Chapter 6
SAFE WORK AUTHORIZATIONS

Contents

Approved by John Heim
Revised 02/13

6.1 Policy
6.2 Scope
6.3 Applicability
6.4 Exceptions
6.5 Roles and Responsibilities
6.6 Definitions
6.7 Required Work Processes

Work Process A. Line Management Authorizations for Routine or Special Hazards
Work Process B. Facility-Based Authorizations
Work Process C. Formal Authorizations for Increased Hazards

6.8 Source Requirements
6.9 Reference Documents
6.10 Appendices

Appendix A. Line Management Authorizations
Appendix B. Formal Authorizations
Appendix C. Facility-Based Authorizations
Appendix D. Activity Hazard Document (AHD) Process
Appendix E. Temporary Work Authorization Template
Appendix F. Hazard Management System

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

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    6.1 Policy

    The Safe Work Authorization Policy at Lawrence Berkeley National Laboratory (Berkeley Lab) ensures that all work is safely performed by:

    6.2 Scope

    Safety of all operations at Berkeley Lab is managed according to the principles outlined in PUB-3140, Integrated Environment, Safety & Health Management Plan: Integrated Safety Management (ISM) System. Five functions which form the core of the ISM process are the following:

    These five core functions apply at all Berkeley Lab operational levels: institution, division or department, and individual projects or work activities. For a description of how these core ES&H functions are applied at each level and of the various programs and policies in place to ensure that they are applied, see PUB-3140.
    Work authorization is a key principle of Berkeley Lab’s safety policy. It is a review and management approval process designed to ensure that procedures, controls, and required resources are in place before work begins. All work at Berkeley Lab proceeds under work authorization, which includes the following classifications:

    This document describes work authorizations and the work authorization process.

    6.3 Applicability

    All Berkeley Lab employees, visitors, affiliates, and subcontractors

    6.4 Exceptions

    Those not performing work, who work only at a site not managed by the Berkeley Lab, or who work only on the UC Berkeley Campus

    6.5 Roles and Responsibilities

    Role

    Responsibilities

    Employee, Visitor, and Affiliate

    • Performing work only for which they are authorized and qualified 

    Principal Investigators, Managers, Supervisors, and Work Leads

    • Identifying the hazards associated with the work to be performed
    • Supplying the controls necessary to safely perform the work
    • Ensuring that employees under their supervision complete the Job Hazards Analysis and receive specialized training as required by PUB-3000, Chapter 24 (see also the EHSS Training Web site).
    • Ensuring that all work under their supervision is evaluated according to the level of authorization required as indicated by the guidelines in this chapter and that the proper authorization is obtained before beginning work.
    • Ensuring that all work under their supervision is performed in compliance with the controls specified for that work
    • Assuring that authorizations for work under their supervision are reauthorized as required, including whenever work changes significantly

    Division Directors

    • Ensuring that all work spaces are evaluated at least annually for identification of hazards and implementation of controls
    • Ensuring that all work is authorized by line management, formal, or facility-based authorization, as required

    Facilities Division

    • Reviewing projects during the project planning phase
    • Preparing the appropriate NEPA/CEQA documentation

    EHSS

    • 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 required
    • Obtaining EHSS concurrence with formal authorizations after review and committee approval

     

    6.6 Definitions

    Term

    Definition

    AHD

    The Activity Hazard Document identifies the elevated hazards associated with higher hazard work and defines the appropriate controls associated with those elevated hazards. The AHD document is reviewed and approved by the line management responsible for the work and is stored in a secure database. Once fully approved, the AHD document serves as an authorization for those qualified and approved workers listed in the AHD. The AHD database serves as the primary tool for developing an AHD.

    JHA

    Job Hazards Analysis requires line management to describe the scope of work for each job, determine the hazards of that work, and define the controls appropriate for those hazards. The documentation of that analysis and the assigned tasks, once fully approved by line management, serves as work authorization for the individual assigned to perform the work. The JHA document is maintained as an electronic record in the JHA database.

    sJHA

    Subcontractor Job Hazards Analysis and Work Authorization is a set of documents that establishes that a Subcontractor has adequately identified the hazards of work and defined appropriate controls for those hazards. The sJHA is required for authorization of subcontractor work.

    TWA

    Temporary Work Authorization provides authorization for a work activity that is short term in duration, covers a limited and clearly-defined work scope, has elevated hazards, and is not a permanent component of ongoing work.

    6.7 Required Work Processes


Work Process A. Line Management Authorizations for Routine or Special Hazards
Work Process B. Facility-Based Authorizations
Work Process C. Formal Authorizations for Increased Hazards

