# Presentation: 885468

## BROOKHAVEN NATIONAL LABORATORY

**Institutional-Level **
**OSH Management Review**
**OHSAS 18001 **
**Safety and Health Management System**
- December 19, 2006

**HANDOUTS **
**Final Rev 0 **
**12/19/06**

## Top management shall evaluate OSH Program for: 
Suitability- Does it “fit” BNL operations & systems?
Adequacy- 
Does it meet requirements?
Is it implemented appropriately?
Effectiveness- Is it achieving the OSH Policy and Objectives?

Identify possible need for changes to the Policy, Objectives, and/or other program elements, based on a review of key system components including:
Audits and assessments
Changing Circumstances 
Commitment to Continual Improvement

Output: Minutes of this meeting, record of management’s decisions

_***Suitability***_***-***** **Does it “fit” BNL operations & systems?
_***Adequacy***_***-***** **
- Does it meet requirements?
- Is it implemented appropriately?
_***Effectiveness***_**-**** **Is it achieving the OSH Policy and Objectives?
- Identify possible need for _***changes***_*** to the Policy, Objectives, and/or other program elements***, based on a review of key system components including:
- Audits and assessments
- Changing Circumstances
- Commitment to Continual Improvement
- Output: Minutes of this meeting, record of management’s decisions

**Purpose of Meeting**

**Notes:**
At the end of the meeting we will be seeking input on improvement areas and your assessment of the programs adequacy suitability & effectiveness.

Please feel free to stop any of the speakers during the presentations to ask questions or add comments.  We try to prepared the data for your evaluation , but may have overzealous...  Interactions will liven up this meeting and certainly welcome.

We will be taking minutes of the discussions during the presentation.

## Inputs into the Management Review

| Inputs | Outputs |
| --- | --- |
| Accident Statistics
Internal & External OSH MS audits
Corrective Actions on the system
Reports on 
 Emergencies
 OSH Rep on the overall performance of the system 
 Line managers on their local OSH programs
 Haz Identification, Risk Assessment & Risk Control Processes | Minutes of this meeting, record of management’s decisions
Revision of OSH Policy and OH&S Objectives
Specific Corrective Actions for managers with target dates
Date for review of corrective actions
Areas of emphasis in planning future OHS MS audits |

## Clearing up the Program Inter-Relationships 

| Programs | Critical Success Factors |  |  |  |
| --- | --- | --- | --- | --- |
|  | Work Planning & Control | Employee Involvement | Management Engagement | Safe Work Place |
| Integrated Safety Management* 
(ISM) | Define Work Scope, Identify Hazards, Develop Controls | Perform Work Within Controls,  Feedback and Improvement | Define Work Scope, Feedback and Improvement | 
  |
| 10CFR851* | Hazard Identification, Assessment,
Prevention and Abatement | Worker Rights and Responsibilities | Management Responsibilities | 
  |
| OHSAS 18001** | Job/Facility Risk
Analysis | Job/Facility Risk Analysis | Management Review |   |
| ISO 14001** | Process Review |  | Management Review |   |
| Safety Observation** |  |  | Workplace Observation, TIER 1  | 
  |
| Human Performance** | Plan for Human Error as a Hazard |  |  |   |

***DOE Mandated            **Voluntary improvement initiatives**

**Clearing up the Program Inter-Relationships **

## Integrated Safety Management (ISM) interaction with OHSAS 18001

| ISMS Guiding Principles | ISM Core Functions | OHSAS Clauses |
| --- | --- | --- |
| Line managers clearly responsible for ES&H | All Five Core Functions | 4.2    OSH Policy
4.4.1 Structure and responsibility |
| Clear ES&H roles & responsibilities
Competence commensurate with responsibilities |  | 4.3.4 OSH management program
4.4.1 Structure and responsibility
4.4.2 Training awareness and competence |
| Balanced priorities

Identify ES&H standards & requirements | 1.	Define scope of work | 4.3.1 Planning for hazard ID, risk assessment & risk control |
|  | 2.	Identify and analyze hazards | 4.3.1 Planning for hazard ID, risk assessment & risk control
4.3.2 Legal and other requirements |
|  | 3.	Develop and implement hazard controls | 4.3.1 Planning for hazard ID, risk assessment & risk control
4.4.6 Operational control
4.4.7 Emergency preparedness and response |
| Hazard controls tailored to the work | 4.	Perform work within controls | 4.4.3 Consultation and Communication
4.4.6 Operational control |
| Operations authorization | --- | 4.4.4 Documentation
4.4.5 Document and Data control 
4.5.3 Records and records management |
|  | 5.	Feedback & Continuous improvement | 4.3.3 Objectives
4.4.3 Consultation and Communication
4.5.1 Performance measurement and monitoring
4.5.2 Nonconformity, corrective & preventive actions
4.5.4 Audit
4.6    Management review |

**Integrated Safety Management (ISM)**** ****interaction with**** OHSAS 18001**

## Discuss: 1. Suitability of the current OH&S policy

| OH&S Policy    (OHSAS 18001 Element 4.2) | ISM Principle and Function  |
| --- | --- |
|  | Line management Responsible for ES&H
Define the scope of work |

- Feedback from line organizations’ Management Reviews in 2005 indicated a _change was needed_
- Team revised the Policy
- Line Organizations reviewed the changes
- BNL adopted the Policy
- Distributed to line organizations

**Issues:**
**1a. Communication of the new Policy may be less than adequate across the site**
**Phase 3 workers did very well in their knowledge on their registration audit.  **
**1b. Replacement of postings of the old Policy with the new revision has not been verified**

**Discuss:**** ****1. Suitability of the current OH&S policy**

**Notes:**
OHSAS 18001 is organized into 6 major sections.  This presentation will be organized to address the five sections which have requirements.  The first OHSAS 18001 Section with requirements is Section 4.2  OH&S Policy.

BNL revised the site level ESSH Policy within 2006.  

These are current issues that may exists in line organizations:
Tier 1 Inspection is being used to find “out-of-date” versions and to replace them.
Workers in Phase 3 organizations need to be able to show NSF Auditors how to find the Policy- physically posted or on the web.

## OHSAS 18001 Element 4.2 requires that the Policy:

| OH&S Policy  (OHSAS 18001 Element 4.2) | ISM Principle and Function |
| --- | --- |
|  | Line management Responsible for ES&H
Define the scope of work |

- Be appropriate to the nature and scale of the organization’s **OSH risks**;
- Include a commitment to **continual improvement**;
- Include a commitment to at least comply with current applicable OSH **legislation and with other requirements** to which the organization subscribes;
- Be **documented, implemented, and maintained**;
- Be **communicated** to all employees with the intent that employees are made aware of their individual OSH obligations;
- Be **available** to interested parties; and
- Be **reviewed periodically** to ensure that it remains relevant and appropriate to the organization.

