Environmental

1
Environmental Waste ManagementServices
Division

• Occupational Safety and Health Management Review
• September 19, 2005
• Anna Bou
• OHSAS 18001 Division Representative

2
Agenda

• 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

3
Agenda (continued)

• FY 05 Objectives
• Effects of Foreseeable Changes to Legislation
• Management Discussion
• Identification of Improvement Actions
• Suitability of current ESSH Policy

4
Job and Facility Risk Assessments

• Summary
• 37 JRAs completed for EWMSD
• 22 JRAs for WM, 2 for LTRA, 12 for Field
  Services, 1 for Env. Compliance
• 18 FRAs completed for EWMSD
• 5 FRAs for WM, 2 for LTRA, 9 for Field Services,
  2 for Env. Compliance
• All JRAs and FRAs as defined in the priority
  tables have been completed to date and are posted
  on the EWMSD OHSAS website. http//intranet.bnl.go
  v/esh/esd/OHSAS18001/

5
Facility and Job Hazards

• List of Hazards Identified through Risk
  Assessment Process

6
Facility and Job Hazards

• List of Hazards Identified through Risk
  Assessment Process

7
OSH Improvements

• Additional controls that resulted from the risk
  assessment process are being tracked for closure
  through Family ATS.

8
OSH Improvements

• (Continued)

9
Noted Weakness

• Noted weakness with the Risk Assessment Process
• Incident occurred recently where worked suffered
  back strain while handling/moving empty 55-gallon
  drums. This incident resulted in no lost work
  time. Upon review of the JRAs, it was noted that
  this hazard was not identified and that no JRA
  for this activity had been considered.
• Status New JRA for empty drum handling has
  been completed and posted.

10
Summary OSH Performance

• FY 05 EWMSD Summary OSH Performance
• Lost Work Day Cases 0
• BNL Traffic Violations 3 (parking, speeding,
  moving)
• Personnel Contamination Incidents 0
• First Aid Cases 0
• Occupational Injuries 1 (4/21/05 back sprain
  from moving empty drum)
• Not currently included as a target or tracked in
  EWMS SAP.

11
OSH Performance EWMS and Site Total Recordable
Case Rate (TRCR) (FY 02 FY 05)

• In FY02, there were 2 Recordable cases (3.57)
• In FY031 case (1.98)
• In FY042 cases (4.40)
• In FY051 case (2.43)
• - 4/21/05 acute low back strain from moving
  empty drum

12
OSH PerformanceEWMS and Site DART Rate (FY 02
FY 05)

• In FY 02, there were 2 DART cases. (3.57)
• In FY03, there was 1 DART case. (1.98)
• There were no DART cases for FY04 and FY05 YTD.
  (0.00)

13
OSH Performance Tier I Inspections

• All EWMS Tier Is are performed as scheduled.
• All Tier I findings were dispositioned within 90
  days.
• Typical deficiencies include general
  housekeeping, postings, drum labeling, electrical
  panel issues, degrading electrical cords,
  inoperable safety switches, waste storage and
  disposal issues, insect/animal issues,
  out-of-date placards.
• Improvements are continual as priorities and
  focus changes are requested by regulators, safety
  professionals and management.

14
BNL Tier I InspectionsTop Seven Categories
15
External OHSAS Audit NSF Desk Audit

• Findings and Status resulting from NSF Desk
  Audit, July 2005
• The list of Legal and Other Requirements is
  identified in the Interim Procedure as being
  located in the OHSAS Management System
  Description. Review of this document revealed
  that the information was not found in this
  document or other documents reviewed. Status
  Any ideas?
• There is insufficient evidence to determine if an
  awareness training program has been developed
  that address all the requirements in clause
  4.4.2. Status Reducing Accidents and Injuries
  in the Workplace is required training for all
  OHSAS Phase 2 staff. In addition, OHSAS
  Factsheets will be distributed to all
  supervisors and managers to be used as training
  tools for training sessions to be conducted prior
  to registration audits in November. Training
  actions for each supervisor/manager will be
  tracked in FATS.

16
External OHSAS Audit NSF Desk Audit

• No evidence of Phase 2 scope internal audits was
  provided or accessible for review. Status
  Internal audits for phase 2 organizations were
  conducted in July 2005 and will be posted on
  website as soon as reports are available.
• BNL did not provide a schedule of the Phase 2
  OHSAS audits that they plan to conduct. Status
  The schedule has been posted on the website and
  available for review.
• At least one management review has not been
  completed. Status Will be completed by/during
  the Readiness Review in September.

