The only official copy of this file is the one on-line in the NSLS ESH website. Before using a printed copy, verify that it is the most current version by checking the document issue date on the NSLS ESH website.
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Number: |
LS-ESH-PRM-1.3.5a |
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Section: |
EXPERIMENT SAFETY REVIEW |
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Date: |
09/08/2008 |
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Revision: |
14 |
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Prepared by: |
John Aloi |
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Approved by: |
Andrew Ackerman, ESH/Q Manager |
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| If you plan to work with
hazardous materials (esp. biohazards, Biosafety Level 2 and CDC Select Agents) or
radiological materials (esp. trans-uranics), read Sections
5 or 6 AND contact the NSLS
Experiment Review Coordinator well in advance of your anticipated
experiment data. Some experiments may take as long as several months
to review and approve. NOTE: These materials shall not be brought to the NSLS without the explicit approval of the Experiment Review Coordinator. |
TABLE OF CONTENTS
NSLS EXPERIMENT SAFETY REVIEW PHILOSOPHY AND SAFETY REQUIREMENTS
Experiments involving Etiologic and Recombinant DNA agents at the NSLS
This document details the NSLS procedures for environment, safety, and health (ES&H) review of experimental operations at the NSLS. All science at the NSLS is subject to ES&H review and must be approved by the NSLS ES&H staff before proceeding. The NSLS is committed to minimizing the risks to employees, visitors, the public, and the environment associated with both accelerator and experimental operations. For additional information, you may read BNL SBMS Subject Area Work Planning and Control for Experiments and Operations.
2. EXPERIMENT SAFETY REVIEW PERSONNEL
2.1 The Department Chairperson is responsible for assuring that all experiments conducted at the NSLS are reviewed for ES&H concerns before operations begin and that appropriate measures are taken to minimize risks through proper design and operation of equipment and proper handling of materials.
2.2 The NSLS Associate Chairman for ES&H is the primary management contact for concerns that arise from the experiment review process.
2.3 The NSLS Experimental Review Coordinator (ERC) is the primary contact for ES&H review of experiments and is authorized to approve experiments at the NSLS. The following personnel are also authorized to conduct the review and give approval.
2.4 The NSLS ES&H Committee may be called by the ERC to review individual experiments that present unusual risks. That committee may be augmented by technical experts from within the department and from outside the NSLS.
2.5 The NSLS Operations Coordinators assure that only approved experiments are allowed to proceed and assist Users in the proper conduct of experimental operations. They are the primary contact for all ES&H concerns on the NSLS Experimental Floor.
2.6 The NSLS User Administration Office assists with the administrative aspects of the review program. That office provides timely information to the User community and holds documents needed to support the program.
3. EXPERIMENT SAFETY REVIEW PROCEDURE
3.1 The information necessary for ES&H review of experiments is collected on the NSLS Experiment Safety Approval Form (SAF) (see Section 3.5.1 for extended reviews).
3.2 An SAF must be submitted at least one week prior to the start of each experiment. The NSLS requires that all experiments be adequately planned and evaluated for ES&H concerns and that adequate time be allotted for input from the ES&H Staff. Investigators planning experiments that present unusual risks and that require special procedures or equipment should contact the NSLS ERC as early as possible to avoid delays and assure sufficient time to develop appropriate controls. Approvals for SAF=s expire in one year at which time the SAF must be resubmitted and reviewed once again.
3.3 Changes to the SAF are expected. New ideas arise during the course of an experiment that require last minute additions of new materials and equipment. All significant changes must be reported to an NSLS Operations Coordinator. The Operations Coordinator will help decide whether additional review is needed and will make any changes to an approved SAF. Most changes are easily accommodated and should not result in significant delay. Changes that will require additional review include:
3.4 The NSLS SAF contains fields designed to collect sufficient information for evaluation of ES&H concerns associated with each experiment. All fields on the form must be completed by an Investigator with responsibility for conducting the experiment. The form is intended to be self-explanatory. Additional information for the use of selected fields is included below.
