# Presentation: 106739

## Environmental & Waste ManagementServices Division

- Occupational Safety and Health Management Review
- September 19, 2005
- Anna Bou
- OHSAS 18001 Division Representative

## 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 05 Objectives**** **
**Effects of Foreseeable Changes to Legislation**
**Management Discussion**
- Identification of Improvement Actions
- Suitability of current ESSH Policy

## Job and Facility Risk Assessments

**Summary**
- 37 JRAs  completed for EWMSD
- 22 JRAs for WM, 2 for LTRA, 12 for Field Services, 1 for Env. Compliance
- 18 FRAs completed for EWMSD
- 5 FRAs for WM, 2 for LTRA, 9 for Field Services, 2 for Env. Compliance
-    ***All JRAs and FRAs as defined in the priority tables have been completed to date and are posted on the EWMSD OHSAS website. **_**[http://intranet.bnl.gov/esh/esd/OHSAS18001](http://intranet.bnl.gov/esh/esd/OHSAS18001/)**__/_

## Facility and Job Hazards

**List of Hazards Identified through Risk Assessment Process**

| Animals, insects,  poisonous plants | Back Injuries from material handling, lifting, bending | Poor indoor air quality | Ergonomic hazards (repetitive motion injuries) |
| --- | --- | --- | --- |
| Tick borne illnesses | Electrical | Striking overhead utilities | Chemical contact (spills, splashes) |
| Slips, trips, falls | Vehicle collision | Heat/Cold Stress | Eye Injury |
| Fire | Drowning | Vapor inhalation | Biological hazards |
| Noise | Cuts, scrapes, punctures | Radioactive source handling | Overhead hazards, pinch points |

## Facility and Job Hazards

**List of Hazards Identified through Risk Assessment Process**

| Radiological contamination | Security hazards and hazards associated with working in remote areas | Flammability/ explosive hazards | Reaction from incompatible wastes, chemicals |
| --- | --- | --- | --- |
| Hydraulic spills, fumes | Airborne particulates (asbestos, lead, silica dust) | Crush hazards from shifting loads | Moving heavy objects, rigging |
| Obstructed, tight work space | Elevated areas | Rotating parts | Injuries from use of hand tools |

## OSH Improvements

**Additional controls that resulted from the risk assessment process are being tracked for closure through Family ATS.**

| FRA/JRA | Physical Item/Activity  | Action (Controls to be Added to Reduce Risk)  | ATS Status |
| --- | --- | --- | --- |
| T-538  | Drill press, grinding wheel  | Area needs to be reviewed for compliance with OSHA regulations for guards.  | Closed (guard and safety start plug were installed) |
| T-538  | Drill press, grinding wheel  | “Eye Protection Area” sign to be posted in area  | Closed |
| T-538  | Natural Hazards such as ticks  | Install geo-membrane with gravel around the building | Closed |

## OSH Improvements

**(Continued)**

| FRA/JRA | Physical Item/Activity  | Action (Controls to be Added to Reduce Risk)  | ATS Status |
| --- | --- | --- | --- |
| T-574  | Storage of gas and diesel fuel for compressors and power washer  | “no smoking” signs and “no ignition sources” signs to be posted  | Closed |
| T-574  | Filling equipment with fuel  | Training provided on how not to overfill equipment  | Closed
 |
| T-574  | Overhead storage  | Reduce or eliminate overhead storage  | Closed |

## Noted Weakness 

**Noted weakness with the Risk Assessment Process**
- Incident occurred recently where worked suffered back strain while handling/moving empty 55-gallon drums. _This incident resulted in no lost work time._ Upon review of the JRAs, it was noted that this hazard was not identified and that no JRA for this activity had been considered.
-      **Status:  New JRA for empty drum handling has been completed and posted.**

## Summary OSH Performance

**FY 05 EWMSD Summary OSH Performance**
**Lost Work Day Cases = 0**
**BNL Traffic Violations = 3 (parking, speeding, moving)**
**Personnel Contamination Incidents = 0**
**First Aid Cases = 0**
***Occupational Injuries = 1 (4/21/05 back sprain from moving empty drum)**
***Not currently included as a target or tracked in EWMS SAP.**

## OSH Performance: EWMS and Site Total Recordable Case Rate (TRCR) (FY 02 – FY 05)

**In FY02, there were 2 Recordable cases (3.57)**
**In FY03...1 case (1.98)**
**In FY04...2 cases (4.40)**
**In FY05...1 case (2.43)**
**    ****-  4/21/05 acute low back strain from moving empty drum**

## OSH PerformanceEWMS and Site DART Rate (FY 02 – FY 05)

**In FY 02, there were 2 DART cases. (3.57)**
**In FY03, there was 1 DART case. (1.98)**
**There were no DART cases for FY04 and FY05 YTD. (0.00)**

## OSH Performance – Tier I Inspections

- All EWMS Tier Is are performed as scheduled.
- All Tier I findings were dispositioned within 90 days.
- Typical deficiencies include general housekeeping, postings, drum labeling, electrical panel issues, degrading electrical cords, inoperable safety switches, waste storage and disposal issues, insect/animal issues, out-of-date placards.
- Improvements are continual as priorities and focus changes are requested by regulators, safety professionals and management.

