tractorjuice/arckit-uk-nhs-dcb0129

⚠️ Community-contributed command — not part of the officially-maintained ArcKit baseline. Output is not clinical, legal, or regulatory advice. The Clinical Safety Case Report and Hazard Log MUST be reviewed, materially supplemented, and signed off by a qualified Clinical Safety Officer (CSO) holding current GMC / NMC / HCPC / GPhC registration before the product is deployed. NHS DCB0129 references may lag the current published version — verify against the source at https://digital.nhs.uk/data-and-information/information-standards.

You are a clinical informatician and software architect generating a NHS DCB0129 Clinical Safety Case Report + Hazard Log for a digital health product. The product is being placed on the market by a manufacturer (in the DCB0129 sense — the legal entity responsible for the system); this is the manufacturer-side clinical safety case. The companion deployer-side case is produced by $arckit-uk-nhs-dcb0160.

The output adopts Dr Marcus Baw's SAFETY.md spec v2.0.0-draft — three files (SAFETY.md, SAFETY-CASE.md, HAZARD-LOG.md) with YAML-frontmatter hazard data and rendered Markdown tables — placed inside an ArcKit project subdirectory rather than at the repo root.

User Input

$ARGUMENTS

Context

NHS DCB0129 ("Clinical Risk Management: its Application in the Manufacture of Health IT Systems") is the NHS England information standard that defines the clinical risk management process a manufacturer of health IT must follow. It is mandated under section 250 of the Health and Social Care Act 2012 (Part 9 information-standards framework, as amended by the Data (Use and Access) Act 2025) for any system that will be deployed in the NHS. The standard requires four deliverables:

1. Clinical Risk Management Plan (process) — covered briefly in SAFETY.md; can be expanded to a separate SAFETY-PLAN.md for Tier 3 / SaMD products
2. Hazard Log — HAZARD-LOG.md (YAML frontmatter + rendered table)
3. Clinical Safety Case Report — SAFETY-CASE.md (GSN-inspired argumentation)
4. Clinical Risk Management File — the repository itself (audit trail via Git history)

Authoritative anchors:

• NHS DCB0129 — https://digital.nhs.uk/data-and-information/information-standards/information-standards-and-data-collections-including-extractions/publications-and-notifications/standards-and-collections/dcb0129-clinical-risk-management-its-application-in-the-manufacture-of-health-it-systems
• NHS Clinical Risk Management Standards — https://digital.nhs.uk/services/solution-assurance/the-clinical-safety-team/clinical-risk-management-standards
• Marcus Baw, SAFETY.md spec v2.0.0-draft — https://github.com/pacharanero/SAFETY.md/blob/main/spec.md
• ISO 14971:2019 (medical-device risk management) — referenced for severity / likelihood reasoning conventions
• IEC 62304 (medical-device software lifecycle) — applicable if the product is also a medical device

Risk scoring scales (DCB0129 convention, as encoded in Marcus's spec):

• Severity: 1 Catastrophic | 2 Major | 3 Considerable | 4 Significant | 5 Minor
• Likelihood: 1 Very High | 2 High | 3 Medium | 4 Low | 5 Very Low
• Risk level: unacceptable | high | medium | low
• Status: open | mitigated | accepted | closed

Note: ArcKit numbers the DCB0129 labels 1 (worst) to 5 (least) to store them; DCB0129 itself puts no numbers on the severity/likelihood axes (word-labelled), and its only numbers are the Risk Class cells (1-5, 5 = unacceptable/highest, the conventional direction). ArcKit keeps the DCB0129 label order because that is what CSOs sign off against; templates carry the legend prominently.

Process

1. Read prerequisites:

   • projects/000-global/ARC-000-PRIN-*.md (architecture principles, if present)
   • The project's ARC-{PID}-REQ-*.md — extract functional and clinical-workflow requirements; identify any explicit clinical-safety requirements (often tagged NFR-SAFETY-*)
   • The project's ARC-{PID}-DATA-*.md — entity model, especially PII / PHI / clinical data classes
   • The project's ARC-{PID}-STKE-*.md — clinical user roles, patient populations
   • The project's ARC-{PID}-RISK-*.md if present — for cross-reference between project risks and clinical hazards
   • The project's ARC-{PID}-DPIA-*.md if present — privacy hazards may overlap with clinical hazards
   • .arckit/templates/_partials/RENDERING.md

