BROOKHAVEN NATIONAL LABORATORY

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BROOKHAVEN NATIONAL LABORATORY

• Institutional-Level
• OSH Management Review
• OHSAS 18001
• Safety and Health Management System
• December 19, 2006

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Purpose of Meeting

• Top management shall evaluate OSH Program for
• Suitability- Does it fit BNL operations
  systems?
• Adequacy-
• Does it meet requirements?
• Is it implemented appropriately?
• Effectiveness- Is it achieving the OSH Policy and
  Objectives?
• Identify possible need for changes to the Policy,
  Objectives, and/or other program elements, based
  on a review of key system components including
• Audits and assessments
• Changing Circumstances
• Commitment to Continual Improvement
• Output Minutes of this meeting, record of
  managements decisions

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Program Inter-Relationships
DOE Mandated Voluntary improvement
initiatives
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1. Discuss Suitability of the current OHS policy

• Feedback from line organizations Management
  Reviews in 2005 indicated a change was needed
• Team revised the Policy
• Line Organizations reviewed the changes
• BNL adopted the Policy
• Distributed to line organizations

See Policy and Handout pages 6 - 7

• Issues
• 1a. Communication of the new Policy may be less
  than adequate across the site
• Phase 3 workers did very well in their knowledge
  on their registration audit.
• 1b. Replacement of postings of the old Policy
  with the new revision has not been verified

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1. Discuss Suitability of the current OHS policy
1c. Does the new revised POLICY meet or improve
on these OHSAS 18001 requirements ?

• OHSAS 18001 Element 4.2 requires that the Policy
• Be appropriate to the nature and scale of the
  organizations OSH risks
• Include a commitment to continual improvement
• Include a commitment to at least comply with
  current applicable OSH legislation and with other
  requirements to which the organization
  subscribes
• Be documented, implemented, and maintained
• Be communicated to all employees with the intent
  that employees are made aware of their individual
  OSH obligations
• Be available to interested parties and
• Be reviewed periodically to ensure that it
  remains relevant and appropriate to the
  organization.

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2. Discuss The adequacy of current hazard
identification, risk assessment, and risk control
processes

• Risk Assessment
• Job Risk Assessments
• Facility Risk Assessments
• ISM Initiatives

See Handout pages 8 - 13

• ISSUE (from line organization Management Reviews)
  
• 2a. Some organizations want the site level JRAs
  to be maintained only at the site level (i.e.
  consolidate line organization versions)
• 2b. Create a sitewide Natural Hazards FRA
• 2c. Fire System Inspection Test and Maintenance
  Life safety (egress) features of older facilities
  legacy

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3. Discuss Recorded instances of procedures not
being effective

• Requirements Management
• NSF Registration Audit SHSD Industrial Hygiene
  procedure was not tracking Noise Hearing
  Conservation legal requirements.
• Internal audit- Safety Engineering- legal
  requirement management process not being
  conducted or documented.
• Arc Flash incident

See Handout pages 14 - 15
Issues 3a. Record of Decisions are not uniformly
documented for all OSH disciplines. (Legacy,
resource limited) 3b. Safety Engineering and
Industrial Hygiene requirements management
procedures in-place but lack resources for timely
review of regulations consensus standards (160
) for impact on OSH program.
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4. Discuss Adequacy of resources (financial,
personnel, material)

• Issues that require continued focus/emphasis
• Industrial Hygiene Personnel Exposure Monitoring
• Safety Engineering and Industrial Hygiene Program
  Administrators
• ESH support in small organizations, CFN, NSLS II
• Nationally Recognized Testing Lab Authority
  Having Jurisdiction
• Fire Protection
• Emergency Management
• Emergency Response

See Handout pages 16 - 23

• Issue
• 4a. Support for Safety Engineering and Industrial
  Hygiene areas is under weighted compared to other
  ESHQ programs
• 75 Programs covered by 11.5 SME (6/1 ratio)

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4. Discuss Adequacy of resources (financial,
personnel, material)

• Nationally Recognized Test Laboratory Approval
  (NRTL) of Electrical Equipment
• Applies to equipment built, acquired, or brought
  onto the BNL site and connected to a source of
  electrical power.
• Electrical equipment is inspected to ensure it is
  free from reasonably foreseeable risks due to
  electrical hazards.
• Electrical Equipment Inspections (EEI) determines
  that equipment has/is
• Enclosed energized parts,
• Bonded and grounded,
• Afforded adequate over-current protection.
• Can not cause a shock, burn or fire if used
  properly.

