16.4.3.3.1 Initial TrainingApproved by Ken Barat
Revised 11/09
The objective of the LBNL laser safety program is to prevent staff exposure to laser radiation in excess of the maximum permissible exposure (MPE) limit for the human eye or skin, and to ensure a safe working environment for laser-related research by effectively mitigating laser-related hazards. The LBNL policy on laser safety requires that all lasers and laser systems be operated in a manner that complies with the American National Standards Institute (ANSI) Z136.1-2000, "Standard for Safe Use of Lasers." Additionally, the program is designed to ensure that adequate protection against collateral hazards is addressed. These collateral hazards include the risk of electrical shock, fire hazard from a beam or from use of dyes and solvents, and chemical exposures from use of chemicals and vaporization of targets.
In order to implement the policy and give the researchers’ flexibility in choosing controls, all laser operations at LBNL must be reviewed and approved by the LBNL Laser Safety Officer (LSO). Requirements for laser safety are multilevel and include engineering controls, administrative controls, training, and personal protective equipment.
This chapter does not describe the theory behind the laser or a number of laser-safety related topics such as bio-effects and how to select laser eyewear. Additional laser safety information is available on the Laser Safety Web site. Background Laser Safety and instructional materials are also on the LBNL Laser Safety Web site, and include information on:
The 2000 version of ANSI Z136.1 was included in the 10CFR851 DOE Worker Safety and Health Program rule, and must be complied with as law. The ANSI process updates the standard at regular intervals as technology changes and to improve the protection afforded byu the standard. The 851 rule makes allowances for such conflicts.This chapter, and the Laser Safety Program tools found in the Laser Safety Web site will be updated to adapt to these changes.
The nomenclature for the classification of lasers was changed between the 2000 and 2007 versions of ANSI Z136.1. Lasers purchased after 2007 will usually have manufacturer’s labels that conform to the updated requirements. While the strict legal requirement is to conform to the 2000 version nomenclature, use of the 2007 nomenclature would be a de minimis violation and is not citable. To minimize confusion, both systems will be considered acceptable until equipment with obsolete labels are removed from the system by attrition. This document will use the current 2007 nomenclature. Table 16-1 below displays the differences.
Table 16-1. Standard Laser Classifications for 2000 and 2007
Standard Version |
Laser Classifications |
||||||
2000 |
1 |
2 |
3a |
3b |
4 |
||
2007 |
1 |
1M |
2 |
2M |
3R |
3B |
4 |
Table 16-2 below indicates the requirements for operating lasers at LBNL. These items are more fully explained below.
Table 16-2. List of Requirements by Laser Class
|
Class of Laser |
Requirements |
Class to 3R |
Note: A laser service AHD or a Temporary Work Authorization (TWA) is required under certain conditions. |
Class 3B & Class 4 |
|
ALS users |
EHS ALS 280 (Laser Safety)*, |
Retraining |
3-year frequency, can take Web-based EHS 281 or special group session with LSO. |
*Or equivalent course, as determined by LSO.
The Supervisor represents line management and sets the tone for laser safety within a research group. Due to competing responsibilities, the Supervisor may spend little time in the actual laser use area. In these instances, the Supervisor may designate one or more Work Leads, who act as a Laser Safety Supervisor (LSS). Work Leads take on the responsibilities of the Supervisor in terms of laser safety. This does not alleviate the original supervisor from the responsibility that safe work is carried out. The Supervisor or Work Lead must ensure that all laser users receive adequate and appropriate laser safety training on two levels: (1) EHS 280, LBNL’s fundamental laser safety course, and (2) On-the-Job (OJT) training from the Supervisor, Work Lead, or designee with respect to the hazards and safe operation of the laser system. OJT must be documented.
Supervisors have the following responsibilities:
Final responsibility for laser safety rests upon the individual laser user. They must have received proper fundamental laser safety training and OJT that allows them to perform their tasks safely, and to be comfortable enough to speak up in times of question or doubt. They must also understand their work goals and be familiar with the LBNL “Stop Work Authority” policy. Authorization to perform laser work must be documented in the individual's JHA. Users have the following responsibilities:
The role of the Laser Safety Officer (LSO), defined in the ANSI Z136.1 laser safety standard, is a key element for effective laser safety.