**1a. Does the new revised POLICY meet or improve on these OHSAS 18001 requirements ?**

**Notes:**
OHSAS 4.2 requires that the Policy shall:
Be appropriate to the nature and scale of the organization’s OH&S risks;
Include a commitment to continual improvement
Include a commitment to at least comply with current applicable OH&S legislation and with other requirements to which the organization subscribes;
Be documented, implemented, and maintained;
Be communicated to all employees with the intent that employees are made aware of their individual OH&S obligations;
Be available to interested parties; and
Be reviewed periodically to ensure that it remains relevant and appropriate to the organization. 

Does the new revision meet or improve on meeting these OHSAS 18001 requirements ?

## 2. Discuss: The adequacy of current hazard identification, risk assessment, and risk control processes 

| Directorate | JRAs | FRAs |
| --- | --- | --- |
| BES | 43 | 11 |
| EENS | 26 | 15 |
| ESH&Q | 101 | 25 |
| ERP | 8 | 10 |
| F&O | 223 | 66 |
| HENP | 74 | 52 |
| NSLS | 38 | 9 |
| Life Sciences | 35 | 10 |
| Support Organizations | 98 | 40 |
| Site | 6 | 1 |
|  | 652 | 239 |

**Risk Assessment prepared for OHSAS and ISM**

## 
Phase 1-  
NSF Registration Audit: no issues
Phase 2-  
NSF Registration Audit: no issues

Phase 3- 
NSF Registration Audit : 
1 OFI for content:  omission of covering two activities (2 organizations)

1 minor non-conformance for process: incorrect use of the “After Additional Control” column or hazards without the risk calculation (1 organization)

**Phase 1-**
- NSF Registration Audit: no issues
**Phase 2-**
- NSF Registration Audit: no issues
**Phase 3-**
- NSF Registration Audit :
- 1 OFI for content:  omission of covering two activities (2 organizations)
- 1 minor non-conformance for process: incorrect use of the “After Additional Control” column or hazards without the risk calculation (1 organization)

**2. Discuss: The adequacy of current hazard identification, risk assessment, and risk control processes **

## Site Wide Hazards
Natural hazards (deer, ticks etc)
Natural Phenomena Hazards (wind, snow, flood)
Traffic/ Vehicle/ Bicycles/ Pedestrian

- Natural hazards (deer, ticks etc)
- Natural Phenomena Hazards (wind, snow, flood)
- Traffic/ Vehicle/ Bicycles/ Pedestrian

_**Facility Specific Hazards**_
- Biological materials
- Chemicals
- Construction activities
- Cryogenics
- Electrical
- Elevated work
- Ergonomics
- Lasers
- Material Handling
- Nanomaterials
- Noise
- Pressure
- Radiological materials
- Walking/working surfaces

**Site Level JRAs are maintained for: **
**Bicycling, **
**Driving, **
**Electrical Safety, **
**Manual Material Handling, **
**Office Work, **
**Walking**

**ISSUE **(from line organization Management Reviews)** **
**2a. Some organizations want the site level JRAs to be maintained only at the site level (i.e. consolidate line organization versions)**
**2b.  Create a sitewide “Natural Hazards” FRA**

**2. Discuss: The adequacy of current hazard identification, risk assessment, and risk control processes**** **

**Notes:**
All these hazards are address in risk assessments conducted at the site level or line organization level.

All planned JRAs and FRAs have been completed for the site in Phase 1, 2, and 3 organizations.  
Phase 1 & 2 organizations are in a cyclic review process for Risk Assessments.

## Issues

**2c. Fire System: Inspection Test and Maintenance**
**Life safety (egress) features of older facilities – legacy**

**2. Discuss: The adequacy of current hazard identification, risk assessment, and risk control processes **

## Improvements in risk reduction resulting from JRA/FRAs
Examples: 
Life Sciences had 22 improvements                         •  ERP had 4 improvements
SHSD had 10 improvements                                      •  EENS had 6 improvements
CAD had 4 in 2006, 14 in 2006, 13 in 2005                •  F&O had 7 improvements
Quality Management Office had 3 improvements

Some Highlights:
Life Sciences 
Add anti-restart devices on older shop equipment
Conduct ODH calculations 
Install animal bedding disposal system
SHSD 
Add lighting to work area
Analyzed fall protection for HEPA filter testing on Roofs

- Examples:
**Life Sciences had 22 improvements                         •  ERP had 4 improvements**
**SHSD had 10 improvements                                      •  EENS had 6 improvements**
**CAD had 4 in 2006, 14 in 2006, 13 in 2005                •  F&O had 7 improvements**
**Quality Management Office had 3 improvements**
- Some Highlights:
- Life Sciences
- Add anti-restart devices on older shop equipment
- Conduct ODH calculations
- Install animal bedding disposal system
- SHSD
- Add lighting to work area
- Analyzed fall protection for HEPA filter testing on Roofs

**2. Discuss: The adequacy of current hazard identification, risk assessment, and risk control processes**** **

## 2. Discuss: The adequacy of current hazard identification, risk assessment, and risk control processes 

**ISM Flowdown to Contractors and Suppliers**
**JRA/FRA process**
**Pre-job briefings**
**Job Change Control**
**Work Planning and Control subject area**
**Teams are currently working on ****IMPROVING ****the existing BNL processes**

**2. Discuss: The adequacy of current hazard identification, risk assessment, and risk control processes**** **

## 3. Discuss: Recorded instances of procedures not being effective

- NSF OHSAS Registration Audit Phase 3:  SHSD Industrial Hygiene procedure was not tracking Noise & Hearing Conservation legal requirements
- OHSAS Internal audit- ESH&Q:  Safety Engineering- legal requirement management process not being  conducted or documented

- Issues:
- 3a. Record of Decisions are not uniformly documented for all OSH disciplines.
**3b. Safety Engineering** and **Industrial Hygiene** *requirements management* procedures in-place but lack resources for timely review of regulations (160 + ) for impact on OSH program

**3. Discuss: Recorded instances of procedures not being effective**

**Notes:**
EMS has an established and funded process for Requirement Management.
OSH topics requirement management is not as well developed. 
SHSD’s Industrial Hygiene has a procedure in place (IH50700) that has been  in place since 07/2004 that works.  The process was being conducted in 2004 and 2005 (3 quarters) , but has been done in 2006 with the re-deployment of the IH SME to line organizations as Safety & Health Representatives.  
SHSD’s Safety Engineering Group has a newly adopted (10/2006) procedure (SE50700) that mimics the IH Group.  It has not conducted yet.
Fire Protection has a system in place via list serves but it is not documented.
Etiologic Agents is not documented.
Radiological Controls has a system in place via list serves but it is not documented.

