Chapter 24
ENVIRONMENT, HEALTH, AND SAFETY (EH&S) TRAINING

Contents

Approved by Don Lucas
Revised 07/09


24.1 Organization
24.2 Policy

24.3 Requirements

24.3.1 General
24.3.2 Identifying EH&S Training Requirements
24.3.3 Completion of Training
 24.3.4 EH&S Training for Personnel at Off-Site Locations
24.3.5 Waivers or Credit by Equivalence for EH&S Training Requirements
24.3.6 Job-Specific Training

24.4 EH&S Training Database
24.5 EH&S Instructor and Course Approval

24.6 Responsible Parties

24.6.1 Work Lead
24.6.2 EH&S Training Group
24.6.3 Safety Advisory Committee (SAC)

24.7 Standards
24.8 Related PUB-3000 Chapters
24.9 References


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

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24.1 Organization

The EH&S Training Program is a collaborative endeavor of the EH&S Division and line management. The EH&S Division provides training courses to meet regulatory and Laboratory requirements, and applicable best practices. 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. Maintenance of the Laboratory-wide training database system is shared by the EH&S Division, IT Division, and all other organizations that provide training.

24.2 Policy

It is LBNL policy, and required by federal law, that all staff, participating guests, 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 EH&S Training Program assists line management to comply with all of the applicable requirements of the Department of Energy, and all other federal, state, and local regulatory agencies.

24.3 Requirements

24.3.1 General

The purpose of EH&S required training is to help ensure that all LBNL personnel are aware of the hazards associated with their jobs, understand the health and safety effects of exposure to those hazards, know how to protect themselves and those around them, and know how to perform operations safely and in accordance with all environmental protection requirements.

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 covering specific hazards. These 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. Specific training requirements are identified in the PUB-3000 Chapter that addresses a given subject area. LBNL uses its Job Hazards Analysis (JHA) and other work authorization programs as means for identifying, analyzing, and controlling work, which includes identification of required training.

24.3.2 Identifying EH&S Training Requirements

Work Leads are responsible for analyzing work, including identifying EH&S training requirements, for staff (including participating guests and students) under their direction.  EH&S Training can provide assistance with identifying training requirements using the Job Hazards Analysis and formal work authorizations.  Examples of formal work authorizations include Activity Hazard Documents (AHD), Biological Use Authorization (BUA), and Radiological Work Authorization (RWA). For more information on the Jobs Hazards Analysis (JHA) process refer to PUB-3000, Chapter 32. The Job Hazards Analysis can be accessed at the following web address: https://ehswprod.lbl.gov/ehstraining/jha/login.aspx

24.3.3 Completion of Training

To receive credit for online and classroom training, personnel must complete the course and pass any examinations. 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 challenge examination. Contact the Training Group for additional information (x2228).

24.3.4 EH&S Training for Personnel at Off-Site Locations

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). In the absence of an MOU or host institution requirements, LBNL requirements must be completed.  These requirements can be identified by a work authorization, such as a JHA (Individual Baseline or Task-Specific), JHA-equivalent system, or formal authorization. In some cases, facility or procedure-based safety training specific to the location will fulfill an LBNL training requirement.

24.3.5 Waivers or Credit by Equivalence for EH&S Training Requirements

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; or
  3. The individual works solely at the UCB campus and this work is governed by UCB EH&S requirements.

The EH&S Training Program Manager (or designee) may grant training credit by equivalence. Certain training received from other DOE facilities or related institutions (e.g., UC Berkeley) is recognized as equivalent upon receipt of proper training documentation. Contact the EH&S Training Program (x2228) for more information.

24.3.6 Job-Specific Training

Job-specific EH&S training can include on-the-job training (OJT), mentoring, hazard-specific training, or training given off site by another facility or organization. OJT is training conducted and evaluated in the work environment through interaction between line management and the staff.  It is used to supplement general EH&S training to provide detailed instructions and controls for performing a specific task or operation.

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. 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.

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. OJT record keeping is a line management responsibility. Assistance is available from EH&S Training (x2228) to help line management design and deliver job-specific training.

24.4 EH&S Training Database

The EH&S Training Database and the Human Resource Information System (HRIS) track and provide reports on EH&S Training data.  Some job-specific training is maintained in paper records.

Individual staff and aggregate training reports, including Training Profiles and Division training completion reports, are available through the EH&S Training Database (ttps://ehswprod.lbl.gov/ehstraining/jha/login.aspx) and the Staff Self-Service Web site (https://hris.lbl.gov/self_service/training/).  In addition, training records can always be requested from EH&S Training (x2228). 

24.5 EH&S Instructor and Course Approval

EH&S Division line management is responsible for determining the qualifications and the most appropriate candidate for teaching an EH&S course. This recommendation must be approved by the EH&S Training Program Manager. New instructors may be asked to work with an EH&S Training Specialist to discuss presentation and teaching strategies that help ensure continuity and quality. In addition, all new instructor-led courses must go through a dry-run prior to implementation. This allows EH&S training staff the opportunity to review the training and provide feedback for improvement prior to implementation.

All new EH&S training courses, or significant changes and updates to existing courses must be approved by the EH&S Training Office.  In some situations (where new training requirements and courses affect large or specific populations at the Laboratory), the EH&S Training Program Manager may request additional approval(s). Approval may be from the EH&S Division Office or Senior Laboratory Management, with advice from the Safety Advisory Committee (SAC), and/or various subcommittees.

The training approval process for institutional courses identifies the purpose and need for training as well as the target population, appropriate training methods, implementation, strategies, resources needed and what level of review/approval will be needed.

Training content, curriculum development, and instructional design will be a joint effort between EH&S 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 EH&S Training Courses.

Required steps for new courses or change(s) to existing courses include:

  1. SME contacts EH&S Training Staff prior to development of a new course, or significant change(s) to existing courses.

  2. Training Office Instructional Designer assigned to work with the SME(s) to design, develop or update the training.

  3. SME prepares or revises course and conducts dry-run.

  4. EH&S Training Office provides feedback and/or approves course.

24.6 Responsible Parties

24.6.1 Work Lead

24.6.2 EH&S Training Group

24.6.3 Safety Advisory Committee (SAC)

24.7 Standards

24.8 Related PUB-3000 Chapters

24.9 References

Chemical Hygiene and Safety Plan, PUB-5341, Lawrence Berkeley National Laboratory, latest revision

Operating and Quality Management Plan, PUB-3111, LBNL/Environment, Health and Safety Division Function Notebook

Biosafety Program and Manual, LBNL

Radiation Protection Program, LBNL

 

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