**LBNL Information Technologies Division**

**EH&S Self-Assessment Report**

**Performance Year 2007**

**Performance Period: 10/1/06 - 9/30/07**

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> **Rosio Alvarez Date**
>
> **IT Division Director**
>
> **\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**
>
> **Ann Tomaselli Date:**
>
> **Division Safety Coordinator**

**[PY 2007 Overview of IT Response to Self-Assessment]{.underline}**

As stated in the IT ISM Plan:

> *The IT Division will conduct all of its operations in a manner that
> protects the health and safety of its personnel/staff, including
> employees, participating guests, contractors, vendors, students and
> visitors, does not endanger the environment, and is consistent with
> all applicable LBNL, university, and government agency policies and
> regulations.*

Attached you will find the Information Technology (IT) Division's
response to this year's ES&H Performance Measures. Our most outstanding
accomplishments in PY2007 were a) the establishment of a division safety
infrastructure, including Division Safety Coordinator, IT Safety
Committee, and Integrated Safety Management (ISM) Plan and b)
implementation of an aggressive division-wide ergonomics safety program.
Through this process, we identified a few significant areas for
improvement, including a) building additional awareness and ownership of
the ISM principles within the Division, b) formalizing, documenting, and
implementing our hazard review process, and c) addressing safety line
management.

We do need some help from EH&S. Specifically, current databases,
including HEAR, CATS, Ergo, etc., are in need of improvement. Currently,
it is difficult to gather required data and metrics to facilitate
tracking as well as measurement of performance. Further the user
interface for the HEAR database is particularly cumbersome.
Additionally, we have concerns, during times of increased workload,
regarding the timeliness of "discomfort" ergonomic evaluations being
performed and entered into the database. Also due to the dissolution of
the chair loaner program, and changes to how ergonomic equipment is
procured, we have experienced delays in receiving as well as proper set
up of equipment needed. We suggest that the Laboratory at large look
into reinstating a loaner program with a broader menu of equipment to
expedite ergonomic purchases as well as formalize a relationship with
Facilities for the set up of this equipment to address ergonomic issues
in a timely manner. This includes a review of equipment and appropriate
layout when new employees first arrive.

Finally when a recordable does occur, due to a shortage in EH&S staff
available to perform incident reviews, we have experienced significant
delays in completing the Tap Root analysis.