## 
Arc Flash- Worker did not follow established procedure and PPE

**Arc Flash- Worker did not follow established procedure and PPE**

**3. Discuss: Recorded instances of procedures not being effective**

## Issues that require continued focus/emphasis:

Industrial Hygiene Personnel Exposure Monitoring
Safety Engineering and Industrial Hygiene Program Administrators
ESH support in small organizations, CFN, NSLS II
Nationally Recognized Testing Lab – Authority Having Jurisdiction
Fire Protection 
Emergency Management 
Emergency Response

- Industrial Hygiene Personnel Exposure Monitoring
- Safety Engineering and Industrial Hygiene Program Administrators
- ESH support in small organizations, CFN, NSLS II
- Nationally Recognized Testing Lab – Authority Having Jurisdiction
- Fire Protection
- Emergency Management
- Emergency Response

**4. Discuss: Adequacy of resources (financial, personnel, material)**

- Issue:
- 4a. Support for Safety Engineering and Industrial Hygiene areas is under weighted compared to other ESH&Q programs:
-  75 Programs covered by 11.5 SME  (**6/1** ratio)

## Financial Investments 
Investment Program Area

- _Investment Program Area_

-  Core Programs
- SHSD

-  Special Projects (ADS)
- OSHA findings
- Fire Protection

**4. Discuss: Adequacy of resources (financial, personnel, material)**

**Notes:**
% line funding re: % FTE on OSH

## Financial Investments: Safety Solution (S2) 
FY05 = $25,000
24 proposals submitted
13 Funded
Good participation by Science Depts.> 60%
Program was compressed into 2 month cycle

FY06 = $14,000
49 proposals submitted
9 Funded
Awareness and participation is increasing
Full year for submission, vetting, & funding

**FY05 = $25,000**
**24 proposals** submitted
- 13 Funded
- Good participation by Science Depts.> 60%
- Program was compressed into 2 month cycle
**FY06 = $14,000**
**49 proposals** submitted
- 9 Funded
- Awareness and participation is increasing
- Full year for submission, vetting, & funding

**4. Discuss: Adequacy of resources (financial, personnel, material)**

**Notes:**
BNL Performance Track

## 4. Discuss: Adequacy of resources (financial, personnel, material)

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
|  | Title | Submitter | Org | Cost($) |
| 06 30 | Vehicle Obstacle Sensors | Henry Hauptman | SS |  $  2,500.00  |
| 06 35 | Purchase of Side Access Dumpsters | Richard A. Jones | EP |  $  2,000.00  |
| 06 13 | Close Driveway on 179 | Christine Carter | SS |  $  1,000.00  |
| 06 03 | Anti-Restart Devices  | Robert L. Colichio | LS |  $     878.00  |
| 06 21 | Various Safety Eye Glass Types/Styles | Robert L. Colichio | LS |  $     400.00  |
| 06 24 | Fall Protection (Overhead Crane) | Robert Sabatini | CMPMSD |  $     600.00  |
| 06 25 | Replace Broken Curb with Ramp | Bob Kiss | NSLS |  $  2,000.00  |
| 06 26 | Falls to Lower Levels | Steven A. Woodburn | ISM |  $     700.00  |
| 06 46 | Pilot Project to Replace 5 gallon Water Bottles | Robert Selvey | SHSD |  $     650.00  |

** ****FY06 Funded S2 Proposals**

**4. Discuss: Adequacy of resources (financial, personnel, material)**

## Onsite OSHA inspection (11/2003)
Identified 4647 findings that were required to be addressed by 2/2006.  
99% (4609) have been closed out with an expenditure of over $4 Million.
The lab has addressed all findings (deadline 2/2006), and will fully abate findings by 2/2009 or sooner.

- Identified 4647 findings that were required to be addressed by 2/2006.
- 99% (4609) have been closed out with an expenditure of over $4 Million.
- The lab has _addressed_ all findings (deadline 2/2006), and will fully _abate_ findings by 2/2009 or sooner.

**4. Discuss: Adequacy of resources (financial, personnel, material)**

**Notes:**
The onsite OSHA inspection in 2003 identified 4649 findings that are required to be addressed by February 2006.  To-date over 82% (3816) have been closed out with an expenditure of over $2.8 Million.  This represents Laboratory and DOE contributed dollars.  The lab is closing findings based on a risk prioritized approach and has a plan to address all findings by the deadline and have all closed by February 2009 or sooner.
About $1 million in 2004
About $1.4 million in 2005

## Onsite OSHA inspection (11/2003)  Open Finding currently being addressed:
Cranes CA 2787 (1 Citation Priority 4) – Guardrails being fabricated.
Electrical CA 3617 (1 Citation Priority 4) – 912 Complex (Guarding Cable Trays) Cables and Trays being removed, before guards installed.
Electrical CA 126 (3 Citations Priority 3) – Disconnects being relocated for fume hoods. 1 of 4 complete.
Electrical CA 1791 (30 Citations Priority 5) – Job should be complete by end of December.
Electrical CA 3879 (3 Citations Priority 4) – 31 of 34 Complete. Guards being fabricated for remaining 3.  2 should be complete before RHIC goes online. 1 will be completed next shutdown.
$1.6 million estimated for Site Wide Panel labeling conducted over the next four years. $400 K designated for this FY.

- Cranes CA 2787 (1 Citation Priority 4) – Guardrails being fabricated.
- Electrical CA 3617 (1 Citation Priority 4) – 912 Complex (Guarding Cable Trays) Cables and Trays being removed, before guards installed.
- Electrical CA 126 (3 Citations Priority 3) – Disconnects being relocated for fume hoods. 1 of 4 complete.
- Electrical CA 1791 (30 Citations Priority 5) – Job should be complete by end of December.
- Electrical CA 3879 (3 Citations Priority 4) – 31 of 34 Complete. Guards being fabricated for remaining 3.  2 should be complete before RHIC goes online. 1 will be completed next shutdown.
- $1.6 million estimated for Site Wide Panel labeling conducted over the next four years. $400 K designated for this FY.

**4. Discuss: Adequacy of resources (financial, personnel, material)**

## Nationally Recognized Test Laboratory Approval (NRTL) of Electrical Equipment 
Applies to  equipment built, acquired, or brought onto the BNL site and connected to a source of electrical power.
Electrical equipment is inspected to ensure it is free from reasonably foreseeable risks due to electrical hazards.  
Electrical Equipment Inspections (EEI) determines that equipment has/is: 
Enclosed energized parts, 
Bonded and grounded, 
Afforded adequate over-current protection. 
Can not cause a shock, burn or fire if used properly.

