LBNL Office of Independent Oversight Preparations –

Red Team Review

Overview

• Cross-Cutting– Things to keep doing – Observations and things to focus on in the

next 46 days• HSS Planning visit is in 26 days• HSS Field visit is in 46 days

• Program or Division Specific– Things to keep doing– Things to focus on in the next 46 days

HSS review Tips

• Identify known weaknesses and corrective actions and present at in brief– Do an in-brief for HSS team– Present issues identified by your feedback

mechanisms – Present accomplishments and planned

corrective actions – Should encompass BSOs feedback to lab…

and beyond

Cross-CuttingObservations

• Inconsistent articulation by personnel of role of JHA as basis for work authorization and personal safety

• Evidence of hazardous waste staging areas for SAAs

• Inconsistent understanding and implementation of PPE policy, postings and practices

• Inconsistent implementation of safety requirements for guests/students (i.e., equivalency, time on-site under supervision)

• The expectations for OJT in the work authorization process are not institutionalized

Recommendations

• Minimize new requirements or initiatives – between now and review

• Mentor personnel on clearly articulating role of JHA role in work authorization

• Implement SAA compliance self-review (labels, start dates, in-process management)

• Implement PPE as posted• Close overdue high/mod risk action items

Material Sciences Division - DougObservations

• “Certified User List” for specialized equipment

• Example of localized safety improvements – relocation of workstations outside laser areas

• Consistent understanding of stop work authorization

• Division distribution of lessons learned cited as positive aspect

• Inconsistent understanding of JHA as work authorization

• Inconsistent understanding of new PPE policy

• Use of “Radiation Control Area” sign as laser block

• Inadequate labeling of hazardous waste – flammable waste cans

Material Sciences Division

Recommendations– Communicate latest PPE policy requirements

and expectations – consistency with area signage

– Conduct Satellite Accumulation Area (SAA) compliance walk-throughs

– Reinforce role of JHAs, AHDs, certified user lists as authorization basis

– Reinforce methods to readily obtain MSDS for chemicals – LBNL internet search services

Environmental Energy Technologies Division - Doug

Observations• Individual ownership of JHA evident – removal of

inappropriate hazards in process• Co-location of lab activities controlled by clear area

ownership• Exposed contacts between power source and glovebox

– verify <50 volt limitation of electrical hazard• Co-location of laboratory/office introduces PPE/food

concerns• CO alarms internal to room – buddy system requirement

only emergency response mechanism• Effective retrieval of MSDS not demonstrated

Environmental Energy Technologies Division

Observations (cont.)• SAA container nearing 9-month storage limitation,

management of wastes being analyzed/sampled• Access limitations prohibit review of JHAs for other

division personnel

Environmental Energy Technologies Division

Recommendations• Communicate latest PPE policy requirements and

expectations – consistency with area signage• Evaluate oxygen deficiency hazards and controls in

combustion lab• Conduct SAA compliance walk-throughs• Reinforce methods to readily obtain MSDS for chemicals

– LBNL internet search services• Verify understanding of <50-volt limitation of electric

hazard• Ensure JHAs appropriately cover all area hazards (hot

surfaces) and can be viewed for visiting personnel

Hazardous Waste Management - Doug

Program Review and assessment of HW facility

Observations• Individual understanding of JHA content demonstrated• Program requirements documented in PUB-3000 and

other procedures• Clear understanding of stop work requirements (refuse

pick up) and authority to request exposure assessment• Requests to collect excess items overwhelming group• Inconsistent understanding of new PPE policy• HW group personnel not directly involved in HW

determinations for new processes

Hazardous Waste Management

Recommendations– Communicate latest PPE policy requirements

and expectations – consistency with area signage

– Prioritize pick-up and processing of hazwaste based on accumulation start date

– Long-term: Consider expanding role of generator assistants to include evaluation of new processes for HW generation/ characterization