+--------------------+----------------------+--------------------------+
| Expectation        | Validation           | > IT Response            |
+====================+======================+==========================+
| ISM CORE FUNCTION  |                      |                          |
| 1: Define Work     |                      |                          |
+--------------------+----------------------+--------------------------+
| E1. Revise         | V1. 1) Divisions     | IT1. 1) On October 1,    |
| Division ISM plan  | revise ISM plans to  | 2006, the IT Division    |
| to reflect a) ES&H | reflect updates to   | was moved from the CS    |
| policy changes,    | ES&H Policy and the  | Directorate to the       |
| and b) updates to  | institutional ISM    | Operations Directorate.  |
| the Institutional  | plan made through    | Prior to October 1,      |
| ISM plan. Line     | June 30, 2007.       | 2006, IT shared a common |
| management         |                      | ISM plan with the other  |
| communicates       | 2\) Division         | Divisions in CS, NERSC   |
| updates of the     | demonstrates that    | and CRD. After the       |
| plan to division   | changes to the ISM   | reorganization, IT       |
| personnel          | plan were            | created its own ISM plan |
|                    | communicated to      | and published it to the  |
|                    | division personnel.  | IT staff website in June |
|                    |                      | 2007.                    |
|                    |                      |                          |
|                    |                      | IT1.2) The IT Division   |
|                    |                      | Director communicated    |
|                    |                      | this IT ISM Plan to the  |
|                    |                      | division on 8/21/07.     |
|                    |                      | 'Hits' to the website    |
|                    |                      | increased three-fold the |
|                    |                      | week of the division     |
|                    |                      | director's email.        |
|                    |                      | (Appendix B).            |
|                    |                      |                          |
|                    |                      | Goal for PY08: Build     |
|                    |                      | additional awareness     |
|                    |                      | within division of the   |
|                    |                      | ISM checklist and safety |
|                    |                      | resources available      |
|                    |                      | within our division      |
|                    |                      | (website and staff) .    |
|                    |                      | Consider development of  |
|                    |                      | ISM training similar to  |
|                    |                      | that developed by        |
|                    |                      | Engineering Division     |
+--------------------+----------------------+--------------------------+
| ISM CORE FUNCTION  |                      |                          |
| 2: Identify        |                      |                          |
| Hazards            |                      |                          |
+--------------------+----------------------+--------------------------+
| E2. Workspaces     | V2. Managers,        | IT2. Quarterly           |
| (including outside | supervisors and work | walkarounds were         |
| workspaces) are    | leads perform        | formally implemented in  |
| inspected/observed | periodic ES&H        | this performance year.   |
| and evaluated on a | walkarounds as       | Line managers conducted  |
| regular basis.     | needed and directed  | walkarounds in December, |
|                    | by divisional ISM    | March and June of 2006.  |
|                    | plans, and for all   | This was officially      |
|                    | work activities and  | published in the IT      |
|                    | facilities for which | Division ISM Plan in     |
|                    | they are             | June 2007. For the       |
|                    | responsible.         | December walkaround, 84% |
|                    |                      | of employees were        |
|                    | Deficiencies are     | evaluated. Of the 16%    |
|                    | tracked in CATS (as  | that were not 44% of     |
|                    | appropriate).        | those were guests who    |
|                    |                      | are not regularly at the |
|                    |                      | laboratory. For the      |
|                    |                      | March walkaround 90% of  |
|                    |                      | employees were           |
|                    |                      | evaluated. Of the 10%    |
|                    |                      | who were not 82% were    |
|                    |                      | guests. For the June     |
|                    |                      | walkaround 86% of        |
|                    |                      | employees were reviewed. |
|                    |                      | Of the 14% not reviewed  |
|                    |                      | 76% were guests. Forms   |
|                    |                      | from all safety          |
|                    |                      | walkarounds are kept by  |
|                    |                      | the Division Safety      |
|                    |                      | Coordinator.             |
|                    |                      |                          |
|                    |                      | As a result of findings  |
|                    |                      | from the walkarounds,    |
|                    |                      | items that were deemed   |
|                    |                      | to be ongoing hazards    |
|                    |                      | were entered into CATS.  |
|                    |                      | Standard ergonomic       |
|                    |                      | issues were tracked in   |
|                    |                      | the Ergonomics database  |
|                    |                      | with regular updates by  |
|                    |                      | the line supervisor and  |
|                    |                      | Division Safety          |
|                    |                      | Coordinator. Ongoing     |
|                    |                      | reviews of those at      |
|                    |                      | highest risk were        |
|                    |                      | discussed weekly with an |
|                    |                      | ergonomist from the      |
