Chapter 24
EHS TRAINING PROGRAM

Contents

Approved by James Basore
Revised 10/13


24.1 Policy
24.2 Scope
24.3 Applicability
24.4 Exceptions
24.5 Roles and Responsibilities
24.6 Definitions
24.7 Required Work Processes

Work Process A. General Requirements and Information
Work Process B. EHS Training Database
Work Process C. Qualifying EHS Instructors
Work Process D. Course Approval Process
24.8 Source Requirements
24.9 Reference Documents



NOTE:
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. . . . . . . . Denotes the beginning of changed text within a section.
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24.1 Policy

The Environment/Health/Safety (EHS) Training Program explains the requirements and purpose of EHS training at Lawrence Berkeley National Laboratory (LBNL). It also explains the roles and responsibilities for the development, delivery, records management, and assignment of training requirements.

24.2 Scope

It is LBNL policy, and required by federal law, that all staff, affiliates, visitors, and others who perform work at, or for, LBNL receive appropriate training necessary to protect their health, and to perform work in a safe and environmentally sound manner.
This training must include information regarding job hazards, possible health effects and environmental impacts, and required work practices and procedures. The LBNL EHS Training Program assists line management to comply with all applicable training requirements of the Department of Energy, and all other federal, state, and local regulatory agencies.

24.3 Applicability

This policy applies to LBNL employees, affiliates, students, visitors, contractors, subcontractors, and vendors whenever planning and performing work at LBNL and LBNL-controlled off-site user locations and facilities, including UC Berkeley–controlled spaces.

24.4 Exceptions

  1. Waivers from Required Training
    1. Waivers from required training may be granted by the work lead through the work authorization processes. Waivers may be given for one of three reasons
      1. The individual has sufficient skills, knowledge, and ability in that subject area to enable him/her to perform the work safely and within compliance of all LBNL policies without fulfilling the training requirement.
      2. The work being performed by the individual is below the level of hazard that necessitate this institutional training requirement.
      3. The individual works solely at the UCB campus and this work is governed by UCB EHS requirements.
  2. Training Credit by Equivalence: The EHS Training Program Manager may grant training credit by equivalence. Certain training received from other Department of Energy (DOE) facilities or related institutions (e.g., UC Berkeley) is recognized as equivalent upon receipt of proper training documentation, and concurrence by EHS Training and the SME associated with the training topic.

24.5 Roles and Responsibilities

Role

Responsibilities

EHS Training Group

  • Develop an EHS training curriculum that addresses pertinent regulatory requirements, Laboratory policy, and best practices.
  • Work with line managers, instructors, and subject-matter experts to develop course objectives, instructional strategies, assessment, and training evaluation.
  • Work with divisions and line management to develop and evaluate division-specific EHS Training programs and new EHS courses.
  • Work with line management to identify and complete all required environment, health, and safety training.
  • Provide LBNL staff with EHS training courses that provide the necessary knowledge and awareness to operate in a safe and environmentally protective manner.
  • Establish and implement EHS training procedures and policies.
  • Review and approve institutional EHS courses.
  • Provide mechanisms to track training completion.
  • Available to provide assistance and support to line management to help develop on-the-job training programs that result in direct skill transference to the job.
  • Manage EHS training records and ensure that training-related records and reports are accessible for use by personnel and Laboratory management as appropriate.
  • Work with line management to qualify EHS instructors
  • Work with EHS IT, and as appropriate, EHS Division management to maintain EHS training database(s).

Supervisor or work lead

  • Identify and ensure completion of EHS training requirements for staff (including affiliates and students) under their direction.
  • Provide and document on-the-job training as required.

Safety Advisory Committee

  • Provide input on EHS Training Program Policies.
  • Review and provide advice as requested on significant changes to EHS training requirements as well as newly proposed courses to ensure these efforts meet the needs of the Laboratory and achieve necessary regulatory compliance.

LBNL employees, affiliates, visitors, and others who perform work at, or for, LBNL

Complete the appropriate training

 

24.6 Definitions

Term

Definition

Supervisor

“Supervisor” is defined in the Higher Education Employer-Employee Relations Act as "any individual, regardless of the job description or title, having authority in the interest of the employer to hire, transfer, suspend, lay off, recall, promote, discharge, assign, reward or discipline other employees, or responsibility to direct them, or to adjust their grievances, or to effectively recommend such action, if, in connection with the foregoing, the exercise of such authority is not of a merely routine or clerical nature, but requires the use of independent judgment. Employees whose duties are substantially similar to those of their subordinates shall not be considered to be supervisory employees."

Work lead

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. A worker’s default work lead is his/her supervisor, but the supervisor may designate another person to be the work lead. Work leads authorize work with the concurrence of the worker’s supervisor.