- Applies to  equipment built, acquired, or brought onto the BNL site and connected to a source of electrical power.
- Electrical equipment is inspected to ensure it is free from reasonably foreseeable risks due to electrical hazards.
- Electrical Equipment Inspections (EEI) determines that equipment has/is:
- Enclosed energized parts,
- Bonded and grounded,
- Afforded adequate over-current protection.
- Can not cause a shock, burn or fire if used properly.

**Issue:  4c.   40,000+ pieces of equipment need Authority Having Jurisdiction (AHJ) approval**

**4. Discuss: Adequacy of resources (financial, personnel, material)**

| Inventory | Total | BNL Built | Commercial Equipment Mod. By BNL | Custom Built to BNL Specs | Commercial Off-the-Shelf | NRTL |
| --- | --- | --- | --- | --- | --- | --- |
| BOP | 14370 | 263 | 272 | 32 | 5452 | 8351 |
| CAD | ~20,000 | - | - | - | - | - |
| NSLS | ~20,000 | - | - | - | - | - |
| Plant Engineering | ? | ? | ? | ? | ? | - |
| Inspection Completed | 1497 | 21 | 70 |  | 406 | 8351 |
| Inspection Needed | 53,000+ |  |  |  |  |  |

**NRTL Inspections**** **Pieces of Electrical Equipment

**4. Discuss: Adequacy of resources (financial, personnel, material)**

## 5. Discuss: The effectiveness of the hazard reporting process

- BNL mechanisms for hazard reporting:
- Tier I Process
- Events/Issues Management
**New process developed, implemented and assessed in 2006**
- Safety reporting hotline
- S2 program
- OMC Clinic
- DOE Hotline
- RAR

## ESH Concerns or Suggestions

- Hazards reported through the ***Safety Hotline*** and the ***ESH Concern web form***
- 19 Concerns and Suggestions submitted to-date
- 1 concern is still open pending review by Traffic Safety Committee
- Examples of concerns that resulted in action:
- Sidewalk with exposed rebar was a trip hazard
- Decaying wooden steps on trailer were a fall hazard
- Contractor operating heavy machinery while on a cell phone

**5. Discuss: The effectiveness of the hazard reporting process**

## Event/Issues Management – 
Implemented November 1st
Applies to both “events” and “issues”
It provides a centralized consistent approach using trained categorizers and facilitators
Was created with broad Lab input (consensus)
 It clearly defines “lower level” events 
Which are below ORPS threshold
New process includes the essential elements of holistic and sustainable CA Management
Requirements & guidance for causal analysis & extent of condition/cause reviews 
Stratification of actions (corrective, preventive and improvement)
Verification of action closure
Effectiveness reviews

- Implemented November 1st
- Applies to both “events” and “issues”
- It provides a centralized consistent approach using trained categorizers and facilitators
- Was created with broad Lab input (consensus)
-  It clearly defines “lower level” events
- Which are below ORPS threshold
- New process includes the essential elements of holistic and sustainable CA Management
- Requirements & guidance for causal analysis & extent of condition/cause reviews
- Stratification of actions (corrective, preventive and improvement)
- Verification of action closure
- Effectiveness reviews

**5. Discuss: The effectiveness of the hazard reporting process**

## Insert the flowchart here?

## Response to the Event 

**ORPS Reportable**
**DOE**
**Significance Category BNL (SCBNL)**
**BNL**
**Line manager’s discretion  **** **

**Event/Issues Reportability Criteria **
**Operational Emergencies**
**Personnel Safety ****(SCBNL added)**
**Nuclear Safety Basis**
**Facility Status ****(SCBNL added)**
**Environmental**
**Cont/Rad Control ****(SCBNL added)**
**Nuclear Explosive Safety**
**Transportation**
**Noncompliance Notifications**
**Management Concerns/Issues**

## Event Management: Support of the Subject Area

**Causal Analysis Training:**
** ****Aug 2006: Five Whys; Barrier Analysis**
** ****Dec 2006: Event & Causal Factor Charting (w/HPI)**
** ****Jan 2007: Facilitator Training **
** ****March 2007: Corrective Action Development **
**Event/Issues Management Effectiveness**** **
**Data reviewed  as of Dec 11, 2006: ****14 Entries; 3 ORPS; 0 SCBNL**
**DOE/Third Party Review April/May 07**
**Effectiveness is included in process**

## ORPS Reportable and Nonreportable Cat Entries

**The**** ****process will capture lessons from 21% of Non-reportables Annually **

**22 Items in 2006**

## Laboratory Tier 1 Inspections

**6. Discuss: The effectiveness of the OH&S inspection process (i.e. Tier 1, Safety Observations, etc.)**

**Laboratory Tier 1 Inspections**

**Notes:**
Categories:
Housekeeping – 325 findings
Working environment department – 294 findings
Electrical Safety – distribution – 589 findings (between both electrical categories)
Electrical Safety – equipment
Working environment plant
Chemical Safety – storage
Chemical safety - labeling

## Issues

6a. BNL needs more OSH SME field deployed (Feedback from ESH Coordinators)

6b. ESH Coordinators need additional OSH training (Feedback from ESH Coordinators)

6c. Fire Hazard Assessments: 56 facilities; 3 complete; 15 in-progress; Funding commitment; Tracking findings

6d. Long periods of Open items submitted to the Traffic safety committee 

- 6a. BNL needs more OSH SME field deployed (Feedback from ESH Coordinators)
- 6b. ESH Coordinators need additional OSH training (Feedback from ESH Coordinators)
- 6c. Fire Hazard Assessments: 56 facilities; 3 complete; 15 in-progress; Funding commitment; Tracking findings
- 6d. Long periods of Open items submitted to the Traffic safety committee

**6. Discuss: The effectiveness of the OH&S inspection process (i.e. Tier 1, Safety Observations, etc.)**

## 7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations 

**Radiological Awareness Reports**
**ORPS**
**Accident/ Injury/ Incident Data**

**Issue: **
**7a. Industrial Hygiene employee exposure surveys not completed for all operations.  Sampling in FY06 indicates BNL may still have some un-discovered exposure operations.   The probable areas are not in laboratories, but in maintenance, construction, and non-lab research operations.**

## Radiological Awareness Reports (Feedback and Continual Improvement)

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## Radiological Awareness Reports

- RARs are used to capture and trend low-level issues for quality improvement
- Analysis shows many FY06 RARs are low-level contamination issues
- leaking tanks
- inadequate procedures
- passing material across boundaries without an adequate survey
- Work planning focused on dose rate, not potential for spread of contamination

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## Radiological Awareness Reports (Cont.)