Chemical Management - DougProgram Review

Observations• Program requirements documented in PUB-3000 and

other procedures• Housekeeping in lab spaces generally good• Line ownership of Chemical Tracking System (CTS)• Initiation of CTS assessments• Continued improvement of JHA questionnaire• Inconsistent line understanding of new PPE policy• Inconsistent line understanding of MSDS availability

Chemical Management

Recommendations– Communicate latest PPE policy requirements

and expectations – consistency with area signage

– Communicate availability of MSDS using search engines subscribed to by LBNL

– Review/update chemical life cycle presentation for appropriate use during upcoming audit

Engineering - Arnold____________________________________________

Keep Doing•Good work planning and authorization execution • Appropriate use of PPE (noted without exception)• Frequent line management field presence• Good integration across adjacent work areas• Effective coordination between Work Groups and EH&S teams• Appropriate control and communication with temporary work groups (e.g. contractors, facilities) performing tasks in Engineering

Focus on• Ensure all signage is accurate and current• Ensure separation of work and food/drink areas by removing vending machines from work area (noted in one location).

Physics - Arnold____________________________________________

Keep Doing• Good understanding and practical application of ISM

• Clean and well controlled work areas; access controlled

• Frequent line management field presence

Focus on• Improve work lead’s understanding of requirements and responsibilities for required tests and inspections of the hazardous gas systems

• Improve positive control of gas cabinets by using existing locks on the cabinet doors and removing the keys

• Review emergency actions and procedures with area occupants

• Ensure control of vendors consistent with new expectations

Life Sciences - BobObservations

• Clear access control requirements• Very engaged and supportive Work Leads and Division

Safety Coordinators (DSC)• Housekeeping very good• Scientific staff understand Stop Work authorities• Most scientific staff understand line management

authorities (Work Leads are “go to persons”)• Scientific staff can generally describe JHA and training

processes (in some instances, some degree of prompting required)

• PPE policy is changing (Lab coats not required if not working in laboratory spaces)

Life SciencesObservations (con’t)

• Role of OJT essentially a pre-condition (requirement) to begin work; relationship to work authorization process could be clearer

• Use of SOPs a key hazard control mechanism; relationship to JHA process could be clearer

Recommendations

• Clarify what elements are needed for line management to authorize work (JHA, BUA, RWA, SOPs, OJT)

• Provide coaching on overall work authorization process (JHA, BUA, OJT, RWA)

Chemical Sciences - Bob

Observations• Excellent access control process• Clear and unambiguous PPE policy• Good understanding and demonstration of line

management responsibility, JHA process • Good understanding of overall work authorization

process (including roles and responsibilities) as it applies to actinide chemistry R&D

• Stop Work authorities and responsibilities well understood

• Formal work authorization and access control process for non-Division personnel who work in laboratory areas

Chemical Sciences

Observations (con’t)• Clear and formal process for maintenance personnel

who require access to laboratory areas• Housekeeping very good

Recommendations• Clarify role and importance of OJT in work authorization

process for students• Improve precision of responses to questions regarding

work authorization• Establish process for examining “Near Misses” in

collective fashion (including understanding the “why” and the “what”)

ALS - Arnold ____________________________________________

Keep Doing• Beam line scientists demonstrated good understanding and application of work authorization process.•Appropriate control of User activity at beam line stations

–Thorough analysis of hazards associated with test specimens

• Positive access controls for Users. • Personnel in beam line stations have good awareness of hazards in adjacent areas.

• Frequent line management/authorizing individual presence in the beam-

line experimental area.

Focus on:• Better segregation of work and areas where food/drink is allowed.• Implement LBL PPE policy in uniform and consistent manner.• Consider control room access controls.