|                    |                      | Occupational Safety      |
|                    |                      | Group in EH&S.           |
|                    |                      |                          |
|                    |                      | The annual review of all |
|                    |                      | common space was         |
|                    |                      | conducted by the         |
|                    |                      | Division Safety          |
|                    |                      | Coordinator, Division    |
|                    |                      | Deputy and line          |
|                    |                      | management (where        |
|                    |                      | applicable) in August    |
|                    |                      | and September of 2007.   |
|                    |                      | Deficiencies that were   |
|                    |                      | not easily fixed during  |
|                    |                      | the walk-through were    |
|                    |                      | entered into CATS by the |
|                    |                      | Division Safety          |
|                    |                      | Coordinator and reviewed |
|                    |                      | at least once every      |
|                    |                      | month for status.        |
+--------------------+----------------------+--------------------------+
| E3. Divisions      | V3. For all Division | IT3. As noted in the     |
| review work        | projects, programs,  | PY06 CS Self-Assessment, |
| activities to      | and operations, have | the hazards in the HEAR  |
| identify, analyze, | hazards been         | database had not been    |
| and categorize     | identified and       | updated since 2000. This |
| hazards and        | inventoried? Does    | year, IT identified      |
| environmental      | inventory include    | hazards in its workspace |
| impacts for the    | non-routine, new     | and entered them into    |
| associated work.   | work and             | HEAR.                    |
|                    | modification of      |                          |
| > Examples of      | existing work?       | Additionally, the        |
| > hazard inventory |                      | Confined Space Program   |
| > include:         | > [Minimum           | Manager evaluated        |
|                    | > requir             | computer room floors and |
| -   HEAR database  | ements]{.underline}: | determined they were not |
|     (or            | > Division's review  | confined spaces. She     |
|     equivalent)    | > of work activities | also assessed manholes   |
|                    | > to identify,       | and added them to        |
| -   Project safety | > analyze, and       | confined space database. |
|     review         | > categorize hazards |                          |
|                    | > is consistent with | Goal for PY08: Remove    |
| -   Workspace      | > Lab policy.        | old entries from HEAR    |
|     safety review  |                      | database, and formalize, |
|                    | [Divisional          | document, and ensure     |
| -   Job Hazard or  | requir               | implementation of our    |
|     Safety         | ements]{.underline}: | hazard review process.   |
|     Analyses       | Division implements  |                          |
|     (JHA/JSA)      | hazards review       |                          |
|                    | process as described |                          |
| -   Environmental  | in its ISM plan.     |                          |
|     review         |                      |                          |
|     (NEPA/CEQA)    |                      |                          |
|                    |                      |                          |
| -   Chemical       |                      |                          |
|     inventory      |                      |                          |
+--------------------+----------------------+--------------------------+
| E4. Divisions      | V4. Divisions review | IT4. The IT Safety       |
| review the         | environmental        | Committee reviewed the   |
| environmental      | impacts of planned   | impacts of its           |
| impact of their    | and ongoing          | activities on the        |
| activities and     | activities; and      | environment and noted    |
| participate in     | demonstrate progress | the following practices: |
| pollution          | in reducing impacts  |                          |
| prevention, energy | through pollution    | -   recycling of paper,  |
| conservation,      | prevention, energy   |     cans, bottles,       |
| recycling, and     | conservation,        |     batteries and toner  |
| waste minimization | recycling, OR waste  |     cartridges           |
| programs.          | minimization.        |                          |
|                    | Examples of reducing | -   reuse of ergonomic   |
|                    | environmental        |     equipment to limit   |
|                    | impacts include:     |     purchasing of        |
|                    |                      |     extraneous equipment |
|                    | -   Waste prevention |                          |
|                    |     (hazardous,      | -   use of recycled      |
|                    |     radioactive,     |     paper products for   |
|                    |     and/or mixed)    |     printing and copying |
|                    |                      |     documents            |
|                    | -   Increase         |                          |
|                    |     procurements of  | -   use of electronic    |
|                    |     Energy Star      |     presentations rather |
|                    |     products         |     than using           |
|                    |                      |     transparencies.      |
|                    | -   Increase         |                          |
|                    |     procurements of  | -   distribution of      |
|                    |     recycled content |     presentations        |
|                    |     products         |     electronically       |
|                    |                      |     although we do       |
|                    | Implement            |     occasionally have    |
|                    | initiatives to       |     paper hand outs      |
|                    | reduce usage and/or  |                          |
|                    | recycle common       | Goal for PY08: Implement |
|                    | office products,     | the following            |
|                    | such as paper and    | initiatives:             |
|                    | batteries            |                          |