- Opportunities for Improvement from Issues Captured in RARs Include:
- Establish more robust surveillance programs in uninhabited buildings (e.g., Bldg. 650)
- Clarify expectations for line-of-sight job coverage when both radiological and industrial hygiene hazards are present
- Formally deploy WMD nuclear-grade work planning processes when requested to work in non-WMD facilities (e.g., packaging wastes)

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## BNL Radiological ORPS

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## Radiological Contamination Events (Reportable and Non-Reportable)

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## BNL Radiological Dose

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## BNL Radiological Events

- Radiological Dose
- No overexposures of workers
- No unplanned external/internal exposures
- No persons > 500 mrem in CY06
- No ACL extensions
- C-AD and ERP YTD exposures very low as compared to several years ago

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## BNL Non-Radiological Events

- 3 overexposures of workers: Exceeded OSHA or ACGIH on a daily basis: Noise; silica
- 2 ORPS:  2 Noise; 1 Silica
- Hearing Standard Threshold Shifts: 2 in FY06; 1 in FY05
- 13 Worker Comp cases initiated in FY06:
- $132,000 medical cost plus 337 lost days, 374 restricted days
- BNL Group B Exposures: mercury, lead, silica, noise

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## 7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations 

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## 7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations 

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## 7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations 

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## 7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations 

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## 7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations 

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## Issue:  

7b.  	FY07 DART and TRCR goals are very challenging.  

DART Goal equals 6 cases, 
TRCR goals equals 16 cases in a year. 

		YTD performance is: 
		DART  = 1 case
		TRCR =  5 cases

- 7b.  	FY07 DART and TRCR goals are very challenging.
- DART Goal equals 6 cases,
- TRCR goals equals 16 cases in a year.
- 		YTD performance is:
- 		DART  = 1 case
- 		TRCR =  5 cases

| Goal / Performance | FY05 | FY06 | FY07 GOAL |
| --- | --- | --- | --- |
| DART | 0.45 / 0.74 | 0.37 / 0.49 | 0.25 |
| TRCR | 1.05 / 1.52 | 0.87 / 1.39 | 0.65 |

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## Site-wide Traffic Violations

*******Parking = parking violations **_**and**_** expired parking stickers**

|  | Speeding | Moving | Parking* |
| --- | --- | --- | --- |
| 2005 | 149 | 200 | 134 |
| 2006 | 108 | 125 | 69 |

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## 7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations 

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## 7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations 

**7. Discuss: Data relating to accidents and incidents that have occurred and the output of  investigations **

## Internal OSH Assessment

- OHSAS 18001 Internal Audits were conducted for Phase 1, 2 and 3 organizations at the organization level.
- Issues were reported in organization’s Management Reviews,
- No Lab-wide issues are currently open from Internal Audits.
- Improvement:  Phase 1 and 2 reports were combined this year into a site report.  Next year all Phases will be combined into one Audit report.

**8. Discuss: Results of internal and external OH&S management system audits **

**Notes:**
Improvements
2727.1.1 (Need from Ray)
Listed Locations of Posted Policy (Improved updating process) (ESH&Q)
E- Permits now Formally Distributed to Key Line Personnel (EWMS)
ESR updating process improved (CFN)
Significant Aspect Matrix Corrected (CO)
Targeted Assessment of Rad Waste Storage Practices (EENS) Communicated Improvements to EWMS SME
Small Science RCRA Task Force (LS, EENS, BES, PO) – Led to RCRA Subject Area Improvements
Improved Document Control in Waste Storage Area (LS)
Facility Review of Required Posting/Improved Communication of Posting Requirement (C-AD / F&O)
Corrected  Document (C-AD)
Corrected Procedure led to “Like” Procedure review (F&O)

## Nov 2006: Phase 3 ORR 

**June 2006: Combined ISO 14001-OHSAS 18001 Surveillance Audit**
- Included Phase 1 & 2 OHSAS 18001 organizations
**0 Major nonconformances**
**0 Minor nonconformances**
**1 Opportunity for Improvement   DOCUMENT CONTROL**
**Nov 2006: Phase 3 ORR**
**0 Major nonconformances**
**0 Minor nonconformances**
**3 Opportunities for Improvement**
**Dec 2006: Phase 3 Registration Audit**
**0 Major nonconformances**
**3 Minor nonconformances**
**3 Opportunities for Improvement**

**8. Discuss: Results of internal and external OH&S management system audits **

**Notes:**
Improvements
Improved the Requirements Management Subject Area to include  other than regulatory requirements  (Performance Track)
Improved Use of Tool Box Meetings to Communicate OSH Policy to Staff (F&O)
Dept Chair increased communication on the need for proper waste labeling (CO) ?? Not Closed
Improved use of Controlled Document (Waste Management 90-Day Area Checklist) (EENS)
Improved Hazardous Waste Subject Area and Training ??(Not Closed)
Communicated proper use of the NSF-ISR ISO14001 Mark (EWMS)
Changed “Scope” language in  Program Description (EWMS)
Improved use of Toolbox meetings for OSHAS JRA & FRA Communication (F&O)
Improved use of  Planning Form (IO)

## FY06 Radiological Assessment Results

- Topical assessments revealed the following issues:
- Need to simplify Radiation Generating Device (RGD) Program
- Need to disconnect ALARA Cost Benefit Procedure from routine radiological work
- Need to develop an improved system of verification that all BNL Radcon Manual policy/program requirements have been implemented
- Need to develop additional thresholds that drive Management involvement
- Need to simplify funding models for RCD services

**8. Discuss: Results of internal and external OH&S management system audits **

## OSH Program Assessments

- Independent Audit and Oversight (IA&O)
- Material handling
- Injury Management Assessment
- Construction Safety Program Review
- Traffic Safety Assessment:
- IH Multiple-Topic Assessment
- Chemical Hygiene
- Fall Protection Assessment
- 10CFR851 Gap Analyses
- Lockout/Tagout assessment
- Nuclear Safety Basis USQ Process Assessment
- Compressed Gas Safety Assessment

**8. Discuss: Results of internal and external OH&S management system audits **

## Emergency Management Assessments

- 2004 DOE-HQ Emergency Management Assessment
- Continuing Progress on findings
- 29/30 were completed
- Re-opened 5 findings and rewrote 1 finding for a revised Action Plan based on 151.1C
- Preparing for assessment in August 2007

**8. Discuss: Results of internal and external OH&S management system audits **

## Emergency Management Assessments

- Emergency Medical Support Assessment
- 1 Finding – Emergency Plan out of date – IN PROGRESS
- Shelter-in-Place (SIP) Assessment
- 1 Finding - Tone Alert Radios (TAR) issue – CLOSED
- Off-site Response Interfaces Assessment
- 1 Finding – Emergency Response procedure out-of-date – COMPLETED
- Program Administration and ERO
- Assessment completed, awaiting report
- Potentially 4 findings – training and record-keeping related