“An individual shall be designated the LSO with the authority and responsibility to monitor and enforce the control of laser hazards and to effect the knowledgeable evaluation and control of laser hazards. The LSO either performs the stated tasks or ensures that the task is performed.”
This fits within the scope of the LBNL Integrated Safety Management plan. The LSO has the authority and responsibility to monitor and enforce the control of laser hazards. The LSO has the authority to suspend, restrict, or terminate the operation of a laser or laser system if it is deemed that laser hazard controls are inadequate. The LSO's duties, responsibilities, and authority include, but are not limited to the following tasks:
The ANSI Z136.1 Laser Standard provides the LSO authority to recommend or approve substitute or alternate control measures when the primary ones are not feasible or practical. This includes, but is not limited to, such actions as establishing a Nominal Hazard Zone (NHZ), approving standard operating procedures, avoiding unnecessary or duplicate controls, selecting alternate controls, and conducting periodic facility and equipment audits to verify that the alternate controls are effective. The approval of these controls must be incorporated into the AHD for the laser experiment. Examples would include the use of curtain maze or posting in place of an entrance interlock.
The concept of a Temporary Controlled Area (TCA) for laser operation comes from the ANSI Z136.1 standard, and is of great practical value in a research setting. Its purpose is to allow a temporary authorization of laser work in settings where a formal Activity Hazard Document (AHD) does not already exist. The term “Temporary Work Authorization (TWA),” as described in Chapter 6 of PUB-3000 (Work Authorizations), is equivalent to a TCA. Examples would be acceptance testing of laser equipment in a lab during initial set up, a short-term change to an existing experiment, short-term laser repairs, or an appropriate laser safety plan to follow while an engineering control is being repaired. The LSO will assist Line Management in generating a TCA/TWA memo listing the circumstances and control measures to be followed by all parties in the TCA/TWA. All parties will sign the memo indicating that they understand the controls and will abide by them. The TWA must be signed off by Line Management, authorizing the work. This TWA is to be posted at the work site and is issued for the shortest possible and most practical time duration, which may not exceed two weeks, and may be extended twice for a total of 6 weeks. Sample controls might be:
The ANSI Z136.1 standard (Safe Use of Lasers) recognizes that its classification and control scheme relate specifically to the laser product and its potential hazards, based on laser operating characteristics. However, the conditions under which the laser is used, the level of safety training of individuals using the laser, and other environmental and personnel factors are important considerations in determining the full extent of safety control measures. Since such situations require informed judgments by responsible persons, the Z136.1 standard assigns major responsibility for such judgments to the person with the requisite authority and responsibility, namely the Laser Safety Officer (LSO).
At LBNL, the LSO shall develop and issue laser protocols, which are interpretations of ANSI Z136.1 requirements that provide acceptable solutions for frequently encountered experimental situations, or resolve conflicts between standards, where the primary Z136.1 recommended control measures are not feasible or practical. Such protocols will be reviewed and approved by the LBNL Laser Safety Committee to ensure they provide equivalent protection, and fit into LBNL’s research environment and needs. Prior to implementing these protocols, they shall go to the U.S. Department of Energy (DOE) Berkeley Site Office (BSO) for review. As appropriate, they will be forwarded to the LBNL Safety Advisory Committee (SAC) for institutional review and approval. The protocols are posted on the Laser Safety Web page. Examples of protocols are:
16.3.4 Laser Safety Committee (LSC)
The LBNL Safety Advisory Committee (SAC) has established a subcommittee to advise the laser safety program on laser safety issues. This subcommittee provides recommendations to the LSO and LBNL management (via the SAC) on laser safety policy and issues. This subcommittee is comprised of the LSO, other EH&S personnel, and experienced laser users from LBNL, and provides a mechanism for laser user input to the LBNL laser safety program. The responsibilities of the LSC are to:
The role of the EH&S Divisio Health Services Group is to:
EH&S Division professionals provide guidance in handling and establishing controls for laser-associated hazards such as:
Purchasing notifies the LSO of all laser purchases and laser-related service requests.