## BNL Tier I InspectionsTop Seven Categories

## External OHSAS Audit – NSF Desk Audit

**Findings and Status resulting from NSF Desk Audit, July 2005**
- The list of Legal and Other Requirements is identified in the Interim Procedure as being located in the OHSAS Management System Description.  Review of this document revealed that the information was not found in this document or other documents reviewed.  **Status: Any ideas?**
- There is insufficient evidence to determine if an awareness training program has been developed that address all the requirements in clause 4.4.2.  **Status: **“Reducing Accidents and Injuries in the Workplace” is required training for all OHSAS Phase 2 staff.  In addition, OHSAS “Factsheets” will be distributed to all supervisors and managers to be used as training tools for training sessions to be conducted prior to registration audits in November.  Training actions for each supervisor/manager will be tracked in FATS.

## External OHSAS Audit – NSF Desk Audit

- No evidence of Phase 2 scope internal audits was provided or accessible for review.  **Status: **Internal audits for phase 2 organizations were conducted in July 2005 and will be posted on website as soon as reports are available.
- BNL did not provide a schedule of the Phase 2 OHSAS audits that they plan to conduct.  **Status: **The schedule has been posted on the website and available for review.
- At least one management review has not been completed.  **Status: **Will be completed by/during the Readiness Review in September.

## External OSHA Assessment – FY 05 Status

**Total of  28 facility related citations: 21 complete**
**     ****7 still pending in FY 05:**
**    ****1.  ****Building 860 (Outside: East of 860: Manhole)** The service vault had not been evaluated to determine if it was a permit-required confined space.
-     **2. Building 865 (High Bay Area)** The waste compacter was not guarded adequately in that employees in the work area were not protected from crushing injuries.
-      **3. Building 810 (Yard)**  The open-sided platform on top of tanks 3 and 4 was not provided with a standard guardrail system.
-      **4. Building 865 (High Bay)** The walkway on the overhead Virginia crane had open ends, exposing a person to a fall hazard exceeding 30 feet.

## External OSHA Assessment - Status

**Pending citations (continued)**
**     ****5. ****Building 811(Basement)** The lights and switches in the basement area were not approved for wet and damp areas.
-      **6. Building 865 (High Bay) **The walkway on the Virginia crane had several holes that were not guarded or covered.
-      **7.** **Building 865 (High Bay)** The trolley on the Virginia 30-ton crane had no rail sweeps.
**    **

## Internal Audit 

**Internal Audit Conducted July 11-27, 2005**
**Findings**
- Based on interviews with workers, employees are not fully aware of the ESSH Policy.  In addition, training on OHSAS should be reinforced.  **Status:  **Policy cards have been distributed to all employees.  OHSAS Factsheets will be used as training tools prior to registration audit.
- Employees not fully aware of who the OHSAS 18001 Division Representative and the BNL OSH Management Representative are.  **Status:  **The organizational chart has been updated in 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 reviewed. Those not updated will be tracked in FATS.

## Internal Audit Findings

**Findings (continued)**
- EWMS organization chart needs to be revised to include key OHSAS personnel.  **Status: **The chart has been updated and posted on the web. (FATS action)
- JRAs and FRAs need to be performed for the BMRR (building 491) for Waste Management Surveillance activities. **Status:  **In progress** **(FATS action)
- It was observed that WM does maintain CO monitors in some of their buildings that could be considered OSH monitoring.  These instruments should be calibrated and put into a calibration program.  **Status:  **In progress** **(FATS action)

## Internal Audit Findings (continued)

- Guests and contractors are not involved or necessarily aware of the risk assessment process.  **Status:  Any ideas?**
- Documentation of the retention period for records has not been established for OSH (site level issue).  **Status:  **OSH retention schedule has been established and posted on website.

## FY 05 Occurrence Reports and Corrective Actions

**Three Occurrence Reports issued for FY 05**
**NYSDEC Notice of Violation for Improper Handling of Universal Waste** Universal waste fluorescent light bulbs were not placed into proper containers/packages and were improperly labeled.  Corrective actions included formal training and posting signs directing individuals to seek assistance (completed 2/3/05).

