**Materials Safety Division**

**Integrated Safety Management Plan**

**[Policy Statement]{.underline}**

The Materials Sciences Division (MSD) has implemented an Integrated
Safety Management (ISM) program that meets or exceeds all of the
standards described in LBNL institutional policy and procedure
documents, including:

-   The Regulations and Procedures Manual (RPM, PUB-201)

-   The Health and Safety Manual (PUB-3000)

-   The Integrated Environment, Health & Safety Management Plan
    (PUB-3140)

-   The Operating and Assurance Plan (OAP, PUB-3111).

This ISM Plan implements the LBNL Integrated Safety Management program
within the Division. The plan establishes the mechanisms and management
strategies that will ensure that all institutional EH&S policies and
procedures are properly implemented.

[Materials Sciences Division Work on the University of California at
Berkeley Campus]{.underline}

Except where noted, this plan applies to work conducted in LBNL
facilities but does not apply to work performed by MSD personnel on the
campus of the University of California at Berkeley. In accordance with
the *Partnership Agreement between UCB and LBNL Concerning Environment,
Health and Safety Policy and Procedures (March 15, 2004)*, all campus
MSD laboratories implement the ISM program via campus-based mechanisms
with the assistance of the campus Office of Environment, Safety and
Health.

The requirements described in this ISM Plan apply, as appropriate, to
faculty, staff, matrixed staff, postdocs, students, participating
guests, visitors, users, vendors and contractors performing work under
the management control of MSD.

**[Division Safety Management Structure]{.underline}**

The Materials Sciences EH&S program structure consists of:

-   Division Director

-   Deputy Division Director

-   Facility/EH&S Manager

-   EH&S Technician

-   Building Managers

-   Facility/EH&S Administrator

-   Electrical Safety Technician

-   SRC Representative

-   Division Safety Committee (representative from each LBNL research
    group)

-   Molecular Foundry Safety Subcommittee

-   Executive Safety Committee

-   EH&S Division Liaison

-   EH&S Division Waste Generator Assistant

Principal investigators (PI's) and supervisors are responsible and
accountable for implementation of this ISM plan in their labs and
workplaces. PI's and supervisors may designate one or more "lab safety
coordinator(s)" to assist in the implementation of the ISM plan and
serve as a point of contact for EH&S issues. Guests and users may not be
so designated without the approval of the Division EH&S Manager.
However, while activities can be delegated, the ultimate responsibility
for implementing the ISM program cannot be delegated below the level of
PI/supervisor.

**[Line Management Responsibility and Accountability]{.underline}**

[Principal Investigator's EH&S Responsibilities]{.underline}

All Principal Investigators (LBNL and UCB-based) are responsible and
accountable to the Division Director for ensuring that all activities
are carried out in a safe manner and in accordance with all Laboratory
or UCB EH&S requirements, as appropriate. PI's are responsible for range
of EH&S functions, including:

-   Ensuring EH&S requirements are integrated into all work activities
    and the necessary resources/controls are provided in a timely manner
    to do the work safely

-   Creating and communicating meaningful EH&S expectations and holding
    staff, students and guests accountable for implementing these
    expectations.

-   Identifying the EH&S training requirements and medical surveillance
    requirements for their staff, students, guests and vendors and
    ensuring that training and medical evaluations are completed in a
    timely manner.

-   Conducting periodic safety walkthroughs of labs, offices and other
    workplaces for which they are responsible to identify problems in
    the facilities, equipment or work practices.

-   Participating in scheduled lab inspections with the MSD EH&S
    Technician (LBNL only) and annually with the Division EH&S Manager
    and EH&S Liaison (campus and LBNL).

-   Preparing, maintaining and renewing required Formal Authorization
    Documents

-   Managing the accumulation, storage and disposal of hazardous waste

-   Ensuring that new or significantly modified projects or facilities
    are reviewed for hazards in the planning stage.

-   Conducting periodic safety meetings with supervised staff, students
    and guests.