17
External OSHA Assessment FY 05 Status

• Total of 28 facility related citations 21
  complete
• 7 still pending in FY 05
• 1. Building 860 (Outside East of 860
  Manhole) The service vault had not been evaluated
  to determine if it was a permit-required confined
  space.
• 2. Building 865 (High Bay Area) The waste
  compacter was not guarded adequately in that
  employees in the work area were not protected
  from crushing injuries.
• 3. Building 810 (Yard) The open-sided
  platform on top of tanks 3 and 4 was not provided
  with a standard guardrail system.
• 4. Building 865 (High Bay) The walkway on
  the overhead Virginia crane had open ends,
  exposing a person to a fall hazard exceeding 30
  feet.

18
External OSHA Assessment - Status

• Pending citations (continued)
• 5. Building 811(Basement) The lights and
  switches in the basement area were not approved
  for wet and damp areas.
• 6. Building 865 (High Bay) The walkway on
  the Virginia crane had several holes that were
  not guarded or covered.
• 7. Building 865 (High Bay) The trolley on
  the Virginia 30-ton crane had no rail sweeps.

19
Internal Audit

• Internal Audit Conducted July 11-27, 2005
• Findings
• Based on interviews with workers, employees are
  not fully aware of the ESSH Policy. In addition,
  training on OHSAS should be reinforced. Status
  Policy cards have been distributed to all
  employees. OHSAS Factsheets will be used as
  training tools prior to registration audit.
• Employees not fully aware of who the OHSAS 18001
  Division Representative and the BNL OSH
  Management Representative are. Status The
  organizational chart has been updated in include
  OHSAS contacts, contact list has been posted on
  website, and OHSAS factsheets will be used as
  training tools.
• R2A2s have not been updated for all staff.
  Status R2A2s for every employee will be
  reviewed. Those not updated will be tracked in
  FATS.

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Internal Audit Findings

• Findings (continued)
• EWMS organization chart needs to be revised to
  include key OHSAS personnel. Status The chart
  has been updated and posted on the web. (FATS
  action)
• JRAs and FRAs need to be performed for the BMRR
  (building 491) for Waste Management Surveillance
  activities. Status In progress (FATS action)
• It was observed that WM does maintain CO monitors
  in some of their buildings that could be
  considered OSH monitoring. These instruments
  should be calibrated and put into a calibration
  program. Status In progress (FATS action)

21
Internal Audit Findings (continued)

• Guests and contractors are not involved or
  necessarily aware of the risk assessment process.
  Status Any ideas?
• Documentation of the retention period for records
  has not been established for OSH (site level
  issue). Status OSH retention schedule has been
  established and posted on website.

22
FY 05 Occurrence Reports and Corrective Actions

• Three Occurrence Reports issued for FY 05
• NYSDEC Notice of Violation for Improper Handling
  of Universal Waste Universal waste fluorescent
  light bulbs were not placed into proper
  containers/packages and were improperly labeled.
  Corrective actions included formal training and
  posting signs directing individuals to seek
  assistance (completed 2/3/05).

23
FY 05 Occurrence Reports and Corrective Actions

• Strontium-90 Groundwater SystemApproximately
  3,500 gallons of ground water had flooded
  building 670 when an extraction pump was placed
  in the manual mode (no automatic shutdown when
  alarm condition has been reached).There was no
  environmental release and no personnel
  contamination. Corrective actions included
  performing training sessions for field engineers
  on system operations, connecting building to BNL
  central alarm station, and evaluating all
  groundwater treatment systems for unintended
  manual operation.
• Personnel Exposure to Excessive Noise
• Upon the request of the LTRA group, noise
  surveys to evaluate noise levels during carbon
  changeouts were conducted. Employees at Building
  521 were found to be exposed to excessive noise.
•        
• .

24
FY 05 Occurrence Reports and Corrective Actions

• Two employees wearing noise dosimeters were
  exposed to noise levels slightly above the 85
  decibel standard. Three other employees not
  wearing noise dosimeters were also exposed. It
  was reported that all BNL personnel associated
  with this event are in the Noise and Hearing
  Conservation (NHC) program. The contractors have
  their own NHC programs.

25
FY 05 Occurrence Reports and Corrective Actions

• A critique was held on 6/7/05 and a written
  notification was sent to all five workers.
  Corrective actions included
• Revising IH SOP-96250 to require that when
  performing noise surveys or when wearing personal
  noise dosimeters, hearing protection shall be
  worn until it is verified that protection is not
  required.
• Workers are required to wear hearing protection
  while compressors are operating during carbon
  changeouts
• Area near compressors posted as hearing
  protection required.
• Develop and submit a Lessons Learned (LL) to the
  BNL and DOE LL databases.

