EETD Self-Assessment Report for PY2006

July 14, 2006

Prepared by:
Guy Kelley, EETD Safety Coordinator

Approved by:
Donald Lucas, EETD Asst. Division Director for Space and EH&S
Mark Levine, EETD Director

PY06 Division EH&S Self-Assessment Report Contents

  1. Executive Summary
    1. Division EH&S Structure
    2. Goals and Objectives
    3. Summary of EH&S Status, Performance and Issues
    4. Conclusions
  2. Effectiveness of Division ES&H Programs
    1. Accomplishments and noteworthy practices
    2. Status and Progress on Corrective Actions for Issues Identified in FY99
    3. Significant or recurring ES&H issues
    4. Possible Root Causes
    5. Corrective Measures Planned
    6. Methods to Track Progress
  3. Measurements of Division ES&H Performance against Laboratory PY06 EH&S Performance Criteria
  4. Division Implementation Plan for PY07
  5. Appendices
    1. EETD Self-Assessment Database Tables showing performance by key criteria, FY96 through PY06
    2. EETD Integrated Safety Management Plan, Rev. 6, June 3, 2005
    3. EETD Quarterly Division Safety Report (Most recent report for Division senior management, July - September 2005)
    4. EETD Waste Minimization Program Report, PY06
    5. Sample Safety Communications & Other Supporting Documents

I. Executive Summary

At the Division level, EH&S activities in EETD are conducted by the Assistant Division Director for Space and EH&S, the Division Safety Coordinator (DSC), and the Division Safety Committee, all working under the general direction of the Division Director. The principal means of communicating within the Division regarding health and safety issues are through the Safety Coordinator and Assistant Division Director for Space and EH&S, Division Council meetings, and the Safety Committee. The Division Council is responsible for Division management, and consists of the Division Director, the Deputy Division Director, the Assistant Division Director, the Business Manager, and the heads of each of the five research departments.

1. Division EH&S Structure

The principal goal of the Division's EH&S effort is to ensure that all research activities in the Division are conducted safely and in compliance with the applicable federal, state, local, and laboratory requirements. Recognizing that much of the responsibility rests with the Division, our efforts focus on working with the Division scientific and supervisory staff to successfully meet these responsibilities.

To this end, our objectives are to: a) ensure that the various responsible parties within the Division recognize and act upon their EH&S responsibilities; b) provide the necessary information, tools, data, etc. for their use in a usable form; c) back these activities with Division oversight by both management and the Safety Coordinator and Safety Committee; and d) collect and maintain records for Division and Laboratory use.

2. Goals and Objectives

The principal goal of the Division's EH&S effort is to ensure that all research activities in the Division are conducted safely and in compliance with the applicable federal, state, local, and laboratory requirements. Recognizing that much of the responsibility rests with the Division, our efforts focus on working with the Division scientific and supervisory staff to successfully meet these responsibilities.

To this end, our objectives are to: a) ensure that the various responsible parties within the Division recognize and act upon their EH&S responsibilities; b) provide the necessary information, tools, data, etc. for their use in a usable form; c) back these activities with Division oversight by both management and the Safety Coordinator and Safety Committee; and d) collect and maintain records for Division and Laboratory use.

3. Summary of EH&S Status, Performance and Issues

The Division EH&S program performed well using the Lab's metrics during this reporting period, though not quite matching the excellent record of the 2000-2004 years. During PY06, all of the Division's research facilities were inspected at least once, all 28 of the authorizations requiring review were reviewed, and radioactive material authorizations were 100% compliant. We had 6 injuries this year, lower than our 11-year average of 7.0 injuries per year. Only one of these injuries was serious enough to be DOE Recordable.

We continue to enjoy productive relationships with staff in the EH&S Division, especially the EH&S Division liaison to EETD and the Waste Management Specialist, and in the topical areas of electrical safety, laser safety, and SAA inspection and compliance. These latter issues are key potential hazard areas within EETD.

The Safety Coordinator devoted 90% of his time to safety issues. He continued to maintain a presence in the "field", walking through laboratories, tracking and closing out CATS deficiencies, and generally improving the Division's EH&S presence among the research staff.

The Assistant Division Director for Space and EH&S now attends Division Council meetings on a regular basis, and EH&S is an agenda item for every Division Council meeting. The Assistant Division Director also chairs the Laboratory's Safety Review Committee, and is part of the Corrective Action Team; this improves communications between the Division and the Laboratory.