|                    |                      | -   set printers and     |
|                    |                      |     copiers to default   |
|                    |                      |     to two-sided rather  |
|                    |                      |     than single          |
|                    |                      |                          |
|                    |                      | -   eliminate fax cover  |
|                    |                      |     sheets               |
|                    |                      |                          |
|                    |                      | -   consider ability to  |
|                    |                      |     print double-side as |
|                    |                      |     a criteria when      |
|                    |                      |     purchasing/leasing   |
|                    |                      |     printers and copiers |
|                    |                      |                          |
|                    |                      | -   consider Energy Star |
|                    |                      |     purchases when       |
|                    |                      |     appropriate          |
+--------------------+----------------------+--------------------------+
| ISM CORE FUNCTION  |                      |                          |
| 3: Control Hazards |                      |                          |
+--------------------+----------------------+--------------------------+
| E5. Divisions      | V5. Are hazards      | IT5. IT follows the ES&H |
| ensure             | controlled for all   | entry requirements for   |
| administrative     | Division             | confined space.          |
| controls are in    | projects/activities? | Completed permits are on |
| place and          | Are administrative   | record with the ES&H     |
| maintained.        | controls reviewed    | Division. IT defined the |
| Examples of        | annually and when    | procedure for confined   |
| administrative     | work is modified?    | space (see Appendix A).  |
| controls include:  | This includes work   |                          |
|                    | under formal         | Goal for PY08: Review    |
| -   Formal         | authorizations (e.g. | logging and internal     |
|     authorizations | AHDs, RWAs,          | tracking of confined     |
|                    | environmental        | space permits. Review    |
| -   Work           | permits).            | MOUs for matrixed        |
|     procedures     |                      | employees.               |
|                    | Division follows its |                          |
| -   Project safety | internal procedures  |                          |
|     reviews        | for preparing and    |                          |
|                    | reviewing AHDs.      |                          |
| -                  |                      |                          |
|   Responsibilities |                      |                          |
|     for matrixed   |                      |                          |
|     employees      |                      |                          |
+--------------------+----------------------+--------------------------+
| E6. Divisions      | V6. Division has an  | IT6. The IT division has |
| ensure that        | effective ergonomic  | been on the leading edge |
| ergonomic hazards  | safety program as    | at the Lab with regards  |
| (computer,         | evidenced by:        | to addressing ergonomic  |
| laboratory, and    |                      | hazards in our division. |
| material handling) | [Minimum             | This performance year,   |
| are adequately     | requir               | IT has done the          |
| controlled and     | ements]{.underline}: | following:               |
| that employees and | Division implements  |                          |
| line management    | Lab policy on        | -   purchased and tested |
| are knowledgeable  | ergonomic safety as  |     30 Dragon Naturally  |
| and engaged in     | stated in PUB-3000   |     Speaking voice       |
| this process,      | Chapter 17:          |     recognition software |
| including the      |                      |     licenses             |
| early reporting of | -   Employees report |                          |
| ergonomic pain or  |     ergonomic pain   | -   piloted the Dragon   |
| discomfort (before |     or discomfort    |     Naturally Speaking   |
| an injury):        |     early and        |     training             |
|                    |     management takes |                          |
| > Ergonomic        |     immediate action | -   piloted with EH&S    |
| > issues/concer    |     to address these |     Remedy Online        |
| ns/discomfort/pain |     reports.         |     Ergonomic System for |
| > are reported     |                      |     assessing high risk  |
| > promptly for     | -   Required staff   |     individuals          |
| > immediate        |     complete EHS052. |                          |
| > corrective       |                      | -   piloted within IT    |
| > action           | -   Required staff   |     the Workers Helping  |
|                    |     complete EHS060. |     Workers program to   |
|                    |                      |     make employees more  |
|                    | -   Supervisors      |     aware of ergonomic   |
|                    |     request an       |     issues               |
|                    |     ergonomic        |                          |
|                    |     evaluation for   | -   communicated both    |
|                    |     employees        |     through the Division |
|                    |     working \> 4     |     Director and         |
|                    |     hours per day at |     supervisors the      |
|                    |     computer.        |     importance of        |
|                    |                      |     ergonomic safety and |
|                    | ```{=html}           |     reporting any pain   |
|                    | <!-- -->             |     or discomfort        |
|                    | ```                  |     immediately          |
|                    | -   Ergonomic        |                          |
|                    |     evaluations are  | -   implemented stricter |
|                    |     conducted in a   |     ergonomic evaluation |
|                    |     timely manner.   |     requirements,        |
|                    |                      |     including the        |
|                    | -   Ergonomic        |     requirement that     |
|                    |     evaluations are  |     ergonomic            |
|                    |     expedited for    |     evaluations be       |
|                    |     any reported     |     performed for each   |
|                    |     pain (EHS will   |     employee at a        |