3.5 The NSLS SAF is an important document used to collect information and to support operation at the beamlines. An outline of the mechanics of how the form is used follows:
3.5.1 Submission of an NSLS SAF initiates review of each experiment. That review is an interactive process that may include discussion between the ERC and the Investigators conducting the experiment and may require additional written support material prior to approval.
3.5.2 The ERC will determine if additional safety controls or training is needed. For example, experiments generating hazardous or radioactive wastes will require a person designated as responsible for the wastes and completion of a BNL web-based training program (Hazardous Waste Generator (HP-RCRIGEN3). Such additional requirements will be communicated by the ERC to the investigator and to the local beam line contact via email.
3.5.3 Approved forms remain active for one year at which time the SAF must be resubmitted for review.
3.5.4 Investigators, ready to begin an experiment, must contact an Operations Coordinator to have the beamline enabled. The Operations Coordinator will only enable the line and allow the experiment to begin if an approved SAF is on file. The Operations Coordinator will confirm that any special requirements established by the ERC have been met, and will post the SAF at the beamline where it will remain for the duration of the experiment. At the completion of the experiment, the Investigator must again contact the Operations Coordinator who will come to the beamline, collect the SAF, and disable the beamline.
3.6 The NSLS experiment review program contains a graded approach to field verification that Investigators adhere to any requirements established during ES&H review of experiments. We expect our Users to conduct their experiments in a conscientious and honest manner and to report unexpected occurrences. The NSLS ERC determines which experiments require added attention. Field verification is accomplished in the following manner.
3.6.1 All experiments involve interaction between the Investigators and an Operations Coordinator. The Operations Coordinators know the facility and BNL policies and are a good source of information to the Users. They read any comments noted on the SAF and assure that appropriate information is given to the Investigator.
3.6.2 There is a check box on the SAF that indicates, AApproved, requires notification.@ If the ERC checks that box, the Operations Coordinator will allow the experiment to begin and will notify the ERC that the Investigators have arrived and have started their experiment. This allows the ERC to keep aware of which experiments are in progress and to determine if an inspection of the experimental set up is required. This approach to verification is used for recurring experiments and for those that the ERC determines require added attention beyond interaction with the Operations Coordinator.
3.6.3 There is a check box on the SAF that indicates, AERC review required.@ If the ERC checks this box, the Operations Coordinator will not enable the beamline and will not allow the experiment to begin until first contacting the ERC. This approach to verification is used for experiments that present unusual risk and that the ERC determines require exceptional attention to detail before operations begin.
3.6.4 The ERC may refer experiments involving Etiologic Agents and Recombinant DNA to the BNL Institutional Biosafety Committee (IBC) for approval to operate. See Section 5 for more details.
4. NSLS EXPERIMENT SAFETY REVIEW PHILOSOPHY AND SAFETY REQUIREMENTS
4.1 Overview
All science at the National Synchrotron Light Source (NSLS) is reviewed for Environmental, Safety, and Health (ES&H) concerns. The experimental program requires special attention as it involves a varied population of visitors who study and use many diverse materials. Guests are trained and oriented before beginning work at the beamlines. They are expected to act responsibly and to understand that NSLS is a shared facility and may require precautions that do not apply at their home institutions.
All experimental proposals are reviewed by the NSLS ES&H Staff before operations begin. Experimenters are required to report their intended activities to the NSLS Staff to allow for an appropriate risk assessment and to determine what measures may be necessary to control their operations. A basic tenet of our program is that the Experimenter is responsible for his actions and his experiment. We expect to be included in the planning stages of experiments and to help determine what engineering or administrative controls are needed to allow the safe and efficient progress of each experiment. We work with the experimental community to anticipate potential concerns and assure that reasonable precautions are taken. The NSLS Staff maintains personal involvement with the experimental program through written and verbal communications and through a routine presence on the experimental floor.
