# Presentation: 664219

## LBNL Office of Independent Oversight Preparations – Red Team Review

## Overview

- Cross-Cutting
- Things to keep doing
- Observations and things to focus on in the next 46 days
- HSS Planning visit is in 26 days
- HSS Field visit is in 46 days
- Program or Division Specific
- Things to keep doing
- Things to focus on in the next 46 days

## HSS review Tips

- Identify known weaknesses and corrective actions and present at in brief
- Do an in-brief for HSS team
- Present issues identified by your feedback mechanisms
- Present accomplishments and planned corrective actions
- Should encompass BSOs feedback to lab...and beyond

## Cross-Cutting

- Observations
- Inconsistent articulation by personnel of role of JHA as basis for work authorization and personal safety
- Evidence of hazardous waste staging areas for SAAs
- Inconsistent understanding and implementation of PPE policy, postings and practices
- Inconsistent implementation of safety requirements for guests/students (i.e., equivalency, time on-site under supervision)
- The expectations for OJT in the work authorization process are not institutionalized

## Recommendations

- Minimize new requirements or initiatives – between now and review
- Mentor personnel on clearly articulating role of JHA role in work authorization
- Implement SAA compliance self-review (labels, start dates, in-process management)
- Implement PPE as posted
- Close overdue high/mod risk action items

## Material Sciences Division - Doug

- Observations
- “Certified User List” for specialized equipment
- Example of localized safety improvements – relocation of workstations outside laser areas
- Consistent understanding of stop work authorization
- Division distribution of lessons learned cited as positive aspect
- Inconsistent understanding of JHA as work authorization
- Inconsistent understanding of new PPE policy
- Use of “Radiation Control Area” sign as laser block
- Inadequate labeling of hazardous waste – flammable waste cans

## Material Sciences Division

- Recommendations
- Communicate latest PPE policy requirements and expectations – consistency with area signage
- Conduct Satellite Accumulation Area (SAA) compliance walk-throughs
- Reinforce role of JHAs, AHDs, certified user lists as authorization basis
- Reinforce methods to readily obtain MSDS for chemicals – LBNL internet search services

## Environmental Energy Technologies Division - Doug

- Observations
- Individual ownership of JHA evident – removal of inappropriate hazards in process
- Co-location of lab activities controlled by clear area ownership
- Exposed contacts between power source and glovebox – verify <50 volt limitation of electrical hazard
- Co-location of laboratory/office introduces PPE/food concerns
- CO alarms internal to room – buddy system requirement only emergency response mechanism
- Effective retrieval of MSDS not demonstrated

## Environmental Energy Technologies Division

- Observations (cont.)
- SAA container nearing 9-month storage limitation, management of wastes being analyzed/sampled
- Access limitations prohibit review of JHAs for other division personnel

## Environmental Energy Technologies Division

- Recommendations
- Communicate latest PPE policy requirements and expectations – consistency with area signage
- Evaluate oxygen deficiency hazards and controls in combustion lab
- Conduct SAA compliance walk-throughs
- Reinforce methods to readily obtain MSDS for chemicals – LBNL internet search services
- Verify understanding of <50-volt limitation of electric hazard
- Ensure JHAs appropriately cover all area hazards (hot surfaces) and can be viewed for visiting personnel

## Hazardous Waste Management - Doug

- _Program Review and assessment of HW facility_
- Observations
- Individual understanding of JHA content demonstrated
- Program requirements documented in PUB-3000 and other procedures
- Clear understanding of stop work requirements (refuse pick up) and authority to request exposure assessment
- Requests to collect excess items overwhelming group
- Inconsistent understanding of new PPE policy
- HW group personnel not directly involved in HW determinations for new processes

## Hazardous Waste Management

- Recommendations
- Communicate latest PPE policy requirements and expectations – consistency with area signage
- Prioritize pick-up and processing of hazwaste based on accumulation start date
- Long-term: Consider expanding role of generator assistants to include evaluation of new processes for HW generation/ characterization