Work Process A. Line Management Authorization for Routine or Special Hazards

  1. Work Planning: Completion of the Job Hazards Analysis
    1. As part of the work planning process, workers and work leads[2] are required to plan all work by determining the tasks to be performed, defining the hazards, risks, and concerns associated with those tasks, and implementing 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.
    2. 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 ensure that employees know how to perform the work safely and in conformance with applicable requirements, and must provide on-the-job training as needed.
    3. Every employee and long-term affiliate[3] is required by Berkeley Lab policy to complete a JHA and the training required for the work assignment on initial hire and whenever assigned to a new position or to tasks with new hazards. It is the supervisor’s responsibility to ensure that each employee and affiliate 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 EHSS, 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 completed the required training.
    4. Appendix A gives examples of work involving special hazards that require specialized classroom training and result in issuing a license, permit, or certification to employees and affiliates who complete the training. Links provide information on where to obtain specialized training.
  2. Line Management Authorization Process
    1. During the JHA process, the worker and work lead discuss the tasks, hazards, and controls of the defined 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.
    2. 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 the computerized training record). Work leads should also review the defined work and the JHA on a regular basis to ensure that all work the employee is performing is authorized on the JHA.
  3. Line Management Reauthorization
    1. Records of JHA completion and classroom training status are maintained on the EHSS 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.
    2. 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. The JHA is reauthorized by the worker and work lead reviewing it, making adjustments as necessary, and then both signing the document.
    3. Some specialized classroom instruction for special hazards, and hence the authorizations enabled by that instruction, requires periodic reauthorization. The reauthorization dates are maintained on the EHSS Training Web site . If retraining or recertification is not completed in a timely manner then that element of work is no longer authorized and may not be performed.
  4. Line Management Authorization Documentation. Records of classes taken at Berkeley Lab are maintained by the EHSS 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.

Work Process B. Facility-Based Authorizations

  1. General
    1. 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 EHSS prepares other facility-based authorizations, with technical input from the applicable operating divisions. The operating divisions within the affected facility are responsible for conducting work within the defined safety operating envelope specified by the authorization.
    2. As used here, a "facility" means any equipment, structure, system, process, or activity that fulfills a specific purpose. At Berkeley Lab, a "facility" of a facility-based authorization is generally a building, but in some cases may refer to an area within a building. Facility-based authorizations differ from line management authorizations and formal authorizations in the following ways:
      1. Line management and formal authorizations are based on individual activities, whereas a facility-based authorization is a function of an additional aggregate hazard, interaction between multiple operations, or a piece of facility equipment (for example, a paint spray booth or waste treatment facility).
    3. 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 Berkeley Lab (Facilities for NEPA/CEQA issues, EHSS for all others). The divisions that operate accelerators or that will be the occupants of new buildings work intimately with EHSS during preparation, review, and update of their respective facility-based authorizations.
    4. The need for facility-based authorizations may be triggered by new programs or facilities or by changes in existing programs or facilities. Once a facility-based authorization is in place, it must be reviewed periodically to ensure that actual operations comply with the operating envelope established for that facility.
  2. Work Planning: Determining if a Facility-Based Authorization Is Needed for New Programs and Facilities
    1. In general, the analysis to determine whether a facility-based authorization is necessary for a new program or facility is carried out during the program or facility proposal and planning process. The various mechanisms for review during the proposal and planning process are described in Berkeley Lab’s Integrated Environment, Health & Safety Management Plan .
    2. Facility-based authorizations may be required if the proposed work presents risks in excess of work already being performed at the facility or Berkeley Lab, if significant on-site or off-site adverse 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 newly acquired buildings at startup.
    3. 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 a facility-based authorization. Appropriate facility-based authorizations and applicable trigger levels are given in Appendix C.[16] 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.[17]
  3. Facility-Based Authorization Process.The authorization process varies depending on the facility-based authorization sought. See Appendix C to determine the precise process to follow.
  4. Facility-Based Authorization Review/Reauthorization
    1. Facility-based authorizations with a built-in reauthorization schedule are reviewed according to that schedule, for example, regulatory permits. 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 resulting from program changes within the building.
    2. For facility-based authorizations for which an EHSS department is responsible, including most regulatory permits, that EHSS department coordinates the reauthorization according to its own internal procedures.
  5. 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 EHSS.