See Handout pages 22- 23
Issue 4b. 40,000 pieces of equipment need
Authority Having Jurisdiction (AHJ) approval
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5. Discuss The effectiveness of the hazard
reporting process

• BNL mechanisms for hazard reporting
• Tier I Process
• Events/Issues Management
• New process developed, implemented and assessed
  in 2006
• Safety reporting hotline
• S2 program
• OMC Clinic
• DOE Hotline
• RAR

See Handout pages 24 - 30
No Issues
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6. Discuss The effectiveness of the OHS
inspection process (i.e. Tier 1, Safety
Observations, etc.)
See Handout pages 31- 32

• Issues
• 6a. BNL needs more OSH SME field deployed
  (Feedback from ESH Coordinators).
• 6b. ESH Coordinators need additional OSH training
  (Feedback from ESH Coordinators).
• 6c. Fire Hazard Assessments 56 facilities 3
  complete 15 in-progress need Funding commitment
  to complete.
• 6d. Long periods of Open items submitted to the
  Traffic Safety Committee.

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7. Discuss Data relating to accidents and
incidents that have occurred and the output of
investigations

• Radiological Awareness Reports
• IH monitoring for noise, silica, chemicals,
  non-ionizing radiation, etc.
• ORPS
• Accident/ Injury/ Incident Data

See Handout pages 33 - 50
Issue 7a. Industrial Hygiene employee exposure
surveys not completed for all operations.
Sampling in FY06 indicates BNL may still have
some un-discovered exposure operations. The
probable areas are not in laboratories, but in
maintenance, construction, and non-lab research
operations.
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7. Discuss Data relating to accidents and
incidents that have occurred and the output of
investigations
See Handout page 47

• Issue
• 7b. FY07 DART and TRCR goals are very
  challenging.
• DART Goal equals 6 cases,
• TRCR goals equals 16 cases in a year.
• YTD performance is
• DART 1 case
• TRCR 5 cases

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Internal OSH Assessment
8. Discuss Results of internal and external OHS
management system audits

• OHSAS 18001 Internal Audits were conducted for
  Phase 1, 2 and 3 organizations at the
  organization level.
• Issues were reported in organizations Management
  Reviews,
• No Lab-wide issues are currently open from
  Internal Audits.
• Improvement Phase 1 and 2 reports were combined
  this year into a site report. Next year all
  Phases will be combined into one Audit report.

See Handout pages 51 - 56
No issues. All site issues addressed in
Corrective Action Plans and FY07 OSH objectives.
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8. Discuss Results of internal and external OHS
management system audits

• OSH External Audit
• June 2006 Combined ISO 14001-OHSAS 18001
  Surveillance Audit
• 0 Major nonconformances
• 0 Minor nonconformances
• 1 Opportunity for Improvement DOCUMENT CONTROL
• Nov 2006 Phase 3 ORR
• 0 Major nonconformances
• 0 Minor nonconformances
• 3 Opportunities for Improvement
• Nov 2006 Phase 3 Registration Audit
• 0 Major nonconformances
• 3 Minor nonconformances
• 3 Opportunities for Improvement Document
  Controls, Risk Assessments procedures

Site Level Issues are addressed in Corrective
Action Plans
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9. Discuss The state of preparedness for
emergency
Emergency Management/ Planning
See Handout pages 57 - 59

• Issues
• 9a. Office of Emergency Management (OEM) is
  comparably understaffed to complete the
  requirements and meet compliance
• 9b. Organizational drills (not conducted by OEM)
  are either not occurring or are not being
  documented
• 9c. CMS does not have all elements needed for
  Emergency Management purposes

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9. Discuss The state of preparedness for
emergency
Fire Department
See Handout pages 57 - 59

• Issues
• 9d. Fire Department staffing for fire response,
  hazardous materials, technical rescue, confined
  space rescue mutual aid does not meet NFPA 1710
  requirements.
• 9e. Emergency Medical Services DOE requires EMS
  to be on par with community.
• 9f. Fire Department equipment replacement.
• 9g. Site Fire Protection Needs Water supply
  system Fire alarm panels Heat Detectors
  Sprinkler head recall replacement Site Fire
  Alarm System