## Chemical Management - Doug

- Program Review
- Observations
- Program requirements documented in PUB-3000 and other procedures
- Housekeeping in lab spaces generally good
- Line ownership of Chemical Tracking System (CTS)
- Initiation of CTS assessments
- Continued improvement of JHA questionnaire
- Inconsistent line understanding of new PPE policy
- Inconsistent line understanding of MSDS availability

## Chemical Management

- Recommendations
- Communicate latest PPE policy requirements and expectations – consistency with area signage
- Communicate availability of MSDS using search engines subscribed to by LBNL
- Review/update chemical life cycle presentation for appropriate use during upcoming audit

## Engineering - Arnold____________________________________________

- _Keep Doing_
- Good work planning and authorization execution
-  Appropriate use of PPE (noted without exception)
-  Frequent line management field presence
-  Good integration across adjacent work areas
-  Effective coordination between Work Groups and EH&S teams
-  Appropriate control and communication with temporary work groups (e.g. contractors, facilities) performing tasks in Engineering
- _Focus on_
-  Ensure all signage is accurate and current
-  Ensure separation of work and food/drink areas by removing vending machines from work area (noted in one location).

## Physics - Arnold____________________________________________

- _Keep Doing_
-  Good understanding and practical application of ISM
-  Clean and well controlled work areas; access controlled
-  Frequent line management field presence
- _Focus on_
-  Improve work lead’s understanding of requirements and responsibilities for required tests and inspections of the hazardous gas systems
-  Improve positive control of gas cabinets by using existing locks on the cabinet doors and removing the keys
-  Review emergency actions and procedures with area occupants
-  Ensure control of vendors consistent with new expectations

## Life Sciences - Bob

- Observations
- Clear access control requirements
- Very engaged and supportive Work Leads and Division Safety Coordinators (DSC)
- Housekeeping very good
- Scientific staff understand Stop Work authorities
- Most scientific staff understand line management authorities (Work Leads are “go to persons”)
- Scientific staff can generally describe JHA and training processes (in some instances, some degree of prompting required)
- PPE policy is changing (Lab coats not required if not working in laboratory spaces)

## Life Sciences

- Observations (con’t)
- Role of OJT essentially a pre-condition (requirement) to begin work; relationship to work authorization process could be clearer
- Use of SOPs a key hazard control mechanism; relationship to JHA process could be clearer
- Recommendations
- Clarify what elements are needed for line management to authorize work (JHA, BUA, RWA, SOPs, OJT)
- Provide coaching on overall work authorization process (JHA, BUA, OJT, RWA)

## Chemical Sciences - Bob

- Observations
- Excellent access control process
- Clear and unambiguous PPE policy
- Good understanding and demonstration  of line management responsibility, JHA process
- Good understanding of overall work authorization process (including roles and responsibilities) as it applies to actinide chemistry R&D
- Stop Work authorities and responsibilities well understood
- Formal work authorization and access control process for non-Division personnel who work in laboratory areas

## Chemical Sciences

- Observations (con’t)
- Clear and formal process for maintenance personnel who require access to laboratory areas
- Housekeeping very good
- Recommendations
- Clarify role and importance of OJT in work authorization process for students
- Improve precision of responses to questions regarding work authorization
- Establish process for examining “Near Misses” in collective fashion (including understanding the “why” and the “what”)

## ALS - Arnold ____________________________________________

- _Keep Doing_
-  Beam line scientists demonstrated good understanding and application of work authorization process.
- Appropriate control of User activity at beam line stations
- Thorough analysis of hazards associated with test specimens
-  Positive access controls for Users.
-  Personnel in beam line stations have good awareness of hazards in adjacent areas.
-  Frequent line management/authorizing individual presence in the beam-line experimental area._ _
- _Focus on:_
-  Better segregation of work and areas where food/drink is allowed.
-  Implement LBL PPE policy in uniform and consistent manner.
-  Consider control room access controls.

