ConSASS: Revolutionizing Singapore Construction Safety

ConSASS

1. Introduction: The Strategic Imperative of Safety Maturity

The construction industry in Singapore, a dense urban metropolis characterized by relentless vertical development, operates at the intersection of architectural ambition and inherent risk. 

For decades, the management of these risks was dictated by a prescriptive regulatory framework—a binary system where compliance was mandatory, yet often performative. 

However, the complexity of modern engineering projects, ranging from subterranean transit networks to high-rise mixed-use developments, has necessitated a paradigm shift. 

This shift is operationalized through the Construction Safety Audit Scoring System (ConSASS), a regulatory instrument that has transcended its origins as a checklist to become the primary driver of safety maturity in the nation’s built environment.

This report provides an exhaustive analysis of ConSASS, positioning it not merely as an audit tool but as a strategic mechanism for profiling the “safety DNA” of construction firms. Moving beyond the simplistic “pass/fail” metrics of the past, ConSASS introduces a nuanced banding system that quantifies the qualitative aspects of safety leadership, risk management, and worker engagement.1 

By aligning with international standards such as ISO 45001:2018 and integrating with Singapore’s “Vision Zero” movement, ConSASS has become the cornerstone of a generative safety culture.3

The analysis that follows will dissect the historical evolution of the system from the early CP 79 standard to the impending 2025 updates; evaluate the impact of digital transformation including Digital Twins and AI; and scrutinize the commercial implications for contractors through the WSH Advocate Programme and government tendering processes. 

Through a synthesis of regulatory circulars, academic research, and industry case studies, we establish that ConSASS is revolutionizing safety by converting intangible safety culture into tangible, actionable data.

2. The Genesis of Modern Safety: From Prescriptive Rules to Systemic Management

To understand the revolutionary nature of ConSASS, one must first examine the regulatory landscape that preceded it. 

The evolution of safety auditing in Singapore mirrors the nation’s broader economic transition from labor-intensive industrialization to a knowledge-based, high-efficiency economy.

2.1 The Era of CP 79: The Limitations of Standardization

Prior to 2006, the construction industry’s approach to safety management was fragmented. While the Factories Act provided the legal baseline, the practical implementation of Safety and Health Management Systems (SHMS) was guided by the Singapore Standard CP 79.1 

This standard, while foundational, suffered from significant limitations in audit consistency.

Auditing organizations (AOs) operated with varying protocols. One auditor’s “compliance” was another’s “non-conformance.” 

Crucially, there was no standardized scoring mechanism. An audit report for a site with a robust, proactive safety culture often looked indistinguishable on paper from a site that met the bare minimum requirements.2 

This lack of differentiation posed a critical problem for developers and government agencies. In a competitive tendering environment, they lacked a reliable “common currency” to assess the safety capabilities of prospective contractors. 

The industry needed a metric that could differentiate between a contractor who treated safety as a paper exercise and one who embedded it into their operational ethos.

2.2 The Legislative Pivot: The Workplace Safety and Health Act (2006)

The turning point occurred with the enactment of the Workplace Safety and Health (WSH) Act in 2006

This legislation represented a fundamental philosophical shift from a prescriptive regime—which told companies exactly what to do—to a performance-based regime, which set goals and held stakeholders accountable for outcomes.5

The Act introduced the concept of “reasonably practicable” measures, placing the onus on employers, occupiers, and principals to identify and mitigate risks specific to their operations. 

This effectively distributed legal duties across the entire value chain, recognizing that safety is not the sole domain of the safety officer but a collective responsibility involving top management and supply chain partners.5

2.3 The Birth and Mandate of ConSASS

To operationalize the performance-based mandates of the WSH Act, the Ministry of Manpower (MOM), in collaboration with industry stakeholders, developed ConSASS in 2006. The system was designed with two primary objectives:

  1. Unified Assessment: To provide a standardized checklist and scoring system, ensuring consistency regardless of which Auditing Organization conducted the assessment.2
  2. Maturity Profiling: To provide a mechanism to assess the maturity levels of different elements of a worksite’s SHMS, allowing for cross-comparison and targeted improvement.1

The regulatory mandate was clear and stringent. Since August 2011, all construction worksites with a contract sum of S$30 million or more have been required to submit a mandatory ConSASS audit report to MOM at least once every six months.2 

This threshold targeted large-scale projects—those with the highest inherent risks, the largest workforces, and the greatest potential for catastrophic failure. 

