DOE ISM

Five Core Functions and Seven Guiding Principles

OHSAS 18001 Clauses/ ISO 14001 Clauses

C-AD OSH and Environmental Programs at the Activity Level

1. Define the scope of the work

4.3 Planning

4.3.3 Objectives and Programs

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4.3 Planning

4.3.3 Objectives, targets and programs

At the activity level, defining the scope of the work is executed by following the requirements in OPM 2.28, C-A Procedure for Work Planning and Control for Operations and OPM 2.29, C-A Procedure for Enhanced Work Planning for Experimenters.  The purpose of these procedures is to enhance work with written procedures, and /or with hazard reviews, whenever they are deemed to be lacking.  These procedures derive directly from the Work Planning Subject Area in SBMS.

Because C-AD is a Conduct of Operations organization, about 33% of work activities associated with routine operations and maintenance of the accelerators are covered by procedures in the C-AD OPM.  About 40% of work activities rely on Skill of the Worker, which quite often includes a standing work permit.  About 15% of work is performed using a specific Work Permit written exclusively for the job.  The remaining work planning involves safety committee reviews by specialists in radiation safety, industrial hygiene, fire safety, electrical safety, accelerator physics, environmental compliance and experimental physics.  See OPM Chapter 9 for committee procedures covering work planning. 

Inputs to the work planning process include:

Occupational Safety and health objectives and targets are management inputs to the work planning processes at C-AD that are updated every year.  They are in the Facility Specific OSH Management Plan.  A similar approach is used for environmental targets and objectives.  See Environmental Management Program for C-AD.

2. Identify and analyze hazards

4.3.1 Hazard identification, risk assessment, and determining controls

4.3.2 Legal and other requirements

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4.3.1 Environmental aspects

4.3.2 Legal and other requirements

The results of the initial hazards and risks reviews were documented in the Workplace Hazard Analyses and Risk Assessments, and in the Safety Assessment Document.  Follow-up reviews are documented in Facility and Area Risk Assessments (FRAs), Job Risk Assessments (JRAs) and Environmental Process Assessments. These assessments are the basis for making decisions regarding the controls to be used when performing work at C-AD, and they are updated annually.  They provide the basis for defining the controls for Skill of the Worker jobs along with pre-job briefings and work-site walk-downs by supervisors and work planners.

For Job Specific Work permits associated with moderate and high hazards, risks to workers' safety and health are identified and assessed for controls prior to performing the work via the Enhanced Work Planning Programs, which are OPM 2.28 for workers and OPM 2.29 for Users.

Changes to accelerators and experiments are reviewed by various safety committees for occupational safety and health issues at the design stage. Procedures governing these reviews are OPM 9.2.1 Procedure for Reviewing Environmental, Health and Safety Aspects of an Experiment, OPM 9.3.1 Procedure for Reviewing Conventional Safety Aspects of a C-A System and OPM 9.1.1 Procedure for Obtaining Review by C-A Radiation Safety Committee.  A Hazard Assessment Tool is used to guide personnel in assessing the OSH and E requirements, legal and other, associated with new or modified experiments or accelerator facilities.  The DOE approved Accelerator Safety Envelope (ASE) also provides requirements to ensure risks and/or consequences are within the approved authorization basis.  ASE requirements are checked by the the safety review committees at the design stage of a project or modification to an accelerator or experiment. For changes to accelerators or experiments outside the ASE, DOE approval and an Accelerator Readiness Review are required.

The Department uses OPM 1.10.3, Guidance on Community Involvement, to determine if large scale projects have OSH or environmental issues that may require community or regulator involvement.

3. Develop and implement hazard controls

4.4 Implementation and operation

4.4.6 Operational control

4.4.7 Emergency preparedness and response

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4.4 Implementation and operation

4.4.6 Operational control

4.4.7 Emergency preparedness and response

For worker planned work and higher risk jobs, environmental protection, hazard prevention and control procedures are summarized in Facility Specific OSH Operational Control Forms, Environmental Operational Control Forms,  Process Specific Environmental Training and  Facility Specific OSH Training Packages.  Hazard controls are also specified on specific permits used in worker planned work or higher risk jobs, e.g., Radiation Work Permits, Working Hot Permits, Confined Spaced Permits and Enhanced Work Permits (See Permits).  The controls established in standing permits and job specific permits are based on risk assessments such as JRAs and FRAs.  It is noted that for worker planned work and higher risk jobs, work planners are also required to have pre-job briefings, work-site walk-arounds, and to use past feedback from post-job reviews in order to establish controls prior to the start of work.