The completion rate for required training courses was 93% and the JHQ completion rate was 97% (excluding personnel in the grace period). Both of these are slight improvements over the last few years. Improvements in the on-line JHQ process and the active role of Division management (and the PRD process) have contributed to this success. Division management has a posted training policy to clarify which personnel need training. Our goal is to have a completed JHQ for every employee in the Division, including students, guests, and faculty.

SAA compliance showed 91% of the inspections (held quarterly) in compliance during PY06. This was several percentage points better than last year. However, the spot check of 8 SAA's by the Office of Contract Assurance resulted in a 75% compliance rate, and this is the figure used for our Self-Assessment metric.

Two, maybe three, performance areas were below the level required for a green score. The 75% SAA compliance rate in the OCA inspections mentioned above will result in a yellow score. Eight waste containers failed Quality Assurance tests by Waste Management, resulting in an 89% pass rate and a red score for this metric. Our CATS corrective action completion rate was 82%, resulting in a yellow score. However, our completion rate for those items under our control is higher, and we should not be penalized for those corrective actions that were held up by the Facilities or EH&S Division, out of our control.

EETD had no Waste Management issued Nonconformance and Corrective Action Reports (NCAR's).

4. Conclusions

Overall, the Division's safety performance was good, but not the excellent all green performance that was achieved for the 2000-2004 years. Evidence shows that EETD's safety program is mature, is effectively founded on the ISM principals, is showing good results as per the performance criteria metrics, and is providing a safe work environment for its staff.

II. Effectiveness of Division EH&S Programs

1. Accomplishments and Noteworthy Practices

The August 2004 IFA report, Executive Summary, states: "Safety within EETD has exceptional management support. The Division has a proactive safety program that is both innovative and effective. The commitment of EETD is evidenced by the condition of the spaces evaluated and the safety conscious attitude demonstrated by the individuals (supervisors and staff members) encountered during the field visits." We believe this statement continues to accurately describe our EH&S program.

The Division conducted at least one all-hands meeting where safety was a primary topic, and the Division Director continues to clearly articulate his commitment to safety and his expectations for safety from the Division staff.

Again this year, our radioactive materials authorizations (2 RWA's (1 inactive), 1 SSA (inactive), and 6 GLA's) have all been renewed on time, have had no significant or major deficiencies, and have 100% completion on required training. Our 13 active and 6 inactive AHD's have all been reviewed on time and have a 97% training completion rate. For the 6 inactive AHD's, the PI's were notified that no research can be done under the inactive AHD until the Safety Coordinator and EH&S reviews the AHD and places it in an active status.

The Division allotted sufficient resources to continue a strong presence of the DSC "in the field", providing both informal inspections and safety reviews, and 'on-the-spot' advice. 100% of the Division's lab and shop spaces are visited by the DSC at least once per year, and typically every few months. The presence of the DSC also improves communications in all directions. The Assistant Division Director also visits division space on a regular basis.

The Division continues to maintain the often arduous process of record keeping, which is important in terms of assessing long-term performance of specific facilities as well as Division programs. Databases maintained by the DSC provide a very convenient overview of all the Division research facilities, including such items as key personnel, space assignments, authorizations, and notes on action items. The databases also provide specific details on most of the self-assessment metrics, which easily allow graphical trend presentations in the Quarterly Safety Reports. (For an example of a Quarterly Safety Report prepared for senior management, see Appendix 3, Quarterly Division Safety Report, July—September 2005.)

The Division's accident prevention efforts have resulted in reasonably low accident rates. We had only one recordable case. This case was an ergonomic injury that worsened even after taking early corrective action that included an ergonomic evaluation.

As part of our accident prevention efforts, injury and accident rates, occurrence reports, exposure reports, safety notices, and lessons learned reports are received and reviewed by the Division Safety Coordinator, and are acted upon and redistributed as appropriate. The DSC posts pertinent safety notices and lessons learned reports on the Division EH&S website. A database is kept of the Division's accidents and injuries for tracking and trending purposes.

Although low in number, over the last ten years, 55% of the Divisions injuries have been ergonomic related (five of the six total injuries this year). The Division has an Ergonomics Committee and an ergonomics action plan. Using both our in-house ergonomic evaluators and EH&S evaluators, the Division has an active workstation ergonomic evaluation program. A total of 95 evaluations were done in PY06, and the Division has an initial goal of performing workstation evaluations for all approximately 182 EETD active career or term employees.

