Management Review Presentation

1

Occupational Safety Health Management
Review ESH Directorate 11/19/07
Final Rev0 11/16/07
2
Management Review Scope

• Review the ESH Directorates OHS management
  system to ensure its continuing suitability,
  adequacy and effectiveness.
• Scope includes only ESH Directorates facilities,
  experiments and operations to determine that they
  are managed in accordance with the OSH Management
  Systems.
• (ESHs Divisions role as service provider (on
  EMS, OSH, Rad) to all of BNL is covered in the
  site OSH Management Review).
• Warning There will be frequent prompts for
  senior managers comments/decisions on the need
  for change or improvement throughout the
  presentation.

3
Format of the presentationTopic Heading

• Issue
• Details on the finding/ concern/
  non-conformance
• Suggested Path forward
• Record of Decision
• ___Do XXX
• ___Do YYY
• ___Accept Risk

• Details on the issue to be reviewed.
• Item 1
• Item 2
• etc.

• Recommendation
• Details on the suggested improvement, change,
  or path of action on an issue
• - or-
• No improvement, change, or new action
• Record of Decision
• ___Do xxx
• ___Do YYY

4
Agenda of Topics
Section 1 Overview of Management System and
Financial Investments Section 2 Evaluation of
Completeness of Hazard evaluations Section 3
Review of OSH Performance- Audits and
Assessments Section 4 Review of OSH
Performance- Lead and Trailing Indicators Section
5 Review of Performance on Injury and Illness
Improvements Initiatives Section 6 Review of
Performance on FY07 OSH Objectives Section
7 Communication, participation and
consultation Section 8 Changing Circumstances
Section 9 Planned Injury and Illness
Initiatives Objectives for FY08 Section 10
Management Review Questions
5
Section 1 Overview of Management System and
Financial Investments

• Overview
• of the ESH Directorate's
• OSH Management System

• Personnel
• Programs
• Financial Investments

6
Overview of the ESH Directorate's OSH Management
System
Recommendation This alignment of resources is
working and there is no suggested improvement,
change, or new action Record of
Decision ___Accept current allocation of
resources ___Change
Facility Support Rep. D. Ryan Acting
ESH Coordinator K. Conkling
ESH Directorate ALD (Acting) M. Bebon
SH Representative J. Peters
Work Control Manager K. Conkling
OSH Mgmt Representative R. Selvey
Enviro. Compliance Rep. A. Bou
OHSAS 18001 Service Providers- Contributed
Resources
Radiological Control Division Division Manager C.
Schaefer
Safety Health Services Division Division
Manager P. Williams
Enviro. Waste Mgmt Serv. Div. Division
Manager G. Goode
OSH Point of Contact K. Conkling
OSH Point of Contact R. Selvey
OSH Point of Contact A. Bou
7
Overview of the ESH Directorate's OSH Management
System
Facility Support Rep. D. Ryan Acting
ESH Coordinator K. Conkling
ESH Directorate ALD (Acting) M. Bebon
Purchased
SH Representative J. Peters
Work Control Manager K. Conkling
ESHD Expert support to ESHD operations
Enviro. Compliance Rep. A. Bou
OSH Mgmt Representative R. Selvey

• Issue
• Safety and Health Representative coverage
  (0.1FTE) is at the bare-bones level, i.e.
  reactive only.
• The staffing level is not meeting the needs of
  the Directorate.
• At least 0.5 FTE SHR coverage is needed.
• This will be discussed in more detail later after
  presentation of more details.

