Chapter 6
SAFE WORK AUTHORIZATIONS

Contents

Approved by John Seabury
Revised 02/08

6.1 Introduction and Summary

6.2 Line Management Authorizations for Routine or Special Hazards

NOTE:
. . . . .	Denotes a new section.
. . . . . . . .	Denotes the beginning of changed text within a section.
. . . . . . . .	Denotes the end of changed text within a section.

____________________

6.1 Introduction and Summary

Safety of all operations at Lawrence Berkeley National Laboratory is managed according to the principles outlined in LBNL PUB-3140, Integrated Environment, Health and Safety Management Plan: Integrated Safety Management (ISM) System. Five functions form the core of the ISM process:

• Defining Work: The tasks that are to be accomplished as part of any given activity must be clearly defined.


• Analyzing Hazards and Risks: Once the tasks have been defined, the hazards and risks associated with the activity must be determined, in particular risks to employees, the public, and the environment.


• Establishing Controls: Controls (e.g., engineering, administrative, personal protective equipment) sufficient to reduce the identified risks must be put into place.


• Performing Work: Any time that work is performed, established controls must be used.


• Feedback and Improvement: The activity and its associated controls must be continually examined to determine if the controls are effective; if not, changes must be made. If additional safety can be achieved, the changes necessary to do so must be made.

These five core functions apply at all levels of Berkeley Lab: at the institutional level, at the division or department level, and at the level of individual projects or work activities. For a description of how these core EH&S functions are applied at each of the above levels, and descriptions of the various programs and policies in place to assure that they are applied, see LBNL PUB-3140.

A key principle is that of work authorization. Authorization is a review and management approval process designed to ensure that procedures, controls, and resources are in place before the work begins. All work at LBNL proceeds under authorization. Work authorization classifications include the following

• Line Management: An authorization implied from other documentation, or explicit but administered by the responsible division doing the work. Examples include the Job Hazards Analysis or equivalent processes.


• Formal: A written document, authorized by the responsible division with EH&S Division review and concurrence, that describes the scope of work, required procedures and controls, authorized materials and equipment to be used, and staff authorized to conduct the work. Examples include Radiological Work Authorizations, Activity Hazard Documents, research involving human or animal subjects, and some high pressure work.


• Facility-Based: Hazard analysis and controls are based on the facility as a whole rather than on an individual operation. Examples include Safety Analysis Documents, air and water discharge permits, some other regulatory permits and NEPA/CEQA analyses.[1]

This chapter of PUB-3000 describes work authorizations and the work authorization process.

6.2 Line Management Authorizations for Routine or Special Hazards

6.2.1 Work Planning: Completion of the Job Hazards Analysis

As part of the work planning process, Workers and Work Leads[2] are required to plan all work: determine the tasks that will be performed, consider the hazards, risks, and concerns associated with those tasks, and implement appropriate controls. The primary tool for work planning at the Line Management level is the Job Hazards Analysis (JHA). For most work, the tasks, hazards and controls are known and typical. These tasks, hazards and controls are specified in the Individual Baseline JHA. For work that is unpredictable, short term or unusual and not included in the Individual Baseline JHA, a Task-based JHA is prepared. Work Leads must assure that employees know how to perform the work safely and in conformance with applicable requirements, and must provide on-the-job training as needed.

Every employee and long-term guest[3] is required by LBNL policy to complete a JHA, and to complete the training required for that employee's work assignment, on initial hire and whenever the employee is assigned to a new position or to tasks with new hazards. It is the Supervisor’s responsibility to assure that each employee completes the JHA and required training as soon as practical. During the JHA process, work may be identified that involves special hazards and requires additional specialized classroom training. Some specialized training is available from EH&S, while other specialized training may be acquired from outside training providers. Employees may work while training is in progress, but they must be within line-of-sight control by someone who has already obtained the required training.