As in past years, the Division has relied upon the self-assessment checklist for systematic evaluation of hazards within its research operations. Facility managers are requested to fill out the checklist, identify new deficiencies, and update the online HEAR database for their space. Deficiencies reported in these checklists are entered into the CATS for tracking. We had 96% compliance with this facility Self-Assessment checklist process. In addition, the Division Safety Coordinator conducted inspections of 100% of the Division Facilities during the year, matching the past six-years' performance.

A continuing area of emphasis for the Division has been the SAA assessment, conducted in conjunction with personnel from the EH&S Division. All SAA's are formally inspected quarterly, and the compliance rate for PY06 was 91%. The official OCA SAA inspections, based on a sampling of 8 SAA's, resulted in a 75% compliance rate.

PI's and laboratory staff maintain their chemical inventories on an on-going basis. Help from EH&S chemical inventory staff is used when needed. 100% of EETD chemical owners updated their chemical inventory during PY06. Only about 0.5% (27 containers) of EETD's 5406 chemical containers are not yet barcoded and entered into the chemical inventory.

The Division maintains a web site specifically for safety items pertinent to our Division (http://eetd.lbl.gov/EHS/EHS.html). For example, the Division ISM Plan, safety guidance, minutes of safety meetings, charters, and other information are available on-line. We also include lessons learned, a list of acronyms, Division contact information, and links to the Lab EH&S sites. The site is periodically updated with additional and revised information.

The Assistant Division Director for Space and EH&S chairs the lab-wide Safety Review Committee and is a member and team leader of the Corrective Action Team.

2. Status and Progress on Corrective Actions for Issues Identified in FY99

Last year we identified the following as significant or recurring EH&S issues:

  1. Ergonomics
  2. Off-site work hazards
  3. JHQ and Training completion rates
  4. Line management participation in EH&S
  5. LCATS deficiency closeouts

Our progress on these items is discussed below.

1. Ergonomics.

An EETD Ergonomics Action Plan was drafted in 1999, and has evolved over the past years with the Ergonomics Committee.

The Division requires EHS-060 training for personnel who work at a computer for more than an average of 4 hours per day, and anyone who has ergonomic injuries.

  • 260 Division personnel have had ergo training (EHS-060). 45 of these were completed in PY06. 100% of the required EHS-060 courses have been completed (after exempting two newly hired employees).
  • 242 Division personnel have had ergo evaluations (EHS-068). 95 of these were completed in PY06.

The Ergonomics Committee oversees the Division's ergonomics program, including the scheduling and progress tracking of the team of in-house ergonomic evaluators.

All of the DSC's quarterly safety reports to senior management include a discussion of ergonomic issues and Committee progress. The Division Director and Division Council are well aware of the ergonomic issues.

2. Identify and evaluate hazards with off-site work.

Though still not to our total satisfaction, we are tracking our off-site work, and documenting it in our annual Work Smart Standards Review and our fairly new EETD Off-Site Safety Review form. In an effort to improve off-site work tracking and hazard evaluation, we are getting more and more of our off-site projects to use this review form. A primary advantage of this form is to have off-site personnel identify hazards and discuss mitigation with their group. A sample completed EETD Off-Site Safety Review form is in Appendix 5. A goal for the upcoming performance year will be to have all our off-site work documented using this form. There is a lab-wide effort (through EH&S and the SRC) to develop a similar system for the entire laboratory; if this proceeds, we will ensure that any new policies are implemented in our Division.

3. JHQ and Training.

With the goal of maintaining EETD's good JHQ and training completion rates, the Division (through the Safety Coordinator and Assistant Division Director) has and will continue to send periodic notices to personnel who have not completed a JHQ and to supervisors and personnel who have not completed required training. JHQ completion is important because it is the primary tool used by the Division to determine what courses are needed for personnel to do their work safely. The JHQ completion rate is 97% this year (see Appendix 1, Table 6), several points higher than recent past years. We will continue our efforts to maintain or improve this rate.

The training rate for the year is 93% of all required courses (see Appendix 1).

We have a written policy regarding training that was approved by the Division Director after discussions with the Safety Committee. The policy is posted on the Division web site.

