opportunity to discover current trends and preview future innovations. 850 participants from 45 countries are expected to attend, of which 70% are end-users from industry, while 30% are official bodies, research laboratories and academics. Comprising measurement processes leaders, quality managers and decision-makers, academics and researchers, all the industrial fields will be addressed, such as mechanics, chemistry, health, environment, pollution and energy. A 2,000sqm Metrology Village will be located in the heart of the partner exhibition, Global Industrie, and will gather the major brands of the measurement and metrology sector. MEMBERSHIP If you are interested in finding out more about becoming a member of the BMTA, please email enquiries@bmta.co.uk, requesting a membership application pack. Membership of the Association is open to all organisations in the measurement, testing and calibration industry. bmta.co.uk ETHICAL AI QUANDARIES Maya Carlyle, Principal Enterprise Architect, National Physics Laboratory (NPL) 12 This is a very clear distinction between AI and Data Science, where the strategy of a social environment comes into effect. The old conundrum of the runaway trolley, ‘do we do’ as Mercedes MD would do and save the occupants of the car or do as the Mercedes Twitter followers suggest and protect the pedestrians until they see the increased cost of the car. Ethics, therefore, are a balance between, cost/convenience and moral values. I believe we should adapt environments, not just introduce new tools. We should do what the strategists suggest and remove the cyclists and pedestrians, as we currently do on the motorways, where both cyclists and pedestrians are restricted. We cannot drive at speed AND respond safely to protect pedestrians and cyclists. Just as AI may impact humans, so might humans impact AI. Imagine London full of autonomous cars, driving us conveniently around and going off to park themselves. Instead of pulling up in front of buildings to drop us off, the architects will have removed lifts from their buildings and requested the car to drive to your office floor in a helical concrete ascending driveway, to prevent congestion in front of the building. The architecture will adapt, and the environment will respond for efficiency and safety. While I pondered the ethical issues around autonomous driving and why Toyota had only opted to go for autonomy level 2 (no feet or hands) whereas Tesla was opting for autonomy level 4 (no feet, hands, eyes, brain), it struck me that this was not a question about Data Science but about AI’s ethical impact in a social environment. bmta.co.uk 13 City plans will adapt. City planners will have commandeered the now permanently empty car park for new buildings for an expanding population. Meanwhile, humans will be gaming the AI, being “unethical in reverse.” Humans will know that driverless cars are designed to stop when a pedestrian steps out in front of an autonomous vehicle. So, the humans in shopping districts will walk carefree into the roads, instead of waiting at designated crossings and ethically sharing time on the roads. Cyclists will game the driverless cars to act as an escort, to drive at an appropriate distance behind, to protect them from human car drivers dangerously tailgating them. Another issue to be considered is around the early release of a model before it is fully tested and productionised. Take for example this simple STOP sign image, with four strategically placed stickers to fool a driverless car’s image recognition into believing it has observed a 40 mile an hour street sign. The consequences could be devastating for the car, its occupants and anyone in the car’s path as it jumps a STOP sign and accelerates. This particular example did not even require code to hack the neural network, just a few simple stickers to upset the probabilistic model. Is it ethical to release a model into the real world which has the potential to be hacked so easily? There are rigorous ways in which to test code quality. At the National Physical Laboratory we assess uncertainty in AI to see if it actually does what it says, and how well it performs that activity. These are some recent examples of the work our Data Science team has done in this space: • CNNs to classify image transformations of ECGs • cycleGANs to generate synthetic image data from one medical imaging modality to another (section 5 of this report) Ethical AI is a fascinating area. There is a balance between computers being helpful or overstepping into what we might consider being “creepy” or a “loss of control.” Computer ethics teaches us a lot about ourselves and our own culture. Buried within many data sets is a history of our cultural beliefs. None is better than that from 600 years of case histories from the Old Bailey – an amazing data set but with an evolution of our culture contained within. For instance, if I use the Old Bailey data set to train an AI to judge us, it might suggest that using excessive force is acceptable if someone were to steal something as nondescript as your pen. Not only do data sets encapsulate our culture, but they can also be skewed on where the information has been captured. An issue we once had with medical data sets was that the bulk of the data was captured from Northern European males, meaning that dosage measures and the analysis of the impact on phenotypes would fall short for other groups of patients. Diversity Netflix recently released a documentary about biased data sets, following Jo, an AI researcher at MIT and her petition to the US government on gender and race bias in data. Jo discussed the controversy of AI and in one particular example, the everyday practical implications applied to a soap