Appendix A gives examples of work involving special hazards, requiring specialized classroom training and/or certification, and resulting in some license, permit, or certification. Links provide information on where to obtain specialized training.
NOTE: The Job Hazards Analysis process will be introduced during FY2008. It uses a similar question-response format as the Job Hazards Questionnaire (JHQ), but replaces the JHQ entirely. Until the JHA is introduced, Workers use the JHQ. JHA (Individual Baseline or Task-based) are not required until the JHA system triggers the need, or until September 30, 2008, whichever comes first.

6.2.2 Line Management Authorization Process

During the JHA process, the Worker and Work Lead discuss the tasks, hazards and controls of the Work. At the conclusion of the process the Worker and Work Lead sign the JHA. This signature by the Work Lead authorizes the described work subject to the controls specified.

Although not specifically required, Work Leads should consider maintaining permanent documentation of the classroom and on-the-job training (for example, printing out and annotating a copy of computerized training record). Work Leads should also review the Work and the JHA on a regular basis to assure that all Work the employee is performing is authorized on the JHA.

6.2.3 Line Management Reauthorization

Records of JHA completion and classroom training status are maintained in the EH&S Training Web site. These records are reviewed at least annually during the division’s self-assessment. Although not required, supervisors are encouraged to also maintain permanent documentation of their employees' specialized and on-the-job training.

All work authorizations must be renewed annually, or more frequently if the work changes significantly.[4] The JHA authorization is considered valid for a period up to 12 months from signature, and must be renewed prior to that time or else the authorization to perform that work expires, and the Work is unauthorized and may not proceed. The JHA is reauthorized by the Worker and Work Lead reviewing it, making adjustments as necessary, and then both signing the document.

Some specialized classroom instruction for special hazards, and hence the authorizations enabled by that instruction, requires periodic reauthorization. The reauthorization dates are maintained in the EH&S Training Web site. If the retraining or recertification is not completed in a timely manner then that element of work is no longer authorized and may not proceed.

6.2.4 Line Management Authorization Documentation

Records of classes taken at LBNL are maintained by the EH&S Training Group and entered into the training database. Individual Baseline JHA records are maintained in the JHA system. Work Leads must maintain records of Task-based JHAs and other line management authorizations as specified in their division's Integrated Safety Management Plan.

6.3 Formal Authorizations for Increased Hazards

Certain work activities pose hazards that require additional controls. Depending on the hazard, the principal investigator, supervisor, or manager (Work Lead) needs to document the work and associated hazards, describe administrative and engineering controls to mitigate those hazards, and document training or certification for the participants in a written document or plan.

A formal authorization is one that includes the EH&S Division in review/concurrence. Work is authorized by line management (generally the Division Director or designee) of the division in which it will be performed. Experts with appropriate certifications or background from within EH&S and other divisions are brought into the process for consultation, review, and/or approval. The formal authorization can be thought of as a "contract" under whose conditions the work will be performed. Formal authorizations are incorporated by reference into the Job Hazards Analysis.

Some work at LBNL is authorized by an outside regulatory authority; these authorizations are generally facility-based authorizations , not formal authorizations, and are described in Section 6.4 , below.

6.3.1 Work Planning: Determining if a Formal Authorization is Needed for New Programs and Facilities

Work for which a formal authorization is required is generally more extensive or inherently dangerous than similar work for which line management authorization applies. "Trigger levels" have been developed that, if exceeded, may require formal authorization. Appendix B shows a list of these levels and the corresponding formal authorization.

To determine if planned work requires a formal authorization, the Work Lead must conduct a thorough analysis of the hazards inherent in that work. Divisions may have internal procedures to be followed as part of the work planning/hazard analysis process (see also Section 6.5.2 ).[5] The Work Lead should then consult Appendix B to determine if any hazard exceeds the trigger level specified for that hazard.[6] If so, a formal authorization as specified may be required. The links provided in the table give additional information.[7]

The hazards and "trigger levels" noted in Appendix B represent the most common hazards encountered at LBNL. If, after analysis of the hazards in the work, the Work Lead determines that the work poses some unusual elevated hazard that is not represented in the Appendix, or if a combination of hazards in the work exceeds those authorized by the Line Management Authorization for that work, then he/she should contact his/her division safety coordinator/administrator (if internal procedures exist) or EH&S Division Liaison (in the absence of internal procedures) to discuss whether a formal authorization should be obtained.

