Support Organizations Reporting to the Directors Office SORD

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Support Organizations Reporting to the
Directors Office(SORD)

• Environment, Safety and Health Management Review
• September 22, 2006

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SORD Management Reps

• Environment Management System
• D. Bauer, Management Representative
• Occupational Safety Health Management System
• N. Bernholc, Management Representative

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Why are we here?

• Discuss how we met the requirements for
• ISO 14001, Environmental Management System
• OHSAS 18001, Occupational Safety and Health
  Management System
• Reflect on our Performance
• Discuss our next step

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Agenda

• Introduction of EMS Rep
• Introduction of OSH Team Members
• Review of OSH Performance
• Review of Facility and Job hazards and activities
  that can cause injuries and illnesses
• OSH improvements (additional controls) identified
  through risk assessments
• OSH Performance, Injury/illness rates, Tier I
  Performance
• Summary of OSH Assessments (external audits,
  internal audits, occurrence reports and
  corrective actions, non conformance reports and
  corrective actions)
• Costs
• OSH implementation and maintenance costs

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Agenda (continued)

• FY07 Objectives
• Effects of Foreseeable Changes to Legislation
• Environmental Performance
• Sr. Management Discussion and Evaluation
• Identification of Improvement Actions
• Suitability of current ESSH Policy

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4.1 OSH Scope

• Scope
• All support organizations reporting to the
  Directors Office including the Directors
  Office.
• Description of SORDs OSH Program
• Occupational Safety and Health (OSH) Management
  System Program Description Manual for the Support
  Organizations Reporting to the Directors Office
• Final Rev. 0e 4/28/06

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SUPPORT ORGANIZATIONS REPORTING TO THE DIRECTOR
Director
Science Tech
Operations
CIO
Info Technology
Computational Science Center
Info Services
HR OMC
Legal
CEGPA
Finance
Diversity
Policy SP
Budget
Comm Rel
MediaCom
IAO
BSD
Educ Prog
FSD
PGA
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OSH Team Members
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5.2 SORD OSH Hazards
Establish JRAs and FRAs to manage significant
hazards

• Facility Hazards
• Traffic/vehicle
• Specialized equipment
• Bicycles
• Natural hazards (deer, ticks, etc)
• Recreational Activities
• Natural Phenomena Hazards (wind, snow, flood)
• Walking working surfaces
• Fire
• Poor indoor air quality

• Facility Specific Hazards
• Electrical
• Chemicals
• Confined Space
• Hand tools
• Noise
• Material Handling (including pinching, strain
  lifting, falling objects)
• Elevated work
• Walking/working surfaces
• Ergonomic repetitive motion
• Cashier
• X-rays
• Bloodborne pathogens
• Eye injuries

• Issues Complete Risk Assessments to address
  hazards associated with routine
  skill-of-the-worker tasks

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5.2 SORD OSH Hazards

• Personnel Security (original effort proposed for
  Lab-Wide implementation)
• Business Travel Domestic (original effort
  NRCO/CI proposed for Lab-Wide implementation)
• Business Travel Foreign Countries - Developed
  (original effort proposed for Lab-Wide
  implementation)
• Business Travel Foreign Countries -
  Underdeveloped and Sensitive Countries

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5.2 SORD JRAs and FRAs

• CEGPA 4 FRAs completed, 2 to be completed
• PG 16 JRAs and 1 FRA Completed, 13 JRAs to be
  completed
• PA 8 JRAs completed (all completed)
• Counter Intelligence
• 12 JRAs and 6 FRAs completed (all completed)
• 4 new JRAs identified as having Lab-Wide
  applicability
• Directors Office/Legal/ Policy Strategic
  Planning
• 1 JRA, 1 FRA completed (all completed)

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5.2 JRAs and FRAs

• Human Resources/Diversity
• 3 FRAs complete, 0 JRAs, 15 to be completed
• Human Resources/OMC
• 9 JRAs, and 1 FRAs complete (all completed)
• Internal Audit Oversight
• 4 JRAs and 1 JRA completed (all completed)

