Chapter 6
SAFE WORK AUTHORIZATIONS

APPENDIX B
Formal Authorizations: Work Requiring EH&S Participation in or Concurrence with Hazard Analysis and Work Authorizations

Approved by John Heim
Revised 02/13

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

 


Hazard/Concern


Trigger Level

Formal Authorization Type

Additional Information

Animal research (vertebrate)

Any research involving vertebrate animals or vertebrate animal tissue

Approval by Animal Welfare and Research Committee

Animal Welfare and Regulatory Committee

PUB-3000, Chapter 22

Biological material See Chapter 26 (Biosafety) of the PUB-3000 for details.

Potential triggers for review include: Work with Risk Group 2 materials, use of Biosafety Level 2 containment for safety, handling OSHA Bloodborne Pathogen materials, and operations that require a regulatory registration or permit  (e.g., work with  human pathogens, human blood or some body fluids,  human tissues, human cells, or select agents/toxins)
Biological Use Authorization approved by the Institutional Biosafety Committee (IBC).

Review for human subjects protections (see "Human Research" below) for human blood, tissues, and cells.
PUB-3000, Chapter 26 and Chapter 20

Biosafety Program

EH&S Biosafety or Medical Waste Subject Matter Experts

CDC-NIH Biosafety in Microbiological and Biomedical Laboratories

NIH Guidelines for Research Involving Recombinant DNA Molecules

10 CFR 851- Worker Safety and Health Program: 851.21, 851.23(3), 851.24, Appendix A- Section 7 Biological Safety

29 CFR 1910.1030 - OSHA Bloodborne Pathogens Standard

Select agent & toxin regulations:  CDC (42 CFR 73) and USDA (7 CFR 331 & 9 CFR 121)

PUB-3095 (Medical and Biohazardous Waste Generator’s Guide)

Chemicals

Routine shop and lab; reproductive toxins; acutely toxic; peroxide-forming chemicals

Formal Authorization is not required; work may proceed under supervisor authorization/line management authorization

Chem Hygiene and Safety Plan,

CHSP — Hazard Evaluation

Reactive (e.g., alkali metals); pyrophoric; possessing lethal or incapacitating toxicity (also see Gases, below), glovebox is required for safety, or failure of other primary engineering controls would result in a significant exposure or safety hazard.

Activity Hazard Document

PUB 3000, Chapter 6

CHSP: Hazards Review

Contact user division’s EH&S Industrial Hygienist

Chemicals that are secondary explosives, such as triaminotrinitrobenzene (TATB), and cyclotrimethylene-trinitramine (RDX). 

Quantities ≤10 mg require no special precautions other than following the requirements in the CHSP.  Divisions shall do a risk assessment in consultation with an EH&S Division Subject Matter Expert for use of quantities >10 mg. 

The following activities are prohibited: Use of primary explosives. Development, testing, processing, blending, pressing and machining of explosives or assemblies containing explosives.

Operations that pose an explosion hazard, a metal fragment hazard or a glass fragment hazard.
Division determines if an AHD is needed on the basis of the risk assessment performed. Activities conducted by  visiting scientists shall be done in accordance with the CHSP. CHSP
Chemicals within equipment or instruments

When normal operation or reasonably foreseeable mishandling may result in a loss of control (such as a spill) that could pose an exposure hazard, cause extensive area contamination, or result in environmental damage.
Divisions shall do a risk assessment in consultation with an EH&S Division Subject Matter Expert. Division determines if a formal authorization (e.g., Activity Hazard Document) is needed on the basis of the risk assessment performed. PUB-3000, Chapter 6

CHSP

Contact user division’s EH&S Division Liaison.

Confined space entry

Permit-required confined space

Specialized training, entry permit authorized by EH&S Division industrial hygienist and/or trained permit writer

PUB-3000 Chapter 4.10

Confined Space Program

29 CFR 1910.146 — Confined Spaces

Construction

Over 1 acre in size

SWRCB General Stormwater Construction Permit

Contact EH&S Division, Environmental Services Group

Cryogenics usage

Stored energy greater than 75,000 ft-lb

Engineering Safety Note; Activity Hazard Document

PUB-3000, Chapter 6

PUB-3000, Chapter 7

Drugs

Radioactive, used in human subjects

Approval for Human Subjects (see "Human Research" below)

Radiological Work Authorization

May require approval by LBNL Radioactive Drug Research Committee

PUB-3000, Chapter 22

FDA, Title 21, Part 361, Radioactive Drugs for Certain Research Uses

 

Electrical hazardous exposure, including testing, measuring, and LOTO verification. Potential exposure to voltages equal to or greater than 50 V AC or DC, and currents equal to or greater than 5 mA

Energized Electrical Work Permit (EEWP) for work where there is hazardous electrical exposure and when the following circumstances DO NOT exist:

  • An Electrical AHD, or approved equivalent authorization, is in place for testing (including LOTO verification), troubleshooting, or inspection work where there is hazardous electrical exposure. See Chapter 8 for a description of the equivalency process.