Hazard

A hazard is the potential to cause harm. Hazards are associated with tasks; if hazards are not controlled, they can cause illness or injury.

24.7 Required Work Processes

Work Process A. General Requirements and Information
Work Process B. EHS Training Database
Work Process C. Qualifying EHS Instructors
Work Process D. Course Approval Process

Work Process A. General Requirements and Information

  1. Organization
    1. The EHS Training Program is a collaborative endeavor of the EHS Division and line management.
    2. The EHS Division provides training courses to meet regulatory and Laboratory requirements, and applicable best practices.
    3. Line management provides On-the-Job Training (OJT) and training that is specific to the work conducted in its actual environment, and ensures that training requirements are met.
    4. Maintenance of the Laboratory-wide EHS training database system is shared by the EHS Division and IT Division.
  2. Purpose of EHS Training Requirements: The purpose of required EHS training is to help ensure that all LBNL personnel are aware of the hazards associated with their jobs and the methods for controlling those hazards; understand the health and safety effects of exposure to those hazards; and know how to perform operations safely and in accordance with required work practices, operating procedures, and applicable environmental protection requirements.
  3. Identifying EHS Training Requirements
    1. Training requirements originate from many sources, including: DOE orders, DOE regulations (10 CFR), OSHA regulations (29 CFR), EPA regulations (40 CFR), Department of Transportation regulations (49 CFR), the California Code of Regulations (Titles 8 and 22), LBNL’s environmental permits, LBNL’s Operating and Assurance Program, and LBNL policies and best practices.
    2. Training requirements are interpreted and promulgated to the individual employee through the ISM processes of defining work, analyzing hazards, identifying required controls, performing the work according to the controls, and providing feedback and continuous improvement.
    3. Job Hazards Analysis (JHA) and other work authorization programs serve as the means for identifying, analyzing, and controlling work, which includes the identification of required training.
      1. For more information on the Jobs Hazards Analysis (JHA) process, refer to the ES&H Manual Job Hazards Analysis program.
      2. The Job Hazards Analysis can be accessed at https://ehswprod.lbl.gov/ehstraining/jha/login.aspx.
    4. Work leads are responsible for analyzing work, including identifying EHS training requirements, for staff (including affiliates and students) under their direction.
    5. EHS Training can provide assistance with identifying training requirements using the Job Hazards Analysis and formal work authorizations. Examples of formal work authorizations include:
      1. Activity Hazard Documents (AHD)
      2. Biological Use Authorization (BUA) and
      3. Radiological Work Authorization (RWA)
  4. Job-Specific and On-the-Job Training (OJT)
    1. OJT is used to supplement general EHS training to provide detailed instructions and controls for performing a specific task or operation.
    2. OJT is training conducted and evaluated in the work environment through interaction between line management and the staff.
    3. Job-specific EHS training can include on-the-job training (OJT), mentoring, hazard-specific training, or training given off site by another facility or organization.
      1. Hazard-specific training explains the specific health and safety hazards of an operation and must include information on health effects, risks, and proper means of protection. For example, the work lead must provide training regarding the safe handling of specific chemicals in connection with the operations that the staff performs.
      2. Off-site training is often necessary to maintain competence in a specialized field, and may be included as part of a staff’s training and development plan.
    4. Written documentation that describes the training and the means to evaluate successful completion should be kept by the line organization that develops and provides the training.
      1. OJT record keeping is a line-management responsibility.
      2. Assistance is available from EHS Training (510) 495-2228 (ext. 2228) to help line management design and deliver job-specific training.
  5. Training Completion
    1. To receive credit for online, hands-on practical, and classroom training, personnel must complete the course and pass any examinations or practical observations.
    2. In some cases, it is possible to receive course credit in lieu of attending a course by passing a proctored written and/or practical examination or a challenge examination.
    3. Contact the EHS Training office for additional information at (510) 495-2228 (ext. 2228) or ehs_training@lbl.gov
  6. EHS Training for Personnel at Off-Site Locations
    1. All LBNL staff working on LBNL projects at off-site locations, including UC Berkeley–controlled spaces, are required to adhere to training requirements as stipulated by the host institution or existing Memorandum of Understanding (MOU).
    2. In the absence of an MOU or host institution requirements, LBNL requirements must be completed.
      1. These requirements can be identified by a work authorization, such as a JHA (Individual Baseline or Task-Specific), a JHA-equivalent system , or a formal authorization.
      2. In some cases, facility or procedure-based safety training specific to the location will fulfill an LBNL training requirement.