By focusing on these “macro” sites, regulators aimed to create a trickle-down effect of safety standards to smaller sub-contractors.

2.4 The Evolution of Oversight: WSH Council and SAC

The administration of ConSASS is overseen by the Workplace Safety and Health Council (WSHC), a statutory body established in 2008 to work closely with the industry to raise standards.4 The Council’s role is complementary to MOM’s enforcement arm; while MOM punishes non-compliance, the WSHC builds capability and sets acceptable practices.

Crucially, to ensure the integrity of the audit process, MOM stipulated in 2019 that only Singapore Accreditation Council (SAC) accredited WSH Auditing Organizations (AOs) are authorized to conduct ConSASS audits.9 

This accreditation ensures that auditors possess the requisite technical competence and impartiality, reducing the risk of “friendly audits” where scores are inflated to please clients.10

3. Decoding the Framework: Methodology, Banding, and Scoring

The ConSASS framework is not merely a checklist; it is a matrix designed to dissect the operational reality of a construction site. 

It moves beyond checking for the existence of documents to verifying the efficacy of their implementation.

3.1 The Plan-Do-Check-Act (PDCA) Structure

ConSASS is structured around the Deming Cycle (PDCA), a continuous improvement model used globally in quality management systems like ISO 9001. 

This structure ensures that the SHMS is dynamic rather than static.2

  • Plan: Establishing objectives, policies, and processes (e.g., Risk Assessment procedures).
  • Do: Implementing the processes (e.g., conducting toolbox talks, erecting safe scaffolding).
  • Check: Monitoring and measuring processes against policies (e.g., site inspections, internal audits).
  • Act: Taking actions to continually improve performance (e.g., management review, corrective actions).12

3.2 The Banding System: Measuring Maturity

The core innovation of ConSASS is its banding system. Unlike a binary pass/fail, ConSASS evaluates specific elements across distinct bands of maturity. 

In the 2020 revision, the system was streamlined from four bands to three to better align with ISO standards and reduce administrative complexity while increasing the focus on implementation.3

 

Band Focus Area Description Verification Method
Band I System Existence Checks if the SHMS has the necessary provisions and documentation. Essentially, “Do you have a plan?” Document Review (DR): Checking for signed policies, established procedures, and training matrices.2
Band II Implementation Checks if the provisions are sufficiently comprehensive and well-implemented on site. “Is the plan working on the ground?” Interview (IP) & Physical Inspection (PI): Verifying that workers understand the RA and that physical controls (e.g., guardrails) exist.13
Band III Best Practices Checks for the adoption of industry best practices and advanced technologies that exceed minimum regulatory requirements. Triangulation (DR, IP, PI): Looking for evidence of proactive safety culture, behavior-based safety programs, or digital monitoring tools.13

The 70% Rule: To pass a specific band for an element, the worksite must satisfy at least 70% of the questions within that band. Critically, maturity is cumulative. 

A site cannot be awarded Band III status for an element if it fails Band I or Band II. 

This logic prevents “gold-plating”—where a company implements flashy technologies (Band III) while failing basic regulatory duties (Band I).1

3.3 The 20 System Elements (Post-2020 Revision)

The 2020 revision expanded the number of system elements from 17 to 20 to align with the High-Level Structure of ISO 45001. 

This comprehensive list covers every facet of safety management:

  1. WSH Policy: Leadership commitment and strategic direction.
  2. Organizational Roles, Responsibilities, and Authorities: Clear definition of who does what.
  3. Actions to Address Risks and Opportunities: Proactive planning.
  4. WSH Objectives and Planning: Measurable safety goals.
  5. Resources: Allocation of financial and human capital.
  6. Competence: Training and qualification of workforce.
  7. Awareness: Ensuring workers understand the implications of non-compliance.
  8. Communication: Internal and external information flow.
  9. Documented Information: Control of records and documents.
  10. Operational Planning and Control: Managing daily risks.
  11. Safety Controls: Specific measures for physical hazards.
  12. Health and Wellness Controls: Focus on occupational health (noise, chemicals).
  13. Contractor Management and Procurement: Managing the supply chain risks.
  14. Emergency Preparedness: Response plans for crises.
  15. System Monitoring, Performance, and Compliance: Tracking key indicators.
  16. WSH Inspections: Routine site checks.
  17. Internal Audit: Self-assessment mechanisms.
  18. Management Review: Top management strategic oversight.
  19. Incident, Nonconformity, and Corrective Actions: Learning from failures.
  20. Continual Improvement: Systemic enhancement over time.3

3.4 Audit Triangulation: Ensuring Integrity

To counter the “paper exercise” phenomenon, ConSASS mandates a triangulation of evidence. An auditor cannot rely on a document alone.