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5.2 JRAs and FRAs

• Information Services
• 4 JRAs and 3 FRAs completed (all completed)
• Information Technology
• 4 JRAs and 2 FRAs completed (3 JRAs to be
  completed 1 FRA to be completed)
• Computational Science Center
• 1 JRA and 1 FRA completed (all completed)
• Finance Directorate
• 4 JRAs and 2 FRAs completed (all completed)

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FRAs

• Many organizations have the challenges of
  working in a mixed-use, mixed occupancy/ownership
  facility

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5.3 OHSAS 18001 SORD Internal Audit

• Summary of OSH Assessments
• Initial results of internal audits
• 3 Noteworthy Practices
• No Major Non-Conformances
• 6 Minor Non-Conformances
• 6 Opportunities for Improvement
• Incorporation of auditors comments/suggestions
  underway vis-à-vis JRAs FRAs

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5.3 OHSAS 18001 SORD Internal Audit

• Noteworthy Practices
• HR has separate Objectives and Targets for the
  Child Development Center (CDC) and Red School
  House (RSH)
• Overall SORD has a good diversity and percentage
  of personnel participating in the JRA and FRA
  process.
• IA employees identified inside overhead falling
  object hazards and deer trapped in courtyard with
  person hazard. They held a safety meeting and
  agreed on corrective actions that should be
  implemented, management supported them and the
  findings were incorporated into the FRA.

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5.3 OHSAS 18001 SORD Internal Audit

• Minor Nonconformance 1
• Directors Office/Policy and Strategic
  Planning/Legal Office No need for priority list
  as there is only one FRA and only one JRA. D.
  Ports said they will be eventually preparing a
  JRA for Travel. To be completed in the next
  review.
• Diversity Office Human Resources JRAs are
  Prioritized. 0 out of 5 are complete.According
  to D. Ports, the DO owns space in building 475
  and they are applying the FRA by EENS for that
  facility.
• Info Technology has a prioritized list, but only
  1 JRA complete.Internal Audit Oversight JRAs
  are not prioritized.
• Minor Nonconformance 2
• SORD Although all organizations have an OSH Rep
  and OSHA POCs, some organizations do not have an
  ESH Coordinator (including IAO, CIO). This issue
  should be resolved.

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5.3 OHSAS 18001 SORD Internal Audit

• Minor Nonconformance 3
• Directors Office/Policy and Strategic
  Planning/Legal Office OHSAS POC could not
  produce R2A2s for documents select for audit (Pam
  Yerry). All R2A2s are kept by individuals. OHSAS
  POC (D. Ports) provided his R2A2 in DRAFT R2A2
  with no signatures or management approval. The
  audit could not determine if staffs R2A2s were
  updated to include OSH roles and
  responsibilities.
• Community Affairs (part of CEGPA) R2A2s reviewed
  included Kathleen Gurski, Catherine Osiecki, and
  Ken White. None of the R2A2s reviewed included
  the OSH responsibilities for Staff. Scott
  Bronson (ESH Coordinator, OSH POC) did not have
  an R2A2. Signed R2A2s were could be produced at
  the time of the audit and are on file with Dawn
  Mosoff.

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5.3 OHSAS 18001 SORD Internal Audit

• Minor Nonconformance 4
• SORD TQ-SAFEAWARE training will be required by
  all employees before registration audit
  (October). Not all employees have successfully
  completed the course.
• Minor Nonconformance 5
• Community Affairs Annual review of ESR did not
  occur for chemical experiments. Document control
  adequate but needs to indicate the location of
  official copy.
• Minor Nonconformance 6
• Some SORD organizations do not have JRAs and FRAs
  completed.

