Integrated Safety Management Plan

June 5, 1998

Revision 1: October 20, 1999
Revision 2: June 23, 2001
Revision 3: July 10, 2002
Revision 4: June 29, 2003
Revision 5: June 9, 2004
Revision 6: June 3, 2005
Revision 7: June 19, 2006
Revision 8: October 1, 2007

1. Preamble

The EET Division Integrated Safety Management Plan has been written to implement the Integrated Safety Management System (ISMS) for the Division. Berkeley Lab uses the ISMS as a means for assuring that work is performed safely. It is built around five core ISM work functions and seven guiding ISM principles.1 The Berkeley Lab Integrated Environment, Health & Safety Management Plan, PUB-3140, documents how the Berkeley Lab implements the ISMS throughout all its work functions. Discussion of the Berkeley Lab ISMS Plan, including the principles and work functions, can also be found in Chapter 1 of the Health & Safety Manual, PUB-3000. The Laboratory's ES&H policies and requirements are established in the Health & Safety Manual, PUB-3000; the Regulations and Procedures Manual (RPM), PUB-201; and the Operating and Assurance Program Plan (OAP), PUB-3111. These three publications establish line management responsibilities and define authorities and authorizations. This EET Division Safety Plan establishes the mechanisms and fundamental management strategy that will ensure that all institutional EH&S policies and procedures are properly implemented.

2. Division Safety Management Structure

The Environmental Energy Technologies Division Environment, Safety & Health (ES&H) program structure consists of the Division Director, the Assistant Division Director for EH&S and Space (representing Division senior management and chair of the Safety Committee), the Safety Coordinator, and a Safety Committee. All Division Staff, including Department Heads, Group Leaders, Principal Investigators (PI's), Division Facility Managers, Work Leads and Supervisors are responsible for ES&H compliance.

3. Accountability

Principal Investigators (PI's) are responsible and accountable to their supervisors and associated line management up to and including the Division Director, for assuring that all activities are carried out in a safe manner and in accordance with all Laboratory EH&S requirements. This responsibility and accountability cannot be delegated, but it is recognized that other staff, guests, or students working under the PI may also have EH&S managerial responsibilities. PI's ought to consult with qualified specialists (e.g., the Division Safety Coordinator or specialists from the EH&S Division) to resolve any questions about EH&S requirements. EH&S performance of the Principal Investigators is reviewed by use of the annual performance review.

As part of line management, PI's are expected to remain fully cognizant and responsive to conditions and practices within the laboratories or other spaces for which they have responsibility. To meet this expectation, PI's must constantly monitor research activities and working conditions in these areas and perform periodic inspections or walkthroughs of these areas, recommended at least quarterly. Senior line management should also participate in periodic inspections or walk-throughs of their areas, including both laboratory and office spaces. Walkthrough checklists for line managers are available in the form of pocket guides, an LBNL standard Walkaround Checklist, or a Lab Safety Inspection Checklist tailored to EETD. Walkthroughs must be documented by use of notes of inspection results, date(s), and locations(s); completed inspection forms; and/or CATS records.

All employees, participating guests, and visitors are responsible for knowing and following the EH&S requirements that apply to their work. They are expected to work safely, to understand which EH&S requirements apply to their work, and to cooperate with the Division EH&S efforts. Whenever an employee, participating guest or visitor encounters conditions or practices that appear to constitute an imminent danger (i.e. potential for death or serious injury) or environmental harm, they have the authority and responsibility to:

  • alert the affected employee(s) and request the work be stopped;
  • call x7911 if it is a life-threatening emergency, or call x6999 to report the incident—EH&S staff will investigate it; and
  • inform (to the extent possible) the person with immediate line management authority, the Division Safety Coordinator, the Assistant Division Director for EH&S and Space and the Division Director.

Supervisors will meet at least annually with their employees to discuss safety issues and identify and evaluate job hazards that may pose risk of accident and/or injury. This meeting is typically a part of the annual performance review process, but these discussions should occur any time the need arises.

There are also established lines of communication both up and down the Division Management hierarchy used to maintain accountability not only with the PI's, but also with all Division staff. The three most relevant means of communicating safety issues and accountability to and/or from line management, including the Division Director, are 1) the Division Council meetings, 2) the Safety Coordinator's communications, and 3) the Division Safety Committee.

The Division Council meets every week (schedules permitting) and is composed of the Division Director, the Deputy Division Director, the Assistant Division Director, the Business Manager, the leader of the Program Development Office, and the heads of each of the research departments. Division Council provides management assistance and guidance to the Division Director on a broad range of issues, including EH&S. Typically the Council reviews the quarterly reports prepared by the Safety Coordinator and serves as a forum for the discussion of and possible action on any EH&S issue for which Division management advice and/or action is appropriate.