It is Division policy that the annual Performance Review includes a plan for completion of outstanding training. The new PRD process requires supervisors to examine deficiencies in training.

For JHQ and training completion rate trends over the last several years, see the trend graphs at the end of Appendix 1.

4. Line Management participation in EH&S.

(Line management is defined as anyone who has authority to allocate resources. In EETD, this generally refers to PI's up through the Division Director.)

The Division's plan of action has been and will continue to be as follows:

  • The Division Director, Deputy Director, and Department and Program Heads will continue with periodic safety walkthroughs of lab space.
  • Senior Division management will include EH&S agenda items in all-hands meetings, department meetings, and at least quarterly in Division Council meetings.
  • Department Heads will encourage their PI's to regularly participate in safety related activities such as
    • doing periodic safety walkthroughs of their spaces,
    • including safety as an agenda item in group meetings, and
    • correcting deficiencies with CATS items, SAA's, and training.
  • Encouragement for line management participation in EH&S will be included whenever possible in EH&S related communications.

In January of this year, EETD safety staff did walkthroughs of all our lab space. This was spurred by Director Chu's Lab-wide safety initiative. The focus of these walkthroughs was to have each PI actually do the walkthrough with assistance and guidance from EH&S personnel. An important achievement was to get the PI's more confident with doing walkthroughs, and to encourage them to do this regularly. In general, the response of the staff was very positive, and significant improvements were made in almost every lab to improve safety and housekeeping. Findings were entered into CATS.

On 6/29/06, we held a safety meeting and an EHS027 Safety Walkaround training session for laboratory PI's and Facility Managers. Our Division Director, Assistant Division Director, and Richard DeBusk from EH&S spoke about the importance of conducting safety walkthroughs, and communicating safety issues up the chain of command and down all the way to the bench workers.

Line Management participation in EH&S and safety "buy-in" by all staff will always be challenging objectives for a research division where personnel are focused on their research activities, worried about their funding sources, and racing to meet their publication deadlines. The great improvement EETD made in FY00 and maintained through the present is evidence that we have made good progress with improving the "safety consciousness" and safety participation of our staff. We attribute this to efforts outlined in the above plan of action and the frequent contact by the Safety Coordinator with Division staff. Also, this performance year, all senior management (department heads and above) made walkthroughs of Division lab and office spaces, and safety was a topic at the Division all-hands meeting during PY06. The support and visible presence of senior line management directly impacts the perception of safety for all staff.

5. LCATS/CATS deficiency closeouts.

EETD continues to have an active inspection program by the Safety Coordinator, facility staff, and management, which produces numerous deficiency findings. All new findings are tracked in CATS. Our combined Level 1, 2, & 3 deficiency closure rate is 82% for PY06, including institutional deficiencies. With only one exception, all the deficiencies that we have been unable to close so far are waiting for Facilities action. Most of these open findings are institutional. Exempting those open findings that we have had little or no control over the corrective actions, our effective closure rate is at least in the mid-90% range.

We had 128 total findings discovered during this performance year. None of these had a High risk level. Highest priority was given to closing Medium risk level findings, and 100% of these were closed. Of all our Low risk level findings, only one remains open that is not institutional or waiting for Facilities action. We consider this a significant accomplishment and is a result of our increased attention to closing deficiencies as set forth in our goal for this year.

In addition to the many routine corrective actions that were completed this year, it is worth noting that we have an on-going project of identifying, assuring proper storage and testing, and encouraging the disposal of peroxide forming and other particularly hazardous chemicals.

3. Significant or Recurring EH&S Issues

Ergonomics.
We are making progress with workstation evaluations, using in-house evaluators as well as EH&S evaluators. Although EETD injury rates are low (by lab standards), over half of the injuries are ergonomic related. In the coming year, the Division intends to continue its efforts to do ergonomic training and evaluations, and improve ergonomic awareness throughout the Division. Many of our staff moved during this year, and their new offices are being evaluated for ergonomics on a regular basis.
Off-site work hazards.
There are staff that work off-site, and there is concern that our present system does not thoroughly identify potential hazards.
JHQ and Training completion rates.
While the Division has made substantial improvements in this area in the past few years, continued effort will be needed to maintain the high levels reached in PY06. The Assistant Division Director for Space and EH&S and the Safety Coordinator need to continue periodic reminders, and the inclusion of safety training in the PRD process also helps. Additionally, we would like to see improved speed with the training of new hires. Our Division training policy makes it clear that we expect the same standards of safety for all staff, including students and guests, and for all locations, including the UC campus and other off-site locations.