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5.3 OHSAS 18001 SORD Internal Audit

• Minor Nonconformance 7
• Directors Office/Policy and Strategic
  Planning/Legal Office Tier 1 deficiencies are
  not communicated for trending with the Quality
  Management Office.
• Minor Nonconformance 8
• Community Affairs Standard Operating Procedures
  maintained on the shared drive need to have
  disclaimer that they are the only official copy,
  otherwise, excellent document control.

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5.3 OHSAS 18001 SORD Internal Audit

• Opportunity for Improvement
• Directors Office/Policy and Strategic
  Planning/Legal Office
• Add Date Closed and Person Responsible columns on
  Tier 1 Log
• Should improve periodic review and reporting of
  progress towards meeting objectives and targets

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5.3 OHSAS 18001 SORD Internal Audit

• Opportunity for Improvement
• IAO
• Possible issue with the lack of labeling of the
  file room and the file cabinets. No labeling on
  file cabinets for security reasons. Suggestion
  for improvement Label the file cabinets and keep
  the file room locked.
• Targets and Objectives The organization chart
  for the division does not adequately reflect the
  names/titles of people named in the targets and
  objectives (i.e., OSH POC, ESH Coordinators,
  Chairs)

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5.3 OHSAS 18001 SORD Internal Audit

• Site-wide opportunities for improvement
• Create a procedure for when OSH elements and
  programs should be recommended for review.
• SBMS updates should be communicated down to
  workers based on BTMS training records (i.e.
  Personnel required to take Hazard Communication
  Training would be automatically be notified by
  email of any changes to the SBMS Working with
  Chemicals Subject Area.

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5.3 External OHSAS Audit NSF Desk Audit

• Three findings were identified in the desk audit
• Objectives, targets and programs were not
  available and/or accessible for each of the areas
  included in the Phase 3 scope for review.
• Status All Objectives and Targets have been
  identified for all SORD organizations. Programs
  are in different stages of implementation. Most
  are almost completed.
• No evidence of Phase 3 scope internal audits was
  provided or accessible for review.
• Status Internal audits for Phase 3 organizations
  were conducted August-September 2006 and will be
  posted on website as soon as reports are
  available.
• At least one management review has not been
  completed.
• Status Will be completed September 22, 2006.

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5.3 Assessments

• ISM Review of BNL (11/05)
• Institutional deficiency in areas of planning and
  feedback and improvement processes
• ISO 14001
• No other occupational related assessments were
  conducted this year in these departments
• Services were provided to the departments for
  safety and health reviews such as chemical
  sampling, noise sampling, and ergonomics

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5.4 Stakeholder Concerns

• Review issues and actions, if any, that are
  related to
• Activists No EMS/OSH issues have been raised
  regarding SORD activities
• Community No EMS/OSH issues have been raised
  regarding SORD activities
• Regulations None that have come through SORD
• Unions No EMS/OSH issues have been raised
  regarding SORD activities
• Employee Concerns Employee concerns were
  captured in JRAs/FRAs

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5.5 OSH Improvements

• Identified gaps in coverage for SORD
  organizations (lack of ESH Coordinators)
• Identified issues with lab wide concern which
  have not been addressed JRAs being considered
  for Lab-Wide implementation (Heightened
  awareness, rgeting, Travel)
• Identified issues of safety related to hearing
  alarms in remote locations
• Several organizations improved tracking of
  closure of Tier 1 findings
• Improvements in document revisions identified

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5.5 Identification of Key OSH

• NRCO - OSH Process improvements
• Designation of ESH Coordinator
• Implementation of Tier I reviews Incident
  reporting
• Heightened communication and awareness

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5.6 Performance Data
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FY 06 Occurrence Reports and Corrective Actions

• There was 1 occurrence report in ITD during FY06.
•        
• .