Purchasing and leasing specifications, laws and regulations and SBMS requirements are identified prior to the procurement of goods and services.  C-AD procurement policies and procedures are found in OPM Chapter 13, Quality Assurance.

Arrangements are established and maintained for ensuring that the C-AD environmental, safety and health requirements, or at least the equivalent, are applied to contractors and their workers. See OPM 1.12, Training and Qualification Plan and Construction Safety Subject Area.

Emergency prevention, preparedness and response arrangements are established in cooperation with the BNL Emergency Services Division. The Collider Accelerator Department’s emergency preparedness and response program (C-A OPM 3.0, Local Emergency Plan) supplements the Laboratory Plan found in the Emergency Preparedness Subject Area, and makes provisions for emergency situations that are unique to the Collider-Accelerator complex.

4. Perform work within authorization agreement

4.4.3 Communication, participation and consultation

4.4.6 Operational control

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4.4.3 Communication

4.4.6 Operational control

The OHSAS 18001 Subject Area describes the methods to communicate OSH policies, hazard and risk identification and control procedures, objectives, procedures, roles, responsibilities, authorities, and other components of the occupational safety and health management system (OSH MS) so that an employee will safely complete an assigned task.

Safe operation and maintenance of the Collider-Accelerator Department's science and technology (S&T) machines, injection systems, and experimental areas are under the supervision of the Collider-Accelerator Department Chair, the Accelerator Division Head, the Experimental Support & Facilities (ES&F) Division Head, the on-duty Operations Coordinator, and the supervisory structure. See the C-A Organization Chart.  Authorization authority for all the activities within the C-A Department is defined in OPM 1.1, Authorizations. 

ASE requirements are communicated to the staff through the OPM 2.5 series of procedures.  See OPM 2.5 Accelerator Safety Envelope Parameters for AGS, Booster Linac and Associated Experimental Areas, OPM 2.5.1 Accelerator Safety Envelope Parameters for C-A Tandem Van de Graaff, OPM 2.5.2 RHIC Accelerator Safety Envelope Parameters, and OPM 2.5.3 NSRL Accelerator Safety Envelope Parameters.

Occupational safety and health controls for specific areas are identified in Facility Specific OSH Operational Control Forms.  Controls are also identified in permits, OPM procedures, FRAs and JRAs.

For environmental aspects, controls are identified for specific C-AD processes in EMS Operational Control Forms.  Controls are communicated to staff via Process Specific Training.

5. Feedback and improvement

4.5 Checking

4.5.1 Performance measurement and monitoring

4.5.2 Evaluation of compliance

4.5.3 Incident investigation, nonconformity, corrective action and preventive action

4.5.4 Control of records

4.5.5 Internal audit

4.6 Management review

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4.5 Checking

4.5.1 Monitoring and measurement

4.5.2 Evaluation of Compliance

4.5.3 Nonconformity, corrective action and preventive action

4.5.4 Control of records

4..5.5 Internal audit

4.6 Management review

To ensure full participation of workers in work–related OSH issues, the Collider-Accelerator Department has established the Worker Occupational Safety and Health (WOSH ) Committee (see OPM 9.8.1) to elicit feedback and promote OSH communications.  Through this committee, Department management helps ensure workers are consulted, informed and trained on all aspects of OSH associated with their work.  Management also ensures workers have the time and resources to participate actively in the processes of organizing, planning, implementing, evaluating and improving the OSH management system.

OSH communications between workers, supervisors and managers is also encouraged by requiring OSH topics be part of every weekly meeting at the C-AD.  See the Safety Discussions Directive from the Associate Laboratory Director for High Energy and Nuclear Physics.

Procedures to monitor, measure and record OSH performance on a regular basis have been developed, established and are periodically reviewed. Collider-Accelerator OSH performance monitoring is achieved through several programs, and Performance Indicators are published quarterly.  C-A-OPM 13.10.1, Independent Assessment describes the overall monitoring of the C-A OSH program.  Specific monitoring of OSH hazards is listed in Facility Specific OSH Operational Control Forms and is specified in the OPM procedures where applicable.  A listing of OPM procedures associated with Performance Monitoring and Measurement can be found in OPM Attachment 1.10.4.a, C-A OSH Document Flow Down Matrix.

