Chapter
24Approved by Jack
Salazar
Revised 12/2006
24.1 Policy
24.2 Objectives
24.3 Organization
24.4 Requirements
24.4.1 General
24.4.2 Identifying EH&S Training Requirements
24.4.3 New Employees and Participating Visitors
24.4.4 Retraining and Recertification
24.4.5 Completion of Training
24.4.6 EH&S Training for Personnel at Off-Site Locations
24.4.7 Waivers or Credit by Equivalence for EH&S Training Requirements
24.4.8 Job-Specific Training
24.5.1 EH&S Training Database
24.5.2 Job Hazard Questionnaire
24.8.1 Employees / Participating Guests / Visitors
24.8.2 Supervisors
24.8.3 Matrix Supervisors
24.8.4 Division Management
24.8.5 EH&S Training
24.8.6 Safety Review Committee (SRC)
24.8.7 EH&S Course Instructors
Appendix A. On-the-Job Training Form
Appendix B. EH&S Training Needs Analysis Form
Appendix C. EH&S Training Course Outline Template
Appendix D. EH&S Training Course Syllabus Template
Appendix E. EH&S Training Instructor Qualifications and Criteria
| NOTE: | |
. . . . . |
Denotes a new section. |
| Denotes the beginning of changed text within a section. | |
| Denotes the end of changed text within a section. | |
____________________
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 required work practices and procedures. The LBNL EH&S Training Program has been designed to assist line management to comply with all of the applicable requirements of the Department of Energy, and all other federal, state, and local regulatory agencies.
The objectives of the EH&S Training Program are:
The EH&S Training Program reports through the Industrial
Hygiene Group Leader to the EH&S Division Director. The EH&S Training
Program is a collaborative endeavor of the EH&S Division and line
management. Line management provides On-the-Job Training (OJT), training that
is specific to the work conducted in its actual environment, and ensures that
training requirements are met. The EH&S Division provides training courses
to meet regulatory and Laboratory requirements, and applicable best practices. Maintenance of the Laboratory-wide training
database system is shared by the EH&S Division, IT Division, and all other
organizations that provide training. EH&S training requirements should be
included as part of each employee’s Performance Review and Development Plan
(PRD).
The EH&S Division publicizes its Training Program and courses
electronically in Today at Berkeley Lab, during New Employee Orientation, and
on the EH&S Training Web site at http://www.lbl.gov/ehs/training/index.shtml.
A complete list and description of courses and courses scheduled for the
following three months can also be found on the EH&S Training Web site at http://www.lbl.gov/ehs/training/courses_code/index.shtml.
Completion of the required EH&S training courses will provide
greater assurance that all LBNL personnel know the hazards associated with
their jobs, understand the possible health and safety effects of exposure to
those hazards, and know how to perform operations safely and in accordance with
all environmental protection requirements.
Training requirements originate in DOE orders, DOE regulations (10
Personnel must complete all pertinent EH&S training requirements before or at the time of initial assignment to a job involving exposure to a hazard, as referenced in their JHQ training profile, unless specified elsewhere in other policies. In the absence of completing this training, the employee, participating guest, student, or visitor is allowed to work for up to 90 calendar days (upon beginning work at the Lab or upon initiating work that introduces new hazards) as authorized by his/her line manager, based on such factors as the nature of the work to be performed, the worker’s previous education and experience with the work to be undertaken, and the specific on-the-job training information transferred to the worker. On-the-Job training for the experimental procedures allowed prior to obtaining appropriate EH&S training must be documented in accordance with the guidance contained in Appendix A of this Chapter, and must be retained as evidence of completion. The 90-day grace period for acquiring EH&S training does not apply to training requirements dictated by formal authorizations (e.g., Radiation Work Authorizations, Biological Use Authorizations, Activity Hazard Documents).
A list of EH&S training is available on the EH&S Training Web
site at http://www.lbl.gov/ehs/training/courses_code/index.shtml.
Some training requires a medical examination and approval before certification
is issued. Examples of training courses that require a medical examination are Crane/Hoist Operator Training, Powered Industrial
Truck Operator Training, and Half- and Full-Face Mask Respirator Training.
Contact EH&S Training (x2228) for more information on training
requirements. Contact Health Services to make an appointment for medical examinations.
EH&S Training requirements are identified through the completion of the Job Hazard Questionnaire (JHQ) and/or through training group modules within the EH&S Training Database or the Human Resources Information System (HRIS).
The Job Hazard Questionnaire can be completed on the EH&S Training Web site at
https://ehswprod.lbl.gov/EHSTraining/Jhq/EHSLogin.asp
As needed, the LBNL division or line manager will establish the EH&S training groups, in either the EH&S Training Database or HRIS, and evaluate the group requirements based upon specific training needs. EH&S Training can provide technical consultation upon request to ensure the training groups are current and meet necessary compliance with DOE, other regulatory, and Laboratory standards.