|                    |     perform all      |     minimum once every   |
|                    |     evaluations with |     two years            |
|                    |     pain reported in |                          |
|                    |     the request).    | -   IT has two           |
|                    |                      |     participants in the  |
|                    | -   Corrective       |     Ergo Advocate        |
|                    |     actions          |     Program              |
|                    |     resulting from   |                          |
|                    |     ergonomic        | -   line management      |
|                    |     evaluations are  |     reviewed all         |
|                    |     completed in a   |     employees            |
|                    |     timely manner.   |     work-spaces on a     |
|                    |                      |     quarterly basis      |
|                    | -   Supervisors      |     reinforcing the      |
|                    |     adhere to the    |     importance to report |
|                    |     requirements for |     discomfort early     |
|                    |     CUE-represented  |                          |
|                    |     employees.       | As of September 11,      |
|                    |                      | 2007, our completion     |
|                    | [Divisional          | rate for ergo            |
|                    | requir               | evaluations was 95%.     |
|                    | ements]{.underline}: |                          |
|                    | Division addresses   | As of September 28,      |
|                    | ergonomic safety as  | 2007, our completion     |
|                    | described in its ISM | rate for EH&S 60         |
|                    | plan.                | (Ergonomics for Computer |
|                    |                      | Users) was 88%.          |
|                    |                      |                          |
|                    |                      | During particularly busy |
|                    |                      | times of year (e.g.      |
|                    |                      | July-September),         |
|                    |                      | ergonomic evaluations    |
|                    |                      | for discomfort, which    |
|                    |                      | were conducted by EH&S   |
|                    |                      | ergonomist, took more    |
|                    |                      | than 48 hours to occur.  |
|                    |                      | Additionally, there were |
|                    |                      | delays in the EH&S       |
|                    |                      | ergonomist entering the  |
|                    |                      | results of an evaluation |
|                    |                      | in the database. This    |
|                    |                      | made the task of         |
|                    |                      | addressing and tracking  |
|                    |                      | potential injuries       |
|                    |                      | problematic and delayed  |
|                    |                      | procurement and          |
|                    |                      | resolution of ergonomic  |
|                    |                      | injuries. An increase in |
|                    |                      | the ergonomic staff      |
|                    |                      | available to review      |
|                    |                      | individuals with         |
|                    |                      | discomfort would be      |
|                    |                      | helpful during peak      |
|                    |                      | times of the year.       |
|                    |                      |                          |
|                    |                      | Often, delays in closing |
|                    |                      | ergonomic evaluations    |
|                    |                      | were directly due to     |
|                    |                      | late receipt of          |
|                    |                      | equipment from vendors . |
|                    |                      | These delays were up to  |
|                    |                      | a couple of months. To   |
|                    |                      | alleviate these delays,  |
|                    |                      | it would be helpful if   |
|                    |                      | the Laboratory looked    |
|                    |                      | into reinstating a       |
|                    |                      | loaner program with a    |
|                    |                      | broader menu of          |
|                    |                      | equipment to expedite    |
|                    |                      | ergo purchases and in    |
|                    |                      | turn, address ergo       |
|                    |                      | issues.                  |
+--------------------+----------------------+--------------------------+
| ISM CORE FUNCTION: |                      |                          |
| Perform Work       |                      |                          |
+--------------------+----------------------+--------------------------+
| E7. Work is        | V7a. Waste           | IT7. Confined space      |
| performed within   | Management           | entries are performed    |
| the ES&H           |                      | per requirements of EH&S |
| conditions and     | -   \% Satellite     | through the confined     |
| requirements       |     Accumulation     | space program. (Appendix |
| specified by Lab   |     Area             | A).                      |
| policies and       |     (SAA)compliance  |                          |
| procedures.        |     (including mixed |                          |
|                    |     waste SAAs,      |                          |
|                    |     radioactive      |                          |
|                    |     waste storage    |                          |
|                    |     areas)           |                          |
|                    |                      |                          |
|                    | -   \% compliance of |                          |
|                    |     sampled waste    |                          |
|                    |                      |                          |
|                    | -   Waste Management |                          |
|                    |     issued Non       |                          |
|                    |     Conformance and  |                          |
|                    |     Corrective       |                          |