26
Nonconformance Reports and Corrective Actions

• Eight Nonconformance Reports issued in FY 05
• Requisitions from Waste Management were submitted
  to procurement without QA review (11/10/04).
• Requisitioners at the WM program will be given a
  refresher training to emphasize the importance of
  proper QA review of requisitions. Completion
  date 12/15/04
• The requisitions of concern will be reviewed by
  QA and a memo written to their procurement file
  so that evidence of QA review is added to the
  procurement file. Completion date 12/15/04
• A follow-up review will be scheduled in the WM
  family ATS for June of 2005, to assure that
  future requisitions are being properly reviewed
  by QA. Completion date 11/19/04

27
Nonconformance Reports and Corrective Actions

• As a result of a recent Occurrence Reporting and
  Processing System (ORPS) report concerning a
  leaking radioactive waste bin, a review of WMF
  POs was done. PO Numbers were found to not have
  documented supplier evaluations as required by
  the Evaluation of Seller Quality Assurance (QA)
  Programs Subject Area (2/10/05).
• SOP WM-ADM-925, Inspection Acceptance Of
  Purchased Items, was revised to require that all
  items/services classified as ESHQ Risk Level A1
  or A2 must use qualified suppliers.

28
Nonconformance Reports and Corrective Actions

• Several unused 55 gallon drums stored at Bldg 855
  did not have an incoming inspection sticker
  (5/5/05). The root cause of this nonconformance
  is that ADM-SOP-925 does not require label
  accountability of the acceptance labels.
• - the procedure was revised to require that an
  accountability of labels will be done to assure
  that all items have been labeled.
• - All the unlabeled drums have been labeled.
• Four scales beyond Calibration Due Date of 3/05
• Calibration of Measurement and Test Equipment
  Procedure being developed.
• Scales have been calibrated

29
Nonconformance Reports and Corrective Actions

• The Certificate of Calibration for the CAS Caston
  Electronic Crane Scale had an As Found value of
  40140 lbs at an applied load of 40,000 lbs.,
  which is outside of the tolerance (? 80 lbs).
  (7/28/05)
• The crane scale was calibrated by Superior Scale
  Instrument Corp.
• No adverse ESHQ impacts
• The draft version of WM-ADM-925, Procurement
  Requirements And Inspection Acceptance Criteria
  For Purchased Items/Services rev. 1 was posted to
  the WM website (6/16/05). The correct version
  has been posted.

30
Nonconformance Reports and Corrective Actions

• Surveillances of WM SOPs, as required by the FY04
  SAP, were not conducted. An FY 05 schedule of
  surveillances has been developed and scheduled
  for completion by 9/23/05.
• While reviewing procedures for Nevada Test Site
  (NTS) certification, Waste Management (WM)
  program staff identified a deficiency in the
  review and implementation of standard operating
  procedures (SOPs)
• WM-SOP-578, Shipping Radioactive Waste, the text
  in the procedure did not reflect the work
  performed as outlined in the checklist.
• WM-ADM-900, Document Control Records Storage.
  The procedure refers to a number of obsolete
  practices previously employed by the WM program.

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Nonconformance Reports and Corrective Actions

• Corrective actions included
• Revise WM-SOP-940, Preparation of Procedures to
  include detailed requirements for performing
  triennial reviews and place a triennial review
  completion on the cover page of each procedure,
  as they are revised/changed. (completed)
• Establish a schedule and enter into the WM Family
  ATS to review all WM SOPs for applicability, and
  reflection of actual WM Operations

32
OSH Costs and Resources

• Contributed resources for the OHSAS 18001 Phase 2
  Registration Effort
• Implementation of Additional Controls from the
  Risk assessment Process
• 37 JRAs
• Approx. 450 person-hours (managers, safety
  professionals and workers)
• 18 FRAs
• Approx. 150 person-hours
• Training
• Approx. 250 person-hours

• 50,000
• 4,500
• 45,000
• 15,000
• 25,000
• Total 139.5 K

33
EWMS OSH Objectives and Targets FY05Objective
Injury-Free Workplace

• Target Safety and Health Measures (Supports
  Critical Outcome 3.4.1)
• Zero OSHA lost work day cases (work related)
• Status Year to date Lost Work Day Cases 0
• Zero personnel contamination incidents
• Status Year to date personnel contamination
  incidents 0
• Zero BNL traffic violations
• Status Year to date traffic violations 3
• Zero first aid cases
• Status Year to date First Aid Cases 0