Supervisors are responsible for ensuring the identification of EH&S training requirements for staff, participating guests, and visitors under their direction, as appropriate for the work expected, and the need for training when safety and health information or a change in workplace conditions indicates a new or increased hazard exist.
Alternative EH&S Training programs and
requirements have been established at user facilities or other divisions (for
example, the Advanced Light Source, Molecular Foundry, Production Genomics
Facility) that are reviewed by the EH&S Training Program.
All new employees, guests, students, visitors, and contractors must receive basic EH&S orientation information prior to commencing work at LBNL. This information may include General Employee Radiological Training at Berkeley Lab (PUB-3152); Integrated Safety Management for Employees, Contractors, Participating Guests, and Visitors (PUB-811); Environment, Health, and Safety Handbook for Subcontractors and Visitors (PUB-708); and, in some cases, being familiar with division-specific material.
Recognized
site-specific orientation training for guests and visitors at user facilities
(such as the Advanced Light Source and the Molecular Foundry) is sufficient
and deemed as equivalent to institutional orientation programs for
the guest (user) population only.
|
Employees, Guests, Students, Contractors with appointments of more than 30 calendar days |
|
|
Employees, Guests, Students, Contractors with appointments of 30 calendar days or less |
|
| Occasional Guests, Students, Contractors |
|
All new employees, guests, students, contractors, and visitors with appointments of more than 30 calendar days must attend the course EHS0010 (Introduction to ES&H at LBNL) within the first month after starting work at LBNL. This course provides general safety orientation and training, including Introduction to EH&S at LBNL (EHS0010), Hazard Communication for Employees (EHS0392), and General Employee Radiation Training (EHS 0405).
Additional training and certification are required for work involving special hazards. These training courses are identified for each individual by completing the Job Hazard Questionnaire. The Job Hazard Questionnaire is available online (via the EH&S Home Page-Training Section, or directly at https://ehswprod.lbl.gov/EHSTraining/Jhq/EHSLogin.asp) for completion, submittal, and automated updates of the LBNL training database.
New employees and participating visitors who will be at LBNL for more than 30 calendar days must complete the Job Hazard Questionnaire within the first month of employment. The EH&S Training Database will then generate an individualized Training Profile identifying EH&S training requirements and recommendations.
For more information on specific EH&S training, please refer to the associated chapters in this manual, such as Lasers (Chapter 16), Lockout/Tagout (Chapter 18), Radiation Safety (Chapter 21), or Industrial Hygiene (Chapter 4). Supervisors, employees, and Division Safety Coordinators will receive an email upon completion of a JHQ by a staff member. Supervisors are to review the JHQ responses accessible from this email for accuracy, and update as appropriate.
Regulations and policy may require periodic retraining and recertification. Examples are the forklift and crane training program, which require recertification every three years, and the laser safety training program, which also requires retraining every three years. The individual’s Training Profile will indicate when retraining is due, and if it is overdue. Individuals will receive an automated email from the EH&S Training Database indicating expected or actual expiration of training compliance 60 days prior to the expiration date, and every month subsequently until the requirement has been satisfied or the Job Hazard Questionnaire has been updated. This email is copied to the individual’s supervisor and Division Safety Coordinator to ensure the proper notifications have been made.
Personnel must attend the entire training course and pass any examinations to receive credit. In some cases, such as Radiation Safety Fundamentals (EHS0400), it is possible to take a proctored written and/or practical examination, or Challenge Examination, in lieu of course attendance and receive course credit by successfully completing the exam. Consult with course instructors or EH&S Training about this option. Many EH&S training courses that are available online (http://www.lbl.gov/ehs/training/courses_online/index.shtml) contain examinations to validate the successful completion of a course prior to the assignment of credit.
In the event that a trainee fails a written or practical examination, the instructor should provide remedial instruction, and the trainee must repeat the examination.
All LBNL employees working at off-site locations, including UC Berkeley–controlled spaces, are required to adhere to EH&S training requirements as stipulated by the host institution or existing Memorandum of Understanding (MOU). In the absence of an MOU or requirements, or in the event training requirements are not deemed equivalent, LBNL requirements must be completed. These requirements can be identified by completing the Job Hazard Questionnaire. In some cases, facility- or procedure-based safety training specific to the location will fulfill an LBNL training requirement. For example, training connected with hazardous waste handling or confined space entry, which covers specific procedures for an off-site facility, may be provided by the institution controlling the work space. Similarly, radiation safety training requirements may be site-specific, depending on whether the facility is DOE- or University-controlled.