dispenser’s inability to detect her hands.bmta.co.uk 14 My career started by looking at the bias in algorithms as opposed to data sets. My focus was on how I could use psychology in my algorithms to gain more time from the customer to process their data – this was back in the day with dial-up modems. Today we see this in computer games, an industry worth £5.5 billion in the UK alone, which uses techniques to slow the player down while they load the next scene. Psychological manipulation of the customer is employed in most user interfaces and more recently in chatbots, to establish empathy and fool us into a sense of security. Prof. Hannah Fry, in her book, Hello World: How to be Human in the Age of the Machine, discusses the American company Compass, which built an algorithm to assess probation periods for ex-offenders. This particular debate was about allowing non-publicly viewable algorithms to make decisions that impact human lives at a profound level, and whether we should have the right to see the inner workings. However, when the algorithm is hidden from us we can often still find out how it works. That access is escalated in AI where computer scientists use a technique known as shadow modelling, where they are able to reverse engineer the proprietary algorithm and extract the original sensitive training sets on which the AI was trained. In Fry’s example, she explains that the algorithm possibly didn’t measure enough of the important societal factors impacting the ex-offenders, eg ability to access child care or a working mode of transport. Our social data In China, they have a social scoring tool known as Sesame. As you disembark the train into Beijing, a passenger is reminded that if they have a score over 500 they can apply to travel on a holiday overseas or use a 5-star hotel. For us in the West, large tech, rather than our governments make those decisions. For example, food purchase data is shared with insurance companies and from this, they can determine if we are model citizens and less likely to call on household insurance, all from observing if we buy certain products such as cauliflowers or dill.bmta.co.uk 15 Writers have an interesting way of looking at the social and ethical impact of new technology, helping us to visualise and ponder the impacts. Here is a fun explanation of the social scoring dilemma from Charlie Brooker talking about “Nosedive”, an episode in the series of the British science fiction anthology series Black Mirror, which is based on a story by Brooker, also the series creator. Too many insights During my work in Vietnam with the government to analyse accents, we very quickly started to see insights into where a person was educated or if they were a native speaker, all from their voice. This threw up an ethical dilemma for me. Had I crossed a line? There are many examples today where the gathering of data that could prove to be of benefit could also be seen as intrusive. Such as using smart meter data to detect my use of appliances via their energy consumption signature, linked to the time of day to indicate if I have early onset dementia, years before I am even aware! Future considerations We need to think about what role might the UK play in a world that uses AI more and more to make decisions about the governance of human lives. How rules to socialise innovation might mirror those in the Human Rights Act which constrain unwanted human behaviours but enables freedom of action where it does not adversely impact others. This may mean reflecting on the environments into which we release AI systems and how they may also need to be adapted or constrained to prevent adverse activities, or humans “gaming” the AI by tricking it into new unwanted activities; protecting the AI from humans. We need to reflect on existing approaches that have been well researched to underpin seemingly complex areas. For instance, would you want to fly with an airline that had not fully tested the automation used to lower its landing gear? The same mathematical proofing tools, like Z methodology, applied to this scenario, also need to be applied to the code that builds the AI tool that leads to the “impenetrable and inexplicable model.” We also need to apply other classical software engineering principles like Big-Oh notation to understand the efficiency, as there is no point in having the mathematically correct operation of the landing gear if it takes three days to lower the wheels. These techniques and other skills from the backend software engineer’s toolbox need to be applied to artificial intelligence, and we can apply them to the observable part of AI. But as people entering the world of AI come from multiple disciplines, this area of rigour is sometimes overlooked and we have edge cases coded into our AI models that lead to biased results influencing decisions made about human lives. As statisticians, we also need to also focus on the data we use to train the AI. As a parent, we would expect a child who is schooled in Japan to be less eloquent in English when compared with a child schooled in the US. AI is also dependent on the data it is fed. The quality and breadth of the data need to be considered if we want a system that is not biased. As humans we are naturally biased, so selecting the key parameters by which the AI model will be trained, will lead to a skewed model. Instead, we need to extract these key parameters using statistics or we will bias the system. The good news is we have the necessary skills to prevent bias which can be applied to the visible components from which we construct the AI models. We can avoid the “black box scenarios”. All of these activities are familiar safety steps that classically trained backend software developers are