6.3.2 Formal Authorization Process

The formal authorization process intimately involves the EH&S Division in the analysis of hazards and the controls necessary, and the preparation of the formal authorization. Subject to internal division procedures, the process proceeds generally as follows (note that this is a general description; the precise process depends upon what the formal authorization is):

• The principal investigator (PI) or Work Lead determines that a formal authorization is needed.


• The PI/Work Lead contacts his/her division safety coordinator/administrator (if specified by internal procedures) or the EH&S Division Liaison assigned to his/her division (in the absence of internal procedures) to initiate the formal authorization process.[8]


• If additional expertise is necessary for proper review (for example, if an EH&S Subject Matter Expert (SME) is required), the EH&S Division Liaison coordinates EH&S’s component of the review process.


• The PI/Work Lead prepares draft documentation and submits it to the division safety coordinator/administrator and EH&S. (Note that the specific individual or program with EH&S that will review the draft documentation depends upon the specific formal authorization.) EH&Smay inspect the installation and make recommendations for incorporation into final documentation.

Note: Follow the links in Appendix B to find instructions for preparation of the specific formal authorization documentation required. Activity Hazard Documents, one form of formal authorization, are addressed in Appendix D .

• The PI/Work Lead and EH&S inspect the work area to confirm that the prescribed hazard controls are in place and operational.[9]


• The PI/Work Lead, division safety coordinator/administrator, and EH&S submit final documentation and recommendation to governing body/committee, if appropriate.


• The PI/Work Lead, division, and EH&S sign the authorization.


• The PI/Work Lead receives authorization specifying the hazard controls.


• Work proceeds in accordance with hazard controls specified.

Principal Investigators and Work Leads are encouraged to contact their division safety coordinator/administrator and EH&S Division Liaison during project planning so that any hazard controls can be factored into the project design and budget. At that time a schedule for the preparation of the formal authorization can be discussed.

6.3.3 Formal Reauthorization

Work under a formal authorization is only permitted if the authorization is currently active. Formal authorizations must be reauthorized whenever work changes significantly.[10] Reauthorization periods are usually scheduled annually, although some may be longer, and some task-specific authorizations are active for periods of much less than one year.

Subject to internal division procedures, the reauthorization process proceeds generally as noted below. Note that this is a general description; the precise process depends upon what the formal authorization is. In particular, some reauthorization processes are initiated by EH&S. Nevertheless, it is the authorization holder’s responsibility to assure that work is only conducted under a current authorization.

• As the reauthorization date approaches, the Work Lead contacts his/her division safety coordinator/administrator or EH&S Division Liaison to initiate the reauthorization process.[5,11] It is recommended that at least four weeks be allowed for the reauthorization process. For some complex operations, or if a committee approval is required, then additional time may be necessary. This will allow sufficient time to review the existing documentation, make changes in response to changes in work over the previous year, and prepare the reauthorization documentation package. Workers who have not completed required retraining may continue to work under the direct oversight of a trained employee until the training has been completed. There must be at least one person in the group who has completed each of the required courses and on-the-job training who can oversee the others before work can be authorized. After the director of the division in which the work is being performed has signed the authorization, then the work has been reauthorized.[12]


• After obtaining the division director's signature, the Work Lead forwards a copy of the signed authorization to EH&S for review and recording.


• EH&S, the Work Lead, and the division may agree upon minor midterm modifications to a formal authorization without obtaining the additional concurrence required for the annual reauthorization. Adding or deleting users from an authorization is generally considered to be a minor midterm modification.

6.3.4 Formal Authorization Documentation

Documentation requirements are given in the descriptions of each authorization process. Consult the links given in Appendix B for information.
The process leading up to the decision of which (if any) formal authorization(s) are required should be documented. Division procedures will determine where the documentation is maintained, and the vehicle used to provide the documentation. See also Section 6.5.2 of this Chapter.

