Tier I Working Group 4th Quarter FY 2010

November 5, 2010

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Overview

Year-end Wrap-up of FY 2010 Tier I Inspection Findings

Tier I and IFM Finalization of Tier I Database

Categories/Subcategories Open Discussion

(Issues & Good Practices)

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Rollup of 4th Quarter FY 2010 Tier I Inspection Findings

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Data Roll-up and ReviewTier I Findings by Fiscal Year

0

1000

2000

3000

4000

5000

6000

2005 2006 2007 2008 2009 2010

1549

2828

3206

3692

50044862

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Data Roll-up and Review Tier 1 Findings By Category

Fiscal Year=2010, Quarter=Q4

0

200

400

600

800

1000

WED ESE ESD HK WEP CG WT CSL CSS FS OGIH ESP OT EM RS MH PPE CSU MS UP BHSEC GS

Find

ings

WED 992ESE 544ESD 526

HK 521WEP 376CG 352

WT 287CSL 237CSS 189FS 161OG 123IH 96

ESP 81OT 76

EM 54RS 53MH 45PPE 43CSU 41MS 35UP 13BH 9SEC 8GS General Safety 0

Working Environment: DepartmentElectrical Safety: EquipmentElectrical Safety: Distribution

HousekeepingWorking Environment: PlantCompressed Gas/Cryogenics

WasteChemical Safety: LabelingChemical Safety: StorageFire SafetyOutside and GroundsIndustrial Hygiene Issues

Electrical Safety: ProgrammaticOther

EnvironmentalRadiation SafetyMaterial Handling and Equipment Safety

BiohazardsSecurity

Personal Protective EquipmentChemical Safety: UseMachine Shop SafetyUnsafe Practices

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Data Roll-up and ReviewTier I Directorate Findings

Fiscal Year=2010, Quarter=Q4

0

200

400

600

800

1000

1200

Light Sources Nuclear and ParticlePhysics

Basic Energy Sciences Life Sciences

GARS F&O

Science & Tech. ESH&Q

ERP Human Resources

Director's Office Finance

CEGPA

Find

ings

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Data Roll-up and Review Tier 1 Top 7 Findings By Category

0

200

400

600

800

1000

2005 2006 2007 2008 2009

CSSESDESEHKOGWEDWEPCGWTCSL

Fiscal Year0

200

400

600

800

1000

2005 2006 2007 2008 2009 2010

CSSESDESEHKOGWEDWEPCGWTCSL

Fiscal Year

WED 992

ESE 544

ESD 526HK 521

WEP 376

CG 352

WT 287Waste

Electrical Safety: DistributionHousekeeping

Working Environment: Plant

Compressed Gas/Cryogenics

Working Environment: Department

Electrical Safety: Equipment

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Tier I and IFM

Tier I and IFM

The Facility Complex Organization is an integral part of the Tier 1 Program• See ES&H (Tier 1) Inspections Subject Area

Facility Complex is also a “Line” Organization• Facility Complex has their own spaces

- MERs, shops, offices, etc.• The Facility Complex needs to conduct their own Tier 1

inspections

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Tier I and IFM

Line organizations responsible for the periodic self-inspection of their work areas • Look for ESSH&Q vulnerabilities and conformance to the

standards imposed under 10 CFR 851• Using capable and qualified staff • Timely resolution of findings is a requisite step in the self-

inspection process The Line Organization’s Responsible Manager

• Designates the Team Leader • Determines the level of training required by team

appointees - Must recognize hazards and compliance violations

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Tier I and IFM Responsibilities

The Core Team may vary, but typically includes: • ESH Coordinator• Facility Support Representative• Environmental Compliance Representative• F&O Facility Project Manager or designee• Subject Matter Experts (SME)

Whenever possible, the Core Team should include:• Principal Investigators/Supervisors• Line Management, and • Workers

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Tier I and IFM

The Team Leader or designee is responsible for scheduling, conducting, and documenting/recording inspections