Under special circumstances, a waiver or credit by equivalence may be granted to a person who is normally required to complete an LBNL EH&S training course indicated on a Training Profile. For example, line management may exercise its judgment in waiving a training requirement for staff in a particular area where significant experience and proficiency is evident. The EH&S Training Program recognizes certain training received from other DOE facilities or related institutions (e.g., UC Berkeley) and can offer credit by means of equivalence upon receipt of proper training documentation. Contact the EH&S Training Program (x2228) for more information.
Job-specific EH&S training can include on-the-job training (OJT), formal mentoring, hazard-specific training, or training given off site by another facility or organization.
OJT is formal training conducted and evaluated in the work environment through interaction between line management and the employee. It is designed to teach the employee how to perform a task or operation and is often used to supplement general EH&S training. For example, once the employee has completed Training for Hazardous Waste Generators (EHS 604), the supervisor should then train the employee about the location of the local Satellite Accumulation Area and the procedures for handling hazardous waste in his/her laboratory or shop.
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 supervisor must provide
training regarding the safe handling of specific chemicals in connection with
the operations that the employee performs. Off-site training is often necessary
to maintain competence in a specialized field, and may be included as part of
an employee’s training and development plan.
It is highly recommended that job-specific training be planned,
delivered, and documented in a manner similar to that of all other EH&S
training. 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. See Appendix A for
a sample On-the-Job Training (OJT) documentation form. OJT record keeping is a
line-management responsibility.
The requirements for identifying job-specific training may be included
in the Job Hazard Questionnaire, in a section containing division- or
facility-specific questions or as defined by a specific division’s JHQ. If
these training requirements are not included in the Job Hazard Questionnaire or
within division policy, then line management must develop other methods to
identify personnel needing the training.
Educational materials, such as videos, pamphlets, and fact sheets
on specific hazards, as well as technical assistance, are available from
EH&S Training (x2228) to help line management design and deliver
job-specific training.
24.5 EH&S Training Database
Systems
All EH&S training must be documented and retained in a readily
accessible manner. The EH&S Training Database (JHQ) system and the Human
Resource Information System (HRIS) provide a centralized means to track and
provide real-time reports on EH&S Training data. Data concerning courses
contained in HRIS include course name, course code, instructor name(s), length
of the course, retraining or recertification cycle, method of delivery, and
class date. EH&S Training data associated with staff accessible via the JHQ
system include the participant’s name, employee number, and courses and/or
examinations successfully completed. If the student fails to pass an
examination or course competencies, the student does not receive credit for the
course until all competency measures are passed.
Individual employee and aggregate training reports, including
Training Profiles and Division training completion reports, are available
through the EH&S Training Database (https://ehswprod.lbl.gov/EHSTraining/Jhq/EHSLogin.asp)
and the Employee Self-Service Web site (https://hris.lbl.gov/self_service/training/). In addition, training records can always be
requested from EH&S. Users with an
LDAP account may access the EH&S Training Database and generate training
reports by using the menu options.
24.5.2 Job Hazard Questionnaire
All personnel, including managers, staff,
and participating visitors working at LBNL for more than 30 calendar days,
are required to complete the Job Hazard Questionnaire (JHQ) to identify pertinent
training requirements. New personnel must complete the JHQ within the first
month after starting work at LBNL. A Web version of the JHQ is available
for data entry via the Job Hazard Questionnaire: https://ehswprod.lbl.gov/EHSTraining/Jhq/EHSLogin.asp.
The JHQ is a tool to help employees, managers, and supervisors
identify which EH&S training requirements must be satisfied. The answers on
the questionnaire lead to a series of training requirements/recommendations
(known as the Training Profile) based on the work environment and hazards that
may be encountered by an employee.
Managers and supervisors are strongly encouraged to complete the
JHQ along with their staff or, at a minimum, review the completed JHQs of all
personnel whom they supervise. If the JHQ is completed online, the review
process will begin when an email notification to the supervisor is made
following each update or completion of a JHQ by a staff member. If adjustments to the JHQ are identified
during the review process, it is the responsibility of the supervisor and
matrix supervisor, as applicable, to ensure the JHQ responses are updated. For those employees who are matrixed to other
divisions, the matrix supervisor must also review the information. Line management is responsible for obtaining
and retaining information to support any changes or modifications to JHQs. EH&S technical staff is available to
offer assistance.
Tracking of training requirements is the responsibility of line
management. Each employee’s JHQ must be reviewed and updated annually, as
appropriate. In any event, the questionnaire will be updated on a timely basis
when the nature of an employee's work environment and hazards change (i.e.,
significant change).
The divisions may use the JHQ to help personnel identify required
or recommended job-specific training courses developed by line management. To
facilitate this, a set of division-specific questions or a division-specific
JHQ can be added. Contact the EH&S Training Program, ext 7524, for
assistance in developing job-specific questions or division-specific JHQs.
