Chapter 6
SAFE WORK AUTHORIZATIONS
APPENDIX
D. Activity Hazard Document (AHD) Process
Approved by John Seabury
Revised 07/11
The Activity Hazard
Document (AHD) is a general-form tool and authorization used to document
the analysis and controls for hazards that do not have specific analytical
tools prescribed elsewhere. In general, if a hazard exceeds the trigger
level specified in Appendix B, or
if a hazard or combination of hazards in an activity exceeds those authorized
by the applicable Line Management Authorization,an Activity Hazard
Document must be prepared unless the hazard has already been included in
a broader, facility-based analysis.
LBNL manages AHDs through an electronic
management system. Many divisions have internal procedures for preparation
and review of AHDs. Work leaders must consult with their division safety
coordinator/administrator to determine what his or her division’s
procedures include. Regardless of a division’s internal procedures,
all actions (initial authorization, reauthorization, updating user list,
etc.) must take place within the electronic management system. The version
of the AHD in the electronic management system is the version of record.*
The
steps below provide an outline of how to prepare and reauthorize
AHDs in
the absence of any internal division procedures. Division internal procedures
for processing AHDs must include the essential elements
of the process provided here (thorough analysis of hazards, concurrent division
and EH&S authorization, annual review and reauthorization by the division,
and review by EH&S).
The initial authorization of the AHD proceeds as follows:
- At
the division level, the principal investigator determines that an AHD is
required by reviewing the planned work against the trigger levels in Appendix
B. If there is any question as to the applicability of a certain situation
to this appendix,
or for consideration of other or combined hazards, the EH&S
division liaison should be consulted.
- The principal investigator prepares the AHD submittal using the template
given in the electronic
management system. He/she may designate a separate individual as “work
leader” for purposes of supplying detail, but the principal investigator
retains responsibility for the AHD. The tutorial and “Help” functions
within the system explain how to use it; questions can be directed to the AHD
coordinator.
- The data management system assigns an AHD identification number and appoints
a review team leader who will recruit additional team members to properly
evaluate the work. Generally, the review team leader will be the division
liaison for that division. At a minimum, the review team should include
the EH&S subject
matter expert for the predominant technical areas included in the work
process, and representatives from all EH&S disciplines.1 The
review team leader may request that resources outside of EH&S be used
to evaluate the planned work. If so, this request should be reviewed with
the EH&S AHD coordinator.
- The review team reviews the work with the principal investigator and/or
work leader.
- The review team makes recommendations to the principal investigator/work
leader, if necessary, for incorporation into the AHD. The review team lead,
principal investigator, and work leader may directly edit the text in the
electronic system.
- The principal investigator releases the final AHD for formal review. There
may be several review/comment cycles depending upon the complexity of the
comments and revisions, and these are documented within the data management
system. Upon agreement that the AHD is acceptable, the review team leader
concludes the review cycle by releasing the AHD for electronic signatures.2
- Work may begin after all required authorization signatures have been obtained.3
Users may not perform work until they have completed their training and have
signed the AHD.
- A printed copy of the fully authorized AHD should be prominently posted
in the work area; however, the electronic version is the version of record.
- The principal investigator and work leader are responsible for assuring
that work proceeds in accordance with hazard controls specified.
Reauthorization of an AHD proceeds in accordance with division procedures
(consult the division safety coordinator/administrator), or proceeds as follows:
- As the reauthorization date approaches, the principal investigator and
work leader review the AHD and the work process.
- If there have been significant changes in the processes or hazards,4 then
the AHD may be modified and submitted for review as outlined above.
An AHD may be internally reauthorized up to 3 years after initial or subsequent "full authorization". After 3 years, an AHD requires a "full authorization" which involves review and concurrence from the EH&S Division as outlined above.
- If there have been no significant changes in the processes or hazards,
the AHD may be submitted for “internal review” and reauthorization
through the electronic management system.
- Work may not proceed in the absence of an authorized AHD. If the AHD falls outside
of its reauthorization cycle, then the electronic management system will remove
its “Active” status, and work must stop until the AHD is again “Active.”
___________
FOOTNOTE
*AHDs
will be transitioned from paper into the electronic management system during
the phase-in in CY2007. Prior to it being incorporated into the electronic
system, the authorized paper version is the version of record and is considered
valid.
END NOTES
- For
purposes of AHD review, EH&S disciplines are defined as Environmental
Protection, Waste Management, Radiation Protection, Industrial Hygiene,
Occupational Safety, and Fire Protection. The
data management system documents this involvement.
- Concurring
signatures are required from the Principal Investigator, the
EH&S Review Team Lead and the Division Safety Coordinator.
The Division Director’s signature authorizes the work.
- Signatures
of EH&S and the division on the authorization document that an Operational
Readiness Review has taken place and that work may proceed in accordance with
the established authorization.
- Minor
changes in personnel, materials, and methods are not generally considered
significant changes unless these changes affect the applicability of the
initial hazard assessment.
<< Return to Chapter 6 || Table
of Contents