-   Designating the following:

    -   Representative/back up for the Division Safety Committee (LBNL
        only)

    -   Managers/backups for all Satellite Waste Accumulation Areas
        (SAAs)

    -   Lab Safety coordinators, as necessary

    -   Crane managers, as necessary

[Shared Lab Space and User Facilities]{.underline}

The scientist responsible for lab facilities (at LBNL and on the UCB
campus) that are shared with individuals outside his or her research
group is responsible for ensuring that the guest/user has been fully
trained and complies with applicable EH&S policies,. The

lab manager may provide required "on the job training", or the line
manager or others may provide this training, but it is the lab managers'
responsibility to prohibit work from proceeding until training has been
completed. This applies equally to user facilities managed by the
Division (NCEM, Molecular Foundry) and labs that are informally shared.
In general, the Division requires guests to follow the same EH&S
procedures and requirements as staff and students. Only the
host/assigned scientist can authorize work to be performed by the guest.

[Students]{.underline}

The Division ISM plan does not distinguish between students and other
personnel working in the Division. Students are afforded the same
protections and assume the same obligations with regard to EH&S as other
workers at LBNL. Students must complete the same EH&S classes as staff.

[Vendors]{.underline}

Division personnel who request or arrange for vendor support for repair
or maintenance of equipment should meet with the maintenance technician
and advise him/her to follow LBNL EH&S requirements and integrated
safety management. The Division provides a form to be used for this
purpose where the equipment is electrically powered. Where additional
information is required regarding EH&S requirements, contact the
Division EH&S Manager for support.

[Matrixed Employees/Employees Working in Non-MSD Facilities]{.underline}

Matrixed employees' supervisors from the home divisions retain all
health and safety responsibilities for matrixed employees, except where
some of the responsibilities have been transferred to the Division
through a formal Memorandum of Understanding. MSD personnel will provide
operation-specific training to matrixed individuals.

**[Assurance Mechanisms]{.underline}**

The Division has implemented a variety of EH&S assurance mechanisms, as
described below.

[Project Hazard Guide]{.underline}

MSD has developed a "Project Hazard Guide" that facilitates the hazard
evaluation of work in laboratories. Central to this process is the
Project Hazard Guide Questionnaire, which is completed annually by each
LBNL-based PI. The form currently lists 41 potential hazards likely to
be present in Division work. The responses on the questionnaire are
reviewed by the EH&S Manager. Positive responses are used to target
hazard evaluations and inspections of research operations which may
require formal authorization or present hazards above the ordinary.

[EH&S Component of Performance Appraisal]{.underline}

LBNL staff scientists receive annual performance appraisals. 10% of
their assessment is based on their EH&S performance, including their
performance in inspections, assessments and reviews conducted during the
appraisal year.

[One-On-One Meetings with New Students, Postdocs and Staff]{.underline}

The Division Facility/EH&S Manager meets briefly with each new staff
member, GSRA student and post doc working for MSD at LBNL to review
their planned work, the answers to the JHQ and discuss the LBNL ISM
program. This does not apply to guests, users or students working
exclusively in UCB laboratories.

[Affirmation]{.underline}

All PI's (LBNL and UCB) confirm their EH&S responsibility at least
annually through their signature on the MSD Safety Assurance Statement
(SAS) which is required for all proposals processed through MSD. The
text of this document to be used in 2006-7 is given below.

> I have reviewed the impact of the component of the research described
> in this proposal that will be performed in my laboratories under my
> direction on the environment and on the health and safety of the
> staff, students and visitors who will do the work. I certify the
> following:
>
> 1\. Proper procedures, equipment, and facilities will be employed and
> all staff will be properly trained to carry out this work in a safe
> and environmentally benign manner. In determining that all the
> procedures, permits, authorizations, and/or approvals required for my
> new and ongoing projects are in place I consulted with LBNL Pub 3000,
> the MSD Project Hazard Guide, or UCB safety guidelines as appropriate.
>
> 2\. **Research in LBNL Main site laboratories**. For all my research
> projects, regardless of funding source, that are pursued in LBNL
> space, I have personally inspected all of the laboratory space under
> my direction and have given a safety presentation to all of the staff,
> students, and visitors under my supervision at least once in the past
> year and will do so at least once in the coming year.
>
> 3\. **Research in UCB laboratories** For all my research projects that
> are funded through LBNL and pursued in UCB space, I or my designee has
> personally inspected all of the laboratory space under my direction at
> least once in the past year using the appropriate checklist for my UCB
> department and has ensured that the completed checklist has been
> submitted to the appropriate UCB Department Safety Coordinator with a
> copy sent to the MSD EHS Administrator. This will be completed at
> least once in the coming year.