|                    |     Action Reports   |                          |
|                    |                      |                          |
|                    | -                    |                          |
|                    |                      |                          |
|                    | V7b. Compliance with |                          |
|                    | regulatory           |                          |
|                    | requirements, formal |                          |
|                    | authorizations,      |                          |
|                    | hazardous work       |                          |
|                    | permits, and         |                          |
|                    | environmental        |                          |
|                    | release limits.      |                          |
|                    |                      |                          |
|                    | -   Work performed   |                          |
|                    |     under formal     |                          |
|                    |     authorizations   |                          |
|                    |     is within scope  |                          |
|                    |     and by           |                          |
|                    |     authorized       |                          |
|                    |     staff.           |                          |
|                    |     Authorizations   |                          |
|                    |     include Activity |                          |
|                    |     Hazard           |                          |
|                    |     Documents,       |                          |
|                    |     Biological Use   |                          |
|                    |     Authorizations,  |                          |
|                    |     Radiological     |                          |
|                    |     Work             |                          |
|                    |     Authorizations,  |                          |
|                    |     Radiological     |                          |
|                    |     Work             |                          |
|                    |     Permits**,**     |                          |
|                    |     X-Ray            |                          |
|                    |     Authorizations,  |                          |
|                    |     etc.             |                          |
|                    |                      |                          |
|                    | -   Work performed   |                          |
|                    |     under hazardous  |                          |
|                    |     work permits is  |                          |
|                    |     within scope and |                          |
|                    |     by authorized    |                          |
|                    |     staff. Work      |                          |
|                    |     permits include  |                          |
|                    |     hot work, ground |                          |
|                    |     penetration,     |                          |
|                    |     confined spaces, |                          |
|                    |     etc.             |                          |
|                    |                      |                          |
|                    | -   Number of        |                          |
|                    |     environmental    |                          |
|                    |     violations from  |                          |
|                    |     external         |                          |
|                    |     regulatory       |                          |
|                    |     agencies         |                          |
|                    |                      |                          |
|                    | -   Number of        |                          |
|                    |     unplanned        |                          |
|                    |     environmental    |                          |
|                    |     releases         |                          |
|                    |     exceeding        |                          |
|                    |     permitted limits |                          |
|                    |     or reportable    |                          |
|                    |     quantities.      |                          |
+--------------------+----------------------+--------------------------+
| E8. Staff is       | V8a. % annual        | IT8. As of September 27, |
| properly trained.  | completion of JHQs   | 2007, JHQ compliance was |
|                    | or equivalent        | 98%.                     |
|                    | system.              |                          |
|                    |                      | As of October 1, 2007,   |
|                    | V8b. Based on JHQs   | training compliance was  |
|                    | or training          | 92%.                     |
|                    | profiles, %          |                          |
|                    | completion rate for  |                          |
|                    | required courses.    |                          |
|                    |                      |                          |
|                    | > Contract           |                          |
|                    | > performance        |                          |
|                    | > measure.           |                          |
+--------------------+----------------------+--------------------------+
| E9. Division       | V9. Does the         | IT9. As stated in our    |
| ensures that       | division have an     | ISM, the IT Division     |
| student safety     | effective safety     | conducts all of its      |
| issues are         | program for          | operations in a manner   |
| effectively        | students? This       | that protects the health |
| addressed.         | includes assuring    | and safety of its        |
|                    | students have        | personnel/staff,         |
|                    | completed their JHQs | including students. All  |
|                    | and required         | staff, including         |
|                    | training, and their  | students, are required   |
|                    | work conditions and  | to take the JHQ as well  |
|                    | work performance are | as receive Ergo          |
|                    | safe.                | evaluations and be       |
|                    |                      | reviewed in quarterly    |
|                    | > Student mentors    | divisional walkarounds.  |
|                    | > complete EHS024    | Their supervisors take   |