Construction - Gus

• Keep doing

– Flow Down of DOE Safety Requirements

– Apply Best Practices from other Labs

– Priority on Improving Safety on Small Projects

Construction

• Focus on:

– Sharing best practices across Lab• Visitor Orientation• Material Movement• Daily Planning Meetings

– JHA At Transition to Commissioning & Operations

– Increase oversight of small projects to ensure LBNL expectations for work planning, authorization and safety requirements are implemented

Maintenance - Gus

• Keep Doing– Use of Task Change Request for review and approval of work

when the task has changed– Open dialog between workers and supervisors– Effective exchange of information including safety at Shift

Change Meetings

• Focus On– Organize the recently occupied Preventive Maintenance

Administrative Area• Remove legacy signs and posters• Remove excess supplies and materials• Ensure good housekeeping

Earth Sciences - Glenn Observations

• Good understanding and use of JHA as work authorization process – but line responsibility needs to be clearly articulated

• “Guests” treated essentially same as employees• New PPE policy appears to be implemented• PPE and food issues associated with offices connected to

lab spaces• Excess equipment needs to be moved in one space

reviewed – otherwise housekeeping good• Hand built electrical devices need to be certified as safe –

need compensatory measures during interim• Waste management practices during clean out need

improvement – no “pre-staging”

Earth Sciences

Recommendations– Management needs to clarify that JHA is line

management means of authorizing work and that other authorizations are also necessary in specific instances before work can begin

– Review other areas where clean-out of hazardous materials is occurring for pre-staging of materials

– Evaluate need for compensatory measures for hand-built electrical instruments

Radiation Protection – Pit Storage - Glenn

Observations

• Very clear on JHAs as authorization of work

• Good processes and systems appear to be in place to control radioactive materials

• Clear authorization necessary before radioactive material is transferred

Accelerator and Fusion Research Division (AFRD) - Kyle

Observations• Excellent understanding and use of JHAs

• Coordination across organizations• Linkage with Activity Hazard Documents – especially regarding

training• Applied to students and guests as well

• “Pre-job briefings” held for infrequently performed tasks• Supervision in workplace on frequent basis• Clear understanding of stop work authority and responsibility• Demarcation of areas that may require PPE is confusing and

practices are not always consistent with postings

AFRD

Recommendations

• Clarification of PPE requirements and practice what is posted

• Consider some documentation of pre-job briefings when held

Physical Biosciences (PBD) - Kyle(Donner) - Observations

• Very good understanding and articulation of personal safety constructs by some personnel

• Clear focus on JHA as basis for work authorization and personal safety requirements not evident

• Some students not familiar/comfortable with all individual safety basis concepts

• Lack of clarity in applying LBNL safety requirements to visiting students

Physical Biosciences (PBD)(Donner) – Recommendations

• Emphasize importance of JHA as basis for personal safety and work authorization

• Formalize basis for ensuring & documenting visitor/guest/student safety

• Ensure all laboratory personnel are familiar with and can articulate basic safety concepts (personal safety, work authorization, actions to be taken when unexpected conditions or changes are encountered)

88-inch Cyclotron (NSD) - KyleObservations

• Formal basis for coordinating JHAs with other divisions

• Operations and safety basis governed by accelerator order and SAD

• Key-controlled access to injector and vault areas• Use of JHA as basis for work authorization and

personal safety requirements not strong• Evidence of formality in operations (e.g.,

configuration control, work planning) as illuminated in review not readily demonstrated

• Ambiguity in radiation area/contamination postings

88-inch Cyclotron (NSD)Recommendations

• Emphasize to staff operational, work planning and configuration controls in authorization basis documents (SAD, ASE)

• Ensure postings are clear:– Radiation areas during various operational

modes– Radiation postings vs. monitoring locations– Eye protection requirements

• Ensure work is appropriately proceduralized given risks and relation to authorization basis

Red Team Members

• Craig Ferguson, SLAC– 650.926.3106

• Arnold Clobes, LLNL/NIF– 925.455.4027– 925.980.7408 (cell)

• August Kugler, UC (retired)– 509.783.2604– 925.818.5885 (cell)

• Bob McCallum, McCallum-Turner• Kyle Turner, McCallum-Turner• Glenn Hoenes, McCallum-Turner• Doug Schlagel , McCallum-Turner