Work Process C. Formal Authorizations for Increased Hazards

  1. General
    1. Certain work activities pose hazards that require additional controls. Depending on the hazard, the principal investigator, supervisor, work lead, or manager must 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.
    2. A formal authorization includes the EHSS Division review and concurrence. Work is authorized by the division director or designee [5] of the line management where work will be performed. Experts with appropriate certifications or background from within EHSS and other divisions are brought into the process for consultation, review, and approval. The formal authorization can be thought of as a contract that defines the conditions under which the work will be performed. Formal authorizations are incorporated by reference into the Job Hazards Analysis.
    3. Some work at Berkeley Lab is authorized by an outside regulatory authority; these authorizations are generally facility-based authorizations, not formal authorizations, and are described in Work Process B .
  2. Temporary Work Authorizations
    1. A Temporary Work Authorization (TWA) may be issued for work that is:
      1. Characterized by elevated hazards
      2. Short-term in duration (two weeks or less)
      3. Limited in scope and clearly defined
      4. Not a permanent component of ongoing work
    2. A TWA is not a substitute for a permanent formal authorization.The intent of a TWA is to encourage the Work Lead and the EHSS subject matter expert (SME) to discuss and concur on the scope of the work to be performed, the hazards of the work, and the necessary hazard controls.
    3. Work authorized by a TWA may be preliminary work required for an experiment or process but must not be a component of that experiment or process. The TWA may not be used to reflect permanent changes to work covered by an existing formal authorization and may not be used to authorize work during a period in which a formal authorization is being prepared. The formal authorization must be amended to reflect permanent changes to work.
    4. Exception. A TWA can be used to identify temporary controls for work covered by an existing formal authorization when engineering controls established by the formal authorization fail or are found to be inadequate and new permanent controls are being implemented.
    5. Types of work that may be authorized by a TWA include the following examples:
      1. A vendor demonstrates a higher hazard piece of equipment to potential customers (for example, a Class IV laser). A TWA would allow the vendor to operate that equipment under very tight controls of limited scope and short-term duration.
      2. A vendor sets up and aligns 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), but a TWA would cover the initial setup, including the initial loading of cryogenic liquids.
      3. A researcher performs preliminary experimental feasibility testing to determine whether a particular health hazard gas will work in his experiment. Further work would be subject to an AHD.
      4. A researcher has a piece of equipment that malfunctions and must use a multimeter to probe for electrical voltages as part of troubleshooting.
      5. A researcher orders items or supplies with a long lead time while the formal authorization for the research progresses through the formal authorization process. A TWA 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 a TWA.
      6. Under a TWA, a researcher in a laser lab implements temporary controls, which are at least as effective as the permanent controls specified in the AHD addressing the laser use. The temporary controls allow for installation and testing of improvements to a laser interlock system.
    6. TWAs must include the following components:
      1. Description of the work to be performed, including restrictions, boundaries, and “hold points” (points within a process or activity at which the activity must stop [i.e., go on hold] until an inspection or check is performed.
      2. Controls necessary to perform the work, including engineering controls, administrative controls, training, and personal protective equipment
      3. Effective and expiration dates
      4. Designation of the Work Lead and specific acknowledgment by the work lead of responsibility for the safety of all persons and activities that are part of the authorized work and for providing appropriate work-specific, on-the-job training
      5. Signatures of all participants in the authorized work, attesting that they have read and agreed to the requirements of the TWA and have received appropriate work-specific orientation
      6. Signature of the EHSS SME for the primary hazard present in the work, indicating the signee concurs with the Work Lead’s analysis of hazards and controls
      7. Signature of a member of the Work Lead’s line management chain (e.g., Division Director, Division Deputy Director, Department Head, or Group Lead)[15], indicating the signee concurs and authorizes the work described.
    7. A TWA may be written in the field (i.e., at the location of the activity), but must have the components and signatures described above. When possible, the controls established for a TWA should be verified before authorization.
    8. Work to be performed under a TWA must be authorized for the shortest practical duration, no longer than two weeks. After the initial authorization by the work lead’s line manager, the TWA may be extended twice, for a total work duration of six weeks, after the work lead and the EHSS SME have modified the scope of work and hazard controls to describe the remaining work. TWAs are subject to cancellation at any time by the work lead’s line manager.
    9. The work lead is responsible for obtaining all authorizing signatures prior to beginning work, for prominently posting a fully signed copy of the authorization at the work location, and for forwarding a copy of the completed TWA to the EHSS SME who signed it.
    10. See Appendix E for a sample TWA form.
  3. Work Planning: Determining if a Formal Authorization is Needed for New Programs and Facilities
    1. Work for which a formal authorization is required is generally more extensive or inherently more dangerous than similar work that requires line management authorization. Trigger levels have been developed that, when reached , may require formal authorization. Appendix B shows a list of these levels and the corresponding formal authorization required.
    2. 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 follow as part of the work planning/hazard analysis process.[6] The work lead should consult Appendix B to determine if any hazard exceeds the trigger level specified for that hazard.[7] If so, a formal authorization as specified may be required. The links provided in the table give additional information.[8]
    3. 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 of the line management authorization for that work, then the work lead should contact the division safety coordinator/administrator (if internal procedures exist) or EHSS Division Liaison (in the absence of internal procedures) to discuss whether a formal authorization should be obtained.
  4. Formal Authorization Process
    1. The formal authorization process intimately involves the EHSS Division in the analysis of hazards and required controls and in 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 on what the formal authorization is):
      1. The principal investigator (PI) or work lead determines that a formal authorization is needed.
      2. To initiate the formal authorization process, the PI/work lead contacts the Division Safety Coordinator/Administrator if specified by internal procedures or, in the absence of internal procedures, the EHSS Division Liaison assigned to the division.[9]
      3. If additional expertise is necessary for proper review (for example, if an EHSS SME is required), the EHSS Division Liaison coordinates the EHSS component of the review process.
      4. The PI or work lead prepares draft documentation and submits it to the Division Safety Coordinator/Administrator and EHSS. (Note that the EHSS program applicable to the authorization and the specific individual who will review the draft documentation depend on the specific formal authorization.) EHSS may inspect the work locations and facilities supporting the activity and make recommendations for the final documentation. NOTE: Follow the links in Appendix B to find instructions for preparing the specific required formal authorization documentation. Activity Hazard Documents, one form of formal authorization, are addressed in Appendix D.
      5. The PI/work lead and EHSS confirm that the prescribed hazard controls are in place and operational.[10]
    2. The PI/work lead, Division Safety Coordinator/Administrator, and EHSS submit final documentation and recommendations to the governing body/committee, if appropriate.
    3. The PI/work lead, division , and EHSS sign the authorization.
    4. The PI/work lead receives authorization specifying the hazard controls.
    5. Work proceeds in accordance with specified hazard controls.
    6. Principal investigators and work leads are encouraged to contact their Division Safety Coordinator/Administrator and EHSS 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.
  5. Formal Reauthorization
    1. Work under a formal authorization is only permitted if the authorization is currently active. Formal authorizations must be reauthorized whenever work changes significantly.[11] 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.
    2. Subject to internal division procedures, the reauthorization process proceeds generally as noted below. Note that this is a general description; the precise process depends on what the formal authorization is. In particular, some reauthorization processes are initiated by EHSS. Nevertheless, it is the authorization holder’s responsibility to ensure that work is only conducted under a current authorization.
    3. As the reauthorization date approaches, the work lead contacts the Division Safety Coordinator/Administrator or EHSS Division Liaison to initiate the reauthorization process.[6], [12] 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 (this may not apply to some formal authorizations, for example, those involving radioactive materials or fields). 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. When the director (or designee) of the division in which the work is being performed has signed the authorization, the work has been reauthorized.[13]
    4. After obtaining the authorizing signature, the work lead forwards a copy of the signed authorization to EHSS for review and recording.
    5. EHSS, the work lead, and the division may agree on 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. Formal Authorization Documentation
    1. Documentation requirements are given in the descriptions of each authorization process. Consult the links in Appendix B for information.
    2. The process leading to the decision that formal authorizations are required should be documented. Division procedures will determine where the documentation is maintained and the method used to disseminate the authorization conditions/requirements.
    3. Generally, the Division retains the original formal authorization with any original signatures. EHSS and others retain copies.[14] Some formal authorizations are software based; the software is the authorization of record and there is no “original.”