[Calendar of Routine EH&S Activities]{.underline}

The Division has developed an annual calendar scheduling 10 routine EH&S
activities for labs. Every month, PI's are asked to conduct 1-3 targeted
EH&S activities, such as inspecting their waste accumulation areas,
reviewing staff and student training or verifying their chemical
inventory. The MSD EH&S Administrator sends PI's (and SAA managers, as
appropriate) monthly notices regarding the activities scheduled for that
month. Use of this tools is voluntary and at the discretion of the PI.

[Inspections and Assessments]{.underline}

> *[Bimonthly Technician Inspections]{.underline}*

Approximately every other month, the MSD EH&S Technician will inspect
each LBNL-based laboratory using a checklist designed specifically for
MSD labs. As part of this inspection the technician will review waste
management practices, chemical inventory, peroxidizable chemical
management, laser safety controls, safety signs, ventilation monitor
function, use of personal protective equipment, and other EH&S issues.
The technician will communicate problems directly to laboratory
personnel and track items that cannot be immediately corrected in the
Corrective Action Tracking System (CATS).

> *[Technician/Principal Investigator Inspections]{.underline}*

Twice a year the MSD EH&S Technician will perform a laboratory
inspection with the principal investigator. The inspection will include
the elements of the bimonthly technician inspections as well as
reviewing new work, laboratory changes and work practices. The
technician will document these joint inspections and track items that
cannot be immediately corrected in the CATS database.

> *[Waste Accumulation Area Inspections]{.underline}*

The EH&S Waste Generator Assistant and the MSD EH&S Technician will
conduct a quarterly comprehensive review of the satellite waste
accumulation areas in the Division. The Waste Generator Assistant
inspects the building 62 waste accumulation area weekly.

> *[Annual Self-Assessment Inspection]{.underline}*

At least annually, the MSD EH&S Manager, EH&S Liaison (LBNL or campus,
as appropriate) and the PI will conduct a joint inspection of each
laboratory (LBNL and UCB). For LBNL labs the EH&S Manager will document
these joint inspections and track items that cannot be immediately
corrected in the CATS database. For campus labs, the Campus Office of
Environment, Health and Safety will track issues identified during
inspections.

> *[Triennial Management of Environment, Safety and Health Assessment
> (MESH)]{.underline}*

As required by the SRC, the Division will participate in the MESH review
that evaluates management systems and implementation of ISM
requirements. This review is run by the Safety Review Counsel and
typically includes representatives from the Office of Contract
Assessment (OCA) and EH&S Division. MSD completed the MESH review in
2006.

> *[Program Reviews]{.underline}*

The EH&S Division is developing a program review process to examine
specific safety topics in details. Examples would be laser safety,
electrical safety and crane safety. MSD will participate in this review
program as requested.

**[Training]{.underline}**

LBNL Policy generally allows:

-   New employees, participating guests and students to work for up to
    90 calendar days without completing required institutional training
    unless the training is required by a formal authorization document.

-   Employees, Guests, Students, Contractors with appointments of 30
    calendar days or less are not required to complete most
    institutional EH&S training and do not need to fill out the Job
    Hazards Questionnaire (JHQ).

-   "Occasional Guests, Students and Contractors" are not required to
    complete institutional training but must be under constant
    supervision by a trained individual.

-   Training specified in formal authorization documents must be
    completed prior to starting work.

MSD has a somewhat different policy for training:

-   Participating guests (including users at the Molecular Foundry and
    National Center for Electron Microscopy) who work at LBNL for fewer
    than 7 continuous days may do laboratory work without LBNL training
    or completion of the JHQ but only under the continuous line-of-sight
    supervision of someone who is trained for that work.

-   New staff, students and post docs are allowed to work under
    line-of-sight supervision for 7 days prior to training or completing
    the JHQ.

-   Due to the limited availability of the EHS0604 "Hazardous Waste
    Generator" class, all people new to LBNL may generate hazardous
    waste for 30 days by completing EHS0623, "Hazardous Waste Generator
    for Guests". After 30 days they must complete EHS0604 to continue
    generating waste.

-   This 7 day grace period does not apply to all training, although the
    EH&S Division has not yet clearly defined this distinction in most
    cases. By Division policy this 7 day "line of sight" proviso does
    not apply to:

    -   EHS 250 series electrical safety classes in the EHS250 series

    -   EHS274, 275 and 277 in the confined space series

    -   EHS310-315 in the respiratory protection training

    -   EHS410-418 X-ray machine safety for operators, supervisors and
        maintenance personnel

    -   TMF10, Integrating EH&S Into Science at the Molecular Foundry

    -   MSD010, Introduction to EH&S for New MSD Students, Staff and
        Guests

-   After 7 days all individuals must complete the JHQ to facilitate the
    identification of training requirements and must complete the
    required training prior to starting/continuing work for which
    training is required.