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5.6 Performance Data - BNL ORPS by Calendar Year
Report Submitted
As of 9/13/06
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5.6 Performance Data - ORPS Reports and
ActionsAs of August 31, 2006
ALD
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FY06 - Support Organizations and BNL as of 8/31/06
TRC Total Recordable Cases TRCR Total
Recordable Case Rate DART Days Away Restricted
Transferred
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5.6 Performance Data - First, Second Third
Quarter FY06 Tier 1 Inspection Results Combined
Total Findings - 1,889
Number of Findings
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5.6 Performance Data - First, Second Third
Quarters FY06 Tier 1 Inspection Results by
Directorate
Total Findings - 1,889
Number of Findings
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BNL Tier I InspectionsTop Seven Categories
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Tier 1 Inspection ResultsTop Ten
Categories/Quarter
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Tier 1 Facility Inspections - SORD

• CEGPA (PG, PA)
• CIO
• Directors Office (Legal Policy and Strategic
  Planning)
• HR Diversity, HR (185, 185A)
• OMC, TQ (703)
• Finance (BS, BU, FO)
• Counter Intelligence
• Information Services
• Information Technology
• Computational Science

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OSH Performance Tier I Inspections

• Some SORD organizations did not have Tier I
  inspections because they do not have ESH
  Coordinators and are not included in the
  Buildings Tier I inspections which are owned by
  other facilities (DB355A CIO IAO)
• Some organizations will be moving into the new
  administration building make sure they are
  covered.
• Typical deficiencies include general
  housekeeping, hazard ID postings, electrical
  deficiencies - electrical panel labeling,
  degrading electrical cords secured shelving
  broken step stools
• Process for formally tracking deficiencies are
  in various stages of maturity

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Director
Operations
CIO
IAO
Orphan organizations lacking Tier I or ESH
Coordinator Coverage
HENP
RHIC Users Group
Color Code
Phase 3
Phase 1
Phase 2
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5.7 OSH Targets and Objectives

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5.7 OSH Objectives and Targets FY06

• Objective 1 Registration of the Occupational
  Safety Health Management OHSAS 18001 System
• Directors Office, Finance Directorate, CEGPA,
  ITD,Computational Science Center, ISD, CIO, HR
  (Includes OMC, Training and Diversity)

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5.7 OSH Objectives and Targets FY06

• Objective 1 Registration of the Occupational
  Safety Health Management OHSAS 18001 System
• Task/Action
• Meet all target dates for Registration Ongoing
• Complete JRAs and FRAs 9/06 v
• Issue OSH Objectives Targets 4/06 v
• Improve OSH awareness by reviewing the OHSAS
  18001 program at meetings Ongoing
• Close corrective actions that result from the
  Registration Audit (as needed) TBD

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5.7 CIO OSH Objectives and Targets FY06
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5.7 CIO OSH Objectives and Targets FY06
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5.7 CIO OSH Objectives and Targets FY06
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5.7 CIO OSH Objectives and Targets FY06
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5.7 CIO OSH Objectives and Targets FY06
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5.7 CIO OSH Objectives and Targets FY06

• CIO Implementation of Lab-Wide JRAs
• Collaborative effort with OMC, EENS and SS
• Implications/ramifications for Lab management and
  stakeholders
• Needs assessment for training and awareness.

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5.7 CIO OSH Objectives and Targets FY06

• On track with FY06 Targets Objectives
• Formulation and identification of FY07 Targets
  Objectives underway
• Focus on implementation of coordinated Tier I
  process
• Implementation of additional controls identified
  through FRA/JRA process.

