Safety Update

Integrated Safety Management

January 8, 2008


Andrew Ackerman
NSLS ESH/Q Manager
ackerman@bnl.gov

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As you might have heard, the DOE Integrated Safety Management (ISM) audit held in August went very well. We were graded on four of the five core functions: define the scope of work, analyze the hazards, develop controls, and perform work within those controls. We received a "green" grade on the first three and a yellow for the fourth. In the ISM audit world, green is the best grade available and indicates "effective performance." Yellow denotes "need for improvement" and red is used for "unsatisfactory performance." There were no red marks on our report and no red marks for the rest of the BNL audit. We are all pleased with this result, as Brookhaven is the only laboratory in recent years to emerge from one of these audits with no unsatisfactory grades.

Most of the Laboratory participated in the audit and the NSLS received the best grades on site. Thanks to all who helped with this effort. This audit was important for the Laboratory and we are glad that the NSLS programs were well recognized. So what does this mean? We have been told that our work planning and risk analysis are well organized and effective, but that our implementation of defined controls needs improvement. We have also been told that BNL’s programs for collection and use of feedback needs improvement. The feedback element is the last of the ISM core functions and, although the NSLS program was not individually evaluated, the overall Laboratory’s use of worker feedback was included in the audit and found to be in need of improvement.

Plans for response to the audit are underway. We received the final report only recently so details will be available soon, but it is clear that the NSLS must focus on consistent use of personal protective equipment (PPE) and improved management of the set-up laboratories. The auditors' observations included comments on those issues and we acknowledge the need for improvement there. Plans for improvement of oversight and management of activities in the laboratories are progressing. Clean up of these spaces has begun; steward assignment is under review and definition of the role and responsibilities for the stewards has been developed and will be implemented.

Assuring consistent use of PPE starts with a clear definition of requirements. That has begun with the discussion of equipment needed for work with liquid cryogens. There has been considerable debate over this issue as various members of the BNL safety community consider both the risks involved and the regulatory requirements imposed by new DOE regulations defined in 10 CFR part 851. A final decision is expected soon and with that definition, the NSLS can begin consistent implementation of the requirements. The next PPE topic for discussion will be requirements for wet chemistry operations – a pertinent topic as we work to improve use of the set-up laboratories.

The Integrated Safety Management five core functions