The Center for Devices and Radiological Health (CDRH) is the Food and Drug Administration body tasked with developing laser light performance product safety standards. It defines a Class 1 product as any laser product that does not permit access during the operation to levels of laser radiation harmful to eyes or skin. Class 1 levels of laser radiation are not considered to be hazardous.
Many times, these Class 1 laser products are used in work areas where no attention or training on laser safety has taken place. Therefore, when open for service, these Class 1 laser products may introduce a potential laser hazard in work areas and staff unaccustomed to the laser safety considerations./p>
During routine operation of a Class 1 product, where laser radiation exposure is not possible, laser safety training, medical surveillance, or user restrictions from a laser safety perspective are not required. Each unit should have an individual responsible for its proper use.
Service or maintenance yielding accessible laser radiation. If these activities are conducted by LBNL staff, then an AHD is required. If conducted by a subcontractor, then either a Temporary Work Authorization is required or a Laser Service AHD must be in place. It is usually beneficial to develop a Laser Service AHD before service is required, as the development and authorization of a Temporary Work Authorization may delay obtaining service for the laser or laser system.
By their classification or definition, and when used as intended, these lasers or laser systems will not present a hazard to the user or those around them. When personnel not familiar with the low-hazard nature of laser operations are present, a sign advising of the low-hazard nature of the operation may be appropriate. In use areas where there is a likely chance of the beams being viewed through a telescope, microscope, binocular, eye loop, or other collecting optics, a review by the LSO, or posting of “Caution” signs will be required.
Authorization to use Class 3B or Class 4 lasers or laser systems is granted to laser users through a formal authorization process. The authorizing document is referenced as an Activity Hazard Document (AHD; see Chapter 6 of the PUB-3000). The AHD and AHD template can be accessed from the LBNL Web site (from the A–Z listing, under A for AHD, or under L for Laser Safety). Only the Supervisor can submit an AHD for review. There are situations where the LSO may approve use of Class 3B and Class 4 lasers or laser systems without an AHD. These are in selective or predetermined situations that will be described in the section on Temporary Work Authorization (which is equivalent to the ANSI term, "Temporary Control Area." Class 3B and Class 4 laser or laser system use in fiber-based communication systems are exempt from the AHD requirement, but training requirements do exist for service staff.
The requirements for Class 3B or Class 4 laser or laser systems are:
The goals of Class 3B and Class 4 laser or laser system controls is to prevent the exposure to hazardous levels of laser radiation to all individuals who may enter the control area. Each particular set of controls will be tailored to the hazards present. The laser hazard review will be conducted by the LSO (see Section 16.4.3.4 below for the hazard evaluation approach) and the appropriate Supervisor or Work Lead:
All Class 3B and Class 4 laser users who will be at LBNL for more than one month must complete a laser eye examination. This examination is performed by LBNL Health Services in Building 26. Alternatively, examinations performed outside of LBNL may be submitted to Health Services for approval and must meet the requirements of the ANSI Z136.1 Standard. Completion of these examinations is tracked as EHS 288, in the training database. For more information, call Health Services at extension 6266 or see PUB-3000, Chapter 3 (Health Services). Prior to receiving an eye examination, laser users can only work under the line-of-sight supervision of an authorized LBNL laser user. An optometrist or ophthalmologist must administer the examination.
Laser eye examinations will be performed as follow-up to suspected eye exposure, or at the request of the LSO or user. It is strongly recommended that the laser user receive an additional laser eye examination on termination of employment.
For those who routinely receive ultraviolet exposure as part of their experimental work, an annual skin evaluation is recommended. This service is available through Health Services.
All employees and guests who are authorized to work unsupervised with Class 3B or Class 4 lasers must complete two laser safety training sessions: EHS 280 and OJT, or equivalent training. Additionally, there is a three-year refresher requirement for EHS 280.
16.4.3.3.1 Initial TrainingEHS 302
EHS 302 is a Web course covering the fundamentals of laser safety. It is required for users of Class 3B and or Class 4 lasers. In addition, it is highly recommended that anyone who regularly works in a Class 3B or a Class 4 laser area take this course.