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5.7 CEGPA OSH Objectives and Targets FY06
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5.7 CEGPA OSH Objectives and Targets FY06
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5.7 Finance Directorate Objectives and Targets
FY06
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5.7 Finance Directorate Objectives and Targets FY
06
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5.7 Directors Office Objectives and Targets FY06
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5.7 Directors Office Objectives and Targets FY
06
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5.7 Directors Office Objectives and Targets FY
06
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5.7 Directors Office Objectives and Targets FY 06

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5.7 Directors Office Objectives and Targets FY 06
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5.7 IAO Objectives and Targets FY 06
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5.7 IAO Objectives and Targets FY 06
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5.7 IAO Objectives and Targets FY 06
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5.7 ISD Objectives and Targets FY 06
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5.7 ITD Objectives and Targets FY 06
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Management Review Decisions

• Are the objectives, targets and performance
  measures suitable taking into account the
  following factors
• Injuries/illnesses?
• Current and future regulatory requirements?
• Business interests, technological capability?
• Internal organizational or process changes?
• Should additional objectives, targets or
  performance measures be established?
• Summary of improvement initiatives identified

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5.8 OSH Costs and Resources
Contributed resources for the OHSAS 18001 Phase 3
for SORD Organization Registration Effort (Does
not include contributed ESHQ time)
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Effects of Foreseeable Changes to Legislation

• 10 CFR 851 Rule Worker Safety and Health
  Program
• Rule provides DOE with enforcement mechanism
  similar to PAAA
• Rule pulls in consensus requirements and makes
  them mandatory (e.g. ANSI, ASTM etc.)
• Rule published February 9, 2006
• Rule is effective/enforceable on February 9, 2007
• BNL must achieve compliance with Worker Safety
  and Health Program by February 9, 2007
• BNL must submit a written worker safety and
  health program by February 25, 2007
• BHSO must approve within 90 days of submittal
• No work may be performed after May 25, 2007
  without an approved plan

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Effects of Foreseeable Changes to Legislation

• Annual updates are required
• No grandfathering of pre-existing conditions
  must comply with rule on February 9, 2007
• Variances must be granted by Under Secretary
• Contractors are subject to civil penalty of up to
  70K per day per violation up to contract annual
  fee.
• Significant costs are expected by implementing 851

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Management Review Decisions

• Is the OSH Management System effective in
  achieving policy commitment?
• Is the OSHMS effective in achieving the
  objectives, targets and performance measures?
• Is the OSHMS adequate in terms of
• Resource allocation?
• Information systems?
• Organizational issues staff expertise
  procedural requirements

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Management Review Decisions

• Suitability of current ESSH Policy

Vision BNL is a world wide leader in scientific
research and demonstrates excellence in
protecting people, property and the environment.
Values BNL research explores the boundaries of
human knowledge for the benefit of humankind and
our environment.  We strive for excellence in all
our endeavors based on our values of personal,
professional and scientific integrity. We value
human life and the protection of our environment
above all else.  We pursue our vision with
passion and creativity in an environment of
openness, mutual respect, and inclusiveness.
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Management Review Decisions

• Suitability of current ESSH Policy? (continued)
• ESSH Excellence Principles
• Environment We plan and perform our research and
  operations in a manner that protects the
  environment, conserves resources, and prevents
  pollution.
• Safety We plan and perform work safely. We
  expect personal commitment to safety and take
  responsibility for the safety of ourselves and
  coworkers.
• Security We plan and perform our work in a
  manner that protects people, property,
  information, computing systems, and facilities.

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Management Review Decisions Suitability of
current ESSH Policy ?

• Health We plan and perform work and maintain our
  facilities in a manner that protects human health
  within our boundaries and surrounding community.
  We promote a healthy lifestyle for our workers
  and neighbors.
• Compliance We will achieve and maintain
  compliance with applicable ESSH requirements.
• Community We maintain proactive and constructive
  relationships with our employees, neighbors,
  regulators, DOE, and our other stakeholders. We
  openly communicate progress and performance.
• Continual Improvement We will continually
  improve ESSH performance. We will define,
  prioritize, and aggressively prevent, correct,
  and/or clean up existing environmental, safety,
  security, and health problems
• Compliance with this policy is the
  responsibility of every employee, contractor, and
  guest.
• In addition to my annual review of BNLs
  progress on ESSH goals and adherence to this
  policy, I invite all interested parties to
  provide me with input on our performance relative
  to this policy, and the policy itself.
• Sam Aronson