Safety Update

10 CFR Part 851; Worker Safety and Health

May 1, 2007

10 CFR Part 851, often called just “851,” is a new rule published in the Code of Federal Regulations that brings various worker health and safety codes and consensus standards into federal law applicable to Department of Energy sites. The incorporated requirements include the Occupational Safety and Health Administration (OSHA) rules, the National Fire Protection Association (NFPA) codes for electrical safety and fire prevention, American National Standards Institute (ANSI) laser safety standards, the American Society of Mechanical Engineers (ASME) codes for pressure vessels, and too many others to list here. Most of these requirements have long been incorporated into BNL practice and policy, but 851 brings renewed scrutiny on these issues and provides a new framework for handling interpretation, variances, and, of course, enforcement.

Considerable effort has gone into reviewing 851 and determining the “gaps” between our existing practices and what is required in the new law. The 851 rules are numerous and we find a need for improvement in training, chemical exposure monitoring, ventilation system maintenance, noise exposure monitoring, and electrical safety. Review of the department’s pressure safety practices is ongoing and the result uncertain as the pressure requirements have been extended to vacuum systems and more time is needed to review the codes.

Users and beamline staff can expect some changes. At the beamlines and in the setup laboratories, we will seek to improve the exhaust hood and ventilation line maintenance, and assure that these systems are operating as expected. Although we expect no significant chemical exposures from experimentation, we will collect some exposure monitoring data on select experiments that involve volatile solvent use. Scrutiny on training for experiments that involve lasers, radioactive materials, and hazardous waste generation will improve, and our mechanisms to assure that contractors and vendors receive the required training and that their projects are subject to work planning will be enhanced.

There will likely be more to come, but this article is just an introduction and we must wait until the Laboratory review and assessment progresses further. The first deadline was February 26, 2007, at which time the Laboratory was expected to submit a comprehensive plan for managing the new law. That plan was submitted on time and incorporated input from all the departments including the NSLS and was accepted by the local DOE office. Implementation will progress throughout the year.