34
EWMS OSH Objectives and Targets FY05 Objective
Injury-Free Workplace

• Conduct Tier I Safety Surveys and Disposition
  actions
• Disposition Tier I findings within 90 days and
  perform as scheduled
• Status All EWMS Tier Is were performed as
  scheduled and findings dispositioned in 90 days.
• Achieve OHSAS 18001 registration according to BNL
  established target dates
• Status All JRAs and FRAs identified have been
  completed. Desk audit and internal audit
  completed with no surprises. NSF Readiness
  Review scheduled for for week of 9/18/05.
  Registration audit scheduled for November.

35
EWMS OSH Objectives and Targets FY05 Objective
Injury-Free Workplace

• Management walk through of operations areas and
  participation in Tier I Inspections
• Managers/supervisors to perform 2 walkthroughs
  per week and 2 Tier Is per year
• Status In progress
• Training and Qualification
• Completion of required courses Employees 90,
  Guests/ Contractors 80
• Status Employees ES98, WM97
• Guests ES88, WM100

36
EWMS OSH Objectives and Targets FY05Objective
Compliance with Laws, Regulations

• FY 05 BNL Required Assessments for All
  Organizations
• Emergency Preparedness Shelter-in-Place
• Worker Safety and Health Lockout/Tagout
• Worker Safety and Health Interlock Safety for
  Protection of Personnel
• Implement additional controls identified through
  risk assessment process
• Status Additional controls have been identified
  and tracked through FATS. All actions have been
  closed.
• Annual review of 1/3 of JRAs/FRAs to begin FY
  06.

37
Effects of Foreseeable Changes to Legislation

• 10 CFR 851 Rule Worker Safety and Health
  Program Proposed Rule
• Rule provides DOE with enforcement mechanism
  similar to PAAA
• Rule pulls in consensus requirements and makes
  them mandatory (e.g. ANSI, ASTM etc.)
• Rule first published in 12/03 to codify existing
  practices in order to ensure worker safety and
  Health
• Final comments due and sent 4/15/05
• Final rule could be promulgated in as little as 6
  months from end of comment period

38
Effects of Foreseeable Changes to Legislation

• Contractors must achieve compliance with Rule
  within 1 year of effective date
• We must reapply for all waivers (exemption
  process)
• 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
• Initial implementation/administration 600K
• Facility upgrades to meet codes 50.7
  million
• Ongoing maintenance activities 1.1
  million
• Total estimated lab impact 52.4
  million

39
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

40
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
• Track to closure all EWMS Tier I Findings in FATS
• Revise OSH MS Description to include list of
  legal and other requirements
• Add zero occupational injuries as target for SAP.

41
Management Review Decisions

• Suitability of current ESSH Policy

• Employees, Contractors and Guests We will
  provide a safe and healthy workplace, striving to
  prevent injuries and illnesses, promoting healthy
  lifestyles, and encouraging respect for the
  environment. We will ensure our employees,
  contractors, and guests have the awareness,
  skills, and knowledge to carry out this policy.
• Compliance We will meet all applicable ESSH laws
  and BNL Standards Based Management System,
  Integrated Safety Management, and Integrated
  Safeguards and Security Management requirements.
• Integration We will integrate ESSH principles
  into our research and operations activities. We
  will integrate hazard prevention/reduction,
  pollution prevention/waste minimization, resource
  conservation, security, and compliance into all
  of our planning and decision-making. We will
  adopt cost-effective practices that eliminate,
  minimize, or mitigate environmental impacts and
  control safety, security, and health risks and
  vulnerabilities.
• Security We will work in compliance with DOEs
  ISSM Program and systematically integrate
  safeguards and security into management and work
  practices at all levels, so that the laboratory
  missions are accomplished in a safe and secure
  manner.
• Sustainable Development We will strive to
  conserve resources and minimize or eliminate
  adverse ESH effects and risks that may be
  associated with our research and operations. We
  will manage our programs in a manner that
  protects the ecosystem and employee/public
  health.
• Stakeholders We will work with our stakeholders
  to help them address their ESSH needs. We will
  maintain a positive, proactive, and constructive
  relationship with our neighbors in the community,
  regulators, DOE, and our other stakeholders. We
  will openly communicate with stakeholders on our
  progress and performance.
• Community and Government We will participate in
  community and government ESSH initiatives. We
  will define, prioritize, and aggressively
  prevent, correct, and/or clean up existing
  environmental, security, and occupational safety
  and health problems.