Radiological Control Division Division Manager C.
Schaefer
Safety Health Services Division Division
Manager P. Williams
Enviro. Waste Mgmt Serv. Div. Division
Manager G. Goode
OSH Point of Contact K. Conkling
OSH Point of Contact R. Selvey
OSH Point of Contact A. Bou
8
Overview of the ESH Directorate's OSH Program
Changes in Personnel in FY07/FY08
Facility Support Rep. D. Ryan Acting
ESH Coordinator K. Conkling
ESH Directorate ALD (Acting) M. Bebon
SH Representative J. Peters
Work Control Manager K. Conkling
OSH Mgmt Representative R. Selvey
Enviro. Compliance Rep. A. Bou
Radiological Control Division Division Manager C.
Schaefer
Safety Health Services Division Division
Manager P. Williams
Enviro. Waste Mgmt Serv. Div. Division
Manager G. Goode
OSH Point of Contact K. Conkling
OSH Point of Contact R. Selvey
OSH Point of Contact A. Bou
9
Overview of the ESH Directorate's OSH Program
Changes in Personnel in FY07/FY08
Facility Support Rep. D. Ryan Acting
ESH Coordinator K. Conkling
ESH Directorate ALD (Acting) M. Bebon
SH Representative J. Peters
Work Control Manager K. Conkling
OSH Mgmt Representative R. Selvey
Enviro. Compliance Rep. A. Bou
Radiological Control Division Division Manager C.
Schaefer
Safety Health Services Division Division
Manager P. Williams
Enviro. Waste Mgmt Serv. Div. Division
Manager G. Goode

• Issue
• FS Representative position needs to be filled
• Interviews are underway, Successful completion
  is anticipated by close end of Q1.
• Record of Decision
• __Continue on the pathway to filling this
  position
• __Other

• Issue
• ESH ALD Position needs to be filled
• Interviews are underway, Successful completion
  is anticipated by February ???
• Record of Decision
• __Continue on the pathway to filling this
  position
• __Other

OSH Point of Contact K. Conkling
OSH Point of Contact R. Selvey
OSH Point of Contact A. Bou
10
Overview of the ESH Directorate's OSH Program
Changes in Personnel in FY07/FY08
Facility Support Rep. D. Ryan Acting
ESH Coordinator K. Conkling
ESH Directorate ALD (Acting) M. Bebon
SH Representative J. Peters
OSH Mgmt Representative R. Selvey

• Issue ORGANIZATION CHANGE OCCURRED -
  Management of Change was not adequate- Did not
  address support roles such as ESH Coordinator.
• QMO Office has moved outside of EHS Directorate
• Does QMO need to move into another organizations
  OSH program ?
• Record of Decision
• ___Keep in ESHD Program
• ___Move to ???
• ___Move to Support Organizations Reporting to the
  Director group
• ___Other

Enviro. Compliance Rep. A. Bou
Quality Management Office Office Manager R. Lebel
Radiological Control Division Division Manager C.
Schaefer
Safety Health Services Division Division
Manager P. Williams
Enviro. Waste Mgmt Serv. Div. Division
Manager G. Goode
OSH Point of Contact K. Conkling
OSH Point of Contact R. Selvey
OSH Point of Contact A. Bou
11
Financial InvestmentsOSH Resources/Cost- OHSAS
18001 Program

• Issue Resource Allocation is not sufficient
• OHSAS Site Project Manager is currently a
  contributed resource (0.2 FTE) from the SHSD
  Industrial Hygiene Group. This was an issue in
  last years Site OSH Management Review that was
  not EFFECTIVELY addressed.
• Record of Decision to be made later after
  additional information is presented

12
Financial InvestmentsOSH Resources/Cost- Worker
Safety Health Program

• Issue Resource Allocation is not sufficient
• The Safety Health Representative coverage is
  currently allotted too few hours (100/year) to
  provide proper oversight of ESH Directorate
  operations, especially considering the changing
  nature of EWMSD chemical handling activities.
  IH Monitoring, Tier 1 Walk-thru, WPC reviews
• Coverage for Instrumentation/Calibration Lab,
  Personnel Dosimetry Lab LTRA, WMF, IH Lab
  EC/RCD/IH field work, Administrative offices.
• Record of Decision to be made later after
  additional information is presented

• Recommendation
• With the exception of SH Rep coverage, this
  alignment of resources is working and there is no
  suggested improvement, change, or new action
• Record of Decision
• ___Accept current allocation of resources
• ___Change

13
Overview of the ESH Directorate's OSH Management
System

• Current Directorate Division level
  documentation system works.
• Written program did well on latest NSF Audit.