Investigations of the origin and underlying causes of work-related injuries, ill health, diseases and incidents identify failures in the OSH management system are documented.  The investigations include determining the extent of condition.  See OPM 9.4.5, C-A Accident/Incident Investigation and OPM 10.1, Occurrence Reporting and Processing of Operations Information.

The C-AD audit policy and program includes a designation of auditor competency, the audit scope, the frequency of audits, audit methodology and reporting.  Audits are used as the basis for examining, identifying and correcting weaknesses within the C-A OSH program to facilitate improved performance and compliance. The C-A Department’s audit process is defined in C-A-OPM 13.10.1, Independent Assessment, and includes:

• monitoring the achievement of specific OSH plans, established performance criteria and objectives (e.g., C-A Management Review and Self-Assessment programs)

• systematically inspecting work systems, premises, plant and equipment (e.g., OPM 9.4.1, Safety Inspection Program or Tier 1)

• surveying the working environment, including work organization (e.g., OPM 9.4.2, Self Evaluation, or the Safety Walk Program)

• surveying workers' health, where appropriate, through suitable medical monitoring or follow-up of workers for early detection of signs and symptoms of harm to health in order to determine the effectiveness of prevention and control measures (e.g., OPM 1.17, Hearing Conservation Program or OPM 8.24 Use of Beryllium)

• reviewing external BNL or DOE safety notices or ORPs reports for applicability to C-AD operations and maintenance tasks

• determining compliance with applicable laws and regulations, collective agreements and other commitments on OSH to which C-AD subscribes (e.g., OPM 1.5, Electrical Safety)

• the results of work-related injuries, ill health, diseases and incident investigations

• performance monitoring and measurement and audit activities

• additional internal and external inputs as well as changes, including organizational changes, that could affect the OSH management system

The findings of the Management Review are recorded, posted on the web and formally communicated to the persons responsible for the relevant elements of the OSH management system so that they may take appropriate action.  Findings are also communicated to the WOSH committee and employees.

Internal communication of significant aspects and EMS strategies is through the weekly planning meetings. During these structured meetings, involving appropriate personnel, work is planned and evaluated, concerns of safety, equipment, hazards, and environment are addressed, and resources are allocated.  

External communications regarding C-AD EMS issues are essential to assure that the policies of the Laboratory as well as those of the Departments are maintained to the highest standard. External communications may include correspondence with the following: regulators, DOE Site Office, suppliers, customers, civic groups, elected officials, general public, and the media. The primary means for official communications to these groups is through the Laboratory’s Correspondence and Commitment Tracking System (CCTS).

Due to the nature of its operations and the possible impact on the public the C-A Department has formalized guidelines for C-A Managers in OPM-1.10.3, Guidance on Community Involvement.

Environmental performance monitoring is achieved through C-A-OPM 13.10.1, Independent Assessment. Specific monitoring of environmental aspects is as outlined in the Operational Control Forms, and as specified in the associated C-AD OPMs.  A listing of OPM procedures associated with Monitoring and Measurement can be found in OPM Attachment 1.10.2.c.

The Environmental Compliance Representative (ECR) plays the key role in evaluating and assuring Environmental Compliance with the Collider Accelerator Department and the Superconducting Magnet Division. The ECR serves as a core team member in the evaluation of regulatory compliance on environmental issues. It is the responsibility of the ECR to be knowledgeable on federal, state and local regulations that impact the environment and to insure that the departments are aware of the impact of the requirements on operations as well as the actions needed to comply. The ECR acts as a liaison between the Laboratory-level Environmental Services subject matter experts and the departments in translating, facilitating, and assuring regulatory requirement implementation. As a core team member the ECR participates in C-AD compliance evaluation through the following programs:

• C-AD Tier I Inspections

• C-AD Work Planning Reviews

• C-AD Experiment Safety Reviews

• C-AD Accelerator Systems Safety Reviews

• Environmental and Waste Management Services Division Targeted Compliance Assessments

On an annual basis the Environmental and Waste Management Services Division targets regulatory compliance assessments to be performed across the laboratory. These regulatory assessments coincide with the laboratory’s environmental regulatory requirements as specified in various SBMS subject areas. The C-AD ECR facilitates these audits and in most cases performs these audits in conjunction with the subject matter expert. The audits are performed in accordance with the Environmental Assessments subject area.

