The Value Chain Risk Institute · OT consequence axis · working reference

The Protective Window

Public data already says who is exposed. It cannot say whether this facility's failure reaches them, or how fast. That coupling is the one field a plant can supply from memory, and it is the field that makes a lives-denominated risk figure defensible.

Drafted 9 September 2026 Cairn Viktor, The Value Chain Risk Institute Working reference · CC BY 4.0
01

The one field

Ask the operator a single question: from loss of control, how long until someone outside the fence is harmed?

One number, in hours. It is a process characteristic rather than a prediction, the plant engineer knows it without looking it up, and it discloses nothing an adversary could use, because it describes chemistry and physics rather than architecture.

Public · already exists

Who is exposed

Counts of people inside the harm geography, published by agencies whose job is to warn communities.

HHS emPOWER, ZIP level, monthly
EPA RMP endpoint population
EPCRA Tier II inventories
HIFLD asset geography
Declared · the missing field

The protective window

Hours from loss of control to first offsite harm. Falls straight out of the existing hazard analysis.

Chlorine residual before contamination
Generator fuel before wards go dark
Line pack before pressure loss
Thermal inertia before excursion
Output

Consequence, in lives

Exposure counted, coupling declared. Neither term is guessed, so the result survives a hostile review.

Stated as people-at-risk over a window,
never as a predicted death toll
exposure (public, counted)×coupling (declared, one field)→consequence (defensible)

What the window is measured against

detect isolate restore margin
loss of controlfirst offsite harm

The protective window is the whole bar. Response consumes it from the left. When detection, isolation and restoration exceed the window, the margin goes negative and the exposed population stops being hypothetical. This is also where a detection product earns its keep in the same units as the risk: anything that shortens detection widens the margin directly.

02

What the window excludes, and why

The window ends at harm outside the fence. A death inside the facility does not move this number. That is a scoping choice rather than a discovery, so it is stated here instead of left to be inferred.

In scope

Harm that propagates

Contamination reaching the distribution network. Loss of power reaching a ward or a home ventilator. A release crossing the property line. Every one of these has a travel time, and travel time is what the window measures.

Out of scope

Harm at the point of failure

The operator standing beside the vessel is hurt at T = 0. There is no margin to consume, so the metric has nothing to discriminate with. Onsite harm is governed by whether the safety instrumented system holds, which is a different mechanism needing a different term.

Known objection, unresolved

In most real OT incidents the people most likely to die are inside the fence. A metric that excludes them systematically understates harm, and it does so in the direction that flatters the facility. Anyone reviewing this adversarially will say so, and they will be right.

There is an audience risk underneath it. This work exists because an OT practitioner said his people count lives rather than dollars, and the lives an OT practitioner thinks about first are usually his own operators. Answering "lives" by counting only the neighbours may land wrong with exactly the audience it was built for.

The defence is scope, not merit. This is the right boundary for a clearinghouse telling third parties what a facility's failure does to them, and it is the wrong boundary for a plant safety tool. If worker harm belongs in the output, it enters as a second declared field with its own denominator, not as a change to this one.

There is also a practical constraint. Both halves of the equation are offsite by construction: emPOWER counts residents, RMP counts residential population inside the endpoint, Census counts the neighbourhood. None of them know how many people are on shift. Onsite exposure has no public denominator, so including it would require asking the operator for a second number as well as the window.

03

Why this field and not another

Four candidates were considered. Three fail for reasons worth recording, so nobody re-proposes them in six months.

A per-sector fatality constant
Rejected
No stable ratio exists. The same outage in Phoenix in July and Seattle in October produce different outcomes. A constant would be wrong everywhere rather than approximately right anywhere, and it is falsifiable in a way a dollar figure never is.
Service population alone
Insufficient
Already public, and already in the model as the exposure term. On its own it says a utility is large, not that its failure hurts anyone. Size is not consequence.
The SIL rating
Nearly right
The plant has one and it encodes tolerable risk properly. But it describes the protection layers already installed, not what happens when they are bypassed, which is precisely the cyber case. Useful as corroboration, wrong as the primary input.
The protective window
Selected
Known without research, non-sensitive, auditable against the safety file, multiplies cleanly with public exposure data, and works in jurisdictions with no public data at all. It is also the only candidate that makes a cyber event legible, because a cyber consequence is a function of how long control is lost.
04

Where the exposure half comes from

The rule that governs this map: consequence data is public where the law exists to tell a community how badly a facility can hurt them, and sealed where the law exists to protect the facility. Every safety and environmental regime surveyed opens part of it. Every cyber regime seals it, without exception.