• Written OSH Program Centralized at Directorate
  level
• Directorate OSH Web Site
• Worker Safety Health Committee DH-ADM-006
• OSH Program Description DH-SOP-007
• Internal Audit
• Management Review
• Written Program Maintained at Division Level
• Division OSH Web Sites
• Objectives
• Hazard List Risk Assessments
• Records and Document Control Management

• Issue Changing Circumstances Management of
  Change was not adequately addressed.
• Quality Office remains in the DH-SOP-007 ESHQ
  OSH Program Description.
• Record of Decision
• ___Revise to remove QMO. Transfer ownership of
  DH-SOP-007 to DH.
• ___Leave QMO in the documentation. Retain
  ownership of SOP in QMO.
• ___Await new ALD for decision on action
• ___Other

14
Overview of the ESH Directorate's OSH Management
System

• Worker Occupational Safety Health (WOSH)
  Committee
• Charter
• Governing Procedure
• Web page
• Suggestion Form
• Regular Scheduled Meetings (3 in FY07)
• Published Minutes
• Log of Resolutions
• Membership
• Fred Horn, Chair, SHSD
• Bill Zak, RCD
• Carol Ogeka, ESH Administration
• James Trombacco, EWMSD
• Maria Beckman, ESH Directorate

• Recommendation
• Based on input from members, meetings were scaled
  back to Quarterly in FY07.
• Committee functions well.
• No major changes needed.
• Changes in membership will occur this year (3
  years cycle ends for the entire team)
• Record of Decision
• ___No changes to program other than planned
  personnel assignments
• ___Action

Number of Meetings Issues
15
ESSH Policy

• ESH Directorates divisions have posted
  controlled copies of the Policy in our buildings.
• Also accessible from the ESHD Web Site
• No issues determined in Internal Audit or NSF
  Audits regarding ESHD staff understanding or
  accessing the policy.

• Recommendation
• No issues or changes needed in Policy
• No changes needed in ESHD Objectives regarding
  ESSH Policy
• Record of Decision
• ___No new action or Objectives
• ___Action

16
Section 2 Evaluation of Completeness of Hazard
evaluations

• Hazard Identification,
• Risk Assessment and Risk Control

• Evaluate completeness of hazard list.
• Review activities that can cause injuries and
  illness (the organizations hazards).

17
Hazard Identification, Risk Assessment and Risk
Control Evaluate the Completeness of the hazard
Lists

• Striking overhead utilities
• Chemical contact (spills, splashes)
• Eye Injury
• Explosion Fire
• ODH Confined Space
• Natural Hazards- Insects, Ticks, etc Heat Stress,
  Weather
• Radiological contamination in areas
• Chemical contamination in areas
• Non-ionizing radiation in areas
• Communicable Disease
• Chemical chemical container handling
• Detergents, hot water from cleaning equipment
• Computer Use CTD, RSI Building Related Illnesses

• Ergonomics- lifting
• Struck by Falling Objects
• Flying Debris
• Cuts/abrasions on glassware, sharp objects
• Trapped, smashed extremities
• Elevated work- falls
• Slips Trips Falls- same level
• Bump to head during required movements
• Being struck by machinery
• Automobile Accidents
• Compressed Gas release
• Toxic Gas Exposure
• High Noise
• Electric shock
• Back Injuries from material handling, lifting,
  bending
• Poor indoor air quality
• Ergonomic hazards (repetitive motion injuries)

• Recommendation The OSH Program is adequate for
  our operations
• ESHDs sub-set of hazards fall within BNLs
  hazard list i.e. no additional hazards.
• Controls are in-place for hazards. All risks
  are controlled to acceptable.
• No new OSH Hazards expected in FY08
• No new Objectives needed.
• Record of Decision
• __No change in Objectives is needed No change
  in controls
• __Action

18
Section 3 Review of OSH Performance

• OSH Audits/Assessments

• Summarize OSH Related assessments and results
• Emphasize the corrective actions that were
  implements to prevent recurrence.
• Review Non-conformances, internal OSH Audit,
  External OSH Audit