Generally, the division retains the original formal authorization with original ("wet") authorization signatures. EH&S and others retain copies.[13] Some formal authorizations are software-based; the software is the authorization of record and there is no “original”.

6.3.5 Temporary Work Authorizations

Temporary Work Authorizations may be issued for work that is of elevated hazard and is of limited scope and short duration. The intent of a Temporary Work Authorization is to promote, between the Work Lead and the EH&S Subject Matter Expert, a discussion of the primary hazards of the work, whereby they will concur on the scope of the work to be performed, the hazards of the work, and the controls necessary.

A Temporary Work Authorization is not a substitute for a formal authorization. The Temporary Work Authorization differs from the formal authorization in that the Temporary Work Authorization is for work that

• is of short-term duration (two weeks or less),


• is of limited and clearly defined scope,


• is not a component of ongoing work, and


• may be written in the field.

Work authorized by a Temporary Work Authorization may be preliminary to an experiment or process but is not part of that process. The Temporary Work Authorization may not be used to reflect changes to work covered by an existing Formal Authorization (the Formal Authorization must be amended to reflect those changes) and may not be used to authorize work during the period that a Formal Authorization is being prepared.
Types of work that might appropriately be authorized by a Temporary Work Authorization include the following examples:

• A vendor demonstrates a higher-hazard piece of equipment (for example, Class IV laser) to potential customers. The Temporary Work Authorization would allow him to operate that equipment under very tight controls of scope and duration.


• A vendor performs setup and alignment of a new Nuclear Magnetic Resonance spectrometer as part of acceptance testing. The actual experimental use of the equipment is subject to an Activity Hazard Document (AHD) for that experiment, but the Temporary Work Authorization would cover the initial setup including the initial loading of cryogenic liquids.


• A researcher performs preliminary experimental feasibility testing to determine if a particular Health Hazard Gas will work in his experiment. Further work would be subject to an AHD.


• A researcher orders items or supplies with a long lead time while the formal authorization for his/her research progresses through the formal authorization process. The Temporary Work Authorization assures division concurrence with the general direction of the researcher’s work while the details of the formal authorization are worked out. No work with the procured items may occur under the Temporary Work Authorization.

Temporary Work Authorizations must include the following components:

• Description of the work to be performed, including restrictions, boundaries, and “hold points”;


• Controls necessary to perform the work including engineering controls, administrative controls, training, and personal protective equipment;


• Effective and expiration dates;


• Designation of the Work Lead, and specific acknowledgment by the Work Lead that he/she accepts responsibility for safety for all persons and activities that are part of the authorized work, and is responsible for providing proper job-specific training (i.e., On-the-Job-Training);


• Signatures of all participants in the authorized work, attesting that they have read and agreed to the requirements of the Temporary Work Authorization, and that they have received proper job-specific orientation;


• Signature of the EH&S Subject Matter Expert (SME) for the primary hazard present in the work indicating that he/she concurs with the Work Lead’s analysis of hazards and controls; and


• Signature of the Work Lead’s line manager (e.g., division director or designee) that he/she concurs and authorizes the work described.

Work to be performed under a Temporary Work Authorization should be authorized for the shortest practical time duration, and that duration may not exceed two weeks. After the initial authorization by the Work Lead’s line manager, the Temporary Work Authorization may be extended twice (for a total work duration of 6 weeks) after the Work Lead and the EH&S SME review the work accomplished and remaining, and modify the scope and controls accordingly. Temporary Work Authorizations are subject to cancellation at any time by the Work Lead’s line manager.

The Work Lead is responsible for obtaining all authorizing signatures prior to beginning the work, for prominently posting a fully signed copy of the authorization at the work location, and for forwarding a copy of the completed Temporary Work Authorization to the EH&S SME who concurred with the work upon its completion.

A sample Temporary Work Authorization form is given in Appendix E.

