# Presentation: 498308

## 
Environmental Management Directorate 
EMS/OSH
Management Review 
September 21, 2006

**Environmental Management Directorate**
- EMS/OSH
- Management Review** **
- September 21, 2006

## Purpose of Meeting

***ISO 14001, OHSAS 18001, and Integrated Assessment Program Self Evaluation requires a Senior Management review of the EMS Program and environmental performance ***
**Review performance of key system components**
**Evaluate ISO 14001 EMS Program**
_**Adequacy**_** – does it meet requirements & implemented appropriately **
_**Suitability**_**- does it “fit” BNL operations & systems**
_**Effectiveness**_**- is it achieving the desired results**
**Expected Outcome**
**Identify areas where focused improvement initiatives are needed**

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

To facilitate this evaluation, we have shown the four evaluation topics on this flipchart, plus have a note paper in your handouts for you to jot down your thoughts and ideas.  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 to Management Review

**a) results of internal audits and evaluations of compliance with legal requirements and with other requirements to which the organization subscribes;**
**b) communication(s) from external interested parties, including complaints;**
**c) the environmental performance of the organization;**
**d) the extent to which objectives and targets have been met;**
**e) status of corrective and preventive actions;**
**f) follow-up actions from previous management reviews;**
**g) changing circumstances, including developments in legal and other requirements related to its environmental aspects; and**
**h) recommendations for improvement.**

## EMS Assessments

**Internal – by EWMSD**
- Noteworthy Practice (1)
**Control of Documents (revision of documents)**
- Opportunity for improvement (3)
**Control of Documents (SBMS document embedded in Procedures did not have rev date)**
**Management review (2), incorporating feedback into objectives and targets, and communicating issues raised during Management review (documentation)**

## External – by NSF 
Noteworthy Practice (3)
Corrective and Preventive Action; Condition Reporting/Corrective Action Process
Communication; use of Lessons Learned in weekly EHS communications activities
Operational Controls; in work-specific procedures; and work permitting/documentation 

- Noteworthy Practice (3)
**Corrective and Preventive Action; Condition Reporting/Corrective Action Process**
**Communication; use of Lessons Learned in weekly EHS communications activities**
**Operational Controls; in work-specific procedures; and work permitting/documentation **

**EMS Assessments**

## Regulatory Compliance Assessments& External Audits

**Multi Topic Environmental Monitoring Self Assessment (EWMSD)**
**ERP was not included in this assessment, due to the scope (ESR’s, Universal and Industrial Waste, and QA/QC of sampling) not fitting with ERP being in a planning phase for much of 2006.**

## Assessments

**Exit Readiness Evaluation of Cold Neutron Facility performed.**
**Tier 1’s**

## 

Have we adequately addressed internal audits and evaluations of compliance?

Do you have any comments on internal audits and evaluation of compliance?

Does this meet our needs?

Any other comments/suggestions?

This satisfies the requirement for section 4.6(a) of ISO 14001 (2004)

**Have we adequately addressed internal audits and evaluations of compliance?**
**Do you have any comments on internal audits and evaluation of compliance?**
**Does this meet our needs?**
**Any other comments/suggestions?**
**This satisfies the requirement for section 4.6(a) of ISO 14001 (2004)**

**Management Review Questions**

## Stakeholder Concerns  Issues and Actions Siva Kumar

## Stakeholder

**Stakeholder**

## Stakeholder Concerns – Issues and ActionsRegulatory Interactions

**Excellent communications and constructive working relationship with regulatory agencies**
**EPA**
**NYSDEC**
**NYSDOH**
**Interactions with Suffolk County Department of Health Services affected by anticipated change in personnel**

## Stakeholder Concerns – Issues and ActionsRegulatory Accomplishments

**HFBR Core Team discussions proved efficient and effective**
**Seven meetings dealt with design, operation, characterization and alternative remedies**
**Agency management reviews coupled with projected personnel changes proved challenging  **
**Conceptual agreement on modified set of alternatives and preferred alternative in sight**

## Stakeholder Concerns – Issues and ActionsRegulatory Accomplishments (cont’d)

**Five-Year Review Report approved **
**Nearing agreement on g-2 Feasibility Study and UST/BLIP/g-2 Proposed Remedial Action Plan**
**BGRR remedy implementation under way**
**Regulatory review of graphite pile remedial design/remedial action plan in progress **
**Remedial design/remedial action plan for biological shield and engineered cap to follow**