19
Results of OSH related Audits/Assessments

• Internal Audit OHSAS by BNL
• External Audit OHSAS by NSF
• EMS and OSH Compliance
• Internal Multi-topic Self Assessments of OSH
  Programs
• DOE
• External Regulators
• Tier 1
• Other

20
Results of Audits

• OSH Internal Audit
• Site Internal EMS/OSH Audit conducted by SHSD and
  EWMSD February 2007
• OSH Major Non-conformances None
• OSH Minor Non-conformances 1
• EWMSD Risk Assessments were not reviewed in 3 yr
  cycle. - CORRECTED
• Opportunities for Improvement
• EWMSD FRA- Reduction on Added Controls not
  calculated. - CORRECTED
• 2 Issues involving SHSD role of support to BNL
• SHSD Improve SH Rep- quantity and consistency
  of support person assigned. Partial Quantity-
  increased by 2 FTE Quality- still under
  resolution.
• Guidance on HF should be revised. Closed

• Issues did not have a pattern within ESHQD. Each
  finding was unique to one organization.
• No problems of a systemic nature were raised by
  audit.
• Recommendation
• Corrective action on findings were covered in
  ATS.
• SHSD addressed SH Rep Quality issue with new FY08
  Objectives.
• No additional FY08 Objectives needed.
• Record of Decision
• ___ No new Objectives or program changes are
  needed
• ___Action

21
Results of Audits

• OSH External Audit
• Phase 3 NSF (RCD/ SHSD) -Dec 2006
• MINOR NC RCD/ SHSD/ QMO- FRA/JRA Additional
  Controls column irregularities CORRECTED
• MINOR NC SHSD - Document Control of a training
  form- CORRECTED
• MINOR NC SHSD - Requirement Management- missing
  driver- CORRECTED
• Site Re-registration NSF (EWMSD, RCD, SHSD, QMO)-
  May 2007 No issues for ESH Directorate in its
  operations.

22
Results of Audits

• OSH Compliance
• Internal Multi-topic- Industrial Hygiene
  (Bloodborne Pathogens, Chemical Use, Confined
  Spaces, and Respiratory Protection)
• No Major findings on ESH Directorates operations
• 1 Minor NC for SHSD to revise Respirator Fit Test
  written procedure
• Internal Control Documentation no issues.
• Extent of Condition- Calibration ESHQ
  Directorates divisions received praise for their
  calibration programs design and implementation.
• Regulators- No Audit
• DOE- BHSO Exhaust Ventilation (no report issued
  yet)

• No major problems in ESH Directorate operations
  were identified.
• The Corrective actions needed for in improvements
  in SHSDs role as fit testing service provider
  are being tracked in ATS.
• Recommendation
• No new Objectives are needed.
• Record of Decision
• ___ No new Objectives or actions are needed
• ___Action

23
Follow-up action from FY06 OSH Management Review
September 18, 2006 Meeting Minutes were taken
No OSH Issues were identified. No Open Items
were tracked. Are the ESHQ Directorate
Occupational Safety and Health and Environmental
Management Systems effective in achieving ESSH
policy commitments? Response Yes, the program is
effective only if its implemented. Are the
ESHQ Directorate Occupational Safety and Health
and Environmental Management Systems effective in
achieving ESHQ ESH objectives, targets and
performance measures? Response Yes, the program
is effective only if its implemented. Are the
ESHQ Directorate Occupational Safety and Health
and Environmental Management Systems adequate in
terms of Identifying Significant Aspects and
Impacts? Resource Allocation? Information
Systems? Staff Expertise? Procedural
Requirements? Response Self-assessment process
helps to identify areas for improvement and
sometimes significant weaknesses. Keep that in
mind when we look forward to putting together the
targets and objectives for next year to
strengthen these areas. Program is adequate,
implementation is difficult. Hard to say its an
inadequate program.
24
Follow-up action from FY06 OSH Management Review

• Are the objectives, targets and performance
  measures for these management systems suitable in
  terms of
• Injuries /illnesses and environmental impacts?
• Concerns of stakeholders?
• Current and future regulatory requirements?
• Business interests technological capability?
• Internal organizational or process changes?
• Should additional objectives, targets or
  performance measures be established?
• Response Yes, they are suitable. There are
  certain program improvements that are going to
  help.
• Recommended revisions to
• ESSH policy and commitments?
• Objectives, Targets and Performance Measures?
• Program elements?
• Response ESSH Policy has recently been updated
  after feedback that the policy was too wordy and
  hard to remember.