The Division Safety Coordinator communicates, both up and down the chain of command, on a variety of safety issues. As noted earlier, the Safety Coordinator prepares quarterly reports (described in more detail later in this Plan) for Division Management. In addition, communications with PI's, supervisors and others with specific EH&S responsibilities range from formal memos and emails to conversations "in the field" as part of the Safety Coordinator's inspection and walk-through process.

4. Safety Committee

The Division maintains a Safety Committee, consisting of the Assistant Division Director for EH&S and Space, who chairs the committee and represents the Division Director, the Division Safety Coordinator, the EH&S Division Liaison, the Deputy Division Director, the Division Business Manager, and the Division's representative on LBNL's Safety Review Committee (SRC). The Division Safety Committee may have sub-committees that represent specific sectors of the division, such as lab environments or office environments. The Safety Committee meets quarterly, or more often if issues warrant, and reports to the Division Director regarding any current or systemic safety issues within the Division. The principal functions of the Safety Committee are to assist the Division Safety Coordinator and Assistant Division Director in identifying and addressing EH&S issues within the division. This assistance may include walkthroughs and inspections of Division lab facilities, reviews of quarterly reports prepared by the Safety Coordinator for the Division Council and other assistance as needed to support the Division in carrying out its safety responsibilities.

The Safety Committee assists in the preparation of an annual self-assessment report for the Division Director and the Office of Contract Assurance that includes an evaluation of how well this Division Safety Plan is implemented. The Safety Committee also assures that the Division works to improve the effectiveness of the Division safety program through the dissemination of lessons learned and other appropriate feedback mechanisms. The EETD Safety Committee Charter contains further details.

Other Division Safety Committee activities may include assisting in the annual reviews of AHD's; evaluation and promotion of good ergonomic practices; safety reviews of new and continuing work proposals; and participating in occurrence report processing to the extent necessary.

The Division's representative on LBNL's Safety Review Committee (SRC) and a representative from the Environment, Health & Safety (EH&S) Division (the EH&S Division Liaison) sit on the Safety Committee to provide updated information and training to the committee network. These representatives also take input and concerns expressed by the committee membership about the Division needs and impact of procedures on the Division back to their respective organizations. The committee makes use of other expertise within the EH&S Division for specific EH&S issues that arise. The EH&S Division and the Office of Contract Assurance (OCA) are prime resources for the Division in the implementation of DOE, state and other federal regulations.

5. Divisional Safety Oversight

The Division Safety Coordinator, with the assistance of the Safety Committee, as necessary, conducts safety reviews and inspections, and provides safety review documents for use by the EETD line management. These include:

  • A quarterly safety report to Division management that includes some or all of the following topics: CATS statistics, SAA compliance statistics, a training summary, status of AHD's, Self-Assessment status, injury reports, reportable occurrences, and special problems.
  • A discussion at an appropriate Division Council meeting of the findings and results of the annual self-inspection process and reporting to OCA.
  • Quarterly formal inspections of all SAA's. In addition, other informal inspections and walkthrough evaluations will be conducted as warranted, with a focus on those SAA's or other entities that failed to maintain compliance with laboratory or division safety practices. At least one inspection annually will be done in the company of the responsible line management personnel (typically the PI).
  • Periodic walkthroughs of all lab space and a representative sample of office space, typically quarterly, to monitor the ongoing conditions and practices in the labs, and to follow-up on the annual Self-Assessment inspections by the PIs.
  • Annual AHD reviews done in conjunction with the PI and/or other staff responsible for the facility.
  • Project Safety Review approvals.
  • Review of corrective action plans developed by the PI and/or responsible staff for any research facility or operation for which safety issues persist.

The Division, through its Safety Committee, conducts an annual self-assessment that involves safety reviews and inspections of all Division laboratory space by the PIs and research groups. Topics reviewed during these inspections cover all aspects of Environment, Health & Safety compliance. Findings are entered into the LBNL Corrective Action Tracking System (CATS), maintained by the Office of Contract Assurance, to facilitate tracking, trending and budget planning. The Division's Safety Committee does follow-up inspections for verification, oversees (to the extent necessary) development of any corrective action plans and preventive measures, assists the PIs, Work Leads, and Building Managers in resolving open findings, and alerts the Division Director to specific problems or non-compliant areas, as warranted.

