Lawrence Berkeley National Laboratory

Integrated Safety Management Systems Review

August 8-9, 2006

Integrated EH&S Management:

The Berkeley Lab’s Plan

Howard Hatayama

EH&S Division Director

1. Berkeley Lab’s Three-Tiered Approach

2. Division Safety Plans

3. Activities/Projects

4. Closing

Agenda

Berkeley Lab’s ISMS Plan Is Comprehensive

• Covers All Work at the Berkeley Lab• Affords Protection for Workers, the Public, and the

Environment• Fully Integrated with Business Systems and

Normal Work Processes• Incorporates Continuous Improvement Through

Self-Assessment at All Levels• Tailors DOE ISMS Criteria to the Berkeley Lab

Culture and Environment

DesignWork

The Berkeley Plan Centers on Core ISM Functions

Program/Activity

EstablishControls

Assess &Feedback

AnalyzeHazards

PerformWork

DesignWork

Division/Department

EstablishControls

AnalyzeHazards

PerformWork

DesignWork

Institution

EstablishControls

Assess &Feedback

AnalyzeHazards

PerformWork

Assess &Feedback

Core Functions Match the Roles at Three Levels

• Institution

– Define mission, set policy, develop guidance and site-wide procedures, provide services, assurance of institutional efforts

• Division/Department

– Implement programs and activities that incorporate institutional policy and procedures, assurance of division/department efforts

• Project/Activity

– Integrate EH&S requirements in work activities

ISMS Plan Outline

Institutional Level

Berkeley Lab Policy Reflects Guiding Principles

Berkeley Lab Policy and Procedures ManualsAre Aligned with ISMS and Reflect Core SafetyFunctions and Guiding Principles:

• Vision 2000“All of our activities will be conducted with full regard for the environment, health, and safety.”

• PUB-201, Regulations & Procedures Manual“As a condition of employment, every employee, visiting scientist,

student, or other person performing work at the Laboratory or at

one of the Laboratory's off-site locations must be familiar with and implement applicable Laboratory safety standards.” (7.01B)

Participating Guests and Visitors

RPM 7.01 Health & Safety, B. Responsibilities

“Each Laboratory manager is responsible for ensuring that employees (including matrixed employees — see Paragraph (D) below), participating guests, contractors, students, and visitors under his or her supervision are properly trained in emergency and safety procedures and are provided a safe and healthful working environment, free from undue hazards. In exercising this responsibility, all managers may delegate authority and assign responsibility for a particular operation, but they retain accountability for oversights and errors that lead to injury, illness, environmental pollution, or damage to property within their jurisdictions.”

Berkeley Lab Policy Reflects Guiding Principles

• PUB-3000, Health & Safety Manual

– Revised to Reflect WSS & ISMS

“Fundamental to the attainment of ISM are personal commitment and accountability, mutual trust, open communications, continuous improvement, worker involvement, and full participation of all interested parties. To achieve ISM, the Berkeley Lab has adopted the following seven guiding principles, discussed below, which are reflected in the detailed policies and procedures of the Laboratory. In addition, principal investigators, managers, and supervisors are expected to incorporate these principles into the management of their work activities. While these principles apply to all work, the exact implementation of these principles is flexible and can be tailored to the complexity of the work and the severity of the hazards.” (Chapter 1, Sect.1.3 Environment, Safety, and Health (ES&H) Integration)

General Policy Reflects Guiding Principles

Pub-3000, Chapter 1 -- Roles and Responsibilities » Line Management Accountability: Protection of

Public, Workers, Environment» Requirements for Competence Commensurate

with Responsibilities» Priorities Assessment» Identification of Hazards and Standards» Authorization Basis

General Policy Reflects Guiding Principles

PUB-3000, Chapter 6 – Safe Work Authorizations» Line Management Authorizations» Formal Authorizations» Facility-Based Authorizations» Responsibilities

Berkeley Lab Policy Reflects Guiding Principles, p.3

• Operating and Assurance Plan– Incorporates ISMS into the Lab’s quality and conduct of

operations efforts

• PUB-5344, Environment, Safety & Health Self-Assessment Program

– Self-assessments explicitly linked to core safety functions and guiding principles

Guiding Principles 1 & 2

• Line Management Responsibility for EH&S– Laboratory line managers are responsible for integrating ES&H into work

and for ensuring active communication up and down the management line and with the workforce

• RPM, Chapter 7: Health & Safety• Health & Safety Manual, Chapter 1

• Clear Roles and Responsibilities– Clear and unambiguous lines of authority and responsibility for ensuring

EH&S is established and maintained at all organizational levels within the Laboratory, and for work performed by its contractors

– RPM, Chapter 7: Health & Safety– Health & Safety Manual, Chapters 1, 6, 10– Position descriptions and performance reviews– Work authorization documents (Division ISM plans, AHDs, RWAs, SSAs,

RWPs, etc.)

Guiding Principles 3 & 4

• Competence Commensurate with Responsibilities.

– Personnel possess the experience, knowledge, skills, and abilities that are necessary to discharge their responsibilities.