-   EHS260, Basic Electrical Hazards and Mitigations, is not required
    for guests/users at NCEM and the Foundry who will not perform work
    that potentially exposes them to \>50 volts (e.g. equipment
    maintenance, repair, construction). The MSD EH&S group will wave
    this class in the database after verifying that the individual will
    not be performing work where he/she will actually be exposed to
    electrical hazards.

-   Training classes subject to the 7 day grace period may be waved by
    the supervisor by providing substantial evidence to the MSD EH&S
    Manager demonstrating that the individual has equivalent training at
    another institution. The final decision on training class wavers is
    the EH&S Manager's.

-   UCB: Campus personnel must be trained to safely perform the work
    they will do. All campus-based students and post docs must complete
    the JHQ. The LBNL classes that are recommended by the JHQ process
    are available to UCB personnel. Campus personnel may be trained by
    attending LBNL classes, campus classes, on-the-job training or other
    means deemed adequate by the principal investigator.

Training is available in a number of ways, including:

-   On-line at the Institutional Training Web Site (e.g., TMF010)

-   On line at the MSD web site (e.g. MSD010)

-   Via CD available from the EH&S Administrator (e.g. EHS060)

-   Via attendance at class

-   By supervisor exemption. A supervisor may exempt an employee/guest
    from a

> required training class if the employee/guest has already been trained
> for a particular hazard by a combination of prior experience
> \[includes training classes taken at other institutions\] and/or
> on-the-job training. This exemption must be proposed to the Division
> EH&S Manager.

**[Medical Surveillance]{.underline}**

Few MSD personnel are required to participate in a medical surveillance
program. The common exceptions are:

-   Laser Eye exam (EHS 280): Must be completed prior to working on a
    class 3b or 4 laser system unless under direct line-of-sight
    supervision by a PI or fully qualified individual designated by the
    PI. Must be completed within 30 days of starting work with a class
    3b or 4 laser system even if fully supervised

-   Respiratory protection medical review: Must be completed prior to
    starting work where a respirator is required.

**[Communication and Feedback]{.underline}**

MSD employs a variety of tools to facilitate communication of EH&S
issues.

-   [Materials Safety]{.underline}--A short safety bulletin addressing a
    single, timely EH&S issue. Members of the Safety Committee are asked
    to bring topics to the attention of the EH&S Manager for
    consideration as an edition of Materials Safety. Suggestions may
    also come from any Division employee, student or guest.

-   [Division Safety Committee]{.underline}--Representatives from all
    LBNL-based research groups attend a quarterly Division Safety
    Committee meeting to review Division EH&S performance and incidents,
    discuss problems and support the self assessment process. The
    committee is chaired by the Facility/EH&S Manager and includes the
    Deputy Director (*ex officio*), the EH&S Technician, the Electrical
    safety technician, building managers and the liaisons from the EH&S
    Division.

-   [Molecular Foundry Safety Subcommittee]{.underline}--Drawn from the
    Division Safety Committee, the subcommittee includes representatives
    from each Foundry program. It meets on an *ad hoc* basis.

-   [Research Group Meetings]{.underline}--Each PI meets with members of
    his or her research group and EH&S topics must be discussed at least
    quarterly. At least annually, the EH&S Manager will attend one of
    these group meetings to facilitate the safety discussion

-   [EH&S News Boards]{.underline}--Glass-enclosed bulletin boards
    dedicated to EH&S issues have been installed strategically in
    MSD-managed buildings (2, 62, 66, 67, 72, total of 16 cabinets).
    These are used to post timely EH&S information such as the monthly
    schedule of EH&S activities and recent editions of Materials Safety.

-   [Annual PI meeting]{.underline}--A review of Division EH&S
    performance and prospective look at initiatives for the coming year
    is presented at the Division Strategic Planning Meeting every year.
    All Division PI's are required to attend this important meeting.

-   [Hazard Communication Sign]{.underline}--MSD has developed a greatly
    enhanced hazard communication door sign that is being phased into
    use, starting in the Molecular Foundry. PIs are responsible for
    maintaining and updating the hazard communication sign when the
    hazards or people change. Contact the MSD EH&S Administrator to have
    new signs created and posted.

