Chapter 19, Appendix A: Guidelines for Exceptions to Policy on Personal Protective Equipment and Food in Technical Areas

1. Introduction

2. Procedure

1. The Requester (a member of the Division “owning” the space and wishing the exception to policy) completes the documentation attached (Appendix A) and submits it to his/her Division.


2. The Division forwards the completed package to the EH&S Deputy Director.


3. The EH&S Deputy Director reviews the package for conformance with existing policy and the guidelines below. The EH&S Deputy may require a site visit, and he/she can request support from EH&S Subject Matter Experts.


1. If the EH&S Deputy Director feels that the package supports the requested exception, he/she forwards to the EH&S Director with an “Approve” recommendation.


2. If the EH&S Deputy Director feels that the package does not support the exception, he/she may return it to the Requester with comments or forward to the EH&S Director with a “Deny” recommendation.
   
   
Note: the recommendation of EH&S Deputy Director does not commit the EH&S Director.


4. The EH&S Director approves or denies the package and returns it to the Requester.


5. If approved, a signed and dated copy of Page 1. of the Worksheet must be posted in each PPE-Exception area.

3. Guidelines

The following are examples of situations where exceptions to existing policy may be granted using the Procedure described above. Note that these are only examples—all exceptions must be approved by the EH&S Director.

1. Technical Areas that house only operations with no inherent physical or chemical hazards during normal, reasonably foreseeable upset, or routine maintenance activities. Examples include some electron microscope rooms, precision measurement rooms, etc.


2. Non-hazardous work areas (e.g., offices, work stations) that are within Technical Areas but are clearly delineated by physical barrier (e.g., walls, doors, or cubicle dividers). It must be clear that the area is intended to be a self-contained, dedicated area. Readily movable furniture does not constitute a physical barrier as envisioned here.


3. Optical microscopes or similar instruments, requiring close contact between the eyes and the eyepieces, located within Technical Areas may be delineated by a 36” deep marked area where safety glasses may be removed. Other PPE requirements for this Area will not be waived. Remote viewing must be considered as part of the exception request.


4. Non-PPE required corridors may be delineated within technical areas provided that the corridor does not pass near any potential source of hazard. A clear, open and free horizontal distance of at least three feet from chemical use areas (e.g., hoods, lab benches, etc.) or six feet from portable or stationary machine tools may be considered adequate.


5. Exceptions for individual desks or work spaces within a Technical Area are discouraged. 

4. PPE and Food/Drink Policy Exception Worksheet Template

This worksheet template is used for requesting, approving, and posting exceptions to the existing policies. Each Technical Area requires a separate Exception Worksheet.  Provide the following for each Technical Area for which Exception to policy is requested:

Page 1:

1. A diagram of the Technical Area, clearly showing all entrances to the Technical Area and the proposed boundaries of the Exception. Clearly indicate which side of the boundary will be excepted from the Policy.
2. Approval signature wording to be added to bottom of Page 1 of the Worksheet:

Approved  ___________________________________________________________________________                  Director, EH&S Division                                                                             Date  

Conditions of Approval:

_____________________________________________________________________________________

Continuing Pages:

Page 2: Name and Division of the person requesting the Exception. It is strongly suggested that the     Requester be the Area Safety Leader for the Technical Area.

Page 3: A narrative discussion on why the Exception should be granted. Note that inconvenience, infrequent hazardous operations, and difficulty of assuring compliance with the Policy are generally not sufficient justifications for Exception.

Page 4: Describe how the Requester will assure the presence, physical limits, and PPE requirements of PPE-required and PPE-Exception areas.

Submit this document and any supporting information to the Division Deputy, Environment, Health, and Safety Division for review.