25
OSH Performance Leading Trailing Indicators
Section 4 Review of OSH Performance

• Injury/illness rates and trends
• Tier 1 performance
• OSH related critiques
• Occurrence Reports
• Injury/illness rates and trends at other DOE
  laboratories.

26
(No Transcript)
27
FY 07 OSH Performance

• OI EWMSD Technician received multiple chigger
  bites from outdoor work
• OI RCD Back Injury exiting truck

28
EWMSD - OSH Performance Injury/illness rates
and trends (FY00 FY07)
29
Performance Data

• Injury/illness rates and trends
• SHSD no injuries/illness in multiple years.
• RCD FY06 to FY07 no change
• EWMSD previous graph
• OSH related critiques
• RCD 1 regarding Bldg 348 source jam RAR
  Critique RCD-07-04
• Occurrence reports none

30
Corrective and Preventative Actions

• Review OSH Incidents
• Causal Analyses RCD 4
• ORPS none
• PAAA none
• Events/Issues Management Occurrences
• EWMSD 1 Occurrence Report

• Status of corrective and preventative actions
• ATS Status
• SHSD One preventative action on SHSD HEPA Filter
  Testing operations. Completed.
• RCD On time completion rate 80 one open
  regarding work planning done by RCD personnel.
• ORPS Reports and Corrective Actions
• EWMSD one
• Internal Corrective Actions
• SHSD ATS closure was selected in SHSD FY07
  Objectives. Improvement was seen.

31
EWMSD Corrective and Preventative Actions

• One Occurrence Report issued for FY 07
• Identification by the DOE of Unanalyzed Hazards
  in the Nuclear Facility at the Waste Management
  Facility
• The Documented Safety Analysis did not identify
  four potential accident scenarios (loss of power
  in bldg. 870, lightning strike, propane tank
  explosion in bldg. 865, and propane tank
  explosion in bldg. 870).
• New controls were developed and incorporated into
  WMF operating procedures.

Recommendation No new initiatives or Objectives
needed in FY08 to address ESHD internal
operations Record of Decision ___No additional
actions ___New Action
32
Tier I Inspections

• EWMS
• All Tier 1s are performed as scheduled.
• All Tier 1 findings were dispositioned within 90
  days.
• ES inspections had 15 findings, minor issues
• LTRA had 37 issues (electrical safety
  distribution and working environment plant)
• WM had 57 issues (housekeeping, working
  environment plant, working environment
  department, electrical safety equipment, and
  chemical safety storage)
• Improvements are continual as priorities and
  focus changes are requested by regulators, safety
  professionals and management.
• RCD
• All scheduled Tier 1s were completed.
• Quarterly in Bldg 348
• Annual Bldg 490, 120 all F/S offices in
  deployed buildings also QMO in Building 902C
• SHSD Participated in the ESHQ Directorate
  level Tier 1 process. Annual in Bldg 120.
• IH Group conducted 13 internal mgmt walk-through
  inspections in Building 120.

33
Monitoring for Compliance

• 40 Industrial Hygiene Exposure Monitoring Samples
  were taken on ESH Staff in FY07.
• EWMSD 20
• RCD 8
• SHSD12
• Hazards Monitored
• Noise
• Airborne contaminants2-Butoxyethanol Acetone
  Cadmium Hexane Isofluorane Mercury Metals
  Naphtha Respirable Dust Silica VOCs Welding
  Fumes
• No over exposures were recorded.
• 2 instances exceed the ACGIH TLV but were in
  compliance based on use of PPE. (Mercury in WM
  Silica in WM)
• 38 were below exposure limits.