6.8 Source Requirements

Other Driving Requirements

6.9 Reference Documents

Document Number

Title

Type

07.07.007.001

Construction Safety

Program

07.07.018.001

Lasers

Program

07.07.018.002

Work Process A, Laser Safety Process and Flowchart

Work Process

07.07.018.003

Work Process B, General Laser Requirements

Work Process

07.07.018.004

Work Process C, Procurement Requirements

Work Process

07.07.018.005

Work Process D, Medical Exam Requirements

Work Process

07.07.018.006

Work Process E, Training Requirements

Work Process

07.07.018.007

Work Process F, Class 1-3A Lasers

Work Process

07.07.018.008

Work Process G, Class 3B- 4 Lasers

Work Process

07.07.018.009

Work Process H, Special Topics

Work Process

07.08.001.001

Radiation Safety

Program

07.07.004.001

Biosafety

Program

03.02.002.001

Research with Human and Animal Subjects

Program

07.02.004.001

sJHA – Subcontractor Job Hazards Analysis

Program

07.02.004.002

Work Process A, sJHA General Requirements 

Work Process

07.02.004.003

Work Process B, Creating an sJHA

Work Process

07.02.004.004

Work Process C, Training and Orientation

Work Process

07.02.001.001

Job Hazards Analysis

Program

DOE, STD 1027.92

Hazard Categorization and Accident Analysis Techniques for Compliance with DOE O 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)  

PUB-5341

Chemical Hygiene and Safety Plan  

PUB-3092

Guidelines for Generators to Meet HWHF Acceptance Requirements for Hazardous, Radioactive, and Mixed Wastes at Berkeley Lab  

PUB-3111

Operating and Quality Management Plan  

PUB-3140

Integrated Environment, Safety and Health Management Plan  

 

6.10 Appendices

Appendix A. Line Management Authorizations
Appendix B. Formal Authorizations
Appendix C. Facility-Based Authorizations
Appendix D. Activity Hazard Document (AHD) Process
Appendix E. Temporary Work Authorization Template
Appendix F. Hazard Management System

Appendix A. Line Management Authorizations

Work Requiring Specialized Classroom Training and/or Certification


Hazard/Work
Requiring Authorization

Type of
Authorization

How Authorization
Is Obtained

Additional
Information

Asbestos

Asbestos Worker

Specialized training

PUB-3000, Chapter 4
See PUB-3000, Chapter 6, Appendix C for notification requirements

Chemicals

Routine shop and lab, reproductive toxins, acutely toxic, peroxide-forming

Supervisor authorization

Specialized training, implement specified controls

Chemical Hygiene and Safety Plan (CHSP),
General
, Hazard Evaluation

Reactive (e.g., alkali metals), pyrophoric, possessing lethal or incapacitating toxicity

Formal authorization
may be required (see Appendix B)

Typically managed within AHD System

CHSP, Hazards Review

Discharge to sink

Formal or facility authorization may be required

Contact EHSS Division Waste Management and Environmental Services Groups

PUB-3000, Chapter 11

Environmental sampling

Environmental sampling policies

Hazardous Waste Operations and Emergency Response (HAZWOPER) training

29 CFR 1910.120, Hazardous Waste Operations and Emergency Response

Forklift operation

Forklift Operator Permit

Specialized training

PUB-3000, Chapter 5
29 CFR 1910.178, Powered Industrial Trucks

Lead

Lead Compliance Plan

Specialized training

PUB-3000, Chapter 4.12
29 CFR 1910.1025, Occupational Exposure to Lead
29 CFR 1926. 62, Lead in Construction

Lifting/rigging, normal

Crane Operator Permit

Specialized training, government identification card

PUB-3000, Chapter 5, Material Handling and Storage
29 CFR 1910 Subpart N, Materials Handling and Storage

Lifting/rigging, high consequence/high value

Formal authorization required.