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- CAD has expanded JRAs with more worker input-
Safety Observation Program- Safety Recognition
Program (S3)
10. Discuss Improvements to the OHS management
system (e.g. new initiatives to be introduced or
expansions of existing initiatives)
See Handout pages 60 - 64
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OSH program Issues brought up from line
organizations OSH management reviews
10. Discuss Improvements to the OHS management
system (e.g. new initiatives to be introduced or
expansions of existing initiatives)
See Handout pages 60 - 64
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11. Discuss Effects of foreseeable changes to
legislation or technology

• 10 CFR 851 brings in new enforcement action to
  legal requirements in 2007
• Nanomaterials
• Employee Exposure Monitoring
• Engineering Controls

See Handout pages 65 - 71
Issues 11a. 10CFR851 Policy Council may need to
authorize funding for gaps in the Institutional
Corrective Action Plan 11b. 10CFR851 Dept.
Chair/Div. managers need to assure that a robust
line organizations Corrective Action Plan is
implemented to address gaps in their
department/division programs.
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12. Setting or updating of OHS objectives for
continual improvement in the forthcoming period
Status on FY06 Objectives, See Handout Pages 72-
79

• Continually improve the OSH management system.
  Expand registration to Phase 2 3 organizations
  and maintain OHSAS 18001 registration in Phase 1
  organizations.
• Close OSHA Inspection Findings and expand
  corrective action to un-cited deficiencies on
  OSHA Inspection Findings (Extent of Conditions)
• Improve Accident/Injury rate performance
• Design Mechanisms to encourage Zero Traffic
  violation
• Expand participation in the BNL Safety Solutions
  (S2) Program. Complete projects, Seek
  alternative funding to support and implement the
  program.

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12. Setting or updating of OHS objectives for
continual improvement in the forthcoming period
Status on FY06 Objectives, See Handout Pages 72-
79

• Improve the implementation of in the Mechanical
  Material Handling site program
• Compliance- 10CFR850 and 10CFR851
• Conduct Gap Analysis and Self Assessments
• Implement the Corrective Action Plan to eliminate
  gaps identified in the BHSO Assessment of
  Industrial Hygiene Monitoring
• Schedule and conduct regulatory OSH compliance
  assessments to evaluate compliance to applicable
  regulations on a three-year cycle

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12. Setting or updating of OHS objectives for
continual improvement in the forthcoming period
Status on FY06 Objectives, See Handout Pages 72-
79

• Develop and implement an Authority Having
  Jurisdiction (AHJ) program to approve equipment
  that does not have Nationally Recognized Testing
  Laboratory certification (NRTL)
• Develop and implement a program to conduct Arc
  Flash Calculations to conform to NFPA 70E
• Open the Laboratory to the public for safety
  related special emphasis programs such as Summer
  Sunday exhibits
• Develop a Safe Employee Recognition and Award
  program (S3)

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12. Setting or updating of OHS objectives for
continual improvement in the forthcoming period
Setting FY07 Objectives, See Handout Pages 77- 79

• Issue
• 12a. Line organizations need to re-focus
  attention on the content of FY07 objectives.
• Better defined measurable targets
• (Assigning owner and date was not an issue)
• (Based on NSF Phase 3 Registration Audit)

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12. Setting or updating of OHS objectives for
continual improvement in the forthcoming period

