# Presentation: 732720

## Overview ofChemical Management at the Berkeley Lab

- Paul Blodgett, CIH
- Industrial Hygiene Group Leader
- January 6, 2009

## Scope

- There are:
- 93 individual buildings that contain chemical containers
- 893 building/room combinations that contain chemical containers
- 66,543 container barcodes listed
- 491 owners listed
- 20 of 23 Divisions have chemicals in the database

## References/Tools

- Chemical Hygiene and Safety Plan (CHSP) – contains the Lab’s procedures to implement hazard communication and chemical use requirements.
- Chemical Management System (CMS) – is the tool used to document  and communicate hazards about chemicals.
- Hazard Management System (HMS) – is the tool used to connect EHS source systems and manage hazard information.

## LBNL Procurement

- Ensure that requesters, preparers, and buyers adhere to the Laboratory’s hazardous material procurement procedures.
- Maintain a _[restricted items ](http://www.lbl.gov/Workplace/CFO/pro/categories.html)_list in consultation with the EH&S Division.
- Notify EH&S of Restricted Item purchases.
- Obtain EH&S approval for purchases of restricted items that require EH&S approval.

## Restricted Item List

- Chemicals: lethal toxicants, unstable and reactive materials
- Hazardous and toxic gases
- Chemical storage cabinets
- Fume hoods
- Gas storage cabinets
- Refrigerators and freezers for flammable liquid storage
- Respiratory protective equipment

## LBNL Transportation

- Ensure that hazardous materials are transported in accordance with federal, state, and local requirements.
- Ensure that all hazardous materials received at LBNL are safely delivered to requesters.
- Provide guidance to Laboratory personnel for off-site shipment of hazardous materials in accordance with Department of Transportation requirements.
- Ensure the proper storage and handling of chemicals awaiting delivery.
- Request guidance from EH&S for items requiring special handling.

## Transporting Hazardous Materials

- Hazardous materials are transported by Transportation Services or a Department of Transportation authorized carrier (except as outlined below).
- Transportation Services (ext. 5404) transports hazardous materials, provided they are unopened and still in their original U.S. Department of Transportation (DOT) shipping containers. They also transport gas cylinders.
- EH&S Waste Management Group (ext. 7528) transports hazardous materials that have previously been opened. This is normally needed for laboratory moves.
- Transporting hazardous materials by employees in public transportation (such as the shuttle bus) or in private or government vehicles, is not permitted.

## LBNL Chemical Users

- Completion of a JHA and if needed an AHD
- Chemical Hygiene and Safety Training (EHS 348)
- Following controls and work practices in the CHSP
- Entry of chemicals into CMS or HMS
- Hazard Assessment and/or Exposure Assessment

## Chemical Management System (CMS)

- CMS is the chemical container based system:
- Assignment
- Identification
- Communication
- Disposal
- Not designed to track usage
- ISM Focused:
- Dependent upon chemical users input and activity

## .

- CMS – Hazard Communication
- Hazard Reports (inc. ENM report)
- Fire Code Threshold Reports
- Emergency Management Reports (151.1C)
- Links to MSDS
- SARA Title III - Community Right-To-Know Report

## Feedback & Improvement: ES&H Assurance

**John Chernowski**
**Manager, Office of Contract Assurance**

## DOE Order 226.1A

**Assessment**

**Issues Management**

**Reporting**

**Measured**
**by**

**Perform Work**
**within Controls**

**Assurance**

**   ****Continuous Improvement   **

**DOE Order 226.1A**

- Assurance

## ES&H Self-Assessment

**ES&H Self-Assessment**

| Assessment | Type of Review | Performed By |
| --- | --- | --- |
| Division 
Self-Assessment |    Safety System |    Line Management |
| Safety Review Committee (Management of ES&H) | Safety Management | Peer Researchers
and Staff |
| ESH Technical Assurance | In Depth Technical | EH&S SME’s
and 
Independent Experts |

## M

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
| 1 | 2 | 3 | 4 | 5
 |

**ESH Technical Assurance Program**** **

**Division Self-Assessment**

**ISM Core Functions**

**ES&H Self Assessment**

**M**
**E**
**S**
**H**

**M**
**E**
**S**
**H**

## Reporting

**Institutional**
**Contract Assurance Council**
**LBNL Risk Registry **
**Annual PEMP Self-Appraisal**
**Annual ES&H Self-Assessment Report**
**Event Reporting**
**ORPS**
**PAAA-NTS and internal logs**
**Worker Feedback**