**8. Discuss: Results of internal and external OH&S management system audits **

## 9. Discuss: The state of preparedness for emergency

**Drills/Exercises**
- 1 Site-wide exercise was held during the fiscal year
- Passed most elements, did poorly in several
- Results are being evaluated for corrective actions
- 21 drills held this year
- Some were building evacuation/fire drill only
- Some were targeted to hazards
**Staffing**
- Office of Emergency Management (OEM) function was staffed at approximately 0.75 FTE in FY06.
- Staffing will be about 1.5 FTE direct and 1.0 FTE matrixed in FY07.
- Rely heavily on organizations to “do the right thing” when it comes to drills, etc

## Issues
9a. OEM is comparably understaffed to complete the requirements and meet compliance
9b. Organizational drills (not conducted by OEM) are either not occurring or are not being documented
9c. CMS is not an adequate tool for Emergency Management purposes 

- 9a. OEM is comparably understaffed to complete the requirements and meet compliance
- 9b. Organizational drills (not conducted by OEM) are either not occurring or are not being documented
- 9c. CMS is not an adequate tool for Emergency Management purposes

**Emergency Management/ Planning**

**9. Discuss: The state of preparedness for emergency**

## Issues
9d. Fire Department staffing for fire response, hazardous materials, technical rescue, confined space rescue; mutual aid does not meet  NFPA 1710 requirements
9e. Emergency Medical Services
Advance Life Support versus current Basic Life Support
One Advance Life Support response per month
DOE requires EMS to on par with community
9f. Fire Department equipment replacement
9g. Site fire Protection Needs: Water supply system; Fire alarm panels; Heat Detectors; Sprinkler head recall replacement; Site Fire Alarm System

- 9d. Fire Department staffing for fire response, hazardous materials, technical rescue, confined space rescue; mutual aid does not meet  NFPA 1710 requirements
- 9e. Emergency Medical Services
- Advance Life Support versus current Basic Life Support
- One Advance Life Support response per month
- DOE requires EMS to on par with community
- 9f. Fire Department equipment replacement
- 9g. Site fire Protection Needs: Water supply system; Fire alarm panels; Heat Detectors; Sprinkler head recall replacement; Site Fire Alarm System

**Fire Department **

**9. Discuss: The state of preparedness for emergency**

## 10. Discuss: Improvements to the OH&S management system (e.g. new initiatives to be introduced or expansions of existing initiatives)

- CAD has expanded JRAs with more worker input
- Safety Observation Program
- Safety Recognition Program (S3)

## Sitewide Safety Steward (S3) Award
New program in 2006
21 nominations
3 individual awards
1 team award 

- New program in 2006
- 21 nominations
- 3 individual awards
- 1 team award

**10. Discuss: Improvements to the OH&S management system (e.g. new initiatives to be introduced or expansions of existing initiatives)**

## Initiatives in communication to staff and other interested parties:
Safety Day
Take 5 video safety minute
ESH&Q Newsletter
SBMS Subject Area training
SHSD webpage
BNL Bulletin / Monday Memo
Summer Sunday
ESH Coordinator Meetings
EFCOG Meetings

- Safety Day
*Take 5* video safety minute
- ESH&Q Newsletter
- SBMS Subject Area training
- SHSD webpage
- BNL Bulletin / Monday Memo
- Summer Sunday
- ESH Coordinator Meetings
- EFCOG Meetings

*Safety PPE Demo at Summer Sunday*

**10. Discuss: Improvements to the OH&S management system (e.g. new initiatives to be introduced or expansions of existing initiatives)**

## OSH program Issues brought up from line organizations OSH management reviews

| Written Program Documentation Issues
10a. Integrate OSH documentation into EMS
10b. Revise manager questions in the Mgmt Review procedure 
10c. Provide improved guidance on FRA/JRA development & review
10d. Revise the ESR to trigger JRA/FRA
10e. Combine JRA and FRA that are common across site |
| --- |

**10. Discuss: Improvements to the OH&S management system (e.g. new initiatives to be introduced or expansions of existing initiatives)**

**Notes:**
OHSAS 18001 Interim Procedures expire in 12/31/06- recommend extending until 03/01/07 to allow efficient merger into other written programs

ESH&Q issues are not being most effectively address in Support Organizations Reporting to the Director’s Office because these organization do not have as strong an ESH&Q Coordinator program as the larger organizations-  Directors Office should consider formally assigning the role to xxxxxxx 

Document Control

## OSH program Issues brought up from line organizations OSH management reviews

| Implementation Issues
10f. SMEs – need available and qualified support in OSH topics
10g. Document Control needs site wide emphasis
10h. Work load and processes that assign work to line organizations for OSH initiatives without management approval |
| --- |

**OSH program Issues brought up **_**from line organizations OSH management reviews**_

**10. Discuss: Improvements to the OH&S management system (e.g. new initiatives to be introduced or expansions of existing initiatives)**

**Notes:**
OHSAS 18001 Interim Procedures expire in 12/31/06- recommend extending until 03/01/07 to allow efficient merger into other written programs

ESH&Q issues are not being most effectively address in Support Organizations Reporting to the Director’s Office because these organization do not have as strong an ESH&Q Coordinator program as the larger organizations-  Directors Office should consider formally assigning the role to xxxxxxx 

Document Control

## 11. Discuss: Effects of foreseeable changes to legislation or technology

**10 CFR 851 brings in new enforcement action to legal requirements in 2007 **
**Nanomaterials **
**Employee Exposure Monitoring****Engineering Controls**

## 10 CFR Parts 850 & 851 Overview

- Final Rule published in Federal Register on February 9, 2006
- Codifies contract requirements stated in DOE Order 440.1A
- Rule is effective/enforceable on February 9, 2007
- BNL must submit a written Worker Safety and Health Program by February 25, 2007
- BHSO must approve within 90 days of submittal
- No work may be performed after May 25, 2007 without an approved plan
- No grandfather clause for pre-existing conditions
- Gaps must be addressed in Corrective Action Plan submitted with Worker Safety & Health Program
- Variances must be granted by Under Secretary
- Annual updates are required

**11. Discuss: Effects of foreseeable changes to legislation or technology**

## 10CFR851 Enforcement – Effective 2/9/2007 
Civil penalties up to $70K per violation per day for continuing violations
Total civil penalties may not exceed fee
Civil penalty mitigation for self identification and prompt reporting (50%) and for prompt and comprehensive corrective action (50%)
No mitigation for self-disclosing events