4. Possible Root Causes

As described last year, the difficulty in obtaining a consistent and appropriate degree of attention to EH&S issues within the Division appears to stem from several factors. An important — possibly the predominant — factor is 'cultural'. Until the last few years, safety issues often did not receive the level and consistency of attention required. This is also true in terms of incorporating recent changes in safety procedures into projects initiated years ago. However, as new personnel replace older, more rigid staff, the safety culture is improving in the Division.

A Lab-wide policy on ergonomics has been lacking. Computers are purchased, new staff are placed in offices, and existing staff move from office to office - all without an automatic concern or allotment of resources for ergonomics.

There has also been little Lab-wide guidance or policy on off-site work. Tracking the presence and nature of off-site work has been difficult. This issue has been identified by EH&S and the SRC, and an initial meeting with the Assistant Division Director (and SRC chair) and EH&S personnel occurred to begin the lab-wide process.

The role of the Lab regarding campus-based personnel is receiving attention at the SRC level, and a new MOU with campus was signed. However, it is still very difficult for a Division to implement policy, since lab-wide guidelines are often lacking.

5. Corrective Measures Planned For FY01

Specific "high effort" activities:

  • Ergonomic issues. We will continue the activities of our workstation ergonomic evaluations, using both our in-house evaluators and EH&S evaluators. Our goal is to conduct evaluations for all 182 target EETD active employees who are career or term, whether full time or part time, and who have not yet had an evaluation.
  • JHQ and Training completion. We will work with supervisors and employees/guests to meet the training requirements identified in the JHQ process and in specific work authorizations. We will attempt to speed the training of new hires. "Mission critical" training, such as that required by AHD's (currently at 97%) or for other specific work functions, will continue to receive emphasis.

Specific "moderate effort" activities:

  • Line management participation in EH&S. We will continue to have all work spaces examined multiple times per year, and involve senior Division management (including the Division Director) in walkthroughs. Other elements of the plan of action discussed earlier, such as promoting safety as an agenda item at meetings, will receive attention.
  • CATS Tracking and Closeouts. The CATS system sends out automatic reminders at specific intervals. In addition, specific follow-up activities — such as verification visits by the Division Safety Coordinator — will be undertaken. Effort will be made to provide more prompt notification of deficiencies after inspections. We will work with Facilities and EH&S to resolve issues that have caused extensive and frustrating delays in evaluating and closing findings.
  • Off-site work reviews. We will incorporate and attempt to resolve issues and comments arising from the use of our relatively new Off-site Safety Review form. We will expand the use of this form to all our off-site experimental work projects. The objective is to improve tracking and identification of off-site work, and ensure that off-site work hazards are identified and controlled.

6. Methods to Track Progress and Improvement

We now have in place a fairly complete recording keeping and tracking system used by the Division Safety Coordinator. This system is also used to prepare quarterly reports for the Division Director and the Division Council, describing the current status of Division EH&S activities, issues, etc. We also have the Project Safety Review process, implemented seven years ago, to provide EH&S information on new projects.

We will continue to periodically assess SAA compliance, in collaboration with EH&S personnel. We will annually review existing authorizations. Division health and safety personnel will work with the PI to develop new or amend existing authorizations as needed. The annual self-assessment process and periodic CATS deficiency reports to facility managers will continue.

In preparation for this report, the Division has continued to develop its record keeping and tracking systems. We expect to utilize these records to maintain and improve upon some of the key performance criteria, such as SAA compliance, AHD review, training status, and self-assessments.

In preparation for this report, the Division has continued to develop its record keeping and tracking systems. We expect to utilize these records to maintain and improve upon some of the key performance criteria, such as SAA compliance, AHD review, training status, and self-assessments.