Written procedure approved by Facilities and EHSS

PUB-3000, Chapter 5, Material Handling and Storage
29 CFR 1910 Subpart N, Materials Handling and Storage

Magnetic field

5-gauss line posting

Request survey from EHSS Division, Radiation Protection Group

ACGIH TLV Handbook

Radio frequency fields

Shielding survey

Request survey from EHSS Division, Radiation Protection Group

ACGIH TLV Handbook

Respirator Use

EHSS Division industrial hygiene hazard assessment

  • Annual training
  • Respirator fit test

LBNL Respiratory Protection Program
PUB-3000, Chapter 4.14
29 CFR 1910.134, Respiratory Protection

Underground work and surface

Dig/Underground Work/Penetration Permit

Request/Utilities survey

PUB-3000, Chapter 10
Contact Facilities Work Request Center


 

Appendix B. Formal Authorizations

Work Requiring EHSS Participation in or Concurrence with Hazard Analysis and Work Authorizations

Hazard/Concern

Trigger Level

Formal Authorization Type

Additional Information

Animal research (vertebrate)

Any research involving vertebrate animals or vertebrate animal tissue

Approval by Animal Welfare and Research Committee

Animal Welfare and Regulatory Committee

PUB-3000, Chapter 22

Biological material

For details, see PUB-3000, Chapter 26, Biosafety.

Potential triggers for review include: Work with Risk Group 2 materials, use of Biosafety Level 2 containment for safety, handling Occupational and Safety Health Administration (OSHA) Bloodborne Pathogen materials, and operations that require a regulatory registration or permit (e.g., work with human pathogens, human blood or some body fluids, human tissues, human cells, or select agents/toxins)

Biological Use Authorization approved by the Institutional Biosafety Committee (IBC)

Review for human subjects protections (see below "Human Research") for human blood, tissues, and cells.

PUB-3000, Chapter 26 and Chapter 20

Biosafety Program

EHSS Biosafety or Medical Waste Subject Matter Experts

Centers for Disease Control and Prevention (CDC) and National Institutes of Health (NIH), Biosafety in Microbiological and Biomedical Laboratories

NIH Guidelines for Research Involving Recombinant DNA Molecules

10 CFR 851,Worker Safety and Health Program: 851.21; 851.23(3);
851.24;
Appendix A, Section 7, Biological Safety

29 CFR 1910.1030, OSHA Bloodborne Pathogens Standard

Select agent & toxin regulations: CDC (42 CFR 73) and United States Department of Agriculture (USDA) (7 CFR 331 & 9 CFR 121)

PUB-3095, Medical and Biohazardous Waste Generator’s Guide

Chemicals

Routine shop and lab, reproductive toxins, acutely toxic, peroxide-forming chemicals

Formal Authorization is not required; work may proceed under supervisor authorization/line management authorization

Chem Hygiene and Safety Plan
CHSP, Hazard Evaluation

Reactive (e.g., alkali metals), pyrophoric, possessing lethal or incapacitating toxicity (also see below “Gases,”), glovebox is required for safety, or failure of other primary engineering controls would result in a significant exposure or safety hazard

Activity Hazard Document

PUB 3000, Chapter 6

CHSP: Hazards Review

Contact user division’s EHSS Industrial Hygienist

Chemicals that are secondary explosives, such as triaminotrinitrobenzene (TATB) and cyclotrimethylene-trinitramine (RDX). 

Quantities ≤10 mg require no special precautions other than following the requirements in the CHSP. Divisions shall do a risk assessment in consultation with an EHSS Division Subject Matter Expert for use of quantities >10 mg.
The following activities are prohibited: Use of primary explosives. Development, testing, processing, blending, pressing and machining of explosives or assemblies containing explosives.
Operations that pose an explosion hazard, a metal fragment hazard, or a glass fragment hazard.

Division determines if an AHD is needed on the basis of the risk assessment performed. Activities conducted by visiting scientists must be done in accordance with the CHSP.

CHSP: Hazards

Chemicals within equipment or instruments

When normal operation or reasonably foreseeable mishandling may result in a loss of control (such as a spill) that could pose an exposure hazard, cause extensive area contamination, or result in environmental damage

Divisions must do a risk assessment in consultation with an EHSS Division Subject Matter Expert.

Division determines if a formal authorization (e.g., Activity Hazard Document) is needed on the basis of the risk assessment performed.

PUB-3000, Chapter 6

CHSP: Hazards

Contact user division’s EHSS Division Liaison.

Confined space entry

Permit-required confined space

Specialized training, entry permit authorized by EHSS Division industrial hygienist and/or trained permit writer

PUB-3000 Chapter 4.10

Confined Space Program

29 CFR 1910.146, Confined Spaces

Construction

Over 1 acre in size

State Water Resources Control Board (SWRCB) General Stormwater Construction Permit

Contact EHSS Division, Environmental Services Group

Cryogenics usage

Stored energy greater than 75,000 ft-lb

Engineering Safety Note, Activity Hazard Document

PUB-3000, Chapter 6

PUB-3000, Chapter 7

Drugs

Radioactive, used in human subjects

Approval for Human Subjects (see below "Human Research")
Radiological Work Authorization
May require approval by LBNL Radioactive Drug Research Committee

PUB-3000, Chapter 22

FDA, Title 21, Part 361, Radioactive Drugs for Certain Research Uses

Electrical hazardous exposure, including testing, measuring, and Lock Out/Tag Out (LOTO) verification.

Potential exposure to voltages equal to or greater than 50 V AC or DC and currents equal to or greater than 5 mA

Energized Electrical Work Permit (EEWP) for work where there is hazardous electrical exposure and when the following circumstances DO NOT exist: An Electrical AHD, or approved equivalent authorization, is in place for testing (including LOTO verification), troubleshooting, or inspection work where there is hazardous electrical exposure. See PUB 3000 Chapter 8 for a description of the equivalency process.
NOTE: Line management must initiate an EEWP, Electrical AHD, or approved Electrical AHD equivalent for all identified work having such exposures.