Compliance is also evaluated at the laboratory and organizational level through assessment by outside Regulatory agencies, Department of Energy Representatives, and through the Laboratory’s Independent Oversight organization.

Internal audit is part of the C-A Self Assessment Plan.  The Plan details C-AD’s response to the Laboratory’s Critical Outcomes and the Environmental and Waste Management Services Division’s Environmental Priorities. The Self Assessment Plan encompasses planned assessments and compliance audits of the EMS Program.  Assessments and audits are used as the basis for examining, identifying strengths, and correcting weaknesses within the EMS program to facilitate improved performance and compliance. C-AD audits its EMS program following the Environmental Assessments Subject Area. C-AD's assessment process is defined in C-AD OPM 13.10.1, Independent Assessment.

As a routine part of their operations, C-AD conducts various reviews at the senior management level. These meetings are held both weekly and monthly. C-AD meetings are reflected in the flow diagrams and table found in C-A-OPM-ATT 2.28.a. Annually, and prior to ISO-14001 re-registration, the C-AD Environmental Management Representative schedules a review of the C-AD EMS Program with senior management. The agenda and presentations are published. The management review is accomplished in accordance with the provisions of the Subject Area, Preparing and Conducting Environmental Management Reviews.  A formal Record of Decision is documented and approved as a result of the Management Review.  As appropriate, these documented decisions are formally included in the next annual cycle of the EMS and OSH programs for action.

1. Line managers clearly responsible for ES&H

4.1 General requirements

4.4 Implementation and operation

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4.1 General requirements

4.4 Implementation and operation

C-A Department’s establishment and maintenance of an OSH program is prescribed by OHSAS 18001 Subject Area. This program also embodies the requirements BNL’s Integrated Safety Management System (ISM) and DOE Order 450.4, Safety Management System Policy.

The C-A Department functional relationships and responsibilities for OSH and E management systems are outlined in C-A OPM 13.1.1, Quality, OSH and Environmental Management Systems. The C-A Department Chairman is responsible for implementation of OSH and E requirements within the C-A Department and appoints an OSH and E Management Representatives (ESSHQ Associate Chair) to ensure that the OSH and E system requirements are established, implemented and maintained.

2. Clear ES&H roles and responsibilities

4.4.1 Resources, roles, responsibility, accountability and authority

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4.4.1 Resources, roles, responsibility and authority

Safe operation and maintenance of the Collider-Accelerator Department's science and technology (S&T) machines, injection systems, and experimental areas are under the supervision of the Collider-Accelerator Department Chair, the Accelerator Division Head, the Experimental Support & Facilities (ES&F) Division Head, the on-duty Operations Coordinator, and the supervisory structure. See the C-A Organization Chart.  Authorization authority for all the activities within the C-A Department is defined in OPM 1.1, Authorizations. 

The Roles, Responsibilities, Accountabilities, and Authorities (R2A2s) establish the expectations and duties of managers and staff for carrying out the work consistent with external and internal requirements.  R2A2s are developed to form an understanding between each employee and their supervisor regarding performance expectations, based on the employee's role.  A C-AD employee's R2A2 is the comprehensive document that clearly communicates management expectations through the assignment of one or more roles for each employee, and the responsibilities, accountabilities, and authorities associated with each role.  C-AD employees acknowledge that he/she understands and accepts what is expected of them.  Individual R2A2s are available upon request and are kept by the Department Secretary.

3. Competence commensurate with responsibilities

4.4.2 Competence, training and awareness

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4.4.2 Competence, training and awareness

The training program for the C-A Department is described in C-A-OPM 1.12, Conduct of Training Policy.  Formal training and qualification programs for the operation of equipment, processes and procedures that could have a significant impact on personal safety or health or the environment are documented. Job specific training is developed for C-AD processes that involve significant hazards or significant environmental aspects. Employees that have interaction in these processes are required to go through training. Competency requirements are specified and can be attained through testing or the read and acknowledgement form.

Specific OSH and E competence and training, within the C-AD consists of the following:

• All C-AD employees and users are given the facility specific Access Training .

• All new C-AD employees complete training assigned to their individual Job Training Assessments (JTA) jointly developed by their supervisor and the appropriate Training Manager. This includes web based courses, classroom courses, and OJT.  BNL’s BTMS is the location where individual’s JTA records are maintained.