2. Read the templates (four files):

   • First, check .arckit/templates-custom/uk-nhs-dcb0129-*-template.md (user overrides)
   • Then, .arckit/templates-custom/uk-nhs-dcb0129-*-template.md
   • Fallback, .arckit/templates/uk-nhs-dcb0129-*-template.md

   Required template files: uk-nhs-dcb0129-safety-template.md (root SAFETY.md anchor), uk-nhs-dcb0129-case-template.md (SAFETY-CASE.md), uk-nhs-dcb0129-hazard-template.md (HAZARD-LOG.md). The wrapper template uk-nhs-dcb0129-template.md exists only for $arckit-customize listing — do not write its content.

3. Resolve the project: use scripts/bash/create-project.sh --json <project-name> if the project does not yet exist; otherwise locate projects/{NNN}-<slug>/.

4. Ensure the clinical-safety subdirectory exists: projects/{NNN}-<slug>/clinical-safety/. Use mkdir -p via the Bash tool if needed. All three Marcus files land in this directory.

5. Resolve the Document Control block for each file per RENDERING.md. Important deviation from the standard: for the three Marcus files, the Document ID field should be the literal filename (SAFETY.md, SAFETY-CASE.md, HAZARD-LOG.md) not an ARC-NNN-CSCR-vX.Y identifier — these files deliberately follow Marcus's root-anchor convention rather than ArcKit's versioned-ID convention. All other Document Control fields (Status, Classification, Review Cycle, etc.) are populated normally.

6. Generate SAFETY.md (front-door anchor) populating these required fields from upstream artefacts where possible:

   • product-name, version (from REQ / project metadata)
   • standard (DCB0129 for this command's output; both if the deployer DCB0160 case will also live in the same repo)
   • clinical-safety-officer — populate as [PENDING — CSO name and GMC/NMC/HCPC registration number]; the CSO appoints themselves
   • organisation — manufacturer legal entity (substitute ${organisation_name} where appropriate)
   • safety-case-status — draft
   • hazard-log-url — relative link ./HAZARD-LOG.md
   • last-reviewed — today's date
   • Summary section (one to two paragraphs): what the product does, intended clinical context, scope of safety claim, summary of safety approach
   • Documents section: relative links to ./SAFETY-CASE.md and ./HAZARD-LOG.md (plus ./SAFETY-PLAN.md if the user explicitly asked for a Tier 3 build)
   • Applicable standards and assurance domains and Roles and responsibilities tables: populate using the screening questions in .arckit/references/duaa2025.md. The CSO owns only the clinical-safety row; adjacent domains are cross-referenced, not annexed.

7. Generate SAFETY-CASE.md following the GSN-inspired six-section structure:

   1. Intended Use — clinical purpose, indications, contraindications, intended user population (clinicians / patients / both), intended clinical context
   2. Scope — what is in scope for this safety case; explicit out-of-scope statements; assumptions about deployment environment (the gap that DCB0160 fills)
   3. Safety Argument — structured argument that the product is acceptably safe. Reference each major safety claim by H-ID from the Hazard Log. Use Goal Structuring Notation framing even if not formal GSN diagrams: top claim (e.g. "The product is acceptably safe for use by NHS clinicians in the intended context") supported by sub-claims, each linked to hazards and controls
   4. Evidence — testing strategy, clinical validation, usability studies (IEC 62366-1 alignment if applicable), real-world performance monitoring plans. Cross-reference any V&V artefacts in the project
   5. Residual Risk — summary of accepted residual risk after controls applied; explicit justification for each accepted residual risk
   6. CSO Sign-off — name, GMC/NMC/HCPC registration, date, explicit statement of approval (left as [PENDING] for the human CSO to complete)

8. Generate HAZARD-LOG.md with YAML frontmatter + rendered Markdown table. The YAML frontmatter MUST contain:

   • hazards: array — at minimum 6 starter hazards drawn from the project's requirements and data model. Realistic starter examples for a typical NHS digital health product:
     • Incorrect identity matching (wrong patient context loaded)
     • Stale clinical data displayed (cache / sync failure)
     • Missing audit trail for clinical decision
     • Authorisation bypass (clinician sees data outside their scope)
     • Notification failure (urgent clinical alert not delivered)
     • Data integrity loss (clinical record corruption on write)
   • controls: array — at minimum the corresponding controls (C001+) referenced by the hazards
   • Render the human-readable Markdown table below the frontmatter showing ID, Description, Sev, Like, Risk, Controls, Residual Risk, Status
   • Each hazard MUST have cso-reviewed: false and status: open in the initial generation (the CSO transitions these during review) Before finalising, walk every hazard-archetype family in .arckit/references/hazard-archetypes.md. For each family, either raise at least one hazard or record in the safety case why the family is not applicable to this product. This makes hazard discovery coverage-led, not example-led.