III. PY 2006 EH&S Performance Criteria

Acronyms and glossary of terms (see also EETD EH&S Acronyms):

ADD:
Assistant Division Director for Space and EH&S — Don Lucas.
AHD:
Activity Hazard Document. Used to document hazards and procedures for projects that involve medium and higher hazards.
CATS:
LBNL Corrective Action Tracking System.
CMS:
Chemical Management System. (http://cms.lbl.gov)
DART:
Days Away, Restricted or Transferred case rate.
DSC:
Division Safety Coordinator — Guy Kelley.
GLA:
Generally Licensed Authorization. Covers low hazard radioactive sources.
HEAR:
Hazards, Equipment, Authorizations & Review Database. Division scope of work and inventory of hazards, equipment, and authorizations.
IH:
Industrial Hygiene. Typically refers to the Industrial Hygiene group of the EH&S Division.
JHQ:
Job Hazard Questionnaire.
LCATS:
Laboratory Corrective Action Tracking System. Old system being replaced by CATS.
NCAR:
Nonconformance and Corrective Action Report. Commonly used for serious violations of SAA and waste handling guidelines.
OCA:
Office of Contract Assurance.
ORPS:
Occurrence Reporting and Processing System.
PSR:
Project Safety Review. All continuing and proposed projects fill out the PSR form as part of the project renewal or proposal process (in addition to the NEPA/CEQA forms). See the PSR FAQ on the EETD EH&S webpage for further information.
QA:
Quality Assurance.
RWA:
Radiation Work Authorization.
SAA:
Satellite Accumulation Area.
SSA:
Sealed Source Authorization.
TRC:
Total Recordable Case rate.

PY 2006 EH&S Performance Criteria Table

 

Division Implementation Plan for PY07

PY07, Quarter1 (July - September)

  • Distribute Self-Assessment report to Division Management and discuss with Division Council.
  • PY06 SA follow-up: verify corrective actions and follow-up on issues raised.
  • Submit quarterly Training Report to Division Supervisors.
  • Conduct SAA assessment, in conjunction with EH&S.

PY07, Quarter 2 (October - December)

  • Submit PY07 1st Quarter Division Safety Report to the Safety Committee and Division Management, and discuss with Division Council.
  • Submit quarterly Training Report to Division Supervisors.
  • Conduct SAA assessment, in conjunction with EH&S.

PY07, Quarter 3 (January - March)

  • Submit PY07 2nd Quarter Division Safety Report to the Safety Committee and Division Management, and discuss with Division Council.
  • Submit quarterly Training Report to Division Supervisors.
  • Conduct SAA assessment in conjunction with EH&S.

PY07, Quarter 4 (April - June)

  • Submit PY07 3rd Quarter Division Safety Report to the Safety Committee and Division Management, and discuss with Division Council.
  • Submit quarterly Training Report to Division Supervisors.
  • Seek completion of JHQ's, and review training profiles for all employees and guests as part of the PRD process.
  • Conduct annual Self-Assessment of division research facilities, including update of the HEAR database as a review of hazards.
  • Review and update current Authorizations.
  • Prepare annual SA report on Division EH&S activities.
  • Conduct SAA assessment in conjunction with EH&S.

V. Appendix

Appendix 1. EETD EH&S Self-Assessment Database Tables

Performance by key criteria, FY96 through PY06

EET Division Self Assessment Performance Criteria Summary; No. 1 - Gas Monitor Calibration; No. 2 - Activity Hazard Document Review; No. 3 - Inspections; No. 4 - Chemical Inventory; No. 5 - Emergency Team Training; No. 6 - LBNL Required Training; No. 7 - Corrective Action Program (CATS); No. 8 - Radioactive Materials Compliance; No. 9 - SAAs; No. 10 - Waste Handling and Shipping; No. 11 - Peroxide Former Inventory & Control.

Appendix 2. EETD Integrated Safety Management Plan

Rev. 7, June 19, 2006

Appendix 3. Sample Quarterly Division Safety Report

(Report for Division senior management, July - September 2005)

Appendix 4. EETD Waste Minimization Program, Performance Year 2006

Appendix 5. Sample Safety Communications & Other Supporting Documents

1. & 2. "What's New in EETD" — Weekly Division newsletter regularly has safety topics

3. "Today at Berkeley Lab" — Daily Lab-wide newsletter regularly has safety topics

4. "EETD Quarterly SAA & Waste Management Newsletter"

5. "Building 90 News and Construction Update" — Periodic newsletter

6. "Carboys" — Sample of Safety Note sent when needed

7. "EETD Project Safety Review" form — Sample

8. "EETD Off-Site Safety Review" form — Sample

  • Contact Guy Kelley for copies of these documents.