## Community Outreach  Involvement and Communications

- Jeanne D’Ascoli
- Community Relations, Manager
- 2006

**October 2005:  Representatives from Department of Energy, regulatory agencies, elected officials, and the community joined to celebrate the completion of high-priority environmental restoration work at and near the BNL site**

## Stakeholders – Most Interested in HFBR

**High Flux Beam Reactor**
**Of great interest to many internal**
**	****and external stakeholders**
- Management
- Community Advisory Council
- Elected and government officials
- Brookhaven Executive
- 	Roundtable
**Opportunities for input from stakeholders included:**
- Presentations
- Through panel discussions
- Tours
- Meetings
- Concerns identified through extensive questions raised

## Concerns of the Most Interested Stakeholders

**Noted concerns regarding the decommissioning and dismantlement of the HFBR ranged from:**
**Worker and employee safety**
**Transportation risks**
**Control rod segmentation and consequences**
**Terrorist threat/ structural integrity, natural phenomena**
**Timing of decommissioning and dismantlement**
**Why 75 years **
**Maintenance of buildings over 75 years**
**Funding availability in 75 years**

## Additional Stakeholders – Interest in the HFBR Stack

**Conducted additional outreach to targeted stakeholders on potential interest in stack demolition.**
**Phone calls to 40 organizations and individuals, including those with air, sea and historic interests**
**Thirteen wanted to be kept informed about the project and to be notified when public meetings will be held**

## Additional Stakeholders – Civics, Media

**Civic Associations**
**In April 2006, letters were sent to local civic associations informing them of the decommissioning process.  **
- Manorville and East Yaphank were given presentations
**Media**
**Keeping the NY Times, Newsday, and local papers informed; inviting them to public meetings**

## Waste Transportation Outreach Plan

**Waste Transportation Communications, Outreach and Involvement Plan drafted**
**Agencies and points of contact identified**
**Relationships are expected to be maintained by staff**

## Stakeholder Survey

**Peconic River**
**Attempted to contact thirteen stakeholders; five provided feedback**
- Four expressed continued interest/ concerns
- All wanted to receive continual updates, preferably by direct mail
- Four want better follow up from Laboratory
** ****Groundwater**
**Attempted to contact thirty-four stakeholders; ten provided  feedback**
- All participants expressed continued interest/ concerns
- All wanted to receive continual updates; preferably by direct mail

## Outcomes

**Community Advisory Council continues to serve as advisors to the Director regarding environmental issues and concerns**
**Good relationships with elected officials are being maintained through regular contact**
**Federal, State and Local **
**Surveys require need for follow-up actions**
**Will act on requests to keep stakeholders briefed on stack **
**Developing a proposal for a newsletter to be issued ~twice a year to inform stakeholders of status of environmental projects**

## 

Have we adequately addressed communications?

Do you have any comments on communications?

Does this meet our needs?

Any other comments/suggestions?

This satisfies the requirement for section 4.6(b) of ISO 14001 (2004)

**Have we adequately addressed communications?**
**Do you have any comments on communications?**
**Does this meet our needs?**
**Any other comments/suggestions?**
**This satisfies the requirement for section 4.6(b) of ISO 14001 (2004)**

**Management Review Questions**

## Environmental Performance

**Spills**
- _No Spills in 2006!! ??_
**(8 in 2005, 7 in FY 04, 4 in FY 03, 8 in FY02)**

## Environmental Performance

**Waste Minimization**
**Conducted “Value Engineering Study” with DOE to develop strategies for reactor D&D**
**Extensive characterization of BGRR pile **
**Removed RCRA hazardous components from BGRR pile to minimize potential for generating mixed waste during pile removal**
**Developed plan for removing materials prohibited from  LLRW packages from HFBR**

## Environmental Performance

_**Recycling**_
**Recycled 620 cubic yards of concrete and brick for reuse on site as roadbed material**
**Recycled 30 tons of metal from demolition projects**
_**Land Reclamation**_
**Began the reclamation of ~2 acres of land space by demolishing HFBR BOP buildings**

## 

Have we adequately addressed our environmental performance?

Do you have any comments on our environmental performance?

Does this meet our needs?

Any other comments/suggestions?