Responsible individuals/organizations address findings to ensure timely close-out

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Finalization of Tier I Database Categories and Subcategories

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I. Biohazards

1. No IACUC (Institutional Animal Care and Use Committee) or IRB (Institutional Review Board) approval as required

2. No labeling

3. No storage posting as required

4. Proper procedures not followed

5. Other

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II. Chemical Safety: Labeling

1. Chemical contents/hazards not identified on labels or illegible labels

2. No CMS (Chemical Management System) Bar Coding/Static Inventory

3. Particularly Hazardous Substances (PHS) not labeled

4. Peroxide-forming chemicals not tested and not date-labeled

5. Other

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III. Chemical Safety: Storage1. Storage impedes fume hood operation2. Container not in good condition3. Corrosives not stored below eye-level4. Particularly Hazardous Substances designated area not posted5. Fume hoods not inspected, labeled, or used.6. Legacy storage of chemicals no longer used/needed (outdated)7. No explosion proof or flammable cabinet/refrigerator/freezer as required8. No segregation of incompatibles9. Nanomaterials are not stored properly in sealed containers when not in use10. Containers storing nanomaterials are not labeled properly with the “Caution: Nanomaterial” label11. Eyewash/shower not available (if corrosives present)12. Other

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IV. Chemical Safety: Use

1. Carcinogen reproductive hazard and/or acute toxin requirements not met

2. Hood sash not kept at proper height

3. Other

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V. Compressed Gas/Cryogens1. Cylinders stored on carts

2. Cylinders do not have status tags

3. Cylinders not capped when not in use

4. Cylinders not secured properly

5. Equipment/piping not appropriate for cryogen use (e.g., tubing or piping not rated for the regulator)

6. Flammable Gas Storage not posted

7. Piping not labeled or secured if over 10 ft or through wall penetration

8. In-service monitors/gauges not properly calibrated as appropriate and used (e.g., CO2, flammable gas meters)

9. No required ODH posting

10. Oxidizers not separated from flammables (20 ft/fire wall)

11. PPE for cryogen transfer not available or not used

12. Static posting for cylinders not current/complete

13. Other

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VI. Electrical Safety: Distribution1. Arc flash labels missing on equipment2. Breakers or disconnects not labeled3. Cable trays overloaded (guidance > 50%)4. Electrical distribution panels/disconnects blocked [1]5. Electrical distribution panels not labeled 6. Electrical distribution panels: inadequate working space (i.e., ~36-42” deep [depending on voltage] x 30” wide x 6.5’ high) unless working space limitations sticker is affixed7. Exposed conductors (bare wires)8. Flexible cords used as permanent wiring

9. Ground Fault Circuit Interrupter (GFCI) protection not within 6 ft. of sinks/wet areas10. GFCI does not trip

[1] Minimum 36 front (42 for 480), 30 width, 6.5 feet height. See Electrical Safety Subject area for more criteria

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VI. Electrical Safety: Distribution (Cont.)

11. Improper grounding/bonding12. Junction boxes not secured13. LO/TO tags: improper, outdated, not durable, illegible, not completely filled out14. Loose or missing covers on panels, raceways, or outlets 15. Missing knockouts/hardware16. Wiring in hazardous areas not reviewed or not in compliance17. Other

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VII. Electrical Safety: Equipment1. Daisy chaining of extension cords/power strips 2. Electrical plugs not grounded3. Frayed power cords, extension cords, or heater tapes4. Hand tools not grounded or not double insulated5. Inappropriate use of extension cord6. Missing or damaged strain relief 7. Missing covers/exposed wires8. Not NRTL listed or EEI inspected9. LO/TO non-compliance 10. Portable GFCI does not trip11. Loose or missing covers on panels, raceways, or outlets12. Other

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VIII. Electrical Safety: Programmatic

