Q: Is the lab now requiring that all problems immediately fixed be entered into CATS? I thought this was only recommended, last I heard.
A: Anything not immediately fixed must be entered.
Q: What chemicals and chemical products need to be entered into the CMS?
A: All chemicals must be entered into the CMS database, with the following exceptions:
- Biochemical materials such as cell culture media, amino acids, or lipids
- Research-produced chemicals and mixtures
- Chemicals or chemical products transferred to secondary (non-manufacturer) containers
- Radiological Materials
- Waste Chemicals
- Consumer products packaged and used in quantities and for uses typical of the general public (this includes office products), see also below.
For more information refer to the Chemical Inventory Guidelines:https://cms.lbl.gov/include/ChemInvGuidelines.pdf
Q: Do consumer products need to be entered into the Chemical Management System?
A: Consumer products do not need to be entered into the Chemical Management System (CMS) as long as their usage is consistent with the consumer usage intended by the manufacturer. If these products are used in excess of intended use (whether amount, duration or frequency), they may require hazard assessment and possibly inclusion in CMS.
Examples of consumer products usage consistent with consumer usage include Dust-Off used in an office or White Board cleaner used in offices and conference rooms. However, consumer products like bleach or paint thinner used daily cleaning in a lab or shop would exceed consumer usage and require entry into CMS.
Q: Do adhesives need to be included in CMS?
A: Adhesives with hazardous components (e.g., epoxies, volatile organics, etc.) must be included. Non-hazardous adhesives that otherwise meet the requirements of consumer products (e.g., white glue) do not need to be included.
Q: What do I need to know about home-built electrical equipment?
A: Newly constructed home built electrical equipment must be inspected by a designated Electrical Equipment Inspector before it is put into service. For contact information email firstname.lastname@example.org, or call Keith Gershon (4694). All existing (legacy) equipment must also be inspected, but since there is so much legacy equipment, it is allowed to remain in use until an inspection can be arranged. Each Division is responsible for identifying all electrical equipment that requires inspection.
Q:What do I need to know about non-NRTL electrical equipment?
A: Electrical equipment is acceptable for use if it has been labeled by a Nationally Recognized Testing Laboratory (NRTL). A list of NRTL marks can be found at http://www.lbl.gov/ehs/pub3000/CH8_AppR.html. Newly acquired non-NRTL electrical equipment must be inspected by a designated Electrical Equipment Inspector before it is put into service. All existing (legacy) equipment must also be inspected, but since there is so much legacy equipment, it is allowed to remain in use until an inspection can be arranged. Each Division is responsible for identifying all electrical equipment that requires inspection.
Q: So we have a new database, the ISM Feedback Database, for inadequate answers given in cross-Division interviews. Where can I get a briefing on how this works?
A: The ISMFeedback.lbl.gov database is not required, but is provided as an aid to both the divisions and the teams. It was copied from a Safety Walkaround database system that was developed in Engineering and is very easy to use. Go here to see a brief description of how to use this database. One of the main reasons to use it is if a team comes across an area where the people show obvious weakness in their understanding and application of ISM, the observation entry will allow you to see that and focus training and coaching on those areas. If you’d rather not use such a system that’s fine, but the intention was to provide a tool to allow people to identify areas for improvement that simply aren’t appropriate for CATS.
Q: Will someone from the inspected Division be calling our cross-inspectors to set up their visits?
A: The Feedback team members should contact the division they’re going to interview.
Q: How am I authorized to do work at LBNL?
A: Your Work Lead authorizes you to do your work. The first step is to analyze the work by listing the tasks you will perform, the hazards associated with the tasks, and the controls necessary (including training) that will mitigate the hazards. Secondly, you and your Work Lead discuss the analysis and agree that it (and the controls) represent the way you will perform the work. Finally, your Work Lead authorizes you to perform the analyzed work, subject to the controls specified.
Q: What is meant by Work Authorization?
A:Work Authorization is the final step in the Work Planning sequence described above. Your Work Lead’s authorization means that he/she and you have analyzed the work, understand the hazards, and agree upon the proper controls. The actual form that the authorization takes depends upon the work, as there are several Work Authorization systems in use at LBNL (e.g., Job Hazards Analysis, Radiation Authorizations, Activity Hazard Documents, Hot Work Permits, and others). Work may not be performed before it is authorized and the controls are in place and used.
Q: What is the role of the JHA in Work Authorization?
A:The Job Hazards Analysis (JHA) is the broad Work Authorization system that most workers at LBNL use to analyze and authorize the routine, predictable aspects of their work. The JHA is a software-based system that uses a question-answer format to aid in analyzing the tasks and hazards associated with the work, and provides typical controls that the worker and the Work Lead can use as a basis for determining how to safely execute the work. All workers at LBNL must be accounted for in the JHA system, by either using the system to analyze the work or by justifying why that requirement does not apply to them.
Q: How are the JHA reviewed and the Work reauthorized?
