§7.01
Environment, Safety, and Health (ES&H)
§7.01
Rev. 7/09
It is the policy of Lawrence Berkeley National Laboratory (LBNL) to perform all work safely with full regard to the well being of workers, guests, the public, and the environment.
Keys to implementing this policy are the following core safety values:
To fulfill this vision, LBNL implements the regulatory requirements of the Environment, Safety, and Health (ES&H) Standards Set through a hierarchy of policies, procedures, and performance objectives in this document (Line Management and the Environment, Health, and Safety [EH&S] Division), the LBNL Integrated Safety Management Plan (ISMP), the LBNL Health and Safety Manual (PUB-3000), and the following ES&H technically based major Implementation Plans:
1. Line Management Responsibilities
The first principle of Integrated Safety Management (ISM) states that Line management is directly responsible for the protection of the workers, the public, and the environment. The second principle, in stating that clear lines of authority and responsibility for ensuring safety shall be established and maintained at all organizational levels, makes clear that this responsibility cannot be delegated outside of the unbroken chain of management personnel responsible for an organization’s direction, operations, performance, and effectiveness. Therefore, the Laboratory Director has the ultimate responsibility for safety at the Laboratory and, in particular, for the establishment and administration of ES&H policies that meet the safety challenges of Laboratory operations and activities as well as the requirements of DOE Contract 31 and the ES&H Standards Set.
The Laboratory Director has delegated to all levels of management the authority to implement the Laboratory’s ES&H and emergency-preparedness policies.
Division directors and heads of independent departments are responsible for ensuring that the Laboratory’s ES&H and emergency-preparedness policies are being observed within their divisions.
Each Laboratory manager or supervisor is responsible for ensuring that employees (including matrixed employees; see below), participating guests, contractors, students, and visitors under his or her supervision are properly trained in safety and emergency procedures, the concepts of an ISM system, and the five core functions of ISM. In addition, managers and supervisors have responsibilities designed to provide a safe and healthful working environment free from undue hazards and to protect the environment (see Chapter 1 of PUB-3000). In exercising these responsibilities, all managers may delegate authority and assign responsibility for a particular operation, activity, or area to a work lead, but they retain accountability for worker and workplace safety. Oversights and errors that lead to injury, illness, environmental pollution, or damage to property within their jurisdictions are their responsibility.
The importance of identifying accountability in cases of delegated authority is applicable to employees from one division (the home division) who are matrixed to another division (the host division) to provide special technical expertise. The matrixed employee’s individual safety, including his or her safety training, the use of special equipment and instrumentation, and acknowledgment of the importance of safety, is the responsibility of the home division supervisor. Identifying workplace hazards and controlling such hazards to maintain safety in the workplace or work area are the responsibilities of the host division supervisor. A host division supervisor may authorize a matrixed employee to be a work lead of two or more host division employees and to provide, for example, on-the-job training and direction in the use of equipment and instrumentation. In this scenario, the matrixed employee assigned as supervisor/work lead is responsible for staff safety in the operation of equipment, but not for the work area. The policy and implementation guidance for matrixed employees is covered in detail in Chapter 1 of PUB-3000. Section 1.3.2.7 recommends developing a memorandum of understanding to alleviate concerns and clarify lines of authority in these situations.
2. The Environment, Health, and Safety (EH&S) Division
The primary responsibility of the EH&S Division is to protect workers, the public, and our environment by providing professional and technical expertise, follow-on services, and integrated ES&H policy to the Lab's research and support programs. The EH&S Division supports and acts as a partner with line management as it meets direct responsibilities to ensure that protection of workers, the public, and the environment is integrated into the primary research and support functions of each division or unit. Of equal importance, the EH&S Division supports and provides expertise directly to each Laboratory worker who seeks ES&H advice and help, or who voices a concern. The Charter of the EH&S Division, broadly based on the key core safety values in the opening statement and the responsibilities listed here, is published as Chapter 2 of PUB-3000.