PUB-3000, Chapter 6

PUB-3000, Chapter 18

29 CFR 1910.333, Selection and Use of Work Practices

Explosives. See above "Chemicals that are secondary explosives."

 

 

 

Gases, compressed (see also below “Pressure”)

Stored energy greater than 75,000 ft-lb (not including cylinders), pressure > 150 psig (gas) or 1500 psig (liquid)

Engineering Safety Note
Activity Hazard Document

PUB-3000, Chapter 7

Flammable >400 cubic feet per room

Activity Hazard Document

PUB-3000, Chapter 6

29 CFR 1910.103, Hydrogen

Pyrophoric, reactive, health hazard
NOTE: There are certain exceptions to these requirements for small cylinders of carbon monoxide. Contact EHSS for details.

Activity Hazard Document

PUB-3000, Chapter 6

PUB-3000, Chapter 13

Hot work/open flame

Welding, soldering (lab-type Bunsen burner not included)

Hot Work/Open Flame Permit from LBNL Fire Department

PUB-3000, Chapter 12

National Fire Prevention Association (NFPA)

29 CFR 1910.252, Fire Watchers

Human research

Any

Approvals by LBNL Human Subjects Committee and UC Berkeley Committee for Protection of Human Subjects

PUB-3000, Chapter 22

45 CFR 46, Protection of Human Subjects, the Common Rule

10 CFR Part 745, Protection of Human Subjects

Laser

Class 3b or 4

Activity Hazard Document

PUB-3000, Chapter 16

PUB-3000, Chapter 16, Work Process G, which addresses requirements for use of Class 3B and 4 lasers.

Lifting/rigging

High consequence/ high value
Custom built or modified lifting fixtures

Written procedure approved by Facilities and EHSS
Engineering Safety Notes for custom lifting fixtures
Specified inspections, tests and re-tests for lifting fixtures

PUB-3000, Chapter 5, Material Handling and Storage

29 CFR 1910 Subpart N, Materials Handling and Storage

Pressure

Noncommercial or modified pressure vessel
Stored energy greater than 75,000 ft-lb (not including gas cylinders), pressure > 150 psig (gas) or 1500 psig (liquid)
Radioactive contents

Engineering Safety Note
Activity Hazard Document
Radiological Work Authorization

 

PUB-3000, Chapter 7

29 CFR 1915.172, Portable Air Receivers and Other Unfired Pressure Vessels

Radiation or Radioactive Materials

Unsealed Source

Radiological Work Authorization or Radiological Work Permit

PUB 3000, Chapter 21

10 CFR 835

Contact EHSS Division, Radiation Protection Group

Sealed Source

Sealed Source Authorization
or
Generally Licensed Source Authorization

PUB 3000, Chapter 21

10 CFR 835

Contact EHSS Division, Radiation Protection Group

Ionizing produced by X-ray machine

X-ray Authorization

PUB-3000, Chapter 21

10 CFR 835

Contact EHSS Division, Radiation Protection Group

Vacuum

Stored energy greater than 75,000 ft-lb

Engineering Safety Note
Activity Hazard Document

PUB-3000, Chapter 6
PUB-3000, Chapter 7

Waste, generation or treatment of

Hazardous, radioactive, or mixed

Up to 55
gallons, less than 270 days

Generation only

Specialized training

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

SAA custodian

Specialized training, Satellite Accumulation Area

Greater than 55 gallons, less than 90 days

Specialized training, Waste Accumulation Area

Treatment at point of generation

Bench-top treatment authorization

Contact EHSS Division, Waste Management Generator Assistant

Medical or biological

Specialized training

Contact EHSS Division, Waste Management

Working Alone

Workers at LBNL are not allowed to work alone when the mitigated hazards associated with their work may incapacitate them making them unable to self-rescue or activate emergency services.
Many of the Hazards/Concerns listed in this table can trigger this restriction.

Division/Work Lead determines if a Working Alone restriction should be included in a formal authorization (e.g., Activity Hazard Document) based on the risk assessment performed.

Working Alone Policy, Requirements and Policies Manual

 

Appendix C. Facility-Based Authorizations


Hazard/Concern


Trigger Level

Formal Authorization Type

Additional Information

General on-site or off-site environment, health, or safety risks

In excess of those already accounted for in LBNL’s NEPA and CEQA documentation

SEIR, addendum to the SEIR, and other NEPA and CEQA documents

Contact Facilities Planning Group for NEPA/CEQA analysis

Acquisition is covered by DOE O 413.3A, Capital Asset Acquisition Process

Hazard Analysis Report1

DOE O 413.3A

Air emission of pollutants into the environment

Non-radioactive material

Bay Area Air Quality Management District (BAAQMD) Permit requirements review

Possible specialized training

PUB-3000, Chapter 11.3.1

Radioactive material

Permit (regulatory)

EPA National Emission Standard for Hazardous Airborne Pollutants (NESHAP) off-site dose assessment

PUB 3000, Chapter 11.3.2

Asbestos removal/abatement

>100 sq ft or >100 linear ft or >35 cu ft

BAAQMD (NESHAP) 10 day notification

Bay Area Air Quality Management District Regulation 11, Rule 2

Chemicals

Discharges to the sanitary sewer system (sink, drain) in excess of permitted limits