• IMPROVE THE OCCUPATIONAL SAFETY HEALTH
  MANAGEMENT SYSTEM (OSH)
• Integrate multiple BNL Management Systems related
  to OSH into more streamlined management systems)
  that are based on the principles and core
  functions of DOEs ISM and OHSAS.
• Complete the site level OHSAS 18001 registration
  and continually improve the OSH management system
  in registered organizations.
• CONDUCT OSHA EXTENT OF CONDITION REVIEWS
• Expand corrective action to un-cited deficiencies
  similar (i.e. like-instances) to the cited OSHA
  Inspection Findings (i.e. conduct an
  extent-of-condition review).
• Improve ladder and industrial stair safety by
  communicating key requirements for fixed stairs
  and ladders to Building Managers and key staff
  involved in Tier 1 inspections.
• IMPROVE ACCIDENT AND INJURY RATE PERFORMANCE
• Improve Accident/Injury injury rate performance
  DART 0.25 TRCR 0.65
• Design mechanisms to encourage Zero Traffic
  violations
• Expand participation in the BNL Safety Solutions
  (S2) Program. Institutionalize the Laboratory
  funding of this accident/injury prevention
  program.
• IMPROVE THE IMPLEMENTATION OF THE MATERIAL
  HANDLING TRAINING PROGRAM
• Implement Corrective Actions on deficiencies in
  the site mechanical material handling program
• Develop/revise new training material as needed
  for the mechanical material handling program,
  exploring outside vendor with equipment specific
  expertise.
• Develop lab-wide manual-lifting guidelines to
  reduce overexertion injuries.
• Improve facility level training by systematically
  evaluating the effectiveness of training through
  Field Observation and ensuring that required
  procedures and equipment are understood and
  utilized on the job. Provide tools (observation
  checklists) to facility experts to aid in field
  observation.

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12. Setting or updating of OHS objectives for
continual improvement in the forthcoming period

• COMPLIANCE - Achieve full compliance with
  applicable occupational safety health
  requirements.
• Actively participate in implementation of new
  initiates to achieve compliance with 10CFR850 and
  10CFR851
• Improve implementation of SBMS OSH Subject Area
  requirements
• Improve implement of BHSO IH Monitoring
  Assessment Corrective Action Plan to eliminate
  gaps in the Industrial Hygiene monitoring
  requirements.
• Conduct regulatory OSH compliance assessments
  that are integrated into a comprehensive audit
  schedule covering OSH, Fire Protection,
  Radiological Protection, Emergency Planning, etc.
  
• Implement the Authority Having Jurisdiction
  (AHJ) program (to approve electrical equipment
  that does not have Nationally Recognized Testing
  Laboratory (NRTL) certification) and 5-year Plan
  developed in FY05.
• Develop and implement a program to conduct Arc
  Flash Calculations to conform to NFPA 70E.
• Increase OSH awareness and requirement
  implementation by line organizations with OSH
  Subject Area training.
• COMMUNICATIONS - Improve communications, trust,
  and relationship with stakeholders on
  occupational safety health programs.
• Open the Laboratory to the public for safety
  related special emphasis programs such as Summer
  Sunday exhibits and Safety Week events.
• Seek a research oriented motivational speaker on
  safety awareness.
• Improve consultation and communication with
  employees on OSH issues.
• Enhance participation in the Safe Employee
  Recognition Award (S3) program.

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12. Setting or updating of OHS objectives for
continual improvement in the forthcoming period

• 7. STUDENT SAFETY Improve awareness and
  training of short term researchers and students
  in occupational safety health hazard control
  programs.
• Incorporate health and safety hazards with an
  emphasis on short term researchers and students
  (who have minimal work experience and familiarity
  with BNL OSH programs) into existing general
  employee training.
• Develop organization level training for short
  term researchers and students who are exposed to
  unique equipment and operations with health and
  safety hazards.
• 8. EMERGENCY PREPAREDNESS Improve awareness and
  training of staff in emergency preparedness and
  response actions.
• Develop and deliver Laboratory level incident
  drills to measure the effectiveness of response
  organizations and line organizations to emergency
  events.
• Enhance organization level staff knowledge and
  skills in emergency preparedness.
• 9. TRAVEL Improve awareness and staff in
  occupational safety health hazards of domestic
  and foreign travel.
• Develop Laboratory level training on health and
  safety hazards associated with domestic and
  foreign travel.
• Develop organization level awareness of health
  and safety hazards if line organization personnel
  encounter unique situations during domestic and
  foreign travel

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12. Setting or updating of OHS objectives for
continual improvement in the forthcoming period

• Senior Management feedback and direction
• Senior Management commitment to Continual
  Improvement
• Suitability- Adequacy- Effectiveness-
• Do the Objectives target Continual Improvement ?
• Do the Objectives address the current level of
  risk ?
• Is there adequate resources (financial,
  personnel, material) to meet the objectives ?
• Do the Objectives address foreseeable changes to
  legislation or technology ?
• Are the Objectives achieving the desired results
  ?
• Is there a need for changes?

Setting FY07 Objectives, See Handout Pages 77- 79
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