3. The LBNL Integrated Safety Management (ISM) Plan
The LBNL institutional ISM Plan provides guidance and performance expectations both to operational and programmatic divisions to develop Division ISM Plans specific to their work, activities, operations, and staffing patterns. This arrangement provides an effective and efficient means for each division to develop and tailor an ISM Plan to address their specific safety challenges. The LBNL institutional ISM Plan and the divisional plans are updated at least annually to address safety challenges derived from changes in programs and/or activities and to reflect improvements based on self-assessments and lessons learned. These relationships and interfaces are depicted in Figure 1, below, and described in detail in the LBNL ISM Plan (PUB 3140).
Figure 1. LBNL document hierarchy: The functional relationship between the DOE/LBNL contract, LBNL ES&H policies, and ES&H implementing elements.
The LBNL institutional ISM Plan sets performance expectations based on the seven principles and five core functions of ISM at three levels: institutional, activity, and individual. Institutional expectations are specified in the Contract 31 Performance Evaluation and Measurement Plan (PEMP). Activity and operational expectations are described in RPM Chapter 8, Section 8.01 (Quality Assurance), and details on the performance assessment at this level are published in the LBNL ES&H-Assessment Program (PUB-5344). Individual expectations are based on the safety-related roles and responsibilities of supervisors, work leads, and each staff member, including guests, subcontractors, and vendors as defined in the Health and Safety Manual (PUB-3000, Chapter 1). Annual performance reviews include safety expectations as part of the performance review process (Employee Institutional Requirements). Division ISM Plans are expected, and measured as part of the annual self-assessment process, to reflect the hierarchy of expectations for activities/operations and individuals. The goal is to provide specific, clear, and current safety expectations that probe performance vertically and horizontally across the organization to guide continuous improvement.
Some Implementation Plans were developed in direct response to regulatory requirements; for example, 10 CFR 835 called for a Radiological Protection Plan, and 10 CFR 851 led to the Worker Health and Safety Plan. However, all are derived from the recognition by the Laboratory of the need, based on potential hazards to the worker, the public, and the environment, for a rigorous approach to work planning, hazard identification and control, and performance of work. Therefore, a component common to these plans is formal work authorizations. Work authorizations applicable to operations and programs such as Activity Hazard Documents for laser use, Radiological Work Authorizations, and the use of forklifts, cranes, and hoists are covered in detail in PUB-3000. Some of the authorizations in these plans are applicable to specific facilities and others to the institution as a whole. Examples of these are Safety Analysis Documents (SADs) that establish the safe operating limits for the Advanced Light Source and environmental and waste management permits from regulatory agencies. The purpose of the Implementation Plans is to translate the regulations and standards in the ES&H Standards Set into technical programs. PUB-3000 acts as the outreach implementation of the plans in a more functional form for integration and implementation into work and activities throughout the Laboratory.
To achieve their technical goals, the implementation plans have policies and procedures internal to the group responsible for the plan to implement the technical aspects of the program (e.g., environmental monitoring, chemical exposure monitoring, radiation dosimetry); to update technical expertise, instrumentation, and standards; and to drive continuous improvement.
5. The LBNL Health and Safety Manual (PUB-3000)
PUB-3000 consolidates ES&H policies, specific responsibilities, and guidance for implementation into a convenient online package. This comprehensive manual is firmly based on the seven guiding principles and is designed to implement the five core functions of ISM. The goal is to ensure that all work will be performed with full regard to the well being of workers, guests, the public, and the environment. LBNL performs work to meet the requirements of the manual, which are based on the ES&H Standards Set. PUB-3000 addresses all the standards of the EH&S Standards Set in a manner designed to provide individual safety and a safe workplace, and to protect the environment. The manual is reviewed and revised on an ongoing basis to comply with new applicable standards and requirements, and to meet the challenges of new research and development activities, operations, and facilities.