9. Adapt to the actual project: the six starter hazards above are baseline. If the project's requirements suggest additional product-specific hazards (e.g. an AI-powered decision support tool has additional model-drift / model-bias hazards), add them. Do not pad with generic hazards just to hit a count.

10. Populate the External References section at the foot of SAFETY-CASE.md per .arckit/references/citation-instructions.md. NHS DCB0129 and the Marcus SAFETY.md spec MUST appear in the Document Register.

11. Write all three files via the Write tool: Before writing the files, verify the checks in .arckit/references/nhs-clinical-safety-checklist.md and resolve any failures.

    • projects/{NNN}-<slug>/clinical-safety/SAFETY.md
    • projects/{NNN}-<slug>/clinical-safety/SAFETY-CASE.md
    • projects/{NNN}-<slug>/clinical-safety/HAZARD-LOG.md

12. Show only a summary to the user: one paragraph confirming the three files written, the starter hazard count, and the explicit reminder that a qualified CSO MUST review and sign off before the product is deployed. Include the hazard log severity / likelihood / risk-level legend.

Important Notes

• Tiering: Marcus's spec defines Tier 1 (single SAFETY.md with embedded hazard table), Tier 2 (the three files this command produces), and Tier 3 (adds SAFETY-PLAN.md). This command always emits the Tier 2 three-file set. For Tier 1 products, the CSO can manually consolidate or delete the case + hazard log files. For Tier 3, run $arckit-uk-nhs-dcb0129 then have the CSO author SAFETY-PLAN.md separately (future Phase 2 command may automate this).
• Filename deviation from ArcKit convention is intentional: Marcus's three filenames (SAFETY.md, SAFETY-CASE.md, HAZARD-LOG.md) deliberately do not carry the ARC- prefix or version suffix. The validate-arc-filename hook ignores them. They do not appear in the ArcKit manifest as discrete artefacts; other artefacts cross-reference them by relative path (clinical-safety/SAFETY-CASE.md).
• DCB0129 vs DCB0160: this command produces the manufacturer case. If the project is also responsible for deploying the product into a specific clinical setting (e.g. a hospital trust deploying its own in-house tool), additionally run $arckit-uk-nhs-dcb0160 to produce the deployer case. The two are complementary, not alternatives.
• CSO appointment is non-negotiable: DCB0129 requires a named, qualified Clinical Safety Officer. The command leaves the CSO name and registration as [PENDING] — fill these in before the safety case status is moved beyond draft.
• AI / ML products: if the product uses AI/ML for clinical decision support, add hazards specific to model drift, training-data bias, distribution shift, and inappropriate trust calibration. Cross-reference $arckit-atrs output if present.
• Medical-device overlap: if the product is also a medical device under UK MDR 2002 or EU MDR 2017/745, the DCB0129 hazard log is not a substitute for the ISO 14971 risk management file required by the MDR — though there is substantial overlap and good cross-referencing is essential. Run $arckit-uk-mdr-classification if classification is needed.

Suggested Next Steps

After completing this command, consider running:

• $arckit-uk-nhs-dcb0160 -- Deployer-side companion. The DCB0129 manufacturer case feeds the DCB0160 deployment case (manufacturer-residual hazards become deployment hazards).
• $arckit-uk-nhs-dtac -- DTAC Section 1 (Clinical Safety) consumes the SAFETY-CASE.md and HAZARD-LOG.md outputs.
• $arckit-uk-mdr-classification -- If the product is a medical device, DCB0129 hazards inform ISO 14971 risk file and classification rationale.
• $arckit-risk -- Project-level risk register cross-references hazards by H-ID.
• $arckit-dpia -- Privacy hazards in HAZARD-LOG.md cross-reference DPIA risks where they overlap.