EHS 303
EHS 303 is a one-hour lecture on Laser Lessons Learned. The course reviews a number of laser incidents at DOE labs and their consequences. A class participation exercise is part of the course. The course is required for anyone who regularly works in a Class 3B or a Class 4 laser area.
EHS 300
EHS 300, Fiber-Optic Safety, is only for staff involved in fiber-optic communications. It is a one-hour lecture that is given as needed. Contact the LSO at ext. 2544 to schedule the class.
On-the-Job Training (OJT)
The Supervisor or Work Lead shall train/orientate staff on the hazards of the specific experimental work to be done as well as the proper alignment techniques and procedures for the safe operation of the specific laser system, experiment, and associated optics. Laser users are responsible for knowing the safety requirements that apply to their specific laser or laser system and for knowing the contents of the applicable Activity Hazard Document (AHD). OJT shall include location and mitigation of potential hazardous beams /reflections, hazards associated with the work, and the proper use of all required personal protective equipment (PPE). The depth of OJT must be tied to the individual responsibilities and degree of hazard. It can apply to the entire experiment or elements of the research work (specific laser systems or experimental operations). OJT that reflects the individual's laser safety awareness and compliance shall be documented and signed by the trainer. The format for documenting OJT can be as part of the AHD or as a paper document, which must be available for review (a sample OJT Form can be found in Appendix C). It is recognized that OJT may be a prolonged process. The supervisor/work team lead is ultimately responsible to ensure that all personnel, visitors, and students with access to the laser use area have a clear understanding of the controls associated with laser operation, and that the relevant laser safety procedures are diligently followed. The OJT must be documented and signed by both the trainer and trainee.
Laser users must participate in refresher training at least once every three years. This is available through the Web as EHS 281. As an alternative, the LSO can provide group-specific refresher training.
Laser and Laser System AHDs are required to be reviewed annually. The following safety analysis process is recommended for laser users in self-assessment of their laser setup during annual review. It is the same process that is used by the LSO during required annual audits. Use of the Laser Operations Audit Form to guide and document the self-assessment is recommended.
The laser use area should be considered as five discrete components and there are overarching documents for management of the system. Each component should be evaluated, as follows:
Guests, visitors, and new employees without LBNL-approved laser safety training (or with incomplete laser safety training) may use lasers ONLY under the line-of- sight supervision of an authorized LBNL laser user. New users may work under these conditions for a maximum of 30 days before completing the training and medical surveillance requirements.
Service and repair providers, whether they are LBNL employees or outside vendors, must be qualified to perform the requested work. This means that the service and repair providers must be trained by their employers, and the work must be authorized, per Chapter 31 of PUB-3000. Firms doing service or maintenance work on lasers under an existing laser AHD will follow control measures outlined in the Maintenance section of the laser schedule. Laser equipment not covered by an AHD, such as Class 1 products (e.g., cell sorters, some Raman units, etc) will either have a laser service AHD or will work under a Temporary Work Authorization (TWA), as described in Chapter 6 of PUB-3000. It is the Principal Investigator (PI), Supervisor, Work Lead, or equipment owners' responsibility to see that subcontractor controls and authorizations are in place before work starts and that subcontractors follow all specified requirements. Control examples are: workers shall receive an orientation to the hazards in the laser use area and be briefed on the AHD controls. Laser users must be aware that they are responsible for the safety of these individuals and their safety compliance with LBNL rules.
The majority of laser accidents in research activities occur while aligning the laser or during similar beam manipulation activities. All possible steps should be taken to prevent such accidents. These activities require carefully developed and detailed OJT covering hazard identification and mitigation techniques. Only laser users who have received OJT and are authorized by the supervisor, Work Lead, or designee shall perform laser alignment/beam manipulation activities unsupervised.
The following laser alignment precautions should be in every laser alignment procedure:
Laser users must report all laser accidents no matter how minimal to their supervisor, Health Services, and LSO. Accidental or suspected laser beam exposure is a serious event. The key initial action is to keep the individual calm.