JurisdictionInstrumentSpineStatusWhat it yields
United StatesHHS emPOWERHealthOpenElectricity-dependent Medicare beneficiaries, ZIP level, monthly. The strongest single exposure source found.
United StatesEPCRA Tier II & LEPC plansSafetyOpenFacility chemical inventory on public request; each LEPC holds a community emergency plan built from it.
United StatesEPA RMP offsite consequence analysisEnvironmentReading roomResidential population inside the worst-case release endpoint. Reference-grade, not scrapeable.
United StatesHIFLDGeospatialMoved400+ infrastructure layers. Open portal closed Aug 2025; preserved via HSDL and HIFLD Next. Treat as a live dependency.
United StatesAWIA s.2013 risk & resilience assessmentsCyberSealedFOIA-exempt by statute. Only the certification and its date. Criminal penalties for official disclosure.
United StatesNERC CIP-002 impact ratingsCyberDerivablePer-asset ratings unpublished, criteria public. A derived tier must be labelled as derived.
United KingdomCOMAH 2015SafetyOpenUpper-tier safety reports publicly available subject to commercial redaction, plus a public establishment search. The most open jurisdiction found.
European UnionSeveso III, Article 14SafetyOpenAll establishments publish Annex V permanently online; upper tier adds main accident scenarios and external emergency plan information.
European UnioneSPIRSSafetyGated~11,000 major-hazard establishments. Non-confidential read still requires Commission ECAS authentication.
European UnionNIS2, Article 21CyberUnverifiedMeasures are specified; disclosure regime not established either way. Assume sealed until checked.
UNECE regionIndustrial Accidents Convention 1992TreatyOpenParties must inform the public in areas an accident could affect. Canada to Central Asia. The best single citation for disclosure as an international norm.
IndiaMSIHC Rules 1989SafetyOpenExplicit duty to inform persons outside the site, directly or via the District Emergency Authority, before the activity begins.
IndiaNCIIPC, IT Act s.70ACyberSealedThe clearest two-spine split inside one country: chemical side open, cyber side closed.
South AfricaMajor Hazard Installation Regs 2022SafetyOpenIn force Jan 2023, referencing SANS 1461 risk assessments. High-hazard licensing began Jan 2026.
South AfricaCritical Infrastructure Protection Act 2019SecurityVerifyReplaced the secrecy-era National Key Points Act. Sources found say commencement not proclaimed; status needs a direct check.
AustraliaSOCI Act, CIRMP annual reportCyberSealedBoard-approved report to the regulator, not the public. Asset register publicness unconfirmed.
CanadaCritical Cyber Systems Protection ActCyberSealedVulnerability and protection information confidential; improper disclosure is an offence.
ChinaCII Security Protection Regs 2021CyberSealedSealed with a state-secrets layer above it, carrying its own penalty regime.
Saudi ArabiaNCA CSCC-1:2019CyberSealedMandatory controls for national critical systems, no public consequence disclosure. No public floor in this market.
BrazilPLANSIC 2022 · CONAMA 398/2008MixedPartialOil-spill emergency plans specified; national survey found many municipalities lack contingency plans at all.
NepalDRRM Act 2074 (2017)DisasterAbsentInstitutions and duties exist; no facility-level public disclosure for water or power. This is the global median, not an edge case.
Kenya · Nigeria · IndonesiaNone established—AbsentNo community right-to-know framework found. Capacity constraint rather than deliberate secrecy. No public floor does not mean no hazard.
Open usable exposure data Partial obtainable with friction Sealed closed by statute Absent / unverified nothing to lean on
05

Three coverage regimes, and the model works in all three

Coverage is uneven by sector and country, so a lives axis must never be promised as universal. What it can promise is that the declared field carries the model wherever the public floor thins out.

Public floor present

Exposure is counted from federal sources. The declaration is checked against it, and a facility can be scored before it ever talks to you.

US electric · US & EU chemical
UK COMAH sites · Indian MAH sites

Floor obtainable with friction

Reading rooms, authenticated databases, derived ratings. Fine for a report, wrong as a product dependency. Label derived values as derived.

US RMP & NERC-derived · eSPIRS
Brazil · anything post-HIFLD-move

No floor at all

The declared window is the entire model. Nothing to cross-check against, so provenance and attestation carry the weight instead.

Every cyber-only filing · Saudi Arabia
Nepal · Kenya · Nigeria · Indonesia
06

Worked example

Pomona Water, loss of chlorination control

Illustrative. Fictional utility, plausible figures, real data sources.
Exposure
200,000 service populationPublic. Utility reporting and Census.
Exposure
1,430 electricity-dependent residents across the served ZIP codesPublic. HHS emPOWER, monthly refresh.
Exposure
8,900 residents inside the worst-case chlorine release endpointPublic with friction. EPA RMP offsite consequence analysis. Note this is the open door around the sealed AWIA assessment.
Declared
6 hours of chlorine residual before contamination becomes credibleThe one field. From the operator, out of the existing hazard analysis.
Response
detect 2.5 h · isolate 1 h · restore 4 hObserved or attested. Total 7.5 hours.
Margin
−1.5 hours. Consequence is credible, and 200,000 people are in the exposed set for the overrun.

Note what the output does not say. It does not predict deaths. It says the protective window closes before the response completes, names who is inside it, and cites where each number came from. That is a claim that survives a hostile reviewer, which a fatality count is not.

07

Open before this becomes methodology

SCOPEWarne has not answered the question that sizes this: does he want a different number, or a different vocabulary? Presentation layer is a week. Methodology change is a quarter. Ask him the onsite question in the same breath: if his OT audience counts its own operators, the offsite boundary in section 02 is wrong for him and a second term is needed.
VERIFYSouth Africa's Critical Infrastructure Protection Act commencement status. Australia's asset register publicness. NIS2's disclosure regime. Singapore, entirely.
TESTThe declared window has not been asked of a real operator yet. One call establishes whether the answer comes back in seconds, which is the whole premise, or whether it triggers a legal review, which kills it.
GUARDThe Düsseldorf hospital ransomware death, the most-cited case in this space, was retracted by German prosecutors. Any lives-denominated output meets that case in its first hostile review and needs an answer ready.
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