1. Other

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IX. Environmental1. Article 12 non-compliance, e.g., Tank inspection forms, tank labels missing, overfill alarm not functioning2. Environmental monitoring equipment non-functioning/maintained/calibrated3. Evidence of spills; not properly cleaned up4. Faucets not equipped with vacuum breakers/equivalent backflow prevention device

5. Hazardous materials by sinks/floor drains6. Hoses hanging below sink rim without anti-siphon device7. Process exhaust near air inlet8. Process ventilation not permitted (lab hoods are exempt)9. No secondary containment for storage of hazardous liquid materials (e.g. fuel, hydraulic oils, and paint)10. No Secondary Containment (e.g. trays) for hazardous liquids [1] 

[1] Moved here from CSS per S. Ferrone who said this is a RCRA violation under the Hazardous Waste SBMS.

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IX. Environmental (Cont.)

[1] Per S. Ferrone, this is both an environmental problem if any oil/gasoline spills onto the ground and is a safety concern if gasoline spills and there is a fire.

11. No sink disposal posting for allowable/pre-approved sanitary discharges

12. Non-compliance with air emissions permits (e.g. logs are not up-to-date, emissions not on permit)

13. Unlabeled/unknown chemical containers

14. Vehicles and equipment not parked on paved or stone-covered areas [1] 

15. Used oil is near a floor drain or is uncontained

16. Other

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X. Fire Safety1. Cutting and welding areas: no current permit2. Emergency exit doors malfunctioning3. Emergency lighting inoperable4. Emergency lighting not located where required [1] 5. Emergency planning postings (i.e., Local Emergency Plan, Shelter-in-Place, Indoor Assembly Area) missing or not current (i.e. postings list individuals who are no longer in the building)6. EXIT signs missing, not posted appropriately, not illuminated if required7. Fire doors impaired, not inspected, or not labeled8. Fire extinguishers blocked, incorrect type, incorrect placement, poor condition9. Fire extinguisher sign if needed is missing or not visible10. Fire wall penetrations not sealed

 [1] Exit corridors and stairs for spaces with more than 2 exits, and exterior egress at different levels

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X. Fire Safety (Cont.)

11. Flammable/combustible materials block or impede egress path or access to exits12. Excessive accumulation of combustible materials13. Hazard Information Placards missing, incorrect, incomplete, or out of date. (Note: These placards have to be updated annually.)14. Non-compliant flammable liquid cabinets 15. Sprinkler heads not free of obstruction (18” clearance)16. Stairways, hallways, passageways/aisles and access to emergency exits not free of obstruction or inadequately lit17. Other

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XI. Housekeeping1. Areas not free of insects, rodents, pests2. Custodial issues (i.e., cleaning floors, emptying trash) not addressed3. Egress paths not kept clear, i.e., floors, aisles, emergency egress 4. Floors not dry or free of debris5. Excessive materials accumulated in laboratory hoods or on work benches6. Other Housekeeping7. Handrails and treads not adequate or in poor condition8. Improper or excessive storage of materials/equipment/heavy equipment9. PPE improperly stored10. Non-industrial and non-lab areas (i.e., locker rooms, wash rooms, toilets, drinking fountains, kitchens, conference, and common areas) not maintained in a safe, sanitary and clutter-free condition11. Leaking chemical containers or piping 12. Proper width of aisles and corridors not maintained [1]

 [1] Width equal to or greater than width of doorway

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XI. Housekeeping (Cont.)13. Shelved items placed in disorderly manner causing potential for item to fall when nearby items are being retrieved14. Stairways, hallways, passageways/aisles and access to emergency exits not free of obstruction or inadequately lit15. Excessive material or equipment16. Materials, chemicals, and equipment no longer needed have not been excessed or disposed of17. Unoccupied storage buildings/areas not maintained, cluttered, or not used to the best advantage18. Unsanitary conditions of eating food prep areas19. Recyclable waste containers inadequate in size and design or overflowing20. Containers not provided for recyclable paper, recyclable cans/bottles, sharps, and trash21. Work area cluttered or dirty22. Work areas (inside or out) not returned to clean and orderly condition upon completion of maintenance or repair work23. Other