**Notes:**
Technical Assurance Drivers

DOE Order 226.1, Implementation of Department of Energy Oversight Policy requires LBNL to:
Self-evaluate compliance with applicable laws, regulations, standards, DOE directives, DOE-approved plans and program documents, contractor procedures and manuals.
Analyze deficiencies, individually and collectively, to enable the identification of programmatic or systemic issues.
10 CFR 851 Subpart B, Program Requirements:
851.10 (a)(2) “...the contractor must ensure that work is performed in accordance with the worker safety and health program for that workplace.” 
January 2006 ISM Peer Review: 
Root cause: Not all EH&S Division technical programs include regular, required inspections of the workplace, work activities, or facilities.
Root cause: Adherence to existing work control program, including the current assessment and performance evaluation processes for work authorizations, particularly AHDs, is less than adequate.
September 2006 MT Review
Recommendation: Conduct institution-wide program evaluations on a risk-prioritized basis; and provide assurance that these processes/programs are conducted effectively, are implemented properly, and result in identifiable improvements to performance.

IFAs last performed in 2006.

## Worker Feedback

**Management- staff direct communication**
**Safety Concerns**
**Anonymous suggestion box**
**Safety concerns email**
**Standing feedback mechanisms**
**Division safety committees **
**Safety Review Committee**
**Division Safety Coordinators Committee**

**Notes:**
Technical Assurance Drivers

DOE Order 226.1, Implementation of Department of Energy Oversight Policy requires LBNL to:
Self-evaluate compliance with applicable laws, regulations, standards, DOE directives, DOE-approved plans and program documents, contractor procedures and manuals.
Analyze deficiencies, individually and collectively, to enable the identification of programmatic or systemic issues.
10 CFR 851 Subpart B, Program Requirements:
851.10 (a)(2) “...the contractor must ensure that work is performed in accordance with the worker safety and health program for that workplace.” 
January 2006 ISM Peer Review: 
Root cause: Not all EH&S Division technical programs include regular, required inspections of the workplace, work activities, or facilities.
Root cause: Adherence to existing work control program, including the current assessment and performance evaluation processes for work authorizations, particularly AHDs, is less than adequate.
September 2006 MT Review
Recommendation: Conduct institution-wide program evaluations on a risk-prioritized basis; and provide assurance that these processes/programs are conducted effectively, are implemented properly, and result in identifiable improvements to performance.

IFAs last performed in 2006.

## Issues Management Elements

**Managing Issues and Corrective Actions through LBNL Corrective Action Tracking System**
**Root Cause Analysis**
**Extent of Condition Review**
**Effectiveness Review**
**Data Monitoring and Analysis**
**Lessons Learned/Best Practices**

## Risk Assignment

| Risk Level | Criteria/Type of Issue |
| --- | --- |
| High | Significant Adverse Condition (SAC)
PAAA NTS-Reportable Incident
ORPS Category 1, R or 2 Incident
Type A or B Accident
Other Issues as designated by management |
| Medium | Adverse Condition identified through formal assessment
PAAA Internally-Reportable Incident
ORPS Category 3 Reportable Incident
Other Issues as designated by management |
| Low | Worker Safety & Health Issue that don’t fall into High or Medium
Adverse condition not identified through formal assessment
Other issues that do not meet the thresholds identified in High or Medium Risk Levels |
| De Minimis | Selected only when the level of risk is too small to be concerned with.
Worker Safety and Health Issue when there is no direct or immediate relationship to the environment, safety, or health. |

## Graded Approach Application

| Issue Risk Level | Document in CATS | Corrective Action Plan | Root Cause Analysis | Extent of Condition | Completion Verification | Effectiveness Review | Lessons Learned |
| --- | --- | --- | --- | --- | --- | --- | --- |
| High | X | X | X | X | X | X | DBM* |
| Medium | X | DBM | DBM | DBM | X | DBM | DBM |
| Low | X | -- | -- | -- | X | -- | DBM |
| Immediately – Corrected Items | DBM | --
 | --
 | --
 | --
 | --
 | -- |

**DBM = Determined by Management**
***Required for ORPS 1 and R**
**	****	**