East Bay Municipal Utility District Discharge Permit

PUB 3000, Chapter 11.3.8

Contact EHSS Division, Environmental Services Group

Emissions/use in excess of listed quantities in Bay Area Air Quality Management District regulations

BAAQMD Permit to Operate
Process Hazards Analysis

Bay Area Air Quality Management District regulations

Storage/use in excess of Threshold Quantities listed in the OSHA Process Safety Management regulation

Process Hazard Analysis

29 CFR 1910.119, Chemical Process Safety Management

Storage/use in excess of planning quantities listed in the State of California Accidental Release Program (CalARP) (note: includes federal substances)

Risk Management Plan (RMP)

California Accidental Release Prevention Program Regulated Substances (Title 19 California Code of Regulations 2770.5)

Contact EHSS Division, Environmental Services Group

Use/handling/emissions in excess of National Emission Standard for Hazardous Air Pollutants or Stationary Source limits

NESHAPS permit (Environmental Protection Agency)

Contact EHSS Division, Environmental Services Group

Radiation or radioactive materials

Accelerators: External radiation level thresholds listed in DOE O 420.2

Accelerator-based Safety Analysis Document (SAD)

PUB 3000, Chapter 21

DOE O 420.2B

Discharges to the sanitary sewer system (sink, drain) in excess of permitted limits

East Bay Municipal Utility District Discharge Permit

PUB 3000, Chapter 11.3.8

Contact EHSS Division, Environmental Services Group

Storage/use in excess of Category 3 limits (Nuclear Facility Limits)2

Safety Analysis Review

DOE STD 1027.92 (advisory)

Contact EHSS Division, Radiation Protection Group for radionuclides not included in DOE STD 1027.92

Use/handling/emissions in excess of National Emission Standard for Hazardous Air Pollutants or Stationary Source limits

NESHAPS permit (Environmental Protection Agency)

PUB 3000, Chapter 11

Contact EHSS Division, Environmental Services Group

Storm drain discharge

Any discharge (including pollutants and sediments) to the storm drain system other than rainwater

SWRCB General Industrial Permit

PUB 3000, Chapter 11.3.9

Use best management practices

Waste, generation or treatment of

Hazardous or hazardous component of mixed

Storage in excess of 90 days in a Waste Accumulation Area or storage of > 55 gal for > 1 year in a Satellite Accumulation Area

Treatment, Storage, and Disposal Facility (California Department of Toxic Substances Control)

California Code of Regulations, Title 22, Section 66260.1 et seq. (Hazardous Waste Regulations)

Radioactive or radioactive component of mixed

Radioactive Waste Management Basis (Department of Energy)

DOE O 435.1 (only those sections/ subchapters adopted in the current LBNL Work Smart Standards set)
Mixed waste is subject to the Hazardous Waste regulations (see above) and the Radioactive Waste regulations

On-line treatment (e.g., acid neutralization)

Fixed Treatment Unit permit (various types) from City of Berkeley

Contact EHSS Division, Environmental Services Group

PUB 3000, Chapter 11

29 CFR 1910.120, Hazardous Waste Operations and Emergency Response


Appendix C Notes

  1. The term “Hazard Analysis Report” was finalized under the 2006 revision of DOE O 413.3A and specifically applies to non-nuclear facilities (below Hazard Category 3 threshold as defined in 10 CFR 830, Subpart B). In previous versions of this order and the repealed DOE O 5481.1B, the term varied, and documents prepared at LBNL over the years have been named Safety Analysis Document and Operational Hazards Analysis Report. None of these documents are a Safety Analysis Document in the context of nuclear facilities (LBNL is not and does not have nuclear facilities), and functionally, they are the same as the Hazard Analysis Report, per DOE O 413.3A.
  2. For any facility in which radionuclides will be stored or used, it must be specifically documented whether these limits (individually and sum of fractions) will or will not be exceeded. EHSS and the applicable division will prepare this analysis, which is submitted to Facilities to become part of the permanent planning record for that facility.