10 CFR 851 Specific Program Requirements 
Management responsibilities and worker rights and responsibilities
Hazard identification and assessment
Hazard prevention and abatement
S & H standards (CFR, ANSI, ACGIH, ASME, NFPA)
Specific Functional Areas
Training and information
Recordkeeping and reporting

- Civil penalties up to $70K per violation per day for continuing violations
- Total civil penalties may not exceed fee
- Civil penalty mitigation for self identification and prompt reporting (50%) and for prompt and comprehensive corrective action (50%)
- No mitigation for self-disclosing events
**10 CFR 851 Specific Program Requirements **
- Management responsibilities and worker rights and responsibilities
- Hazard identification and assessment
- Hazard prevention and abatement
- S & H standards (CFR, ANSI, ACGIH, ASME, NFPA)
- Specific Functional Areas
- Training and information
- Recordkeeping and reporting

**11. Discuss: Effects of foreseeable changes to legislation or technology**

**Notes:**
To assure appropriate enforcement of the worker safety and health program, the Rule  establishes requirements and procedures for investigating the nature and extent of a violation, determining whether a violation has occurred and imposing appropriate remedy. 
Does not allow for grandfathering activities of the contractor, therefore the contractor must be in compliance on the effective date of the Rule.

## 10 CFR 851 Schedule

**11. Discuss: Effects of foreseeable changes to legislation or technology**

| Perform 10 CFR850/851/DOE440.1A Gap Analysis and Develop CAP | 6/15/2006-12/31/2006 |
| --- | --- |
| NTS Trial Reporting Near Miss, Incidents, Assessments, etc. | 6/1/2006 – 2/9/2007
 |
| Prepare Worker Safety and Health (WSH) Program (1st draft to BHSO) 	 | 8/01/2006
 |
| Department/division assessment	 | 10/30/2006 - 12/15/2006
 |
| Request for Variances | TBD
 |
| PPM Requirements Flow-down | 2/1/2007
 |
| Submit WSH Program to BHSO for approval	 | 2/25/2007 |

## 10 CFR 851: Functional Areas- Gap Analysis 

- Chronic Beryllium Disease Prevention Program –no significant gaps
- Construction safety  - subcontractor flow down issues
- Fire protection  - significant gaps/no comprehensive corrective action plan
- Explosives Safety – no significant gaps
- Pressure Safety – gap analysis still needs to be done
- Industrial Hygiene – significant gaps/corrective action plan initiated
- Biological Safety – minor gaps
- Occupational Medicine – subcontractor flow down issues and minor gaps
- Motor Vehicle Safety – minor gaps
- Electrical Safety – significant gaps/no comprehensive corrective action plan
- Firearms Safety – no significant gaps
- Nanotechnology safety-TBD
- Workplace violence prevention - TBD

**11. Discuss: Effects of foreseeable changes to legislation or technology**

## 10 CFR 851: Path Forward - Subcontractor flow down issues (To Be Determined)

- Process for flowing down requirements through contract modification still needs to be address
- Training & Qualification for electrical safety, etc.
- Occ Med program for workers employed >30 days
- Subcontractors must submit WS&H Program - BNL is considering options on who should approve the program—BNL or BHSO
- Liability issues
- Approval / turnaround schedule issues
- Oversight and approval of work permits
- Signoffs on permits such as (Electrical Energized Permit, Confined Space, Cutting/Welding, risk assessments, etc.)
- Verification of Training and Qualification of workers

**11. Discuss: Effects of foreseeable changes to legislation or technology**

## 10 CFR 851: Path ForwardSHSD/SMEs will assure that robust Corrective Action Plan is in place to address institutional programmatic gaps by January 2007.BNL will submit NTS reports for programmatic gaps that exist after February 2007.

- Issues:
- 11a. Policy Council may need to authorize funding for gaps in the *Institutional Corrective Action Plan*
- 11b. Dept. Chair/Div. managers must assure that a robust Corrective Action Plan is implemented to address gaps in their dept./div. programs.

**11. Discuss: Effects of foreseeable changes to legislation or technology**

## 12. Setting or updating of OH&S objectives for continual improvement in the forthcoming period

- Issue:
- 12a. Line organizations need to re-focus attention on the content of FY07 objectives.
**Better defined **_**measurable**_** targets**
- (Assigning owner and date was not an issue)
- (Based on NSF Phase 3 Registration Audit)

## 
Continually improve the OSH management system.  Expand registration to Phase 2 & 3  organizations and maintain OHSAS 18001 registration in Phase 1 organizations. 

Close OSHA Inspection Findings and expand corrective action to un-cited deficiencies on OSHA Inspection Findings (Extent of Conditions) 

 Improve Accident/Injury rate performance: 

Design Mechanisms to encourage Zero Traffic violation 

Expand participation in the BNL Safety Solutions (S2) Program.  Complete projects, Seek alternative funding to support and implement the program.    

- Continually improve the OSH management system.  Expand registration to Phase 2 & 3  organizations and maintain OHSAS 18001 registration in Phase 1 organizations.
- Close OSHA Inspection Findings and expand corrective action to un-cited deficiencies on OSHA Inspection Findings (Extent of Conditions)
-  Improve Accident/Injury rate performance:
- Design Mechanisms to encourage Zero Traffic violation
- Expand participation in the BNL Safety Solutions (S2) Program.  Complete projects, Seek alternative funding to support and implement the program.

| Goal / Performance | FY05 | FY06 | FY07 |
| --- | --- | --- | --- |
| DART | 0.45 / 0.74 | 0.37 / 0.49 | 0.25 |
| TRCR | 1.05 / 1.52 | 0.87 / 1.39 | 0.65 |

- Status on FY06 Objectives

**12. Setting or updating of OH&S objectives for continual improvement in the forthcoming period**

## Improve the implementation of in the Mechanical Material Handling site program 

Compliance- 10CFR850 and 10CFR851
Conduct Gap Analysis and Self Assessments
Implement the Corrective Action Plan to eliminate gaps identified in the BHSO Assessment of Industrial Hygiene Monitoring 

Schedule and conduct regulatory OSH compliance assessments to evaluate compliance to applicable regulations on a three-year cycle 

- Compliance- 10CFR850 and 10CFR851
- Conduct Gap Analysis and Self Assessments
- Implement the Corrective Action Plan to eliminate gaps identified in the BHSO *Assessment of Industrial Hygiene Monitoring*
- Schedule and conduct regulatory OSH compliance assessments to evaluate compliance to applicable regulations on a three-year cycle