## FY 05 Occurrence Reports and Corrective Actions

**Strontium-90 Groundwater System**Approximately 3,500 gallons of ground water had flooded building 670 when an extraction pump was placed in the manual mode (no automatic shutdown when alarm condition has been reached).There was no environmental release and no personnel contamination.  Corrective actions included performing training sessions for field engineers on system operations, connecting building to BNL central alarm station, and evaluating all groundwater treatment systems for unintended manual operation.
**Personnel Exposure to Excessive Noise **
**      **Upon the request of the LTRA group, noise surveys to evaluate noise levels during carbon changeouts were conducted.  Employees at Building 521 were found to be exposed to excessive noise.
- .

## FY 05 Occurrence Reports and Corrective Actions

- Two employees wearing noise dosimeters were exposed to noise levels slightly above the 85 decibel standard.  Three other employees not wearing noise dosimeters were also exposed. It was reported that all BNL personnel associated with this event are in the Noise and Hearing Conservation (N&HC) program. The contractors have their own N&HC programs.

## FY 05 Occurrence Reports and Corrective Actions

- A critique was held on 6/7/05 and a written notification was sent to all five workers.  Corrective actions included:
- Revising IH SOP-96250 to require that when performing noise surveys or when wearing personal noise dosimeters, hearing protection shall be worn until it is verified that protection is not required.
- Workers are required to wear hearing protection while compressors are operating during carbon changeouts
- Area near compressors posted as “hearing protection required”.
- Develop and submit a Lessons Learned (LL) to the BNL and DOE LL databases.

## Nonconformance Reports and Corrective Actions

**Eight Nonconformance Reports issued in FY 05**
- Requisitions from Waste Management were submitted to procurement without QA review (11/10/04).
- Requisitioners at the WM program will be given a refresher training to emphasize the importance of proper QA review of requisitions.  Completion date: 12/15/04
- The requisitions of concern will be reviewed by QA and a memo written to their procurement file so that evidence of QA review is added to the procurement file. Completion date: 12/15/04
- A follow-up review will be scheduled in the WM family ATS for June of 2005, to assure that future requisitions are being properly reviewed by QA. Completion date:  11/19/04

## Nonconformance Reports and Corrective Actions

- As a result of a recent Occurrence Reporting and Processing System (ORPS) report concerning a leaking radioactive waste bin, a review of WMF POs was done. PO Numbers were found to not have documented supplier evaluations as required by the Evaluation of Seller Quality Assurance (QA) Programs Subject Area (2/10/05).
- SOP WM-ADM-925,** **Inspection & Acceptance Of Purchased Items,** **was revised to require** **that all items/services classified as ESH&Q Risk Level A1 or A2 must use qualified suppliers.

## Nonconformance Reports and Corrective Actions

- Several unused 55 gallon drums stored at Bldg 855 did not have an incoming inspection sticker (5/5/05).  The root cause of this nonconformance is that ADM-SOP-925 does not require label accountability of the acceptance labels.
- -  the procedure was revised to require that an accountability of labels will be done to assure that all items have been labeled.
- -  All the unlabeled drums have been labeled.
- Four scales beyond Calibration Due Date of 3/05
- Calibration of Measurement and Test Equipment Procedure being developed.
- Scales have been calibrated

## Nonconformance Reports and Corrective Actions

- The Certificate of Calibration for the CAS Caston Electronic Crane Scale had an “As Found“ value of 40140 lbs at an applied load of 40,000 lbs., which is outside of the tolerance ( 80 lbs). (7/28/05)
- The crane scale was calibrated by Superior Scale &     Instrument Corp.
- No adverse ESH&Q impacts
- The draft version of WM-ADM-925, Procurement Requirements And Inspection & Acceptance Criteria For Purchased Items/Services rev. 1 was posted to the WM website (6/16/05).  The correct version has been posted.

## Nonconformance Reports and Corrective Actions

- Surveillances of WM SOPs, as required by the FY04 SAP, were not conducted.  An FY 05 schedule of surveillances has been developed and scheduled for completion by 9/23/05.
- While reviewing procedures for Nevada Test Site (NTS) certification, Waste Management (WM) program staff identified a deficiency in the review and implementation of standard operating procedures (SOPs)
- WM-SOP-578, Shipping Radioactive Waste, the text in the procedure did not reflect the work performed as outlined in the checklist.
- WM-ADM-900, Document Control & Records Storage.  The procedure refers to a number of obsolete practices previously employed by the WM program.