**[Institutional EH&S Databases]{.underline}**

MSD actively participates in the management of Division data in the
following institutional EH&S Databases:

-   Chemical Management System (CMS)

-   Supervisors Accident Analysis Report (SAAR)

-   Hazards, Equipment, Authorizations Report (HEAR)

-   Corrective Action Tracking System (CATS)

-   Job Hazards Questionnaire (JHQ)

-   Laser inventory Database

-   Activity Hazard Document database (AHD)

**[Authorization of Work]{.underline}**

[Formal Authorization]{.underline}

Approximately 30 Division operations are "formally authorized" via
Activity Hazard Documents (AHDs), X-Ray Authorizations, Human Subjects
Approvals or other institutional mechanism. These authorizations are
contracts between the PI, the Division and the institution that bind the
PI to a set of safety conditions and requirements. These contracts are
inviolate; if the PI or others working in the lab cannot meet the
conditions of the work authorization then work must be suspended until
changes can be made in the work, controls or authorization document.

PI's are responsible for recognizing when they are planning work that
requires formal authorization and obtaining that authorization prior to
starting work. The institutional triggers for formal work authorization
can be found in Pub3000, the MSD Project Hazard Guide and the slides
from MSD/EHS026 "ISM for PI's and Supervisors" class.

Individual principal investigators prepare AHDs. Principal investigators
may appoint work leaders to assist in the preparation and maintenance of
their AHDs, but they may not delegate their responsibility for these
actions. AHDs are initially authorized by the Division Director and
annually reauthorized by the Facility/EH&S Manager. If the scope of work
changes substantially, resulting in increased hazards, the EH&S Manager
may, at his discretion, request the Division Director to reauthorize the
AHD. All AHDs will be transferred to the on-line AHD database before the
end of FY07.

Maintenance of formal work authorizations is the responsibility of the
PI. The PI must update his or her AHDs at least annually or immediately
whenever the work changes such that new personnel or hazards are
involved. All researchers, including users and guests participating in
research that is authorized via an AHD must be added to the electronic
AHD before starting work (does not apply if the guest is not actually
performing potentially hazardous work; does not apply for up to 7 days
during which the user is under line-of-sight supervision by a trained
individual). For the radiological authorizations (other than X-Ray), it
is necessary to notify EH&S in advance of new or short term users,
guests or students.

[Line Management Authorization]{.underline}

Work that falls below the threshold for formal authorization is
authorized by the principal investigators/supervisors. The Project
Hazard Guide Questionnaire is one mechanism that is used to authorize
work. The answers to this questionnaire are reviewed by the Division
Facility/EH&S Manager to ensure that work authorizations are appropriate
and to target further hazard assessment activities.

Work by users at the Molecular Foundry is authorized by the lead or
staff scientist assigned to the work via the "Molecular Foundry Work
Authorization Record\". It is anticipated that this process will be
converted from a paper system to a computer-based system within FY07.

**[The Molecular Foundry]{.underline}**

Each user proposal to the Molecular Foundry is screened by the Division
Facility/EH&S Manager twice to identify EH&S requirements. As part of
the initial proposal submission process, the prospective user answers 7
key EH&S questions that pertain to high hazard activities. This allows
the identification of proposed work that falls outside of the safety
envelope of the facility or that will have significant cost or
administrative impacts.

Accepted proposals go through a second, comprehensive EH&S review
intended to identify appropriate training, formal authorization
requirements, additional engineering or personal protective controls and
the need for government permits.

The Foundry scientist responsible for each accepted proposal will
authorize the work to proceed only when all of the requirements
identified in this EH&S review have been implemented. Authorization of
work requires the user and the managing Foundry scientist to cosign a
Work Authorization Record that summarizes the EH&S requirement and
affirms that the user has met all of the requirements and will seek
further authorization if the scope of his or her work changes.

Prior to starting work in the Foundry, all users and guests must
complete the on-line training class TMF010, "Integrating EH&S into
Science at the Molecular Foundry". All users of class 3b and 4 lasers
must complete the institutional laser training prior to working directly
with lasers in the Foundry.

The Foundry is instituting the consensus document on nanoscale safety
developed by the five DOE Nanoscale Research Centers *(Nanoscale Science
Research Center:\
Approach to Nanomaterial ES&H* dated 8/2/06).