A:Every worker needs to constantly be aware of what work they have been authorized to perform. If the actual work changes, the worker needs to consider whether the change includes work that is outside of his/her current Work Authorization. If so, then the JHA or other Work Authorization needs to be modified to reflect the revised work. In addition, at least annually the Worker and Work Lead are required to review the Work Authorization and make necessary changes, after which the Work Lead reauthorizes the work. The JHA software system contains mechanisms to make review, modification and reauthorization a streamlined process.
Q: What are higher hazard work authorizations such as AHDs, BUAs, RWAs
A: Some work at LBNL is of a higher hazard and EH&S professionals must enter into the hazards analysis process with the Work Lead and the worker. This higher-hazard work requires a separate formal authorization that supplements the baseline Work Authorization. The formal work authorization process is covered in PUB-3000, Chapter 6. These formal work authorizations include a very detailed analysis of that high hazard work, and the separate Work Authorization is incorporated into the baseline JHA automatically.
Q: Can I use a ladder or stepstool at LBNL?
A: The requirements depend upon the type of ladder you are using.
- Step Stool: The use of a stepstool (a ladder whose top step is less than 32" above the floor) is considered to have hazards similar to those assumed by the general public. If this is the sole use of ladders then it does not need to be included in the Job Hazards Analysis. Common sense dictates that you inspect the stepstool before use and pull it out of service if it is damaged, and that you be sure that the surface is stable and level.
- Ladders: Use of ladders whose top step is higher than 32" above the floor is considered to be work-related and must be included and authorized as an identified task on the Job Hazards Analysis. The JHA system provides controls for ladder use, including EHS02789 Ladder Safety Training, which must be reviewed by the Supervisor/Work Lead and agreed upon with the Worker.
Q: What is the minimum PPE needed for labs and shop areas?
A: Safety glasses with side shields, long pants, and closed toe shoes are the minimum. Additional PPE may be required for certain areas and operations.
Q: What are Safety Glasses? Are they ok to use when handling chemicals?
A: Safety glasses with side shields are the minimum requirement for lab and shop areas. Safety glasses must be supplemented with goggles and/or face shields when there is a greater risk of exposure to chemical splashes or flying particles.
Cover goggles are required for operations where there is a greater risk of exposure to chemicals and to flying particles. Furthermore, they are required for activities producing airborne eye irritants including gases, vapors, fumes, dusts, and mists. Safety glasses provide no protection against eye irritants.
This is explained in the Eye and Face Protection section of the CHSP at http://www.lbl.gov/ehs/chsp/html/materials.shtml#PPE.
Q: How can I request an exception to the PPE and food policy?
A: Divisions can request exceptions using the procedure outlined in PUB-3000:
Note that the EHS Division Director must approve all exceptions.
Q: What is the proper way to store and dispose of sharps, such as single-edged razor blades?
A: Sharp edged and pointed tools (e.g., razor blades, scalpels, needles) must be stored and disposed of in a manner that will not create a hazard. The principal hazards are laceration and puncture.
- Storage: Keep the edges and points covered. Do not expose the sharp parts until you are ready to use them – keep the paper on the razor blades, the cover on the scalpel, the cover on the needle. After you are done using them, dispose of sharps into a plastic sharps container. Often a sharp tool can be reused several times before disposal. The best way to protect against contact with a blade or point when the tool is not being used is to embed the sharp portion into some protective medium. Dense polyethylene foam works well for storing sharps between uses (do not use polystyrene foam (aka Styrofoam), it crumbles). Needles should not be recapped, and must not be recapped if they have a potentially biohazardous material in them.
- NEVER dispose of sharp edged or pointed objects into the trash.
- Dispose of sharp edged or pointed tools into a plastic sharps container. Be sure to deface the “biohazard” warning that comes on some sharps disposal containers if you are not handling potentially contaminated objects.
- If a sharps container is not immediately available, uncontaminated sharp edged objects can be wrapped several times in tape (to secure the edge) and then placed aside until a sharps container is obtained.
For additional information on disposal of sharps, refer to EH&S Hazardous Waste Management, PUB-3095, Chapter 3.
Q: What caution Placard do I need at the entrance to a lab or shop area?
A: Entrances to technical Areas (Laboratories, shops, workrooms), and similar areas need to be posted with a Caution Placard. The placard needs to indicate:
- The hazard types in the work area (such as corrosives and carcinogens) depicted by hazard icons.
- Minimum PPE requirements.
- Contact information.
The Caution Placard and icons can be downloaded from the Section entitled "Posting Area Entrances" in the Chemical Hygiene and Safety Plan. Instructions for the use of the placards and icons are also available.
Note: The caution placard does NOT include radiological, laser and noise icons. There are different requirements that pertain to these hazards and EH&S will post the proper signs and placards.
Q: How do I dispose of pre-soaked alcohol wipes?
A: If alcohol wipes are used to clean a benign substance (i.e Optics), and the alcohol is consumed in the process, the wipe can be disposed in the trash. However, if you use an alcohol wipe to clean up hazardous material (i.e nano material or metal dust), the wipe must be treated as hazardous waste.