6.4 Facility-Based Authorizations

Facility-based authorizations provide safety "operating envelopes" based on activities taking place within that facility. There are several formats of facility-based authorizations; examples are given in Appendix C. The Facilities Division prepares NEPA/CEQA documentation, and EH&S prepares other facility-based authorizations, with technical input from the operating division(s). The operating divisions within the affected facility are responsible for conducting work within the defined safety "operating envelope" specified by the authorization.

As used here, a "facility" means any equipment, structure, system, process, or activity that fulfills a specific purpose. At LBNL, a "facility" for purposes of a facility-based authorization is generally a building; but in some cases the "facility" may be an area within a building but not the whole building. Facility-based authorizations differ from line management authorizations and formal authorizations in the following ways:

• Line management and formal authorizations are based on individual activities, whereas a facility-based authorization is a function of some additional aggregate hazard or interaction between multiple operations or else is a function of some piece of facility equipment (for example, a paint spray booth or waste treatment facility).
• With the exception of authorizations for accelerators and initial safety analyses performed during the capital asset acquisition process, the operating division is generally not involved in obtaining or renewing facility-based authorizations; the activity is coordinated by LBNL (Facilities for NEPA/CEQA issues; EH&S for all others). The divisions that operate accelerators or that will be the occupants of new buildings work intimately with EH&S during preparation, review and update of their respective facility-based authorizations.

The need for one or more facility-based authorizations may be triggered by new programs or facilities, or it may be triggered by changes in existing programs or facilities. Once a facility-based authorization is in place, it must be reviewed periodically to assure that the actual operations comply with the operating envelope established for that facility.

6.4.1 Work Planning: Determining if a Facility-Based Authorization is Needed for New Programs and Facilities

In general, the analysis of whether a facility-based authorization for a new program or facility is necessary is carried out during the program or facility proposal and planning process. The various mechanisms for review during these phases are described in LBNL’s Integrated Environment, Health and Safety Management Plan.

Facility-based authorizations may be required if the proposed work presents risks in excess of work already being performed at the facility or LBNL, if significant onsite or offsite consequences might be expected if controls are not adequate to mitigate the risks, or if the work involves hazards not routinely encountered and accepted in the course of everyday living by the vast majority of the public. Safety analyses are also required as part of the DOE capital asset acquisition process and establish the baseline safety envelope for programs/projects taking place in that building at startup.

Certain conditions relating to the handling or storage of hazardous materials automatically require a facility-based authorization. In a manner similar to the formal authorization process (see above), the handling or storage of hazardous materials in quantities above "trigger" levels requires that a facility-based authorization be obtained. Appropriate facility-based authorizations and applicable trigger levels are given in Appendix C.[14] Appendix C does not list all applicable local, state, and federal requirements that might apply to operations within a facility, but it includes items that can affect planning and design decisions.[15]

6.4.2 Facility-Based Authorization Process

The authorization process varies, depending on the facility-based authorization being sought. See Appendix C to determine the precise process to be followed.

6.4.3 Facility-Based Authorization Review/Reauthorization

Facility-based authorizations with a built-in reauthorization schedule (for example, regulatory permits) are reviewed according to that schedule. Accelerator facility-based authorizations are reviewed per the procedures outlined in LBNL Radiation Protection Group Procedure 703 (see also PUB-3000, Chapter 21 “Radiation Safety”). Facility-based safety analyses prepared during the capital asset acquisition process are not reviewed after initial occupancy and operation of the building; operations-based work authorization processes (including monthly building code compliance reviews by the LBNL Fire Marshal) evaluate the safety envelope as a result of program changes within the building.

For facility-based authorizations for which an EH&S department is responsible (including most regulatory permits), that EH&S department coordinates the reauthorization according to its own internal procedures.

6.4.4 Facility-Based Authorization Documentation

Documentation is specified for each authorization in Appendix C. Original facility-based authorizations, including amendments or changes as required, are generally retained by EH&S.

6.5 Additional Information

6.5.1 Activity Hazard Documents

Appendix D describes how Activity Hazard Documents, one form of formal authorization, are prepared and renewed.