- Status on FY06 Objectives

**12. Setting or updating of OH&S objectives for continual improvement in the forthcoming period**

**Notes:**
Completed Assessments – 
IH Multi-topic Assessment (Bloodborne Pathogens, Confined Spaces, Heat Stress, Lead)
Safety Engineering Multi-topic Assessment (Compresse)
Chemical Hygiene
Injury Prevention and Post-Injury Management Process (w/Liberty Mutual)
Fleet Vehicle Assessment

Incomplete Assessments – 
Machine Shop Safety Assessment
Lockout/Tagout (Divisions that did NOT respond were Plant Engineering, Physics, Instrumentation, Medical, Biology, Chemistry, NSLS, Environmental Management)
Traffic Safety Assessment

Cancelled Assessment – 
Incident Investigation Process Assessment (due to scheduling difficulties)

## Develop and implement an “Authority Having Jurisdiction (AHJ) program” to approve equipment that does not have Nationally Recognized Testing Laboratory certification (NRTL) 

Develop and implement a program to conduct Arc Flash Calculations to conform to NFPA 70E 

Open the Laboratory to the public for safety related special emphasis programs such as “Summer Sunday” exhibits  

Develop a Safe Employee Recognition and Award program (S3)

- Develop and implement a program to conduct Arc Flash Calculations to conform to NFPA 70E
- Open the Laboratory to the public for safety related special emphasis programs such as “Summer Sunday” exhibits
- Develop a Safe Employee Recognition and Award program (S3)

- Status on FY06 Objectives

**12. Setting or updating of OH&S objectives for continual improvement in the forthcoming period**

## 12. Setting or updating of OH&S objectives for continual improvement in the forthcoming period

**Integrate multiple BNL Management Systems related to OSH into more streamlined management systems) that are based on the principles and core functions of DOE’s ISM and OHSAS.**
**Complete the site level OHSAS 18001 registration and continually improve the OSH management system in registered organizations. (BNL Annual Laboratory Plan)**
_**CONDUCT OSHA EXTENT OF CONDITION REVIEWS**_
**Expand corrective action to un-cited deficiencies similar (i.e. “like-instances”) to the cited OSHA Inspection Findings (i.e. conduct an extent-of-condition review).**
**Improve ladder and industrial stair safety by communicating key requirements for fixed stairs and ladders to Building Managers and key staff involved in Tier 1 inspections.**
_**IMPROVE ACCIDENT AND INJURY RATE PERFORMANCE **_
**Improve Accident/Injury injury rate performance: DART  ≤0.25     TRCR  ≤ 0.65**
**Design mechanisms to encourage Zero Traffic violations **
**Expand participation in the BNL *****Safety Solutions***** (S2) Program.  Institutionalize the Laboratory funding of this accident/injury prevention program. **
_**IMPROVE THE IMPLEMENTATION OF THE MATERIAL HANDLING TRAINING PROGRAM**_
**Implement Corrective Actions on deficiencies in the site mechanical material handling program**
**Develop/revise new training material as needed for the mechanical material handling program, exploring outside vendor with equipment specific expertise.**
**Develop lab-wide manual-lifting guidelines to reduce overexertion injuries.**
**Improve facility level training by systematically evaluating the effectiveness of training through Field Observation and ensuring that required procedures and equipment are understood and utilized on the job.  Provide tools (observation checklists) to facility experts to aid in field observation.**

**12. Setting or updating of OH&S objectives for continual improvement in the forthcoming period**

## 12. Setting or updating of OH&S objectives for continual improvement in the forthcoming period

**Actively participate in implementation of new initiates to achieve compliance with 10CFR850 and 10CFR851. ****(BNL Annual Laboratory Plan)**
**Improve implementation of SBMS OSH Subject Area requirements **
**Improve implement of BHSO IH Monitoring Assessment Corrective Action Plan to eliminate gaps in the Industrial Hygiene monitoring requirements.**
**Conduct regulatory OSH compliance assessments that are integrated into a comprehensive audit schedule covering OSH, Fire Protection, Radiological Protection, Emergency Planning, etc. **
**Implement the “Authority Having Jurisdiction (AHJ)” program (to approve electrical equipment that does not have Nationally Recognized Testing Laboratory (NRTL) certification) and 5-year Plan developed in FY05.**
**Develop and implement a program to conduct Arc Flash Calculations to conform to NFPA 70E. (BNL Annual Laboratory Plan)**
**Increase OSH awareness and requirement implementation by line organizations with OSH Subject Area training. **
_**COMMUNICATIONS**_** - Improve communications, trust, and relationship with stakeholders on occupational safety & health programs. **
**Open the Laboratory to the public for safety related special emphasis programs such as “Summer Sunday” exhibits and “Safety Week” events.   **
**Seek a research oriented motivational speaker on safety awareness.**
**Improve consultation and communication with employees on OSH issues. **
**Enhance participation in the Safe Employee Recognition Award (S3) program.**

**12. Setting or updating of OH&S objectives for continual improvement in the forthcoming period**

## 12. Setting or updating of OH&S objectives for continual improvement in the forthcoming period

**Incorporate health and safety hazards with an emphasis on short term researchers and students (who have minimal work experience and familiarity with BNL OSH programs) into existing general employee training.**
**Develop organization level training for short term researchers and students who are exposed to unique equipment and operations with health and safety hazards.**
**8.**  _**EMERGENCY PREPAREDNESS**_: **Improve awareness and training of staff in emergency preparedness and response actions. **
**Develop and deliver Laboratory level incident drills to measure the effectiveness of response organizations and line organizations to emergency events.    **
**Enhance organization level staff knowledge and skills in emergency preparedness.   **
**9.  **_**TRAVEL: **_**Improve awareness and staff in occupational safety & health hazards of domestic and foreign travel.  **
**Develop Laboratory level training on health and safety hazards associated with domestic and foreign travel.    **
**Develop organization level awareness of health and safety hazards if line organization personnel encounter unique situations during domestic and foreign travel**

**12. Setting or updating of OH&S objectives for continual improvement in the forthcoming period**

## 12. Setting or updating of OH&S objectives for continual improvement in the forthcoming period

***Senior Management feedback and direction***
***Senior Management commitment to Continual Improvement***
_***Suitability***_***-***** **_***Adequacy***_***-***** **_***Effectiveness***_**-**** **
- Do the _**Objectives**_ target ***Continual Improvement*** ?
- Do the Objectives address the **current level of risk** ?
- Is there **adequate resources** (financial, personnel, material) to meet the objectives ?
- Do the Objectives address foreseeable changes to legislation or technology ?
- Are the Objectives achieving the desired results ?
- Is there a need for changes?

**12. Setting or updating of OH&S objectives for continual improvement in the forthcoming period**

## Feedback on the format of this presentation

**Questions/ Comments ?**