Once the data has been entered, the Training Profile is generated. The Training Profile shows EH&S training requirements and recommendations. If a requirement has been satisfied, the Training Profile shows when it was completed, and when retraining or recertification is necessary. The Training Profile is a tool to enable line management to track completion of EH&S training requirements. The Training Profile is available as a report choice in the EHS Training Database at https://ehswprod.lbl.gov/EHSTraining/Jhq/EHSLogin.asp.
In addition to the JHQ, EH&S training requirements can be
identified via the Group Training Modules in either the EH&S Training
Database or the Human Resource Information System (HRIS). These group requirements are owned and maintained
by the given Division/Group, and are reviewed annually, with the assistance of
the EH&S Training Program (as necessary), to ensure that requirements
reflect current policy regulations and standards.
The
records in the EH&S Training Database (e.g., completed JHQs and Training
Profiles) constitute the official training documentation. Divisions
have the option of maintaining hard-copy EH&S training records as desired
(e.g., signed and completed JHQs) in division files.
The EH&S Division has developed a procedure for approving and
evaluating EH&S training courses, as well as a policy on instructor
qualifications.
All new EH&S training courses, changes, and updates to
existing courses must be approved by the EH&S Training Office prior to
implementation. In some situations (where new training requirements and courses
affect large or specific populations at the Laboratory), additional approval
from the EH&S Division Office, senior Laboratory management, the LBNL
Safety Review Committee (SRC), and/or various subcommittees may also need to be
obtained.
A Training Needs Analysis (see Appendix B) must be completed by the
requestor of a new course and evaluated by the EH&S Training Program, and
other entities (EH&S Management, Lab Management, SRC, Subcommittees) where
necessary to verify the need for such training. The
Training Needs Analysis will identify the need for training or another educational
method, the purpose/requirement of the course, the target population, method
of delivery, implementation strategy, costs, resources needed, and what level
of review/approval will be necessary.
Training content, curriculum development, and instructional design
will be a joint effort between EH&S Training staff, subject matter experts,
and course content developers or other members of the Laboratory community to
ensure the quality and continuity of the EH&S Training Courses.
Required documents needed for all new courses include:
Exam or learner competency measures
All documents must be submitted by course content developers, and approved by an EH&S Training staff prior to any dry-run, pilot, and/or classroom/Web-based training. This information, along with other written material relevant to the course, can be provided to senior Laboratory management and/or the Safety Review Committee for review.
The procedure for new course review and implementation is outlined
in the table below:
|
New
Course Development |
Participants |
|
Submittal of supporting course documents: Training Needs Analysis, Syllabus, Outline, Course description, Course training materials. |
Instructor/course owner submits documents to the EH&S Training Office |
|
Course Content Review |
EH&S Training Staff |
|
Course Content Dry Run |
EH&S Training Staff and/or selected members from within EH&S or Division Safety Coordinators, or other Laboratory employees |
|
Course Pilot (Final Dry Run) |
EH&S Training staff and selected pilot group |
|
Final Approvals |
EH&S Training Office (if applicable, EH&S Senior Management, Safety Review Committee, and/or Laboratory Directorate may be necessary) |
|
Course Implementation |
EH&S Training Staff and Instructor/Course Owner |
Final implementation of a new course will occur when all necessary
materials have been submitted, and reviews and approvals have been completed
and obtained. New EH&S Training courses will be identified and tracked in
the Job Hazard Questionnaire.
24.7 EH&S Instructor Competency
All EH&S Training Instructors will need to verify and submit
instructor certifications and qualifications to the EH&S Training Program.
It is the responsibility of the Instructor to maintain current certifications
and keep their Instructor Profile in the EH&S Training Office up to date. When
certification has expired or the instructor qualifications no longer meet the
program needs, the individual will cease instruction, and an alternative
instructor will be identified by EH&S group leaders or specific program
managers.
New course instructors must participate and successfully complete
a 10-hour “Train the Trainer” session prior to or simultaneous to the delivery of
the course. Contact EH&S Training (x7524) to initiate this program.
In addition, all course instructors must:
Failure to comply with the instructor qualifications and EH&S
Training Instructor Qualifications and Criteria (see Appendix
E) can lead to
the removal of an instructor from training responsibilities. This will be a
shared determination between the EH&S Training Program Manager, EH&S
Group Leader, Specific Program Manager, and EH&S Management.
The EH&S Training Program is a collaborative effort between the EH&S Division and the line-management organizations of LBNL. Individuals and groups must implement the following aspects of the EH&S Training Program:
Adhere to stipulations noted in Appendix E.
_____________________
<< Chapter 23 || Table of Contents