## Construction - Gus

- Keep doing
- Flow Down of DOE Safety Requirements
- Apply Best Practices from other Labs
- Priority on Improving Safety on Small Projects

## Construction

- Focus on:
- Sharing  best practices across Lab
- Visitor Orientation
- Material Movement
- Daily Planning Meetings
- JHA At Transition to Commissioning & Operations
- Increase oversight of small projects to ensure LBNL expectations for work planning, authorization and safety requirements are implemented

## Maintenance - Gus

- Keep Doing
- Use of Task Change Request for review and approval of work when the task has changed
- Open dialog between workers and supervisors
- Effective exchange of information including safety at Shift Change Meetings
- Focus On
- Organize the recently occupied Preventive Maintenance Administrative Area
- Remove legacy signs and posters
- Remove excess supplies and materials
- Ensure good housekeeping

## Earth Sciences - Glenn 

- Observations
- Good understanding and use of JHA as work authorization process – but line responsibility needs to be clearly articulated
- “Guests” treated essentially same as employees
- New PPE policy appears to be implemented
- PPE and food issues associated with offices connected to lab spaces
- Excess equipment needs to be moved in one space reviewed – otherwise housekeeping good
- Hand built electrical devices need to be certified as safe – need compensatory measures during interim
- Waste management practices during clean out need improvement – no “pre-staging”

## Earth Sciences 

- Recommendations
- Management needs to clarify that JHA is line management means of authorizing work and that other authorizations are also necessary in specific instances before work can begin
- Review other areas where clean-out of hazardous materials is occurring for pre-staging of materials
- Evaluate need for compensatory measures for hand-built electrical instruments

## Radiation Protection – Pit Storage - Glenn 

- Observations
- Very clear on JHAs as authorization of work
- Good processes and systems appear to be in place to control radioactive materials
- Clear authorization necessary before radioactive material is transferred

## Accelerator and Fusion Research Division (AFRD) - Kyle 

- Observations
- Excellent understanding and use of JHAs
- Coordination across organizations
- Linkage with Activity Hazard Documents – especially regarding training
- Applied to students and guests as well
- “Pre-job briefings” held for infrequently performed tasks
- Supervision in workplace on frequent basis
- Clear understanding of stop work authority and responsibility
- Demarcation of areas that may require PPE is confusing and practices are not always consistent with postings

## AFRD 

- Recommendations
- Clarification of PPE requirements and practice what is posted
- Consider some documentation of pre-job briefings when held

## Physical Biosciences (PBD) - Kyle

- (Donner) - Observations
- Very good understanding and articulation of personal safety constructs by some personnel
- Clear focus on JHA as basis for work authorization and personal safety requirements not evident
- Some students not familiar/comfortable with all individual safety basis concepts
- Lack of clarity in applying LBNL safety requirements to visiting students

## Physical Biosciences (PBD)

- (Donner) – Recommendations
- Emphasize importance of JHA as basis for personal safety and work authorization
- Formalize basis for ensuring & documenting visitor/guest/student safety
- Ensure all laboratory personnel are familiar with and can articulate basic safety concepts (personal safety, work authorization, actions to be taken when unexpected conditions or changes are encountered)

## 88-inch Cyclotron (NSD) - Kyle

- Observations
- Formal basis for coordinating JHAs with other divisions
- Operations and safety basis governed by accelerator order and SAD
- Key-controlled access to injector and vault areas
- Use of JHA as basis for work authorization and personal safety requirements not strong
- Evidence of formality in operations (e.g., configuration control, work planning) as illuminated in review not readily demonstrated
- Ambiguity in radiation area/contamination postings

## 88-inch Cyclotron (NSD)

- Recommendations
- Emphasize to staff operational, work planning and configuration controls in authorization basis documents (SAD, ASE)
- Ensure postings are clear:
- Radiation areas during various operational modes
- Radiation postings vs. monitoring locations
- Eye protection requirements
- Ensure work is appropriately proceduralized given risks and relation to authorization basis

## Red Team Members

- Craig Ferguson, SLAC
- 650.926.3106
- Arnold Clobes, LLNL/NIF
- 925.455.4027
- 925.980.7408 (cell)
- August Kugler, UC (retired)
- 509.783.2604
- 925.818.5885 (cell)
- Bob McCallum, McCallum-Turner
- Kyle Turner, McCallum-Turner
- Glenn Hoenes, McCallum-Turner
- Doug Schlagel , McCallum-Turner