Chapters in PUB-3000 provide technical information and guidance derived from the EH&S Standards Set and the Implementation Plans. This information provides LBNL staff with policies, guidance, and sufficient technical information to develop work authorizations that mandate working safely in a safe workplace with minimal adverse impact on the environment. The impact of the OSHA-related plans (e.g., Worker Safety and Health, Chemical Hygiene and Safety) is broadly expressed across PUB-3000. Other plans are more specific and individually comprehensive but have ramifications for information in other chapters. Hence, each chapter in PUB-3000 provides cross-references to other chapters containing related or pertinent information. The more direct relationships are shown below:
In addition, Chapter 6 and Chapter 32 of PUB-3000 provide direct support and guidance for responsible individuals to understand the need for work authorizations and the tools and guidance to conduct them through the process of job hazard analysis and determination of the appropriate authorization. The success of the formal work authorization process depends upon line managers' recognition of the need for a rigorous approach to work planning and authorization, and their commitment to working with and training staff to work within the authorized safety envelope. Success also depends upon individuals taking responsibility for their own safety and that of their co-workers. These expectations are detailed in Section 6 of the ISM Plan and in Chapter 1 of PUB-3000. Some chapters of PUB-3000 are applicable to all technical areas: lessons learned, training, and occurrence reporting.
1. The Safety Advisory Committee (SAC)
The SAC is an interface between the research and operations divisions of LBNL, as well as between the ES&H technical programs (mainly in the ES&H Division) and assurance and assessment activities of the Office of Contract Assurance (see RPM Chapter 8). To effectively execute this role, the SAC has direct access to the Laboratory Director and the Senior Management Team.
The SAC makes recommendations to the EH&S Division Director on the development and implementation of ES&H policy, guidelines, codes, and regulatory interpretation. It conducts reviews of special safety problems and provides recommendations for possible solutions to the Laboratory Director, Associate Laboratory Director for Operations / Chief Operating Officer (ALDO/COO), and/or the EH&S Division Director as requested. The SAC also provides advice and counsel to the ALDO/COO by reviewing appeals from the Laboratory divisions when any division and the EH&S Division do not agree on the interpretation or application of criteria, rules, or procedures. Such advice and counsel may include options for a resolution. The SAC has established five permanent subcommittees—electrical, laser, mechanical, traffic, and Division Safety Coordinators—to assist in the review of ES&H issues and concerns and the development of recommendations for institutional implementation. These subcommittees report to the SAC.
To properly execute its responsibilities under its charter, the SAC Chair may set up additional subcommittees made up of subject matter experts to address specific health and safety matters. Such subcommittees may become long-standing expert subcommittees, or they may be of short duration, depending upon technical support requirements.
In addition, the SAC chair, in cooperation with the Office of Contract Assurance (OCA), is responsible for scheduling and conducting the portion of institutional self-assessment known as the Management of Environment, Safety, and Health (MESH) reviews. These reviews are designed to ensure management systems consistent with ISM are in place in all Laboratory divisions and that these systems are leading to the effective implementation of the Laboratory's ES&H program. MESH reviews are normally triennial by division and are conducted by an SAC subcommittee. Depending on the MESH review results and the division's response, the SAC shall have the option to recommend changing the interval by one year. All members of the SAC are expected to serve on MESH subcommittees. MESH reviews will be submitted directly to the Laboratory Director.
2. The Office of Contract Assurance (OCA)
In addition to supporting the SAC in conducting and assessing MESH review results, OCA is responsible for providing technical support to the EH&S Division Director for developing ES&H performance objectives and criteria for division self-assessments, ES&H technical assurance, DOE/LBNL Contract 31, and Appendix B self-assessments (see RPM Chapter 8).
The OCA, in consultation with the EH&S Division Director, analyzes the results of all self-assessment reports to improve the effectiveness of the technical and management aspects of Laboratory ES&H programs.
In addition to each Laboratory employee’s and line management’s commitment to safety, the LBNL ISM Plan and the ES&H technical Implementation Plans, which carry out the ES&H Standards Set and are implemented by PUB-3000, provide the basis for an efficient and effective safety program. LBNL recognizes that improvement is always possible and should be sought continuously. Therefore, we, as an institution—as line managers, supervisors, work leads, and as individuals—apply lessons learned and the self-assessment process (see RPM Section 8.01 [Quality Assurance]) to continually strive for higher levels of safety excellence.