In the case of suspected laser injury:
The LSO (with appropriate assistance from others) will perform a follow-up investigation on all reported suspected injury incidents. The goal is to determine the factors that led to the incident, and to develop corrective actions to prevent a recurrence at any LBNL laser-use site. When appropriate, a Lessons Learned will be generated.
The energy emitted from a laser or the reflection of a laser beam can present a highly concentrated energy source, sufficient to cause permanent eye injury. Although engineering controls are preferred to mitigate this hazard, it may be necessary or prudent to use laser protective eyewear. Eyewear must be matched to the wavelength(s) emitted and for the laser intensity. Laser protective eyewear must be marked with the optical density of the lens for which protection is provided (OD and wavelength). Fit and visual light transmittance round out the remaining leading factors in selecting laser eyewear. Laser protective eyewear can either be full protection or alignment style. Information for obtaining laser protective eyewear can be found on the LBNL Laser Safety Web page.
Full protection will block a direct or reflective strike from the laser source in question for a minimum duration of 10 seconds. Full protection must be worn whenever one is dealing with solely invisible beams.
Alignment eyewear is an option for use with visible beams and gives partial visibility for beam observation from diffuse or attenuated reflections, but not full protection from the direct beam. Authorization to use alignment eyewear will be specifically stated as part of an AHD.
In the research setting, there may be times when no commercial laser protective eyewear is available to meet experimental needs. At these times, the user and LSO must re-examine beam controls and, if necessary, select less-than-optimal protective eyewear. See the Laser Safety Web page for an extensive review of parameters for the selection of laser protective eyewear, including suggestions for alignment eyewear OD versus beam output.
Safety of laser users on site is extremely important to LBNL. Laser safety at off-site locations (even at other DOE facilities) should be equivalent to safety at LBNL. No LBNL employee shall work in a facility off-site where they feel their safety is at risk. If such an occasion arises, stop work and discuss with the LBNL Supervisor or Work Lead (line management) or local management, or contact the LBNL LSO to see what assistance LBNL can grant the host site. Off-site locations fall into two categories: (1) where LBNL has management responsibility and (2) where LBNL does not have management responsibilities. See Chapter 5, Section 5.5 (“Off-Site Safety”) of PUB-3000 for details on LBNL policy.
LBNL laser safety responsibility on the U.C. Berkeley (UCB) campus will extend only to the training of LBNL employees working with lasers on campus, as part of their LBNL employment duties. The LBNL LSO will ensure these employees receive equivalent training (including On-the-Job Training) as LBNL employees working on site, and will have the discretion to grant training credit for equivalent training received on campus (or other institutions).
Consistent with the “Partnership Agreement between UCB and LBNL Concerning Environment, Health and Safety Policy Procedures,” all other laser activities on campus (including DOE-funded research involving lasers, or DOE-funded laser equipment) will be the responsibility of U.C. Berkeley. Also consistent with the agreement, operating safety procedures for lasers on campus will follow campus requirements, and these are expected to be equivalent to the operating procedures at LBNL, as both LBNL and UCB laser safety programs are based on the ANSI Z136.1 standard. Periodic visits, by the LBNL LSO, of LBNL laser users working on campus, will be arranged in collaboration with the U.C. Berkeley LSO.
• American National Standards Institute (ANSI) Z136.1, 2000, American National Standard for Safe Use of Lasers
• 10 CFR 851, DOE Worker Safety and Health Program
Table A-1 lists reference sources for information on laser safety items.
Table A-1. Information Sources for Laser Safety Items
| Item | Information Source |
Warning and danger signs |
Laser Safety Web page or LSO |
Laser labels |
LSO |
Eyewear literature |
Laser Safety Web page or LSO |
Eyewear holders |
LSO |
Curtain material |
Laser Safety Web page |
Table B-1. Phone Numbers
| Job Title or Organization | Individual |
Phone Number (510-486-xxxx) |
Laser Safety Officer |
Ken Barat |
2544 |
Health Services (Medical) Department |
6266 |
|
Emergency |
7911 |