|                    | > ES&H for Mentors   | EHS022 "Ergonomics for   |
|                    | > and Supervisors,   | Supervisors". As of      |
|                    | > or EHS026 ES&H for | October 1, 2007,         |
|                    | > Supervisors,       | training compliance was  |
|                    | > Managers, & PIs    | 90% for all IT           |
|                    | > (per requirements  | supervisors.             |
|                    | > of JHQ).           |                          |
|                    | >                    |                          |
|                    | > Division           |                          |
|                    | > implements         |                          |
|                    | > policies and       |                          |
|                    | > procedures as      |                          |
|                    | > described in its   |                          |
|                    | > ISM plan.          |                          |
+--------------------+----------------------+--------------------------+
| > ISM CORE         |                      |                          |
| > FUNCTION 5:      |                      |                          |
| > Feedback and     |                      |                          |
| > Improvement      |                      |                          |
+--------------------+----------------------+--------------------------+
| E10. ES&H          | V10. ES&H            | IT10. ES&H deficiencies  |
| deficiencies that  | deficiencies are     | are entered and tracked  |
| cannot be resolved | tracked in CATS and  | in CATS, As of September |
| upon discovery are | corrected in a       | 27, 2007, the completion |
| entered and        | timely manner:       | rate for IT's corrective |
| tracked in CATS to |                      | actions in the CATS      |
| resolution.        | -   ES&H             | database was 94%. 4% are |
|                    |     deficiencies     | currently on schedule    |
|                    |     identified from  | while only 2% are behind |
|                    |     workspace        | schedule.                |
|                    |     inspections,     |                          |
|                    |     self-assessment  | This measure however is  |
|                    |     activities,      | somewhat misleading as   |
|                    |     SAARs,           | CATS incorporates more   |
|                    |     Occurrence       | than just safety items   |
|                    |     Reports,         | in the data collected.   |
|                    |     Non-compliance   | EH&S should clarify      |
|                    |     Tracking System  | metrics tracked by CATS  |
|                    |     Reports,         | as well give divisions   |
|                    |     environmental    | the tools so that this   |
|                    |     inspections,     | data can be easily and   |
|                    |     Division         | accurately delivered for |
|                    |     Self-Assessment, | reporting purposes.      |
|                    |     EH&S technical   |                          |
|                    |     reviews,         | Finally the timely       |
|                    |     Management of    | return of Tap Root       |
|                    |     ES&H (MESH)      | analysis from EH&S after |
|                    |     Reviews, and     | recordable incidents has |
|                    |     external         | been problematic in      |
|                    |     appraisals are   | PY07. We believe this is |
|                    |     entered in CATS  | due to a personnel       |
|                    |     in a timely      | change in EH&S. We hope  |
|                    |     manner.          | this will be rectified   |
|                    |                      | in PY08.                 |
|                    | -   Opportunities    |                          |
|                    |     for improvement  |                          |
|                    |     identified       |                          |
|                    |     during the       |                          |
|                    |     previous         |                          |
|                    |     self-assessment  |                          |
|                    |     cycle (Division  |                          |
|                    |     Self-Assessment, |                          |
|                    |     EH&S technical   |                          |
|                    |     reviews, and     |                          |
|                    |     MESH) are        |                          |
|                    |     implemented in a |                          |
|                    |     timely manner.   |                          |
|                    |                      |                          |
|                    | > \% completion rate |                          |
|                    | > of CATS corrective |                          |
|                    | > actions (High,     |                          |
|                    | > Medium and Low     |                          |
|                    | > risk categories)   |                          |
|                    | > implemented as     |                          |
|                    | > scheduled.         |                          |
+--------------------+----------------------+--------------------------+
| E11. Division      | > V11. [Minimum      | IT11. As detailed in our |
| employees report   | > requir             | ISM Plan, IT conducted a |
| injuries and the   | ements]{.underline}: | formal incident analysis |
| division performs  | > Division           | on all recordable        |
| a thorough review  | > implements Lab     | injuries. Any actionable |
| of all staff       | > policy on accident | items were entered into  |
| injuries and       | > investigations and | CATS. Incidents are      |
| accidents,         | > reporting.         | reviewed at a high level |
| including analysis |                      | in the bi-monthly IT     |
| of conditions that | [Divisional          | Safety Committee         |
| led to injury.     | requir               | meeting.                 |
| Corrective actions | ements]{.underline}: |                          |
| to prevent         | Division implements  |                          |
| recurrence are     | accident             |                          |
| identified and     | investigation and    |                          |
| effectively        | reporting policies   |                          |
| implemented.       | and processes as     |                          |
|                    | documented in its    |                          |
|                    | ISM plan.            |                          |
+--------------------+----------------------+--------------------------+