trained to apply to both AI and non-AI systems, so it is important to bring those design principles into the governance conversation.bmta.co.uk PANDEMIC REFLECTIONS A REVIEW FOLLOWING THE PPE CRISIS OF 2020 Alan Murray, Chief Executive Officer, British Safety Industry Federation (BSIF) The events of 2020 elevated the profile of PPE to a level never seen before and highlighted the dependence the country has on extended supply chains. The pervasive marketing of non-compliant and unsafe PPE shone a bright light on the lack of regulatory control for these safety-critical products and resulted in the market being full of potentially unsafe products. The existence of poor quality PPE, while extreme during the pandemic, is not a phenomenon just of that period. These concerns and the vulnerabilities were already known to BSIF and those in the industry. While BSIF sets out to review and reflect on the events of 2020 and their efforts to support the country’s response, it calls on action to address the current and ongoing marketing of PPE which is non-compliant and not fit for purpose. The landscape Many PPE items, while safety-critical, are of high volume but relatively low unit value, and much of their manufacturing has long been off-shored to China. By late February of 2020, BSIF began hearing of interruptions in PPE supply and reports of the Chinese Government taking control of PPE manufacturing, directing products exclusively for domestic use. 16BSIF advised the Health and Safety Executive (HSE) of likely shortages. The alert to the HSE was driven by concerns that PPE stocks for the industrial safety and health market would be significantly affected, but given the scale of what unfolded, in hindsight, this concern for the industrial market seems almost naïve. Later, with Italy in lockdown and their health service overwhelmed, the demand for Covid-19 related PPE exploded, first across Europe and then globally. This was at the same point that the authentic supply chain was collapsing, a perfect storm of skyrocketing demand, coupled with dwindling resources. By the start of March, BSIF was supporting the UK authorities who were scouring for immediate supplies of FFP masks for front-line healthcare staff. By the beginning of March 2020, BSIF was providing support and information on PPE sources to the Cabinet Office, the Crown Commercial Agencies and the various structures supporting the NHS and public health agencies across the devolved nations. BSIF supplied the senior contact information for legitimate manufacturers and suppliers in the UK and across Europe, in order to ensure that the authorities could communicate directly with the right people. In addition, along with the European Safety Federation (ESF), BSIF did the same for the EU Commission which was seeking to source communally, on behalf of member states. Meanwhile, the UK’s strategic pandemic PPE stocks were being audited and often found to be beyond their useful life. In response to the shortages, certain EU states unilaterally prohibited the export and free movement of PPE with a range of conditions applied by the various member states. The ensuing chaos of this action led to the EU publishing “Recommendation 2020/402” which required any exporting of PPE to undergo an “authorisation” process. BSIF and ESF were active in engaging with the Commission and other authorities on the damage such a poorly designed protectionist process would do. In the first place, PPE and Covid related PPE does not have identifiable tariff codes, and furthermore, many international PPE manufacturers who warehoused centrally in EU states, including the UK, had difficulties moving products to legitimate priority markets. In the UK, Her Majesty’s Revenue and Customs (HMRC) took the lead in providing approvals for the movement of relevant products. Subsequently, the EU Commission produced their ‘Recommendation 2020/403’ which allowed PPE for covid-facing healthcare workers to be placed on the market without it having to go through the full product approval processes. Along with ESF, BSIF challenged the EU Commission on the potential dangers of this move. In parallel, BSIF began to work extremely closely with the Department of Business Energy and Industrial Strategy (BEIS) and the Office for Product Safety and Standards (OPS&S) on supporting how the EU ‘Recommendation 2020/403’ could be employed in the UK. BSIF proposed a triage system of receipt and testing of PPE, recommending appropriate laboratories with easy access to and from Heathrow. In the end, a version of the proposed system was set up, led by a dedicated OPS&S/HSE technical team working out of the MoD facility in Daventry. This team was charged with “accepting and releasing, fit for purpose PPE” sourced directly by the Government on behalf of healthcare workers. By April 2020, BEIS/OPS&S produced the first Guidance on how ‘Recommendation 2020/403’ could be applied in the UK. The Recommendation changed the process by which PPE would be allowed to be placed on the UK market. Along with the consultations BSIF provided to BEIS/ OPS&S on creating the Recommendation Guidance, once published, it had to be interpreted and communicated to the BSIF membership and the wider market including end-users. bmta.co.uk 17bmta.co.uk ‘Recommendation 2020/403’, produced in April 2020, was to be applied by member states (including the UK) as they each saw appropriate for their own specific needs. Confusion, over what the Recommendation actually allowed and how it should be applied, was significant with the member states and Notified Bodies giving approval decisions as they saw fit. The government, in parallel, had put out the call for UK based manufacturers to convert production to Covid-PPE and many