• Facility Specific OSH Training and Process Specific E Training has been developed for processes that involve significant hazards or environmental aspects. This training addresses process-specific conformance, safety and health issues, benefits of improved performance, each person’s role and responsibility, the consequences of nonconformance and the appropriate actions to be taken in an emergency.

• Job specific training required by DOE Orders or 29 CFR 1910.  See the "Required Training" link at BTMS for the list of required training courses for specific target audiences.

4. Balanced priorities

4.2 OH&S policy

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4.2 Environmental policy

General environmental, safety and health policy for the C-A Department is flowed down from the BNL Environmental, Safety Security and Health Policy and the BNL OSH Vision Statement.  The principles are documented at the Department level in OPM 1.10, C-A Environmental, Safety and Health Policy, and the specific details of the occupational safety and health policy is documented in OPM 1.10.4, OSH Management System Program Description.

5. Identify ES&H standards and requirements

4.3.2 Legal and other requirements

4.4.4 Documentation

4.4.5 Control of documents

4.5.4 Control of records

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4.3.2 Legal and other requirements

4.5.3 Nonconformity, corrective and preventive actions

4.4.4 Documentation

4.4.5 Control of documents

4.5.4 Control of records

At the design stage, occupational safety and health requirements and standards are applied to accelerators and experiments by C-AD safety committees.  Procedures governing these reviews are OPM 9.2.1 Procedure for Reviewing Environmental, Health and Safety Aspects of an Experiment and OPM 9.3.1 Procedure for Reviewing Conventional Safety Aspects of a C-A System and OPM 9.1.1 Procedure for Obtaining Review by C-A Radiation Safety Committee.  A Hazard Assessment Tool is used to guide committees in assessing the OSH and E requirements, legal requirements and other requirements associated with new experiments or changes to the accelerator facilities.

Operations procedures are controlled under the requirements in OPM 1.4, Collider-Accelerator Department Plans, Policies, and Operating Procedures defines the management of new or changed operating plans, procedures, and policies at the Collider-Accelerator Department.

OPM 13.6.1,  Preparation & Issuance of Engineering Drawings/Specifications defines a process for the preparation and release of C-A drawings and specifications (excluding architectural).  This process supplements the BNL Standard Based Management System (SBMS) Design Subject Area and has been prepared in consultation with the C-A Mechanical and Electrical Design Rooms.

OPM 13.4.1 defines a records management program for C-AD, which supplements the BNL SBMS Management System Description for Records Management and the Records Management Subject Area.

OPM 13.4.2, Records Index, lists those records which provide important departmental information about items, processes, operations, and activities that may have significant impact on personnel, environmental, or health.  OPM 13.4.2.c is a specific list of occupational safety and health records and their retention times.

Nonconformities and corrective and preventive actions are documented through the DOE Occurrence Reporting System and through Critiques,  Actions are tracked in BNL ATS or C-AD Family ATS.  

6. Hazards controls tailored to the work

4.3 Planning

4.3.1 Hazard identification, risk assessment, and determining controls

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4.3 Planning

4.3.1 Environmental aspects

The results of the initial hazard reviews were documented in the Workplace Hazard Analyses and Risk Assessments.  Follow-up reviews are documented in Facility and Area Risk Assessments (FRAs) and Job Risk Assessments (JRAs). These assessments are the basis for making decisions regarding the implementation of the OSH management system, and they are updated annually.

Hazard controls, procedures or arrangements are also identified in Facility Specific OSH Operational Control Forms.

Because Collider-Accelerator Department is an accelerator facility, a Safety Assessment Document and Accelerator Safety Envelopes were developed.  The ASEs were approved by DOE for accelerator operations. 

The results of Process Evaluations were documented in 1999. and are updated annually to reflect changes in environmental aspects, changes in processes, changes in waste streams and pollution prevention upgrades.  Specific operations controls, maintenance plans, and actions to be taken if controls fail are outlined in process-specific Operational Controls Forms.

7. Operations authorization

4.4 Implementation and operation

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4.4 Implementation and operation

Authorization authority for all the activities within the C-A Department is defined in OPM 1.1, Authorizations.  Operations authority for accelerator operations is defined in OPM 2.1, Operations Organization and Administration.  Activity level authorization is indicated on permits and in procedures.  The basis for DOE authorization were the Accelerator Readiness Reviews.