Work Process B. EHS Training Database

  1. The EHS Training Database and the Human Resources Information System (HRIS) track and provide reports on EHS Training data. Some job-specific training and OJT are maintained in paper records.
  2. Individual staff and aggregate training reports, including training profiles and division training completion reports, are available through the EHS Training Database. Individual staff can also use the LBNL Onsite Date Warehouse (BRS) to access a training report that includes all training that has been completed. In addition, training records can always be requested from EHS Training by calling (510) 495-2228 (ext. 2228).

Work Process C. Qualifying EHS Instructors

  1. EHS Division line management is responsible for determining the qualifications and the most appropriate candidate for teaching an EHS course.
  2. The candidate must be approved by the EHS Training Program Manager.
  3. New instructors may be asked to work with an EHS Training staff to discuss presentation and teaching strategies that help ensure continuity and quality.
  4. All new instructor-led courses must go through a dry run prior to implementation. This allows EHS Training staff the opportunity to review the training and provide feedback for improvement prior to implementation.

Work Process D. Course Approval Process

  1. All new EHS Training courses, or significant changes and updates to existing courses, must be approved by the EHS Training office.
    1. In some situations (for example, where new training requirements and courses affect large or specific populations at the Laboratory), the EHS Training Program Manager may request additional approval(s).
    2. Approval may be from the EHS Division office or senior Laboratory management, with advice from the Safety Advisory Committee (SAC) and/or various subcommittees.
  2. The following training-approval process (see steps 2.a–d in this work process, below) is required for new or revised institutional courses to identify the purpose and need for training as well as the target population, appropriate training methods, implementation, strategies, resources needed, and the level of review/approval needed:
    1. SME contacts EHS Training staff prior to development of a new course, or significant change(s) to existing courses.
    2. EHS Training staff member is assigned to help the SME design, develop, or update the course.
    3. SME prepares or revises the course and conducts a dry run.
    4. The EHS Training office provides feedback and/or approves the course.
  3. Training content, curriculum development, and instructional design will be a joint effort between EHS Training staff, subject matter experts (SME), and course-content developers or other members of the Laboratory community to ensure the quality and continuity of the EHS Training courses.

 

24.8 Source Requirements

  • 10 CFR 851.25, Worker Safety and Health Program, Training and Information
  • 29 CFR 1910, Occupational Safety and Health Standards
  • 29 CFR 1926, Safety and Health Regulations for Construction
  • 10 CFR 835.103, Occupational Radiation Protection, Education, Training and Skills

24.9 Reference Documents

Document number

Title

Type

02.13.002.001

Health Services

Program

03.02.002.001

Research with Human and Animal Subjects

Program

07.01.002.001

General ES&H Requirements, Responsibilities, and Work Practices

Program

07.01.002.001

EHS Division Charter

Program

07.02.001.001

Job Hazards Analysis

Program

07.02.003.001

Safe Work Authorizations

Program

07.02.004.001

sJHA Process – Subcontractor Job Hazards Analysis

Program

07.03.001.001

Occurrence Reporting

Program

07.03.002.001

Injury and Illness Reporting

Program

07.06.001.001

Emergency Management

Program

07.07.001.001

Elevated Work – Aerial Work Platforms, Ladders, and Scaffolds

Program

07.07.002.001

Asbestos Hazards and Controls

Program

07.07.004.001

Biosafety

Program

07.07.005.001

Chemical Safety Hazards and Controls

Program

07.07.006.001

Confined Spaces

Program

07.07.007.001

Construction Health & Safety

Program

07.07.008.001

Cranes, Hoists, and Rigging Safety

Program

07.07.009.001

Safe Handling of Cryogenic Liquids

Program

07.08.001.001

Radiation Safety

Program

07.07.011.001

Electrical Safety

Program

07.07.012.001

Ergonomics

Program

07.07.014.001

Fall Protection Program

Program

07.07.015.001

Gas Safety

Program

07.07.018.001

Laser Safety

Program

07.07.019.001

Lead Hazards and Controls

Program

07.07.020.001

Lockout/Tagout Program

Program

07.07.021.001

Machine Safeguarding – Shop and Machine Safety

Program

07.07.022.001

Noise Hazard Assessment and Control

Program

07.07.023.001

Non-ionizing Radiation

Program

07.07.024.001

Personal Protective Equipment (PPE)

Program

07.07.025.001

Forklifts and Other Powered Industrial Trucks

Program

07.09.006.001

Spill Prevention, Control, and Countermeasures Program

Program

07.07.026.001

Pressure Safety and Cryogenics

Program

07.09.007.001

Storm Water Pollution Prevention

Program

07.07.031.001

Welding, Joining, and Thermal Cutting Safety

Program

07.10.001.001

Transporting and Shipping Hazardous Materials

Program

07.10.002.001

Waste Management

Program

07.07.032.001

Respiratory Protection

Program

07.11.001.001

Fire Prevention and Protection

Program

 

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