did. Once again, however, BSIF had many well-intentioned businesses lacking the appropriate knowledge in making PPE and attempting to have it certified under the temporary easement. The results were mixed. At this time, the BSIF Test and Certification Association, the group of UK Notified Bodies, were debating the actions necessary to apply the Recommendation consistently in the UK. This unique collaboration provided for the Government through the BSIF Test and Certification group, was extremely valuable to BEIS/ OPS&S, even if ultimately the process was imperfect. Coinciding with the soaring demand and fracturing of traditional supply chains, came an eruption of other opportunist businesses attempting to supply PPE into the UK. They were doing this without understanding the critical nature of the product and with little attention paid to compliance or product provenance. Internet portals and online marketplaces were promoting significant quantities of non-conforming, unproven PPE. It was not just the traditional online platforms selling these products, they were also being sold by individuals on personal Twitter and LinkedIn accounts, at hugely inflated prices. While we use the term “PPE” within this text, the priority focus early on was around the supply of filtering facepiece FFPs (disposable masks). However, as the crisis wore on, the supply of other PPE items such as face shields, limited life garments and gloves were added to the list of products in short supply and subject to the same abuses as experienced with respiratory protective equipment. End users, the vast majority in healthcare and essential services, were desperate to find supplies, but often did not know what legitimate products looked like. BSIF were asked to contribute to the creation of PPE Guidance for GP Surgeries. At this time we began to see the arrival of FFP masks with “ear loops” instead of the “adjustable head harnesses” as required by the product standard. In most cases, the FFPs being supplied were “KN95” – a classification of respirator under the Chinese domestic standard GB2626. The KN95 is not compliant with UK or European PPE standards. Many of the products were not even legitimate KN95 certified respirators. Despite it clearly being outside of the Regulation, the products flooded the market. The KN95 was being commonly marketed as KN95/FFP2, but they perform differently with testing and quality assurance requirements less stringent than an FFP2 under PPE Regulation 2016/425. The HSE were aware of the product and its drawbacks and in June 2020, the HSE position was clarified via a “Safety Alert”, warning against the use of KN95 to protect against Covid-19. However, the KN95 masks continued to be sold openly. In addition to the KN95, FFP masks certified to EN149 with ear loops, instead of adjustable head harnesses were being seen in the UK. Such masks struggle to “face fit” properly, failing to provide a seal with the face leaving the wearer unprotected. The HSE and the NHS refused to allow the wearing of FFPs which had ear loops. While HSE insisted on the need for face fitting when any tight-fitting respirator such as an FFP was deployed, a consistent supply of the masks did not happen. With insufficient competent face fitters available and the kit necessary for carrying out face fits also in short supply, BSIF was actively supplying the recipe for the manufacture of the test agent used in the “Qualitative” method to potential manufacturers. It must be recognised that Fit2Fit Accredited face fitters carried out more than one million face fits in the NHS Trusts and in the new Nightingale facilities in extreme circumstances. 18Many areas of society were now confronting the need to wear PPE to mitigate against the risk of Covid including GP and Dental Surgeries. Dentists, closed since late March, were by June attempting to re-open but needed the appropriate PPE and face fitting for respirators. With little background in PPE, respiratory protective equipment or the need for face fitting, the situation in dental was chaotic. The Royal College of Nursing and the British Medical Association were also concerned and wrote to BSIF about the challenge of providing respiratory protective equipment suitable for the diverse NHS workforce. In support of the market, BSIF created a webinar to assist users in identifying safe and compliant PPE. Alongside the webinar, a series of documents were published to help users and potential suppliers identify genuine PPE amongst all of the non-compliant and illegal products being offered in the market. BSIF produced and publicised a series of guidance documents including “Is it Genuine” to illustrate what users and inexperienced suppliers should be looking for when checking PPE paperwork. At this time there was also the conflation of medical masks and PPE requiring BSIF staff to develop at least some expertise in Medical Device Regulations, as well as reaching out and creating relationships at the Medicines and Healthcare products Regulatory Agency (MHRA). At every turn, non-compliant PPE was being placed on the market and, central to the problem, was a number of fraudulent, dishonest and misleading documents offered in support of products. While some paperwork was clearly fictional, some were wrong or not what was required by legislation, with others misleading and copies of legitimate paperwork applied to different products. There was also something of a growing phenomenon whereby several Notified Bodies (not scoped for PPE approvals) were providing certificates purporting to be CE certificates for PPE but which were nothing of the sort. Along with fake certificates, bogus certification bodies offering CE PPE approval decisions emerged. bmta.co.uk 19Next >