## Nonconformance Reports and Corrective Actions

- Corrective actions included:
- Revise WM-SOP-940, Preparation of Procedures to include detailed requirements for performing triennial reviews and place a triennial review completion on the cover page of each procedure, as they are revised/changed. (completed)
- Establish a schedule and enter into the WM Family ATS to review all WM SOPs for applicability, and reflection of actual WM Operations

## OSH Costs and Resources

**Contributed resources for the OHSAS 18001 Phase 2 Registration Effort**
**Implementation of Additional Controls from the Risk assessment Process**
**37 JRAs**
- Approx. 450 person-hours (managers, safety professionals and workers)
**18 FRAs**
- Approx. 150 person-hours
**Training**
- Approx. 250 person-hours

-      ~**$50,000**
**     ****~$  4,500**
**     ****~$45,000**
**     ****~$15,000**
**     ****~$25,000**
_**Total $139.5 K**_

## EWMS OSH Objectives and Targets FY05Objective:  Injury-Free Workplace 

**Target Safety and Health Measures (Supports Critical Outcome 3.4.1)**
- 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 = 3**
- Zero first aid cases
**Status: Year to date First Aid Cases = 0**

## EWMS OSH Objectives and Targets FY05 Objective:  Injury-Free Workplace 

- Conduct Tier I Safety Surveys and Disposition actions
- Disposition Tier I findings within 90 days and perform as scheduled
**Status**:  **All EWMS Tier Is were performed as scheduled and findings dispositioned in 90 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 no surprises.  NSF Readiness Review scheduled for for week of 9/18/05.  Registration audit scheduled for November.**

## EWMS OSH Objectives and Targets FY05 Objective:  Injury-Free Workplace 

**Management walk through of operations areas and participation in Tier I Inspections**
- Managers/supervisors to perform 2 walkthroughs per week and 2 Tier Is per year
**Status: In progress**
**Training and Qualification**
- Completion of required courses Employees = 90%, Guests/ Contractors = 80%
**Status: Employees ES=98%, WM=97%**
**                ****Guests ES=88%, WM=100%**

## EWMS OSH Objectives and Targets FY05Objective:  Compliance with Laws, Regulations

**FY 05 BNL Required Assessments for All Organizations**
- Emergency Preparedness:  Shelter-in-Place
- Worker Safety and Health:  Lockout/Tagout
- Worker Safety and Health:  Interlock Safety for Protection of Personnel
**Implement additional controls identified through risk assessment process**
**Status:  Additional controls have been identified and tracked through FATS.  All actions have been closed.**
**   ****Annual review of 1/3 of JRAs/FRAs to begin FY 06.**

## 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
- Final comments due and sent 4/15/05
- Final rule could be promulgated in as little as 6 months from end of comment period

## Effects of Foreseeable Changes to Legislation

- Contractors must achieve compliance with Rule within 1 year of effective date
- We must reapply for all waivers (exemption process)
- Contractors are 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 OSHMS effective in achieving the objectives, targets and performance measures?
- Is the OSHMS 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 EWMS Tier I Findings in FATS
- Revise OSH MS Description to include list of legal and other requirements
- Add zero occupational injuries as target for SAP.

## Management Review Decisions

**Suitability of current ESSH Policy**

**Employees, Contractors and Guests:** We will provide a safe and healthy workplace, striving to prevent injuries and illnesses, promoting healthy lifestyles, and encouraging respect for the environment. We will ensure our employees, contractors, and guests have the awareness, skills, and knowledge to carry out this policy.
**Compliance:** We will meet all applicable ESSH laws and BNL Standards Based Management System, Integrated Safety Management, and Integrated Safeguards and Security Management requirements.
**Integration:** We will integrate ESSH principles into our research and operations activities. We will integrate hazard prevention/reduction, pollution prevention/waste minimization, resource conservation, security, and compliance into all of our planning and decision-making. We will adopt cost-effective practices that eliminate, minimize, or mitigate environmental impacts and control safety, security, and health risks and vulnerabilities.
**Security:** We will work in compliance with DOE’s ISSM Program and systematically integrate safeguards and security into management and work practices at all levels, so that the laboratory missions are accomplished in a safe and secure manner.
**Sustainable Development:** We will strive to conserve resources and minimize or eliminate adverse ESH effects and risks that may be associated with our research and operations. We will manage our programs in a manner that protects the ecosystem and employee/public health.
**Stakeholders:** We will work with our stakeholders to help them address their ESSH needs. We will maintain a positive, proactive, and constructive relationship with our neighbors in the community, regulators, DOE, and our other stakeholders. We will openly communicate with stakeholders on our progress and performance.
**Community and Government: **We will participate in community and government ESSH initiatives. We will define, prioritize, and aggressively prevent, correct, and/or clean up existing environmental, security, and occupational safety and health problems.