This satisfies the requirement for section 4.6(c) of ISO 14001 (2004)

**Have we adequately addressed our environmental performance?**
**Do you have any comments on our environmental performance?**
**Does this meet our needs?**
**Any other comments/suggestions?**
**This satisfies the requirement for section 4.6(c) of ISO 14001 (2004)**

**Management Review Questions**

## Objectives and Targets

**Draft Appendix L-1 (of the draft DOE/BSA contract) identifies the ERP objectives and performance measures:**
- _Performance Goal 9 - Deliver best-in-class performance in completing the Brookhaven Environmental Management Completion Project (BEMCP)_
**Complete the BEMCP including Brookhaven Graphite Research Reactor (BGRR) pile and biological shield removal, and the High Flux Beam Reactor (HFBR) decommissioning project.**
**Complete BEMCP tasks in accordance with the DOE-approved Performance Baseline.**
**This is a multi-year performance goal for the period FY06 through FY11 or beyond.**
**Contract modifications currently being revisited-will effect objectives and targets. As a result ALL objectives and targets are likely to be re-racked**

## Targets

| FY | Work Package | Description |
| --- | --- | --- |
| 06 | 302 | Graphite Pile Removal Building Modifications IN  PROCESS  there are questions about DOE work Authorization |
| 07 | 303 | Graphite Pile Removal Detailed Planning & Mobilization |
| 07 | 304 | Graphite Pile Removal  |
| 07 | 305 | Graphite Pile Removal Waste Management |
| 07 | 306 | BGRR Graphite Pile In-Core Removal Work  ACCLERATED IN PROCESS |
| 07 | 321 | Bioshield Removal Detail Planning & Mobilization |
| 08 | 322 | Bioshield Removal |
| 08 | 323 | Bioshield Removal Waste Management |
| 08 | 324 | BGRR Post Removal Restoration |
| 09 | 399 | BGRR LTRA Transition and Regulatory Close-out |
| 06 | 412 | HFBR BOP D&D COMPLETE |
| 09 | 413 | HFBR Fan House D&D |
| 09 | 414 | HFBR Stack D&D |
| 07 | 415 | HFBR Underground Utilities D&D |
| 09 | 416  | HFBR Legacy Waste |
| 09 | 417 | HFBR Post D&D Restoration |
| 09 | 499 | HFBR LTRA Transition and Regulatory Close-out |

## All the work performed by ERP is related to a BNL Significant Environmental Aspect.
Financial obligations are documented in the ERP baselines for BGRR and HFBR.

ERP Funded Interdisciplinary staff includes:
Environmental Compliance Representative/EMS representative
ESH Coordinator
Training Coordinator
Corrective Actions Manager/Condition Reporting System Owner
Quality Assurance Program Manager
Safety and Industrial Hygiene Manager/OHSAS Representative
RCD Personnel (~6)

**Financial obligations are documented in the ERP baselines for BGRR and HFBR.**
**ERP Funded Interdisciplinary staff includes:**
**Environmental Compliance Representative/EMS representative**
**ESH Coordinator**
**Training Coordinator**
**Corrective Actions Manager/Condition Reporting System Owner**
**Quality Assurance Program Manager**
**Safety and Industrial Hygiene Manager/OHSAS Representative**
**RCD Personnel (~6)**

**Financial Investments**

## 

Have we adequately addressed our objectives and targets?

Do you have any comments on ERP objectives and targets?

Does this meet our needs?

Any other comments/suggestions?

This satisfies the requirement for section 4.6 (d) of ISO 14001 (2004)

**Have we adequately addressed our objectives and targets?**
**Do you have any comments on ERP objectives and targets?**
**Does this meet our needs?**
**Any other comments/suggestions?**
**This satisfies the requirement for section 4.6 (d) of ISO 14001 (2004)**

**Management Review Questions**

## Corrective and Preventative Actions

**ERP OPM 2.2, Corrective Action Program and Condition Reporting System**
**41 Condition Reports Total, (12 E, 18 OSH-Rad)**
**NO INJURIES!!!**
**92.5% Corrective Action, 7.5% Preventive Action**
**48% Closed (55% E, 56% OSH closed)**
**52% in process**
**Most resulted in causal analysis**
**Staff trained in causal analysis (“5 Whys” and “Barrier Analysis”)**

## Corrective and Preventative Actions

**ORPS**
**2 ORPS incidents in 2006**
**1)EM--BHSO-BNL-BNL-2006-0012**
**	**_**[HFBR Dumpster alarms BNL Radiation Truck Monitor ](https://orps.tis.eh.doe.gov/orps/reports/displayReport.asp?idx=99970)**_
**2)EM--BHSO-BNL-HFBR-2005-0001**
**	**_**[Violation of High Flux Beam Reactor DOE Safety Evaluation Report ](https://orps.tis.eh.doe.gov/orps/reports/displayReport.asp?idx=90670)**_
**Resulted in root cause analysis, and operational/procedural changes.**

## 

Have we adequately addressed corrective/preventive actions?