6.5.2 Project Hazard Analysis

As part of any work planning process, potential hazards must be analyzed so that proper controls can be included in project design and budget. Appendix F provides an optional tool for divisions and Work Leads to document that consideration has been given to possible formal authorizations that might be required for the work. This form uses information from Appendix B regarding the formal authorizations required at any "trigger level." Its use in the project hazard analysis process is optional; divisions are encouraged to add items to this form that help them implement their own Integrated Safety Management Plans.

6.6 Responsible Parties

6.6.1 Division Directors

Division directors are responsible for the following:

• Assuring that all work spaces are evaluated at least annually for identification of hazards and implementation of controls.


• Assuring that all work is authorized by line management, formal, or facility-based authorization, as required.

6.6.2 Principal Investigators, Managers, and Supervisors

Principal investigators, managers, and supervisors (Work Leads) are responsible for the following

• Identifying the hazards associated with the work to be performed.


• Supplying the controls necessary to safely perform the work.


• Assuring that employees under their supervision complete the Job Hazards Analysis and receive specialized training as required by PUB-3000, Chapter 24 (see also the EH&S Training Web site).


• Assuring that all work under their control is evaluated as to the level of authorization required in accordance with this chapter, and that the proper authorization is obtained before beginning work.


• Assuring that all work under their control is performed in compliance with the controls specified for that work.


• Assuring that authorizations for work under their control are reauthorized as required, including whenever work changes significantly.

6.6.3 Facilities Division

The Facilities Division is responsible for reviewing projects during the project planning phase and preparing the appropriate NEPA/CEQA documentation.

6.6.4 EH&S Division

The EH&S Division is responsible for the following:

• Assisting divisions with the annual self-inspection and line management authorization process, as requested by the division.


• Providing technical input to divisions, the Facilities Division, and review committees during the preparation of all levels of authorization.


• Coordinating and reviewing the preparation of formal and facility-based authorizations, including presentations to review committees as necessary.


• Obtaining EH&S concurrence with formal authorizations after review and committee approval has been obtained

6.7 Standards

• Title 42, United States Code, Section 4321 et seq. (NEPA, National Environmental Policy Act)


• Title 29, Code of Federal Regulations, Section 1910.119, Process Safety Management of Highly Hazardous Chemicals


• DOE Order 420.2, Safety of Accelerator Facilities


• DOE Order 435.1, Radioactive Waste Management (only those sections/subchapters adopted into the current LBNL Work Smart Standards set)


• California Public Resources Code, Section 2100 et seq. (CEQA, California Environmental Quality Act)


• Title 19, California Code of Regulations, Section 2770.5, List of Substances


• Title 22, California Code of Regulations, Section 6620.1 et seq., California Hazardous Waste Regulations

6.8 Related PUB-3000 Chapters

• Industrial Hygiene (Chapter 4)


• Occupational Safety (Chapter 5)


• Pressure Safety and Cryogenics (Chapter 7)


• Electrical Safety (Chapter 8)


• Fire Prevention and Protection (Chapter 12)


• Gases (Chapter 13)


• Lasers (Chapter 16)


• Lockout/Tagout (Chapter 18)


• Hazardous Waste Disposal (Chapter 20)


• Radiation Safety (Chapter 21)


• Research with Human and Animal Subjects (Chapter 22)


• EH&S Training (Chapter 24)


• Job Hazards Analysis (Chapter 32)

6.9 References

• DOE, STD 1027.92, Hazard Categorization and Accident Analysis Techniques for Compliance with DOE Order 5480.23, Nuclear Safety Analysis Reports (advisory only)


• Los Alamos National Laboratory, Fact Sheet LA-1281-MS, Table of DOE STD-1027.92 Hazard Category 3 Threshold Quantities for the ICRP-30 List of 757 Radionuclides (advisory, for radionuclides not included in DOE STD 1027.92)


• LBNL Chemical Hygiene and Safety Plan


• LBNL/PUB-3092, Guidelines for Generators to Meet HWHF Acceptance Requirements for Hazardous, Radioactive, and Mixed Wastes at Berkeley Lab


