RAAML11 — STPA is not properly implemented

RAAML claims to implement STPA, but some important elements are missing.

For example,

In Step-1 of the STPA process (in the 2018 Leveson/Thomas STPA Handbook – Figure 2.3) it calls out the need to derive “Safety Constraints” from the Losses. I can find no reference to Safety Constraints in the RAAML.

Furthermore the RAAML does not provide any linkage from Losses to Hazards, which is expected in the Handbook.