**Appendix A**

**Confined Space process for IT entry into communication manholes**

Areas with confined space hazards or other unusual work activities are
covered by Lab policy.

Confined Space Process:

A.  Get proper LBNL confined space training

    1.  Basic Confined Space Entry Class

    2.  Confined Space Permit Writer\'s Class

    3.  First-Aid

    4.  CPR

B.  Gather all safety gear for confined space work

    1.  Full-body harness

    2.  Life-line

    3.  Rescue tripod, with winch

    4.  Gas meter

    5.  electric, ventilation fan, with hoses

    6.  bilge pump

    7.  Cones, rope, caution tape, or barricades to alert others of open
        man-hole, and prevent accidental falls/trips into man-hole

    8.  Tools for entry: crow-bars, man-hole cover cam-lifter

    9.  PPE: safety shoes, gloves, long pants, and is some cases;
        hard-hat, and protective eyewear

    10. Confined-space permits, pen

C.  Once you are ready to open a manhole the steps are as follows:

    1.  Put on Safety shoes, and gloves

    2.  Barricade off the man-hole area

    3.  Ensure that there are, at least, two qualified people at site

    4.  remove the man-hole cover with approved method

    5.  Turn on, and self-test gas meter

    6.  Lower gas meter into hole, testing at three levels: bottom,
        middle space, and near the entrance

    7.  Fill out permit, filling in all information, and checking
        applicable boxes

    8.  Write down \"start time\" and sign permit

    9.  Permit MUST be signed by trained Permit writer only

    10. Pump out water, and ventilate space with fan, if needed

    11. Either test air with gas meter continuously, or at fifteen
        minute increments

    12. Post permit, clearly at site, so it is in clear view for
        passers-by

D.  To enter confined Space:

    1.  Discuss safety plan, and emergency procedures

    2.  Person entering must have full-body harness properly put on, and
        checked by the space attendant (aka: safety or fire watch)

    3.  Attach life-line to pulling ring of the full-body harness

    4.  Attach other end of life-line to the rescue tripod

    5.  Confined space worker can now enter space

    6.  Attendant has to watch, and stay at space the entire time worker
        is in the hole

    7.  If attendant has to leave for any reason, then the worker must
        come out of space before the attendant leaves

    8.  Complete work, and leave confined space

E.  Close man-hole cover, and write down \"end time\" on permit

F.  Gather all permits for that week up, and deliver them to the Lab\'s
    EH&S Confined Space Manager\'s office at end of the week.

**Appendix B**

**Hits related to IT ISM web posting**

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<td><strong>Month</strong></td>
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<td>0</td>
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<td>9</td>
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<td>Jul</td>
<td>57</td>
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<td>17-Jun</td>
<td>12</td>
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<td>74</td>
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<td>16</td>
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<td>Sep</td>
<td>44</td>
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<td>1-Jul</td>
<td>9</td>
<td></td>
<td><strong>Total:</strong></td>
<td><strong>212</strong></td>
<td colspan="2">as of 25 Sep</td>
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<td>14</td>
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<td>22-Jul</td>
<td>11</td>
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<td>29-Jul</td>
<td>10</td>
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<td>5-Aug</td>
<td>8</td>
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<td>12-Aug</td>
<td>13</td>
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<td>19-Aug</td>
<td>41</td>
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<td>26-Aug</td>
<td>12</td>
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<td>2-Sep</td>
<td>13</td>
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<td>9-Sep</td>
<td>8</td>
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<td>16-Sep</td>
<td>23</td>
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