Do you have any comments on corrective/preventive actions?

Does this meet our needs?

Any other comments/suggestions?

This satisfies the requirement for section 4.6(e) of ISO 14001 (2004)

**Have we adequately addressed corrective/preventive actions?**
**Do you have any comments on corrective/preventive actions?**
**Does this meet our needs?**
**Any other comments/suggestions?**
**This satisfies the requirement for section 4.6(e) of ISO 14001 (2004)**

**Management Review Questions**

## Follow up actions(Management Review)

**EMS**
**NONE, Although need to close out condition report by documenting management review with formal ROD **
**OHSAS **
**NONE, Although need to implement plans to address internal audit findings and prepare for registration audit**

## Follow up action(from ESHQ Management Review)

**EWMSD goal to improve communication between ERP and EWMSD**
**Les, ESH&Q wants your feedback. Has it improved?**

## Other Follow up Actions(last years commitments)

**Restructure EMS to include entire remaining scope of work **
**Enhance Condition Reporting process**
**Thoroughly review applicability of SBMS procedures and include in contracts**
**Stay focused on completing ERP mission SAFELY!**
**Waste minimization/P2**
**Continued strong, visible management support for EMS**

## 

Have we adequately addressed follow up actions?

Do you have any comments on follow up actions?

Does this meet our needs?

Any other comments/suggestions?

This satisfies the requirement for section 4.6(f) of ISO 14001 (2004)

**Have we adequately addressed follow up actions?**
**Do you have any comments on follow up actions?**
**Does this meet our needs?**
**Any other comments/suggestions?**
**This satisfies the requirement for section 4.6(f) of ISO 14001 (2004)**

**Management Review Questions**

## Changing Circumstances

**New BNL ORPS SBMS Subject Area **
**Reissuing baseline (changing DOE requirements)**
**Contractual issues**

## 

Have we adequately addressed changing circumstances?

Do you have any comments on changing circumstances?

Does this meet our needs?

Any other comments/suggestions?

This satisfies the requirement for section 4.6(g) of ISO 14001 (2004)

**Have we adequately addressed changing circumstances?**
**Do you have any comments on changing circumstances?**
**Does this meet our needs?**
**Any other comments/suggestions?**
**This satisfies the requirement for section 4.6(g) of ISO 14001 (2004)**

**Management Review Questions**

## Recommendations for improvement

**Revise ERP OPM 2.2, Corrective Action Program and Condition Reporting System to align with new BNL ORPS SBMS requirements**
**Improve recordkeeping and documentation by implementing a log book system for Legal Requirement Review, ORPS, Lessons Learned, and Condition Reporting**
**Complete EMS and OHSAS web pages**
**Improve integration of management systems (EMS, OHSAS, ISM)**
**Clear “line of sight” metrics (TBD) for ES&H performance**
**Implement the “Safety Observation Program” to provide leading indicators of ES&H performance.**

## Goals FY 07

**“****Nuclear grade” program documentation**
**Work on completing Reactor Projects SAFELY!**
**Continued strong, visible management support for EMS, OHSAS and ISM**
**Operate **_**EVENT**_**-free**

## 

Have we adequately addressed improvement?

Do you have any comments on improvement?

Does this meet our needs?

Any other comments/suggestions?

This satisfies the requirement for section 4.6(h) of ISO 14001 (2004)

**Have we adequately addressed improvement?**
**Do you have any comments on improvement?**
**Does this meet our needs?**
**Any other comments/suggestions?**
**This satisfies the requirement for section 4.6(h) of ISO 14001 (2004)**

**Management Review Questions**

## Environmental Restoration ProjectsOccupational Safety and Health Management Review
September 21, 2006

- September 21, 2006

## Agenda 

- Review of OSH Performance
**Review of Facility and Job hazards and activities that can cause injuries and illnesses**
**OSH improvements (additional controls) identified through risk assessments**
**OSH Performance, Injury/illness rates, Tier I Performance**
**Summary of OSH Assessments (external audits, internal audits, occurrence reports and corrective actions, non conformance reports and corrective actions)**
- Costs
**OSH implementation and maintenance costs**

## Agenda (continued)

- FY 06 Objectives
- Effects of Foreseeable Changes to Legislation
- Management Discussion
**Identification of Improvement Actions**
**Suitability of current ERP Policy**