34
Monitoring for Compliance

• Issue
• ESH Directorate operations have not been fully
  characterized for IH hazards.
• Staffing level for the SH Representative
  assigned to ESHD limits the pace of closure of
  this gap. This issue would be solved by more
  time assigned to the SH Rep.
• Record of Decision
• ___No additional actions or staffing to
  accelerate pace.
• ___Address with decision to be made on SH
  representative later.
• ___Other

35
Monitoring for Compliance

• Safety Engineering Hazards
• Critical lift Hazard analysis in EWMSD was done.
• Fall Protection on HEPA Filter Testing was done.
• NRTL Electrical Equipment Inspections- Open
  Issue
• ESH Directorate has no high hazard un-listed
  equipment or BNL made equipment.
• Survey of status of NRTL listings has been done
  on all equipment.
• Inspections have not been completed on all
  equipment.

POSSIBLE ISSUE Will Inspections of all
equipment be done by the 09/30/09 commitment
date? Record of Decision
36
Performance on FY07 OSH Objectives
Section 5 Performance on Injury and Illness
Initiatives

• Review the status of past FY objectives and
  targets not addressed in other slides and the
  extent to which objectives and targets have been
  met.
• Targets Completed
• Implementation milestones for safety related
  recommendations from standing or ad hoc safety
  committees
• Implementation milestones for priors year
  Management Review
• Compliance with regulatory requirements
• Implementation of illness/injury reduction
  initiatives
• Facility specific performance measures

Presented by Division
37
Reflections on Performance in FY07
Seeking improvements, not blame or criticism
The worst thing about being a CLONE
is having no one to blame but myself.
38
Performance on OSH Objectives for FY07

39
Performance on OSH Objectives for FY07
40
Performance on OSH Objectives for FY07
41
Performance on OSH Objectives for FY07
42
Performance on OSH Objectives for FY07
43
Performance on OSH Objectives for FY07
44
Performance on OSH Objectives for FY07
45
Performance on OSH Objectives for FY07
46
Performance on OSH Objectives for FY07
47
Section 5 Performance on Injury and Illness
Initiatives

• FY07 Injury/Illness
• Reduction Initiatives
• OSH Improvements

48
Injury/Illness Reduction InitiativesOSH FY07
Improvements
49
Injury/Illness Reduction InitiativesOSH FY07
Improvements
50
Section 7 Communication, participation and
consultation

• Communication

51
Communication OSH communications from external
and internal interested parties (stakeholders)

• Positive feedback
• BHSO on Investigation of BGRR Beryllium Exposure
  in the 1950s.
• External EFCOG on Chemical Storage Project in
  small science Baseline IH Exposure Monitoring
  Project.
• BHSO, DOE, NSF on IH Groups procedures
• BNL internal customers High praise for 2 new SH
  Representative who had immediate impact
• Radiological Surveillance- customer feedback is
  they are pleased with this performance.
• Negative feedback
• Line organization (BES, Life Science) to SHSD on
  speed of reconciliation of CMS re-inventory
• BES CAD to SHSD on SH Representative poor
  performance of one employee.
• Employee feedback
• SHSD held 49 staff meetings with Safety Topic
  opening.
• SHSD Division held 2 all-hands meetings on ESH.
• 1 ESHQ Directorate OSH Meeting.
• Multiple JRAs were reviewed in team setting.
• EWMSD, DH, RCD SHSD participated in WOSH
  Committee.
• RCD conducted one-on-one interviews with
  employees.

• ISSUES (discovered by Communication with
  Customers)
• Poor performance of one SH Representative
• Slow CMS reconciliation of container inventory
  survey in FY07.
• Recommendation
• Existing Human Resource processes are addressing
  the personal performance issue.
• CMS reconciliation project was projectized with
  a plan and deadlines for completion. Filling of
  the CMS vacancy has freed up additional
  man-power. Pace is greatly improved. Will be
  resolved by end of Q1.
• SHSD FY08 Objectives on more training for the SH
  rep position were prepared.
• Record of Decision
• ___Agree with current actions
• ___Other Action

• Communication process
• Recommendation
• Existing Communication process is effective, no
  changes needed.
• No new or proposed Objectives are recommended.
• Record of Decision
• ___Agree with recommendation actions
• ___Other Action