– RPM, Chapter 7: Health & Safety– Health & Safety Manual, Chapter 1, 6, 24– Position descriptions and performance reviews– Job hazard questionnaires/EH&S Training– Work authorization documents (Division ISM plans, AHDs, RWAs, etc.)– EH&S personnel matrixed to divisions

• Balanced Priorities– Berkeley Lab Institutional Plan– “Unified Call” incl. risk prioritization, review by Lab and DOE management– RPM, Chapter 7: Health & Safety– Health & Safety Manual, Chapter 1

Guiding Principles 5, 6 & 7

• Identification of EH&S Standards and Requirements– 1996 Integrated Hazard Assessment and Work Smart Standards Process,

updated annually – Health & Safety Manual revised to reflect WSS– Work authorizations according to Health & Safety Manual, Chapter 6

• Hazard Controls Tailored to Work Being Performed– Division ISM Plans– Work authorizations according to Health & Safety Manual, Chapter 6

• Operations Authorization– UC/DOE contract– Institutional ISMS Plan– Health & Safety Manual– Division ISM Plans– Work authorizations according to Health & Safety Manual, Chapter 6

ISMS PLAN

Division Level

Division ISM Plan Features

• Implement in all Berkeley Lab Divisions:– Work Smart Standards– Guiding Principles– Core Safety Functions

• Fully Establish Accountability and Decision Authority for EH&S in Divisions/Departments

• Clear Mutual Understanding of EH&S Expectations• Authorization Agreement• Division ISM Plans are Updated Annually (ISM Review

Board after MESH)• Tailoring Vehicle

Division ISM Plans Are Authorization Documents . . . Expressions of Line Ownership

• Division Directors Commit to How They Will Conduct EH&S in Their Divisions

• EH&S Director Commits to Provide Specified Level of Technical Resources

• Internal Review and Acceptance

• Formal Acceptance by Laboratory Director

• Annual Self-Assessment and Roll-Up

• Division Directors Defend Division Program and Performance to Senior Management

ISMS PLAN

Activity Level

Policy Applicable to Project or Activity Level

“It is the policy of the Ernest Orlando Lawrence Berkeley National Laboratory to provide a safe and healthful working environment for its employees, participating visitors, and other visitors; to prevent any harm to the health and safety of the general public or to the environment as a result of the Laboratory’s activities; and to protect its property from damage or loss due to accidents or other causes.”

(PUB-3000, Chapter 1, 1.2 Policy)

“As part of the work planning process, principal investigators, managers, and supervisors (work leaders) are required to consider what hazards, risks, and concerns are present, and to implement appropriate controls.”

(PUB-3000, Chapter 6, 6.2.1 Work Planning)

Research Activities

Researcher Review for All Activities

• Researcher Is Required to Review All Activities for Conformance to PUB-3000 EH&S Requirements.

• Hazard Assessment Guide Table Is Designed to Facilitate the Process.

EH&S Review and Authorization Processes

• Activity Hazard Documents• Government Identification

Card (Crane Operators)• Forklift Operator Certificate• Engineering Safety Note• Construction Safety & Health

Program/Site-Specific Safety Plan and Hazard Communication Program.

• Construction Subcontractor Pre-Job Checklist and Hazard Communication Program.

• BAAQMD Permit (Bay Area Air Quality Management District)

• Burn (Hot Work) Permit• Wastewater Discharge Permit• Fire Safety/Code Review• Hazardous Waste Disposal

Requisition & Related Documentation

• Radiation Work Authorization• Radiation Work Permit• X-Ray Machine Safety

Document• Human-Subject Protocol• Animal-Use Protocol

Line Management Authorization for All Research Projects

“The processes undertaken to fulfill … requirements are specified in each division’s approved Integrated Safety Management (ISM) plan and implementing procedures. As long as the process and hazards control are routine and conform to the individual division’s ISM Plan, and the individuals are trained as specified, then work is considered to be authorized under that division's self-authorization. Each employee must familiarize himself/herself with the provisions of his/her division’s ISM Plan.”

(PUB-3000, Chapter 6, 6.2.2 Line Management Authorization Process)

Non-Research Activities

and Projects

Project/Activity Review Processes (Facilities Projects)

• Work Review

– 1. Large Projects - each project assigned an EH&S lead and EH&S team appropriate to the hazard

– 2. Small projects (operational funds/non-cap)– EH&S lead recruits subject matter experts as required

– 3. Maintenance projects – Planning/review process outlined in Maximo system; Facilities recruits EH&S assistance as required.

– ALL PROJECTS: Safety is the responsibility of the Facilities ALL PROJECTS: Safety is the responsibility of the Facilities Project ManagerProject Manager

Tailored Approaches for Other Employment Relationships

• Participating Guests and Visitors– Laboratory host is responsible for assuring full

qualifications or for providing escort or supervision by a fully qualified individual

• Contract Labor– Same qualifications as career employees, screening by

hiring division or contract labor agency– Same EH&S requirements as career employees– Included in all corrective actions

Five Strategies for Dealing with Contractors and Guests, Each Tailored for Best Fit:

Tailored Approaches for Contractors

• Construction Contractors– Project Work:

• > $ 50,000 - Safety plans submitted and approved

• < $ 50,000 - Checklists submitted and approved

• Frequent job-site surveillance and follow-up• Report accidents and hours worked

– Safety is considered as a component of “best value” when evaluating bids

Tailored Approaches for Contractors

• Service Contractors with a Major Presence– Contractors with 10 or more people on site– Submit “Injury and Illness Prevention Plan” for approval– Report accidents and hours worked

• Other Service Contractors– Get booklet on entry– Follow Lab rules– Lab sponsor responsible for:

• selecting demonstrably competent contractor• assuring contractor employees not at risk from Lab

operations• assuring Lab employees not at risk from contractor

operations

Service Contractors

Fire Extinguisher Servicing Copy Machine Service Scientific Instrument Installation,

Calibration, Repair Software Support Vendors Crane and Hoist Maintenance Consultants “Goats-R-Us”

Berkeley Lab ISMS

Like Research Integrity,

Scientific Discipline, and

Fiscal Responsibility,

SAFETYSAFETY Is a Product of

Culture and Sound

Management