NOTE: These requirements are being phased-in. Line management must initiate an EEWP, Electrical AHD, or approved Electrical AHD equivalent by April 1, 2010, for all identified work having such exposures.

PUB-3000, Chapter 6

PUB-3000, Chapter 18

29 CFR 1910.333 — Selection and Use of Work Practices
Explosives.  See "Chemicals that are secondary explosives," above.      

Gases, compressed (see also “Pressure” below)

 

Stored energy greater than 75,000 ft-lb (not including cylinders), pressure > 150 psig (gas) or 1500 psig (liquid)

Engineering Safety Note; Activity Hazard Document

PUB-3000, Chapter 7

Flammable >400 cubic feet per room

Activity Hazard Document

PUB-3000, Chapter 6

29 CFR 1910.103 — Hydrogen

Pyrophoric, reactive, health hazard

Note: There are certain exceptions to these requirements for small cylinders of carbon monoxide. Contact EH&S for details.

Activity Hazard Document

PUB-3000, Chapter 6

PUB-3000, Chapter 13

Hot work/open flame

Welding, soldering (lab-type "Bunsen" burner not included)

Hot Work/Open Flame Permit from LBNL Fire Department

PUB-3000, Chapter 12

NFPA

29 CFR 1910.252 – Fire Watchers

Human research

Any

Approvals by LBNL Human Subjects Committee and UC Berkeley Committee for Protection of Human Subjects

PUB-3000, Chapter 22

45 CFR 46 - Protection of Human Subjects, the Common Rule

10 CFR Part 745 - Protection of Human Subjects

Laser

Class 3b or 4

Laser Activity Hazard Document

PUB-3000, Chapter 16

PUB-3000, Chapter 16 Appendix B includes laser alignment AHD requirements.

Lifting/rigging

High consequence/ high value

Custom built or modified lifting fixtures

Written procedure approved by Facilities and EH&S

Engineering Safety Notes for custom lifting fixtures

Specified inspections, tests and re-tests for lifting fixtures

PUB-3000, Chapter 5 – Material Handling and Storage

29 CFR 1910 Subpart N — Materials Handling and Storage

Pressure

Noncommercial or modified pressure vessel

Stored energy greater than 75,000 ft-lb (not including gas cylinders), pressure > 150 psig (gas) or 1500 psig (liquid)

Radioactive contents

Engineering Safety Note,

Activity Hazard Document

Radiological Work Authorization

 

 

PUB-3000, Chapter 7

29 CFR 1915.172 – Portable Air Receivers and Other Unfired Pressure Vessels

 

Radiation or Radioactive Materials

Unsealed Source

Radiological Work Authorization or Radiological Work Permit

PUB 3000 – Chapter 21

10 CFR 835

Contact EH&S Division , Radiation Protection Group

Sealed Source

Sealed Source Authorization

or

Generally Licensed Source Authorization 

PUB 3000 – Chapter 21

10 CFR 835

Contact EH&S Division, Radiation Protection Group

Ionizing produced by X-ray machine

X-Ray Authorization

PUB-3000 – Chapter 21

10 CFR 835

Contact EH&S Division, Radiation Protection Group

Vacuum

Stored energy greater than 75,000 ft-lb

Engineering Safety Note, Activity Hazard Document

PUB-3000, Chapter 6

PUB-3000, Chapter 7

Waste, generation or treatment of

Hazardous, radioactive or mixed

Up to 55
gallons, less than 270 days

Generation only

Specialized training

Guidlines for Generators to Meet HWHF Requirements for Hazardous, Radioactive, and Mixed Wastes at Berkeley Lab (PUB-3092)

SAA custodian

Specialized training, Satellite Accumulation Area

Greater than 55 gallons, less than 90 days

Specialized training, Waste Accumulation Area

Treatment at point of generation

Bench top treatment authorization

Contact EH&S Division, Waste Management generator assistant

Medical or biological

Specialized training

Contact EH&S Division, Waste Management

Working Alone

Work Practice

Workers at LBNL are not allowed to work alone when the mitigated hazards associated with their work can incapacitate them such that they cannot self-rescue or activate emergency services.

Many of the Hazards/Concerns listed in this table can Trigger this restriction.
Division/work lead determines if a Working Alone restriction should be included in a formal authorization (e.g., Activity Hazard Document) that has been determined to be needed on the basis of the risk assessment performed. \Working Alone Policy, Requirements and Policies Manual

 

_____________________

<< Return to Chapter 6 || Table of Contents