52
Stakeholder Concerns

• Activists none
• Community
• Nanomaterials Community Advisory Council-
  addressed in FY07 and will grow in FY08
• Summer Sunday Safety Presentation
• Healthfest Display by SHSD and EWMSD
• Regulators
• ISM was a big initiative this year. ESHD
  supported the Assessment in a large way.
• 10CFR851- Working with the local office on
  meeting this regulation.
• Unions
• No issues within ESHD operations.
• SHSD met with unions on 10CFR851 issues (site
  level concerns)
• RCD Service contractors (RASI) current contract
  does not cover expenses of 10CFR851 medical exams.

53
Changing Circumstances
Section 8 Changing Circumstances

• Changing circumstances, including developments in
  legal and other requirements related to its
  environmental aspects or OSH Hazards
• Changes to SBMS Subject Areas
• Other information regarding changes in
  legislation, changes in expectations and
  requirements of interested parties, changes in
  production activities, advances in technology,
  and lessons learned from ESH incidents.

54
Effects of Foreseeable Changes to Legislation

• OHSAS 18001
• 10 CFR 851 Worker Safety and Health Program
• Integrated Safety Management (ISM)
• OSH Program Areas

55
Effects of Foreseeable Changes to Legislation

• OHSAS 18001
• New Requirements published in 2007.
• BNL will begin transition from the 1999
  Specifications to the 2007 Requirements this year
  and through 2009.
• No major problems anticipated in implementation,
  as the elements now match exactly with EMS ISO
  14001.
• OHSAS 18001 2007 elements are being built into
  the new OSH Subject Area and Internal Audit
  Checklists.
• SHSD owns the OHSAS 18001 Subject Area
  development for the site. Without additional
  staffing, this will be covered at the expense of
  the IH program.

56
Effects of Foreseeable Changes to Legislation

• 10 CFR 851 Worker Safety and Health Program
• No issues within ESH Directorate operations.
• At the site level
• Site Plan is approved.
• Gap Analysis will be expanded with OSH Program
  Assessments. SHSD owns these actions.
• Variance for MRI Static Magnetic Field exposure
  is pending.
• NTS Reporting has been done for
• IH Monitoring,
• NRTL evaluations
• These are on track for on-time closure.
• SHSD owns the overall site program for
  implementing this driver. Staffing for
  oversight of this program is adequate.

57
Effects of Foreseeable Changes to Legislation

• Integrated Safety Management (ISM)
• No issues within ESH Directorate operations.
• Corrective Action Plan for site is not owned by
  ESH Directorate.

Recommendation No new initiatives or Objectives
at ESH Directorate level needed in FY08 to
address the changing circumstances of
legislation. Record of Decision ___No additional
actions ___New Action
58
Effects of Foreseeable Changes to Legislation

• OSH Program Areas
• No issues within ESH Directorate operations.
• For the site programs
• Industrial Hygiene ANSI Laser Consensus
  Standards are undergoing a major revision.
  Requirements for Research Lasers are being
  broken off from industry use. This changes
  will likely will improve implementation.
• Safety Engineering No significant changes in
  regulations upcoming.
• Fire Protection No significant changes in
  regulations upcoming. Programs are not owned by
  ESH Directorate.
• Radiological Protection Amendment to 10CFR835
  may have impact on BNL operations. RCD is
  tracking this potential change. Expected
  compliance date 07/2010.

Recommendation No new initiatives or Objectives
needed at the Directorate level in FY08 to
address this changing circumstances. Record of
Decision ___No additional actions ___New Action
59
Changing Circumstances

• Anticipated or Planned Changes to the scope of
• ESH Directorates operations that impact OSH
• EWMSD none
• SHSD none
• RCD none

• Recommendation
• No new or proposed Objectives are needed based on
  changing circumstances.
• Record of Decision
• ___ No new or proposed Objectives are needed
• ___Action