• LBNL/PUB-3111, Operating and Assurance Plan


• LBNL/PUB-3140, Integrated Environment, Health and Safety Management Plan

6.10 Appendices

Appendix A. Line Management Authorizations: Work Requiring Specialized Classroom Training and/or Certification
Appendix B. Formal Authorizations
Appendix C. Facility-Based Authorizations
Appendix D. Activity Hazard Document (AHD) Process
Appendix E. Temporary Work Authorizations
Appendix F. Example Form for Formal Authorizations and Project Hazard Analysis

Notes

1. NEPA: National Environmental Policy Act (42 U.S.C. 4321 et seq.), CEQA: California Environmental Quality Act (California Public Resources Code 2100 et seq.).


2. "Work Lead" is anyone who directs, trains, and/or oversees the work and activities of one or more workers. Work Leads provide instruction on working safely and the precautions necessary to use equipment and facilities safely and effectively. Work Leads need not be Line Managers, HEERA-designated Supervisors, or LBNL Employees.


3. A long-term guest is one who works at LBNL for a continuous period of three months or longer. Career employees and long-term guests must complete the Job Hazards Analysis within the first month of employment. A guest who is present for less than three months is not required to complete the Job Hazards Analysis, but must work under the direct supervision of an LBNL sponsor who is responsible for that guest's safety. See PUB-3000 Chapter 24, LBNL's training policy, for additional information.


4. "Significant" as used in this chapter means any change that results in an increase or decrease in hazard. Changes that do not result in a change in hazard are not significant. Examples of conditions that might result in changes in hazard, and hence must be evaluated as to whether they constitute a significant change, are


• changes in chemicals or compressed gases, in either identity or quantity, used in an experiment, particularly if the chemicals have different hazards from those previously used;


• changes in operating parameters, such as pressure changes, wavelength changes (e.g., lasers), operating duty cycles, or controls/interlocks; and


• changes to the identity and quantity of radionuclides, which must be reflected in the authorization.


5. Divisions may develop their own internal procedures for processing Activity Hazard Documents, one form of formal authorization, provided the essential elements of the process described here (thorough analysis of hazards, concurrent division and EH&S authorization, annual review and reauthorization by the division and EH&S) are included.


6. The guidelines given in this chapter are minimum standards. Divisions may have more comprehensive requirements within their own Integrated Safety Management Plans or Safety Programs, and if so Work Leads must comply with these additional requirements.


7. Appendix 2 is a summary document intended to raise questions as to applicability. The user must consult the primary source documents, as indicated by the links in the reference column, to determine the exact applicability of the situation.


8. For some hazards (for example, work with radioactive materials), EH&S has highly developed internal procedures for processing formal authorizations that do not directly require the Division Liaison's involvement. For these situations, the processing of the authorization may be delegated to another EH&S representative to make the processing more efficient.


9. This final inspection constitutes an "Operational Readiness Review." Signatures of EH&S and the division on the authorization serve to document that this review has taken place and that work may proceed in accordance with the established authorization.


10. Satellite Accumulation Areas and Waste Accumulation Areas are audited more frequently. If significant changes are made to a work process described in the formal authorization, then these changes may initiate the reauthorization process at that time.


11. Reauthorization for work involving radioactive materials or machines are initiated by EH&S's Radiation Protection Group. Work Leads are responsible for assuring that all work complies with the authorization in effect.


12. Authorizations involving work with radioactive materials or machines require both user division and EH&S signature for reauthorization.


13. Original authorizations for work with radioactive materials or machines are retained by EH&S, and a copy is present in the work area.


14. The trigger levels given in Appendix B for formal authorizations do not generally apply when reviewing cumulative hazards, because the total hazards across programs do not generally add due to independent control of the programs. (Exceptions to this general rule exist for certain fire code analyses.)


15. In particular, analysis of fire code requirements is beyond the scope of this document. Fire code classification is an integral part of the facility planning effort.