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XII. Industrial Hygiene Issues 1. Ergonomic concerns not addressed2. Hazard assessments not completed where required3. High-noise areas not assessed or posted4. Indoor air quality issues not addressed by Industrial Hygiene/Safety and Health Services Division Rep5. Laser-controlled area interlock not tested within last 6 months6. Laser Standard Operating Procedure not reviewed within the last year7. Surface contamination from hazardous metals8. Required hazard-specific monitoring not completed, documented, or communicated9. Other

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XIII. Machine Shop Safety

1. Anti restart devices not installed on machines2. Machine guarding non-compliant3. Machines not secured (i.e. to floor, table)4. Other

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XIV. Material Handling and Equipment Safety

1. Extreme temperature warning not posted2. Forklift unsafe or not inspected3. Non-ANSI or non-OSHA compliant ladder (fixed and portable)4. Material-handling equipment – improper operation or maintenance, overdue inspection (i.e. cranes, hoists, slings)5. Pressure or compressed gas system not reviewed6. Scaffolding not properly installed, secured, and maintained7. Other

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XV. Outside and Grounds 1. Automatic door opener buttons for handicapped accessibility non-functional2. Facility Project Manager placard missing, displays inaccurate information3. Butt stops of non-approved type, not emptied4. Refuse collection containers (recyclable metal/cardboard/C&D debris, trash) not present, inadequate in size or design or are overflowing5. Exterior lighting not provided, inadequate, or non-functional6. Handicapped/ADA parking requirements not met (if required)7. Modular building/trailer skirts not intact8. Outside areas or roofs not maintained clear of rubbish, leaves, weeds, or snow/ice9. Pest/rodent/wildlife issue (i.e. animal or insect nests observed)10. Poor condition of stairs, ramps, walkways outside the building11. Trees/shrubs near sidewalks, parking lot, road not trimmed or damaged12. Trenches, pits, or sumps not covered, barricaded, or otherwise protected (i.e., to prevent slips/trips/falls) and free of any liquid accumulation13. Other

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XVI. Personal Protective Equipment (PPE)

1. Appropriate PPE in hazard areas not available, not sanitary, or in poor condition (e.g. electrical, chemical, cryogen, etc.)2. Eye protection not used, unavailable, or in poor condition3. Face shield and gloves for cryogens not worn, unavailable, or in poor condition4. Proper gloves not used, unavailable, or in poor condition5. Hard hat and safety shoes required but not posted or used as required6. Hearing protection not used, unavailable, or in poor condition7. Improper selection of respirator8. PPE for cryogen transfer not available or not used.9. PPE not stored in a clean and sanitary manner10. PPE not available, stored, or used appropriately11. Proper Footwear in Labs/Industrial areas not worn12. Lab coats/uniform not worn when required13. Other

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XVII. Radiation Safety 1. Access not controlled where required2. Not wearing TLD badge or dosimeter when required (potential PAAA)3. Area posting(s) not current or incorrect4. Calibration of survey and dosimetry equipment not current5. Custodian not assigned (Radiological Materials Area [RMA] sealed source, etc.)6. Fixed contamination not properly identified or labeled7. Improper storage or labeling of sources and rad materials8. Radiation survey levels not updated or incorrect9. Radiation Work Permits not current, posted or used10. Sealed source log not current as to location/usage of sources11. X-ray compliance – not posted, interlock, log12. Other

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XVIII. Security

1. Door locks malfunctioning where required2. Doors with self-closing features not closing properly3. Personnel not wearing ID Badge4. Property Protection Area postings not current and logbooks not up to date5. Unsecured/free access to buildings during off-hours6. Other

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XIX. Unsafe Practices

1. Imminent danger - climbing without fall protection2. Imminent danger - failure to tie down ladders or using cable tray for climbing3. Not wearing PPE during hazardous work4. Working on or near exposed conductor violations5. Nanomaterial does not comply with nanomaterial waste requirements.