60
Section 9 Performance on Injury and Illness
Initiatives for FY08

• Injury/Illness
• Reduction Initiatives
• OSH Improvements
• Planned for FY08

61
FY08 OSH Objectives
62
FY08 OSH Objectives

63
FY08 OSH Objectives
64
FY08 OSH Objectives

• SHSD

65
FY08 OSH Objectives
Recommendation These Objectives are adequate to
address issues from Internal OSH Audits, NSF
Audit, known weakness, and improvements. Record
of Decision ___Accept these Objectives ___Additio
nal Objectives or changes
66
Recommendations for FY08 Improvement in ESH
Directorate Operations
Senior Management feedback Red Accept Risk.
Yellow Address with additional study or pass
to higher level. Green Accept Recommendation
which addresses need.
67
Recommendations for FY08 Improvement in ESH
Directorate Operations

• Issue
• Safety and Health Representative coverage
  (0.1FTE) for ESH Directorate (especially EWMSD)
  is at the bare-bones level, i.e. reactive only.
  The staffing level is not meeting the needs of
  the Directorate.
• Current coverage is too few hours (100/year) to
  provide proper oversight of ESH Directorate
  operations, especially the changing nature of
  EWMSD chemical handling activities.
• Coverage should provide IH Monitoring, Tier 1
  Walk-thru, WPC reviews for Instrumentation/Cali
  bration Lab, Personnel Dosimetry Lab LTRA, WMF,
  IH Lab EC/RCD/IH field work.
• At least 0.5 FTE
• SHR coverage
• Is needed.

Record of Decision ___ESH Directorate purchase
0.5 FTE OSH Professional Coverage from
SHSD. ___ESH Directorate purchase 0.5 FTE OSH
Professional Coverage from RCD. ___Use GA funded
staff by reducing support to another
organization. ___Await new ALD for decision on
action. ___Accept Current Risk. ___Other
68
Recommendations for FY08 Improvement in ESH
Directorate Operations

• Issue Resource Allocation is not sufficient
• OHSAS Site Project Manager is currently a
  contributed resource (0.2 FTE) from the SHSD
  Industrial Hygiene Group. This was an issue in
  last years Site OSH Management Review that was
  not EFFECTIVELY addressed.
• Pulls resources from the IH Program, which is
  already under-staffed
• 18 Subject Areas covered by 1.5 FTE ? 1.3 FTE.
  
• LSO 0.5 FTE, CHO 0.5, Ergo 0.1 Balance 0.2
  FTE 15 Subject Area
• Functions of OHSAS Project Manager
• Plan and conduct Internal Audits,
• Plan and serve as counterpart for NSF Audit,
• Assist with Site OSH Management Review,
• Prepare Site OSH Objectives,
• Maintain Web page SBMS OHSAS Subject Area
• Administer S2 and S3 program.
• Train new OSH Reps and POCs
• Level of effort needed is 0.3 FTE dedicated to
  OHSAS program maintenance. EMS has 0.5 FTE
  assigned.

Record of Decision ___Accept current allocation
of resources ___Add additional Resources
from within ESH Directorate existing
staff. ___Add additional Resources from new
funding. ___Pass issue to Site Level Management
Review ___Other

• What gets short changed in the IH Programs
• Site Program Audits
• Assistance to Line Orgs in self assessments
• Subject Area Development Maintenance
• Qualification of Deployed Service Providers
• Hazard Inventories
• Site Training Material

69
Decisions on FY08 Improvement in ESH Directorate
Operations
Senior Management feedback Red Accept Risk.
Yellow Address with additional study or pass
to higher level. Green Accept Recommendation
which addresses need.
70
Section 10 Summary Questions

• Management Review Questions
• Summary of the Strength of
• ESH Directorates OSH Program
• regarding our internal operations

71
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

72
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?

73
Management Review DecisionsReality Check
Do we really mean it when we say we are O.K. and
nothing new is needed ?
74
Any Additional Comments or Concerns ?

• Thank you for Your Participation
• This PowerPoint presentation will be posted on
  the ESH Directorate's OSH Web Page
• Minutes of this Meeting and a Record of Decision
  on Issues will be prepared and posted on the ESH
  Directorates OSH Web Page