## Job and Facility Risk Assessments

- Summary
**37 JRAs* completed for ERP**
**9 FRAs* completed for ERP**
- * **Eight JRAs and Nine FRAs as defined in the priority tables have been completed to date and are posted on the ERP OHSAS website.  In addition, 29 Work Package specific JRAs have been completed during the work planning process.** ** **

## Facility and Job Hazards

- List of Hazards Identified through Risk Assessment Process

| Animals, insects,  poisonous plants | Back Injuries from material handling, lifting, bending | Heavy Equipment Operation | Ergonomic hazards (repetitive motion injuries) |
| --- | --- | --- | --- |
| Working at elevation | Electrical | Striking underground/
Overhead utilities | Chemical contact (spills, splashes) |
| Slips, trips, falls | Vehicle collision | Heat/Cold Stress | Eye Injury |
| Fire | Hand/power tool use | Confined Spaces | Biological hazards |
| Noise | Cuts, scrapes, punctures | Radioactive Contamination | Overhead hazards, pinch points |

## OSH Improvements

- Additional controls that resulted from the risk assessment process and worker feedback.

| FRA/JRA | Physical Item/Activity  | Action (Controls to be Added to Reduce Risk)  | Status |
| --- | --- | --- | --- |
| WP 306 | Scaffolding | Inconsistency noted between OSHA regulations and SBMS.  | Plant Engineering to revise training and scaffold inspection form |
| WP 306  | Plug Removal  | Procedure modification to allow alternate methods of removal  | JRA Revised based upon worker feedback |
| WP 302 | Elevator Repair | Controls to be replaced because of confined working space and electrical hazards | Work Postponed |

## OSH Improvements

- (Continued)

| FRA/JRA | Physical Item/Activity  | Action (Controls to be Added to Reduce Risk)  | Status |
| --- | --- | --- | --- |
| BGRR Pile | Radiological Contamination Control | Use of PCM to reduce “hot particle” spread | Implemented |

## Noted Weakness 

- Noted weakness with the Risk Assessment Process
**Activities such as administrative staff performing archiving activities (material handling) due not perform pre-activity briefings of review JRAs or perform tailgates prior to performing lifting activities.**
**     **Status:  New training matrix for administrative personnel that includes back safety/lifting.

## Summary OSH Performance

- FY 06 ERP Summary OSH Performance
- Lost Work Day Cases = 0 (Last occurrence back injury in August of 2004)
- BNL Traffic Violations = 2 (turn signal use and cell phone use)
- Personnel Contamination Incidents = 0
- First Aid Cases = 2
- *Occupational Injuries = 1 (shoulder strain from moving boxes)

## OSH Performance: ERP and Site Total Recordable Cases (TRC) (FY 03 – FY 06)

- In FY03, there was 1 Recordable case
- In FY04...1 case
- In FY05 there was 1 case
- In FY06...1 case

## OSH PerformanceERP and Site DART Cases (FY 03 – FY 06)

- In FY 03, there was 1 DART case.
- In FY04, there was 1 DART case.
- There were no DART cases for FY05 and FY06 YTD.

## OSH Performance – Tier I Inspections

**All ERP Tier Is are performed as scheduled.**
**All Tier I findings were addressed within 30 days or placed on FATS for continued tracking.**
**Typical deficiencies include general housekeeping and radiological postings. **
**Improvements are continual as facilities have reduced activity or are decommissioned.**

## BNL Tier I InspectionsTop Seven Categories

## External OHSAS Audit – NSF Desk Audit

**NSF Desk Audit Completed – No ERP Action Items**
**External Audit To Be Conducted for Phase 3 Organizations (includes ERP) on October 12****th**** & 13****th****, 2006.**

## Internal Audit 

- Internal Audit Conducted August 16-21, 2006
- Findings
- Based on interviews with workers, employees are not fully aware of the BNL ESSH Policy.  In addition, training on OHSAS should be reinforced.  **Status:  **Policy cards will be distributed to all employees.  OHSAS Factsheets will be used as training tools prior to registration audit.
- Organizational Chart and OHSAS Plan do not adequately identify specific personnel including the OHSAS 18001 Division Representative and the BNL OSH Management Representative.  **Status:  **The organizational chart has been updated to include OHSAS contacts, contact list has been posted on website, and OHSAS factsheets will be used as training tools.
- R2A2s have not been updated for all staff.  **Status:**  R2A2s for every employee will be revised when the SBMS subject area template has been corrected.