  • Document Review (DR): The auditor reviews the Risk Assessment (RA) for “Work at Height.”
  • Physical Inspection (PI): The auditor walks the site to see if the specific fall protection systems listed in the RA are actually installed and functional.
  • Interview of Personnel (IP): The auditor interviews the scaffold erector. Does he know the SWP? Can he explain the risks? This verifies that the “Competence” element is real, not just a certificate in a file.10

The 2020 revision significantly increased the weight of implementation checks (Band II), with over 52% of questions now focused on verification rather than just documentation.3

4. Globalization and Harmonization: ConSASS and ISO 45001

The revision of ConSASS in 2020/2021 was not merely an update; it was a harmonization exercise designed to integrate Singapore’s construction sector into the global safety framework established by ISO 45001:2018.

4.1 The Shift from OHSAS 18001 to ISO 45001

Historically, many Singaporean firms utilized OHSAS 18001. However, with the release of ISO 45001, the international standard for Occupational Health and Safety Management Systems, the WSH Council convened an industry-led workgroup to realign ConSASS. 

This ensured that companies complying with ConSASS were effectively building a system compatible with ISO 45001, reducing the administrative burden of maintaining two separate systems.3

4.2 Structural and Philosophical Alignment

The alignment adopted the Annex SL High-Level Structure, which facilitates the integration of safety (ISO 45001) with quality (ISO 9001) and environmental (ISO 14001) management systems. 

This promotes the concept of an Integrated Management System (IMS), allowing construction firms to manage QEHS (Quality, Environment, Health, Safety) holistically rather than in silos.16

Key Philosophical Shifts:

  • Risks AND Opportunities: Unlike OHSAS 18001, which focused primarily on hazards (negatives), ISO 45001 and the new ConSASS require organizations to identify opportunities for improvement (positives), such as adopting new safer technologies.18
  • Worker Participation: ISO 45001 places a heavy emphasis on the consultation and participation of non-managerial workers. ConSASS reflects this by embedding questions that verify workers’ input in Risk Assessments and incident investigations, ensuring safety is not just a top-down directive.3
  • Leadership Accountability: The removal of a standalone “Leadership” element in favor of embedding leadership questions across all 20 elements reinforces the ISO principle that safety leadership is pervasive. Top management is now audited on their visibility and commitment throughout the entire system, not just in the policy statement section.3

4.3 Clause-by-Clause Comparison Table

The following table illustrates the direct mapping between ISO 45001 clauses and ConSASS elements, highlighting the synchronization of the two frameworks.

 

ISO 45001 Clause Description Corresponding ConSASS Element Audit Focus (ConSASS)
Clause 4 Context of the Organization Element 3 (Actions to Address Risks) Verifying the organization understands internal/external issues (e.g., regulatory changes, labor shortages) affecting safety.19
Clause 5 Leadership & Worker Participation Embedded across Elements 1, 2, 4 Checking for top management visibility and evidence of worker consultation in RA/SWP processes.21
Clause 6 Planning Elements 3, 4, 11 Assessing the rigor of Hazard Identification, Risk Assessment, and the setting of measurable WSH objectives.19
Clause 7 Support Elements 5, 6, 7, 8, 9 Verifying resources (budget/manpower), competence (training records), and communication channels.19
Clause 8 Operation Elements 10, 11, 12, 13, 14 Checking operational controls, including procurement (contractor management) and emergency preparedness.19
Clause 9 Performance Evaluation Elements 15, 16, 17, 18 Evaluating monitoring mechanisms, internal audits, and the depth of management reviews.22
Clause 10 Improvement Element 19, 20 Verifying that non-conformities lead to root cause analysis and systemic corrective actions.19

Table 1: Mapping ConSASS 2020 Elements to ISO 45001 Clauses.13

5. The Future Regulatory Landscape: ConSASS 2025 and Beyond

The regulatory environment in Singapore is dynamic, continuously adapting to emerging risks and incident trends. The upcoming updates to ConSASS, scheduled for 1 June 2025, represent the next evolution in this journey.