Each experiment receives individual attention. For the NSLS Staff to review proposals, Experimenters are required to report what materials they intend to use, how they will use them, and what equipment will be involved. It is not enough to submit a list of materials to be studied. The NSLS Staff needs to know what operations are planned to assess whether they are appropriate for the experimental floor or other experimental areas of the facility. Often this assessment requires a dialog between the Experimenter and the Staff. Few experiments are disallowed. However, many are changed to reduce the risk presented to both personnel and equipment. Our focus is on controlling risks to personnel and compliance with regulatory requirements.
4.2 Safety Requirements
Experimental risk assessment and control is a process that requires knowledge of the proposed operations and of the facilities available at the NSLS. Decisions about appropriate work practices include consideration of the nature of the materials to be used, the proposed process, the availability of engineering controls such as exhaust ventilation systems and storage facilities, specific experimental needs, and the unique concerns associated with working in an open facility.
4.2.1 The following general considerations apply to review of the experimental program.
- Many experiments involve use of samples that are prepared at the Experimenter's home institution. The samples arrive at the NSLS sealed in capillary tubes, cuvettes, holder assemblies, or taped to glass slides. There is no manipulation of the material. The preassembled samples are placed in the synchrotron beam for data collection and then returned to the Experimenter's home institution. These experiments are easily accommodated and require no special attention.
- Many experiments involve use of small quantities (<500 ml) of typical laboratory solvents such as ethanol, methanol, acetone, etc. Routine laboratory precautions are adequate to control the risks presented by these materials. Stored glass bottles larger than 1000 ml are not allowed unless specific permission is obtained from NSLS ESH staff. Stored plastic bottles or glass bottles with protective plastic sleeves larger than 1000 ml are allowed.
- Many experiments involve use of small quantities of dilute (millimolar) electrolytes such as sulfuric acid, nitric acid, sodium hydroxide, etc. Routine laboratory precautions are adequate to control the risks presented by these materials. Stored glass bottles larger than 1000 ml are not allowed unless specific permission is obtained from NSLS ESH staff. Stored plastic bottles or glass bottles with protective plastic sleeves larger than 1000 ml are allowed.
- Compressed inert gases and liquid nitrogen are in common use. Routine laboratory precautions are adequate to control the risks presented by these materials.
4.2.2 All other experiments require some communication between the Experimenter and the NSLS Staff. Examples of specific controls that could be required follow.
- Minimize the quantity of potentially hazardous material brought to the NSLS to that required by the experiment.
- Utilize exhaust systems to control personnel exposures or avoid accumulation of combustibles.
- Provide secondary containment to control spills.
- Assure compliance with Brookhaven National Laboratory training and medical examination requirements.
- Survey for physical hazards.
- Test and assure proper grounding of electrical equipment.
- Assure proper handling of radioactive materials.
- Evaluate and control stored energy concerns.
4.2.3 A checklist has been developed to document the review of Environmental Management System significant environmental aspects, the Facility Use Agreement (FUA), and the Safety Assessment Document/Accelerator Safety Envelope (SAD/ASE) (see Attachment II). This checklist will be used for reference purposes during SAF reviews, but a separate form will not be completed for every experimental review. Any changes for reference purposes to the environmental aspects, FUA, SAD/ASE or NEPA Environmental Assessment will result in a memo from the ERC to the NSLS Associate Chairman for ESH/Q.
5. Experiments involving Etiologic and Recombinant DNA agents at the NSLS
BNL guidance for dealing with hazardous biological materials is provided in
the Biosafety in
Research Subject Area. Additional
NSLS information is provided below.
5.1 Etiologic Agents (BSL 2 or Select Agents) are defined as:
Proposals to use Etiologic Agents at the NSLS will require an extended review
and may also require registration with the CDC or other agencies. This
registration and NSLS approval may take several months to complete.
In order to conduct Etiologic Agent research at the NSLS, use the Etiologic
Agent Form to determine if your agent is listed and proceed according to the
instructions, in collaboration with the NSLS Experiment Review Coordinator.