Appendix D. Activity Hazard Document (AHD) Process

  1. The Activity Hazard Document (AHD) is a general-form tool and authorization used to document the analysis and controls for hazards that do not have specific analytical tools prescribed elsewhere. In general, if a hazard exceeds the trigger level specified in Appendix B, or if a hazard or combination of hazards in an activity exceeds those authorized by the applicable line management authorization, an Activity Hazard Document must be prepared unless the hazard has already been included in a broader, facility-based analysis.
  2. LBNL manages AHDs through an electronic management system. Many divisions have internal procedures for preparation and review of AHDs. Work leaders must consult with their division safety coordinator/administrator to determine what the division’s procedures include. Regardless of a division’s internal procedures, all actions (initial authorization, reauthorization, updating user list, etc.) must take place within the electronic management system. The version of the AHD in the electronic management system is the version of record.
  3. The steps below provide an outline of how to prepare and reauthorize AHDs in the absence of any internal division procedures. Division internal procedures for processing AHDs must include the essential elements of the process provided here (thorough analysis of hazards, concurrent division and EHSS authorization, annual review and reauthorization by the division, and review by EHSS).
  4. The initial authorization of the AHD proceeds as follows:
    1. At the division level, the principal investigator determines that an AHD is required by reviewing the planned work against the trigger levels in Appendix B. If there is any question about how hazards or combined hazards of the planned work apply to the appendix scenarios, the EHSS Division Liaison should be consulted.
    2. The principal investigator prepares the AHD submittal using the template given in the electronic management system. The principal investigator may designate a separate individual as Work Lead for purposes of supplying detail, but the principal investigator retains responsibility for the AHD. The tutorial and  help functions within the system explain how to use it; questions can be directed to the AHD coordinator.
    3. The data management system assigns an AHD identification number and appoints a Review Team Leader who will recruit additional team members to properly evaluate the work. Generally, the review team leader will be the division liaison for that division. At a minimum, the review team should include the EHSS subject matter expert for the predominant technical areas included in the work process and representatives from all EHSS disciplines.1 The Review Team Leader may request that resources outside of EHSS be used to evaluate the planned work. If so, this request should be reviewed with the EHSS AHD Coordinator.
    4. The review team reviews the work with the principal investigator and/or work lead.
    5. The review team makes recommendations to the principal investigator/work lead, if necessary, for incorporation into the AHD. The Review Team Leader, principal investigator, and work lead may directly edit the text in the electronic system.
    6. The principal investigator releases the final AHD for formal review. There may be several review/comment cycles depending on the complexity of the comments and revisions, and these are documented within the data management system. Upon agreement that the AHD is acceptable, the Review Team Leader concludes the review cycle by releasing the AHD for electronic signatures.2
    7. Work may begin after all required authorization signatures have been obtained.3 Personnel may not perform work until they have completed their training and have signed the AHD.
    8. A printed copy of the fully authorized AHD must be prominently posted in the work area; however, the electronic version is the version of record.
    9. The principal investigator and work lead are responsible for assuring that work proceeds in accordance with the hazard controls specified.
  5. Reauthorization of an AHD proceeds in accordance with division procedures (consult the Division Safety Coordinator/Administrator), or proceeds as follows:
    1. As the reauthorization date approaches, the principal investigator and work lead review the AHD and the work process.
    2. If there have been significant changes in processes or hazards,4 then the AHD must be modified and submitted for review as outlined above. An AHD may be internally reauthorized up to three years after initial or subsequent full authorization. After three years, an AHD requires a full authorization, which involves review and concurrence from the EHSS Division as outlined above.
    3. If there have been no significant changes in processes or hazards, the AHD may be submitted for internal review and reauthorization through the electronic management system.
  6. Work may not proceed in the absence of an authorized AHD. If the AHD falls outside of its reauthorization cycle, then the electronic management system will remove its Active status, and work must stop until the AHD is again Active.

Appendix D Notes

  1. For purposes of AHD review, EHSS disciplines are defined as Environmental Protection, Waste Management, Radiation Protection, Industrial Hygiene, Occupational Safety, and Fire Protection. The data management system documents this involvement.
  2. Concurring signatures are required from the principal investigator, the EHSS Review Team Lead and the Division Safety Coordinator. The Division Director’s signature authorizes the work.
  3. Signatures of EHSS and the division on the authorization document indicate that an Operational Readiness Review has taken place and that work may proceed in accordance with the established authorization.
  4. Minor changes in personnel, materials, and methods are not generally considered significant changes unless these changes affect the applicability of the initial hazard assessment.

 

Appendix F. Hazard Management System

As part of any work planning process, potential hazards must be identified and analyzed so that proper controls can be established.
EHSS provides the Hazard Management System (HMS), which serves as:

HMS integrates existing hazard information into a simple format called the EHSS Summary Report. All existing or potential hazards and potentially hazardous equipment must be identified (via independent hazard systems or HMS itself) and represented on the EHSS Summary Report.

This report provides a high-level overview of identified hazards as well as links to web accessible data systems when viewed from the HMS Web application. Employees and divisions must maintain data on hazards for which they are responsible, which includes updating information as work or hazards change.

____________________
Program 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. A “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 Berkeley Lab employees.
  3. A long-term affiliate is one who works at Berkeley Lab for a continuous period of three months or longer. Career employees and long-term affiliates must complete the Job Hazards Analysis within the first month of employment. An affiliate 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 a Berkeley Lab sponsor who is responsible for that affiliate's safety. See PUB-3000 Chapter 24, EH&S Training, 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
  5. Authorizing signatures are designated in the Activity Hazards Documents Database. The default authorizing signature is the division director. Contact the AHD Program Manager to change who may authorize AHDs on behalf of the division.
  6. 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 EHSS Division authorization, annual review and reauthorization by the division and the EHSS Division) are included.
  7. The guidelines given in this program 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.
  8. Appendix B is a summary document intended to address potential questions as to applicability. The user must consult the primary source documents, as indicated by the links in the Additional Comments column, to determine the applicability of the situation.
  9. For some hazards (for example, work with radioactive materials), EHSS 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 EHSS representative to make the processing more efficient.
  10. This final inspection constitutes an "Operational Readiness Review." Signatures of EHSS 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.
  11. 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.
  12. Reauthorization for work involving radioactive materials or machines are initiated by the EHSS Radiation Protection Group. Work leads are responsible for assuring that all work complies with the authorization in effect.
  13. Authorizations involving work with radioactive materials or machines require both user division and EHSS signature for reauthorization.
  14. Original authorizations for work with radioactive materials or machines are retained by EHSS, and a copy is present in the work area.
  15. The division director may specify which line managers have signature authority for Temporary Work Authorizations. The names of line managers who have been authorized by their division director to sign Temporary Work Authorizations should be published in the division's Integrated Safety Management Plan.
  16. 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.)
  17. 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.

 

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