5.1 The 2025 Update: Targeting High-Risk Activities

Following a review of workplace fatality statistics in 2024 and early 2025, MOM and the WSH Council have calibrated the ConSASS checklist to focus intensely on high-risk activities. 

The 2025 update introduces “Compliance Clarity” and stricter criteria for specific sectors.23

  • Vehicular Safety: In response to vehicular incidents being a top cause of workplace fatalities (accounting for a significant portion of Type A incidents), the new checklist places heavier weight on Traffic Management Plans (TMP). Auditors will be required to verify not just the plan, but the physical segregation of pedestrians and vehicles, and the use of technology like blind-spot detection.24
  • Work at Height (WAH): With falls from height remaining a perennial killer, the 2025 update enhances the scrutiny on scaffolding and formwork. This aligns with MOM Circular MOM/OSHD/2025-04, which mandates enhanced licensing conditions for Approved Scaffold Contractors (ASC). 

From July 1, 2025, ASCs facing suspension for safety lapses will be barred from operations, directly impacting their ability to pass ConSASS audits.26

5.2 Mental Health and Total WSH

While physical safety remains paramount, the future of ConSASS is increasingly integrating Total Workplace Safety and Health (Total WSH)

This approach views the worker holistically, recognizing that health conditions (like diabetes or fatigue) can lead to safety incidents. 

The 2025 checklist and subsequent iterations are expected to include more questions in Element 12 (Health and Wellness Controls) regarding the management of psychosocial hazards, fatigue management, and heat stress prevention—a critical factor in Singapore’s warming climate.27

5.3 Compliance Clarity and Reducing Ambiguity

One of the key feedbacks from the industry was the ambiguity in certain audit questions, which led to inconsistencies between auditors. 

The 2025 update aims to resolve this by providing clearer “Compliance Clarity.” Specific parameters are defined for implementation credits. 

For example, instead of a vague requirement to “inspect machinery,” the checklist might specify “daily pre-use checks documented with operator signatures and verified by supervisors weekly”.3

6. Digital Transformation: ConSASS 4.0 and the Digital Twin

As Singapore accelerates its “Smart Nation” initiative, the construction sector is undergoing a profound digital transformation. 

ConSASS is evolving from a manual, paper-based exercise into a data-driven, continuous monitoring ecosystem.

6.1 Digital Twins: The New Frontier of Auditing

A Digital Twin is a dynamic virtual replica of a physical asset, processes, systems, or devices that can be used for various purposes. In the context of ConSASS, Digital Twins allow for the simulation and real-time monitoring of safety conditions.29

  • Remote Inspection: Instead of physically climbing a 30-story scaffold, an auditor can inspect the structure via the Digital Twin, which is updated in real-time by drone photogrammetry and sensors. This reduces the risk to the auditor and allows for the inspection of inaccessible areas.31
  • Predictive Analytics: By integrating AI with the Digital Twin, safety managers can predict potential ConSASS failures. For instance, if the digital model detects that a temporary earth retaining wall is moving beyond its tolerance (Element 11 – Safety Controls), the system can trigger an alert before a collapse occurs. This moves the audit from a “lagging” indicator (checking what happened) to a “leading” indicator (predicting what will happen).32
  • Virtual Reality (VR) Training: ConSASS Element 6 (Competence) is revolutionized by Digital Twins. Workers can undergo safety training in a VR environment that perfectly mimics their actual worksite. This ensures that their competency is site-specific and verified through data logs of their VR performance.29

6.2 AI and Computer Vision

Artificial Intelligence is automating the “Check” phase of the PDCA cycle. AI-powered cameras can now monitor worksites 24/7, detecting non-conformities that a human auditor might miss during a single site visit.