## Internal Audit Findings

- Findings (continued)
**ERP procedures need to be finalized and placed on web.  Historical procedures need to be archived.  **Status: **In process**** **
**JRAs and FRAs need to document worker involvement in development process.**** **Status:  **In progress**
**It was observed that Consultation and Communication of Legal Requirements could be improved. **Status:  **In progress**
**It was observed that a specific room has not been identified for records retention. **Status:  **In progress**

## Internal Audit Findings (continued)

**Contractors are not involved with the initial risk assessment process.  **Status:  **Use similar procedure to Plant Engineering (approved organization) – further discussion required.**

## OSH Costs and Resources

- Contributed resources for the OHSAS 18001 Phase 3 Registration Effort
- Implementation of Additional Controls from the Risk assessment Process
- 37 JRAs
**Approx. 360 person-hours (managers, safety professionals and workers)**
- 9 FRAs
**Approx. 80 person-hours**
- Training
**Approx. 150 person-hours**
**                                               **

**     ****~**$50,000
-      ~$10,000
-      ~$36,000
-      ~$  8,000
-      ~$15,000
- _Total $119,000_

## ERP OSH Objectives and Targets FY06Objective:  Event-Free Workplace 

- Target Safety and Health Measures
**Zero OSHA lost work day cases (work related) **
**Status:  Year to date Lost Work Day Cases = 0**
**Zero personnel contamination incidents**
**Status: Year to date personnel contamination incidents = 0**
**Zero BNL traffic violations**
**Status: Year to date traffic violations = 2**
**Zero first aid cases**
**Status: Year to date First Aid Cases = 2**
**Zero Events**
**Status: Year to date Events = ? (Condition Reports=38)**

## ERP OSH Objectives and Targets FY06 Objective:  Injury-Free Workplace 

**Conduct Tier I Safety Surveys and Disposition actions**
**Disposition Tier I findings within 30 days and perform as scheduled**
**Status**:  **All ERP Tier Is were performed as scheduled and findings dispositioned in 30 days.**
**Achieve OHSAS 18001 registration according to BNL established target dates**
**Status:  All JRAs and FRAs identified have been completed.  Desk audit and internal audit completed with follow up required.  NSF registration audit scheduled for October 12****th**** and 13****th**** (All Phase 3 Organizations).**

## ERP OSH Objectives and Targets FY06 

- Achieve OHSAS 18001 registration by meeting target dates for Phase 3 registration
- Status: On schedule
- Accident and Injury Reduction
**Review high risk assessments for improvement potential**
- Status: On schedule
- Improve Operational Performance
**Close findings involving corrective actions within 30 days.  Analyze performance if trends detected.**
- Status: Meeting 30 day corrective action or tracked on FATS.
- Communications Improvement
**Improve OHS awareness and obtain staff feedback**
- Status: Improved feedback is being documented

## Effects of Foreseeable Changes to Legislation

- 10 CFR 851 Rule:  Worker Safety and Health Program “Proposed Rule”
**Rule provides DOE with enforcement mechanism similar to PAAA**
**Rule pulls in consensus requirements and makes them mandatory (e.g. ANSI, ASTM etc.)**
**Rule first published in 12/03 to codify existing practices in order to ensure worker safety and health**

## Effects of Foreseeable Changes to Legislation

**Must achieve compliance with Rule within 1 year of effective date (February 26, 2007)**
**Subject to civil penalty of up to $70K per day per violation up to contract annual fee.**
**Significant costs are expected by implementing 851**
- Initial implementation/administration     $600K
- Facility upgrades to meet codes           $50.7 million
- Ongoing maintenance activities            $1.1 million
- Total estimated lab impact                $52.4 million

## Management Review Decisions

**Is the OSH Management System effective in achieving policy commitment?**
**Is the OSH Management System effective in achieving the objectives, targets and performance measures?**
**Is the OSH Management System adequate in terms of:**
**Resource allocation?**
**Information systems?**
**Organizational issues – staff expertise; procedural requirements**

## Management Review Decisions

- Are the objectives, targets and performance measures suitable taking into account the following factors**:**
**Injuries/illnesses?**
**Current and future regulatory requirements?**
**Business interests, technological capability?**
**Internal organizational or process changes?**
- Should additional objectives, targets or performance measures be established?
**Summary of improvement initiatives identified:**
- Track to closure all ERP Tier I Findings in FATS
- Add zero events as target.
- Implement STOP observation procedure as a leading indicator of H&S performance for all staff levels

## Management Review Decisions

- Suitability of current BNL ESSH Policy