6. Using broken or damaged tools or ladders7. Other

Findings Reported Under Unsafe PracticesIO:Finding:  A room in the basement that had no windows and no way of indicating if anyone was working inside while the door was closed. Resolution:  Placed a sign stating that no work should be done in the room while the door was closed.

ITD:Finding:  A wooden ladder in very poor condition and still in service was located in the basement.Resolution:  Threw out the ladder.

Chemistry (Per D. Cabelli, these are unsafe issues, and not necessarily unsafe practices.)Q3 Findings:Step stools needs new rubber feet.Remove or post area in back by mat – trip hazardResolution:  All of the stepstools were fixed for the following Tier I.  Q4 findings:Remove or post area in back by mat – Trip hazard.Heavy items on top shelf.Lead on wooden counter in vault is too heavy; should be removed or supported.

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XX. Waste1. 90-day area is not inspected on a weekly basis using an SBMS or SME-approved weekly checklist2. Haz Waste Contingency Plan is not posted inside room and in nearby location, or is not current, or 90-day Rules postings not present.3. Incompatible wastes are not separated4. Rad Waste area not being inspected on a monthly basis and/or checklist not being completed5. Rad Waste area postings not present (90-Day Rules postings and RCD area postings)6. Rad inventory sheet not present7. For Regulated Medical Waste, open sharps box/sharps sticking out of container8. For Regulated Medical Waste, biohazardous symbol not present on Regulated Medical Waste container9. For Regulated Medical Waste, use of a non-biohazardous bag10. For Regulated Medical Waste, use of a non-sturdy, non-approved red sharps container

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XX. Waste (Cont.) 11. Secondary containment not present or inadequate for liquid wastes (does not hold: 10% of total volume of all containers or 100% of the largest container—whichever larger)12. Container not properly labeled (MISSING red haz waste label and/or MISSING/illegible chemical descriptions – chemical symbols/secret formulas used)13. Incompatible wastes being stored together 14. UNP (unbound engineered nanoparticles) nanomaterial does not comply with the nanomaterial waste requirements.15. Battery types mixed together (e.g. Lead-acid vs. NiCd) and terminals are not taped to prevent shorts16. Fluorescent Light Bulbs not stored to prevent breakage and container is open17. Universal Waste posting missing18. Waste not properly labeled.19. Other

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XXI. Working Environment: Department

1. Eyewash/shower pathways not obstructed, travel distance > 10 seconds and > 100 feet, not well maintained 2. Eyewash tags not completed with proper dates3. Dirt present in and around eyewash or covers on eyewash fountains4. Piping not labeled5. Refrigerators/freezers not labeled, malfunctioning, or storing non-food items with food6. Safety signs & postings illegible, missing, or in poor condition7. Work area barricades (when applicable) not in place and not maintained in good condition8. Other

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XXII. Working Environment: Plant

1. Broken hardware on doors, windows or machines (other than security)2. Emergency shower/eye wash inspections not done annually3. Exposed building insulation4. Floor load ratings not posted or incorrect5. Improper (non-compliant) handrails or tread, or no anti-skid tread on stairs6. Inadequate general ventilation, heat and/or AC7. Inadequate lighting in work area8. Lack of toe-boards or missing or improper railings9. Leaks (i.e., roofs, basements) causing potential safety issues are not properly contained or repaired10. Missing floor or ceiling tiles (> 10%)

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XXII. Working Environment: Plant (Cont.)

11. Out of date or missing inspection certificates in elevators12. Utility piping (i.e., steam, water) not labeled13. Walking and Working Surfaces not kept clean and free of debris14. Walking and Working Surface issue concerning building floors 15. Portable ladders not secured when not in use 16. Other

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XXIII. Other 1. Environmental, Safety & Health, Security and Quality Issues that cannot be otherwise categorized2. No findings found

Open Discussion (Issues & Good Practices)

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