  • Automated PPE Detection: AI algorithms can identify workers not wearing helmets or harnesses (Element 12 compliance) and instantly log the violation.34
  • Geo-Fencing: AI systems can alert supervisors if a worker enters a hazardous zone, such as the swing radius of a crane (Element 10 – Operational Control). These automated logs serve as irrefutable evidence during ConSASS audits, forcing companies to maintain high standards continuously, not just on “audit day”.34

6.3 The Productivity Solutions Grant (PSG)

Recognizing that these technologies are costly, the Singapore government supports their adoption through the Productivity Solutions Grant (PSG)

This grant is a critical enabler for SMEs, covering up to 50% of the cost (capped at S$30,000) for pre-approved digital safety solutions.35

Pre-Approved Solutions:

  • Hubble Safety Management System: A comprehensive platform that digitizes Permit-to-Work (ePTW), inspection checklists, and toolbox meeting records. It ensures that data is centralized and tamper-proof, directly supporting ConSASS Element 9 (Documented Information) and Element 10 (Operational Planning).37
  • Electronic Permit-to-Work (ePTW): These systems use GPS and worker competency data to ensure that only authorized personnel can open a permit. If a worker lacks the required training (Element 6), the system blocks the permit, ensuring 100% compliance.38

By subsidizing these tools, the government is effectively democratizing access to Band III maturity, allowing smaller contractors to compete on safety quality with major MNCs.

7. Cultural Maturity: The Human Element of Safety

While systems and technologies are vital, ConSASS ultimately aims to measure and improve Safety Culture

The scoring bands are a proxy for where a company sits on the cultural maturity ladder.

7.1 The Hudson Maturity Model

Singapore’s safety roadmap frequently references the Hudson Maturity Model to categorize organizational culture. ConSASS scores correlate strongly with these stages:

  1. Pathological: Safety is viewed as a problem caused by workers. The organization cares only about not getting caught. (Corresponds to ConSASS Failure).
  2. Reactive: Safety is important, but only after an accident happens. (Corresponds to Low Band I).
  3. Calculative: The organization has systems in place to manage hazards. Safety is driven by data and checklists. (Corresponds to ConSASS Band I/II).
  4. Proactive: Leadership drives continuous improvement. Workers are involved in safety decisions. (Corresponds to ConSASS Band II/III).
  5. Generative: Safety is how business is done. There is high trust, and failure is used as a learning opportunity. (Corresponds to High Band III).39

The goal of ConSASS is to push the entire industry from the Calculative stage (where many currently sit, relying on paperwork) to the Proactive and Generative stages.

7.2 Worker Participation: The New Imperative

A significant cultural shift in the post-2020 ConSASS is the requirement for non-managerial worker participation. It is no longer acceptable for safety policies to be dictated solely by management.

  • Audit Verification: Auditors now interview workers to ask: “Were you consulted on this Risk Assessment?” “Did you participate in the incident investigation?”
  • Impact: This empowers the workforce, transforming them from passive recipients of rules into active “risk sensors” who can identify hazards that management might miss.3

7.3 Psychological Safety and “Chronic Unease”

A Generative culture requires “psychological safety”—the belief that one will not be punished for reporting a mistake or a near-miss. 

ConSASS encourages this through Element 19 (Incident Reporting), looking for evidence that near-misses are reported and analyzed without blame. 

This fosters a state of “chronic unease,” where the organization remains vigilant against complacency even when accident rates are low.41

8. Commercializing Safety: Tenders, Advocates, and the “Queen Bee” Effect

Safety is no longer just a regulatory requirement; it is a commercial asset. The WSH Council has successfully integrated ConSASS performance into the commercial ecosystem of the construction industry.

8.1 The WSH Advocate Programme

Launched to leverage the influence of major service buyers, the WSH Advocate Programme enlists large companies (“Queen Bees”) to champion safety excellence within their supply chains.

  • Role of Advocates: Companies like CapitaLand, City Developments Limited (CDL), and ST Engineering commit to requiring their contractors to have WSH accreditation (like bizSAFE Level 3 or Star).
  • Impact: These Advocates favor contractors with good safety records during procurement. They also mentor their SME contractors, helping them build capability. As of September 2025, 37 WSH Advocates were supporting nearly 2,900 SMEs, creating a massive ripple effect where safety compliance becomes a prerequisite for doing business with major developers.42

8.2 Tendering and the Price Quality Method (PQM)

Government tenders in Singapore utilize the Price Quality Method (PQM), where “Quality” accounts for a significant portion of the evaluation score. 

Safety performance, evidenced by ConSASS scores and safety awards, is a key component of the Quality score.