Besides the annual Self-Assessment process, the Division uses a Project Safety Review form to evaluate new and on-going projects for new or changed hazards, for the need for new or modified safety authorizations, to identify new or modified staff and training requirements, and to assure that the proper administrative or engineering controls are implemented. This form reminds PI's that they must allocate appropriate resources for these EH&S concerns. All proposals for new projects and annual reviews of continuing projects must include the Project Safety Review form. This form is reviewed and approved by the Division Safety Coordinator.

Historically, ergonomic injuries comprise about 55% of all EETD injuries. Ergonomics is not just about the equipment—it is critical that all staff understand the importance of early reporting of discomfort and the use of workload management as strategies for preventing ergonomic injuries. Ergonomics for Computer Users training, EHS0060, is required for personnel who work at a computer for more than an average of 4 hours per day, and is recommended for all other computer users. EHS0062, Worksmart Ergonomics, focuses on lifting and other material handling issues. Additional ergonomics training can be conducted by EH&S staff for laboratory and other specialized tasks. A current ergonomic workstation evaluation is required whenever there is pain or discomfort, or whenever computer usage is more than an average of 4 hours per day. A current ergonomic workstation evaluation is strongly recommended for all other computer users, especially when there are significant changes to the workstation set-up, when the workstation is relocated, or for new hires. EH&S Division evaluators are used for more critical evaluations where there are injuries, discomfort, or other complexities involved. EETD has an in-house team of trained evaluators who conduct routine evaluations, assist with evaluation follow-up tasks, promote ergonomic issues awareness and early reporting, and identify risk factors such as problem postures and work habits.

An injury investigation meeting will be held to discuss each injury in the Division. The injured person, their supervisor, the Division Safety Coordinator, and the EH&S Division Liaison participate in these meetings. Additionally, the EETD Assistant Division Director for EH&S participates in the investigation of DOE Recordable accidents and injuries, and presents the findings to the Division Safety Committee.

Typically the EETD Assistant Division Director discusses these and other safety related topics with the Division Director and/or the Division Council. Applicable information from the Laboratory's lessons learned program and any relevant EETD incidents will be disseminated to Division personnel for accident prevention and hazard awareness. Finally, safety should be an agenda item in all regular department, program, and group meetings.

6. Scope of Work Authorized

a. General

EET Division research incorporates many diverse disciplines - physics, engineering, chemistry, architecture, economics, computer science, life science, and others. The Division maintains uniquely advanced research and test facilities available for cooperative and sponsored R&D in energy efficiency and environmental health. Details of the scope of work authorized for this Division are documented in the Hazards, Equipment, Authorizations, and Review Database (HEAR), which is available online. This scope statement is an important part of this plan and describes the range of permitted work. Annually, the PI, with help from the Division Safety Coordinator and the EH&S Division as necessary, will review and update this Scope. The Principal Investigator will bring work outside of this scope statement to the attention of the Safety Coordinator prior to commencement or contractual commitment to determine EH&S impact.

b. Off-site work

All EET Division employees working off-site are expected to practice at least the same level of safety awareness required at LBNL, and are required to be knowledgeable of any additional safety requirements at the off-site facility appropriate to the task they are performing. Division personnel working off-site are required to conform to LBNL's EH&S training requirements (as determined by the Job Hazards Questionnaire). However, training provided by off-site institutions may in some cases be substituted for LBNL training. Under no circumstances will EET Division employees conduct themselves in such a fashion that will place themselves, the host facility personnel, or any member of the public in danger or increase risk or liability. Examples of off-site work include short or long-term assignments in UCB Campus space, at LBNL's Washington DC office, at field sites, etc. Offsite experimental work that is not in UCB campus space must have an EETD Offsite Safety Review form filled out and reviewed by the DSC before the offsite work commences.

Specifically, LBNL work performed at the UC Berkeley campus must conform to the "Partnership Agreement Between UCB and LBNL Concerning Environment, Health and Safety Policy and Procedures" dated March 15, 2004, as provided in the LBNL Institutional ISM Plan [Download].

  • Lab PIs have an obligation to Berkeley Lab management to provide a safe workplace for all Berkeley Lab-sponsored work. At UCB, this is satisfied by complying with the UCB Safety System.
  • Lab PIs are responsible for analyzing work of persons under their direction and for assuring that the proper training for safe conduct of work is identified and obtained. Until an individual has been properly trained, s/he will work under the direct supervision of someone who is already trained. The type and method of training for work performed at UCB is specified by UC Berkeley.
  • Lab PIs conducting Berkeley Lab-sponsored work are free to implement controls and other measures beyond the institutional requirements if they deem it appropriate.
  • Lab PIs working at UCB can request a joint safety assessment (to be conducted by representatives of both the UCB and LBNL EH&S organizations) to further aid them in ensuring a safe workplace.
  • Lab PIs conducting Berkeley Lab-sponsored work at UCB will comply with UCB standards including properly specifying training requirements (for themselves, workers and students), obtaining and adhering to UCB work authorizations, and meeting UCB self-inspection requirements.