  • Differentiation: A contractor with consistent Band III scores and WSH Performance Awards has a distinct advantage over a competitor with lower safety credentials, even if the competitor’s price is slightly lower. This financial incentive drives companies to invest in safety not just to avoid fines, but to win work.2

9. Case Studies: Excellence in Action

The theoretical frameworks of ConSASS come to life in the operations of Singapore’s leading firms.

9.1 Power Partners Group (PPG): Integrating Total WSH

Power Partners Group, a recipient of the bizSAFE Enterprise Exemplary Award and WSH Performance Awards, exemplifies the proactive culture ConSASS promotes.

  • Strategy: PPG integrates “Total WSH” by combining physical safety with health initiatives. Their risk management plans cover not just workplace hazards but also employee health risks, aligning with ConSASS Element 12.
  • Leadership: Their “Work Safely from the Heart” slogan reflects a generative culture where safety is a core value, driven by top management visibility (Element 1).44

9.2 Keppel: Sustainability and Zero Fatality

Keppel, a major conglomerate, integrates ConSASS principles into its broader sustainability strategy.

  • Performance: In their 2024 Sustainability Report, Keppel reported zero fatalities and high training hours per employee, exceeding targets.
  • Governance: They utilize a “Zero Fatality Strategy” and tie safety performance to executive remuneration, a “Band III” best practice in accountability. Their use of digital tools and rigorous internal auditing (ConSASS Element 17) ensures they consistently meet the highest standards.46

10. MOM Enforcement: The Stick Behind the Carrot

While grants and awards act as carrots, MOM’s enforcement regime serves as the stick. ConSASS audits provide the intelligence that guides this enforcement.

10.1 1H 2025 Safety Statistics

MOM statistics from the first half of 2025 show the impact of this regime. The annualized workplace fatal injury rate dropped to 0.92 per 100,000 workers, putting Singapore on par with global leaders like the UK and Sweden.24

  • Sectoral Improvement: The construction sector saw a decrease in fatal and major injury rates from 30.6 (1H 2024) to 28.2 (1H 2025). This improvement is attributed to the “Safety Time-Out” exercises and targeted inspections focused on high-risk areas identified in ConSASS audits.24

10.2 Targeted Interventions

Data from ConSASS reports allows MOM to identify systemic weaknesses across the industry. If multiple audits reveal poor “Vehicular Safety” scores, MOM launches a targeted enforcement operation (Ops) focusing on that specific hazard.

  • Safety Time-Out (STO): In June 2025, following a spate of accidents, MOM advised a voluntary STO focusing on vehicular safety and work at height. This mechanism forces companies to pause work, review their ConSASS compliance in these specific areas, and rectify gaps before resuming.25

11. Challenges and Solutions for SMEs

Despite the success of ConSASS, the “capability gap” between large MNCs and local SMEs remains a challenge.

11.1 The Resource Barrier

SMEs often lack the dedicated WSH personnel and financial resources to implement complex systems like ISO 45001 or advanced Digital Twins. For them, ConSASS can feel like a crushing administrative burden.12

11.2 Bridging the Gap: StartSAFE and SME Centres

To address this, the WSH Council and MOM have rolled out specific support programs:

  • StartSAFE: A fully subsidized program that helps SMEs identify WSH risks and implement basic structures, acting as a stepping stone to bizSAFE Level 3 and ConSASS compliance.42
  • SME Centres: These centers provide consultancy to help SMEs navigate the grant landscape (PSG) and implement scalable safety solutions that fit their budget.51

12. Conclusion: The Road to Vision Zero

ConSASS has fundamentally altered the trajectory of construction safety in Singapore. 

It has evolved from a static checklist into a dynamic, data-driven ecosystem that integrates international standards, digital technology, and cultural maturity.

The revolution lies in the visibility it provides. By quantifying the intangible—safety culture—ConSASS allows stakeholders to manage safety with the same rigor as they manage finance or schedules. 

The alignment with ISO 45001 has globalized Singapore’s standards, while the 2025 updates and Digital Twin integration ensure they remain future-proof.

As Singapore marches toward its WSH 2028 goal of a fatality rate below 1.0 per 100,000 workers—a goal it is currently meeting—ConSASS remains the central operating system of this success. 

It ensures that as the nation builds higher and faster, it does so with a conscience, proving that in the modern built environment, the only acceptable score is zero harm.

Citations Used:

 

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