c. Work Requiring Specific Approval

As part of each project proposal, the Principal Investigator completes an EETD Project Safety Review form and fills out the NEPA/CEQA Review document. For each funded project, the Principal Investigator prepares EH&S documentation and obtains required approvals for potentially hazardous or regulated work as specified in Chapter 6 of PUB-3000 prior to commencement of the work. The PI is expected to maintain accurate safety documentation (including a chemical inventory); and reevaluate his hazard assessment when necessary, and at least annually during the Division's Self-Assessment process. The following table lists authorizations active, as of 9/07, in the EET Division. Details as to the Facility, location, and Principal Investigator can be found in the 2007 EETD Self-Assessment Report section shown.

Authorization Number 2007 SA Report
[Appendix 1]
Activity Hazard Document (AHD) 12* Table 2
Radiation Work Authorization (RWA) 1 Table 8
Sealed Source Authorization (SSA) 6 Table 8
X-Ray Authorization 1 Table 8
Satellite Accumulation Area (SAA) 26 Table 9
Radiation Waste Collection Area (RWCA) 1 Table 9

* Additional 9 AHDs are in inactive status

7. Qualifications and Training

The Principal Investigator and/or supervisor will determine the requisite qualifications to function safely, and will document that the employee possesses these qualifications. This applies to students and guests as well. This documentation is typically found in the individual's JHQ and Training Profile, Job Description, performance evaluation, any relevant formal authorization, and/or any relevant Facility Notebook covering the experimental facility in which the employee, student or guest works. Until such safety qualifications have been established and satisfied, individuals will only be allowed to work under the supervision of a qualified employee. Qualifications include skills, knowledge, training and certifications required by law or by Laboratory policy.

The Job Hazards Questionnaire (JHQ) is the tool used by the EET Division to determine what EH&S training is required and recommended for each employee. The EET Division Training Policy is outlined on the Division intranet site. The Training Profile summarizes the JHQ results and shows what courses are required and recommended, and whether the requirements have been met. The JHQ is updated annually, or upon any significant change in work scope, by the employee, visitor or participating guest (anyone who works at LBNL for a period of 30 days or longer). The supervisor ensures that their employee's required training is satisfied as part of the PRD review. New employees are required to fill out the JHQ within 30 days of employment, and complete required training within 90 days.

Qualifications and training are reviewed by the Safety Committee as part of the annual Self-Assessment report prepared by the Division.

8. Balanced Resources

Principal Investigators incorporate appropriate resources for EH&S concerns in all research proposals, to include provisions for safety equipment, permits, training, maintenance, waste disposal, and facilities modifications.

9. EH&S Resources

To facilitate implementation and execution of this EET Division Safety Program, the following resources are made available:

  • 0.35 FTE Assistant Division Director for Space and EH&S
  • 0.85 FTE Division Safety Coordinator

The following resources are made available by the EH&S Division on a matrix basis. They are available to assist Principal Investigators, the Safety Committee, and the Division staff in general with any aspects relating to the implementation of this program. The matrixed individuals are accountable to the EETD Safety Committee Chair.

  • 0.20 FTE Division Liaison
  • 0.10 FTE Laser Safety
  • 0.10 FTE Industrial Hygiene (AHD & process reviews, hazard & exposure evaluations, ventilation surveys, participation in surveys, etc.)
  • 0.04 FTE Radiation Protection
  • 0.01 FTE Occupational Safety (elevated work, machine safeguarding, material handling, tools, transportation, etc.)
  • 0.01 FTE Electrical Safety
  • 0.46 FTE Total

1 Core ISM functions:

  1. Define the scope of work.
  2. Identify and evaluate the hazards of the work.
  3. Develop and implement controls for the hazards.
  4. Perform the work as authorized.
  5. Sustain continuous improvement from regular feedback.

In carrying out these functions, divisions are guided by the seven ISM principles:

  1. Line Management Accountability
  2. Clear Roles & Responsibilities
  3. Competence Commensurate with Responsibilities
  4. Balanced Priorities
  5. Identification of Safety Standards
  6. Hazard Controls Tailored to Work being Performed
  7. Requirements and Operations Authorizations

Annual Update Approved By:

___________________________
William Fisk
Acting EET Division Director

___________________________
Robert Kostecki
Assistant Division Director for EH&S and Space

___________________________
Guy Kelley
Division Safety Coordinator