Introduction/Administrative News
The TRADE Industrial Hygiene/Occupational Safety Special Interest Group (IH/OS SIG) Steering Committee met on August 22, 2006 through a conference call meeting. IH/OS SIG Steering Committee Chair Ralph Hinterman, Argonne National Laboratory-East (ANL-E), facilitated the meeting in which the following Steering Committee members/guests participated:
Deana Colley, Pacific Northwest National Laboratory
Tom Cornell, Fluor Hanford Inc.
Andria Dutcher, Battelle, Grand Junction
Ralph Hinterman, ANL-E
Michael Hurshman, S.M. Stoller
Debbie Jenkins, Oak Ridge National Laboratory (ORNL)
Bob Kapolka, ORISE
Dr. Daniel Marsick, DOE, EH-52, Office Of Worker Protection Policy and Programs
Deborah McFalls, Oak Ridge Institute for Science and Education (ORISE)
Bob Selvey, Brookhaven National Laboratory (BNL) (representing John Peters)
The following Steering Committee members notified the IH/OS SIG Chair/Coordinator that they could not participate in the meeting:
Harvey Grasso, DOE National Nuclear Security Administration, Livermore Site Office
Rob Nicholas, Los Alamos National Laboratory (LANL)
John Peters, BNL
Request for Information to Document Site Hazard Assessments
Committee Member Michael Hurshman is looking for a good electronic tool for documenting site hazard assessments that could be shared with him. He needs it in electronic format that includes types of potential hazards, potential for exposure, severity, etc. in an easy-to-use format. Michael asked any information they may have be sent to him at: Michael.Hurshman@gjo.doe.gov.
10 CFR 851 NTS Reporting Thresholds System
Deborah Jenkins, ORNL, provided information about the 10 CFR 851 NTS Reporting Thresholds System to the Steering Committee. As of August 16, there had been 20 reports made to the NTS Reporting System that included information on:
Fractures
Potential Exposures
Uncontrolled energy sources
The reports have been coming from DOE facilities such as:
ANL-E
BNL
Lawrence Berkley National Laboratory
LANL
Pantex Plant
Sandia National Laboratories
Savannah River Site
Waste Isolation Pilot Plant/Project
EH provided the contractors a list of reporting requirements to use during the trial period for the NTS Reporting System. The requirement to report to the system becomes official when 10 CFR 851 goes into effect in February 2007.
In related information, the Office of Price-Anderson Enforcement Program posted their draft enforcement program plan in August on their Web site for Price-Anderson Coordinators to review and comment on (http://www.eh.doe.gov/enforce/index.html).
Prototype Compliance Inspection Visit at ORNL
DOE Official Dan Marsick reported in a previous meeting that the DOE 851 Prototype Compliance Inspection visit at ORNL occurred to explore issues of building codes, legacy wastes within the labs, adequate emergency response, NTS reportable items, and pressure safety. No formal trip report or citations were issued. The DOE team hoped to clarify issues with NTS thresholds, reporting and codes of record.
ORNL PAAA Coordinator Debbie Jenkins provided additional details about the visit during this conference call meeting. Five DOE Officials from Headquarters came to ORNL for the Prototype Compliance Visit during a three day period. They focused on:
Fire Department activities
Compliance Inspections of different laboratory areas
Housekeeping
Hazard monitoring for some areas (types/results reviewed)
In response to a question about when to do hazard monitoring, Debbie recommended contacting Randy Ogle (ORNL) for information
Overall general safety and health issues within the laboratories
Recent occurrence reports to determine if those reports should have been reported into the NTS Reporting System
Mock investigation
Upon completing the inspection, DOE Officials briefed ORNL on their findings and provided a related written summary. As noted in an earlier meeting, there was no formal written report issued.
Debbie noted the benefits of the visit included:
Learning about what DOE considers ORNL is doing well
Having a better understanding about areas ORNL should improve
Obtaining more information about the NTS Reporting Thresholds System
Debbie noted that if this had been a real inspection:
Only a short notice of the visit would have occur
Visit would likely take longer to complete and be more wide open
Would look more at areas where the inspection would lead them
ORNL is making some changes as the result of the DOE visit:
Changing the approach on the worker safety and health written program being drafted to now include more than what was previously planned (include a cross walk of the 851 requirements to ORNL documents and how they meet these requirements)
Changing the format to the program
Changing how they determine what goes into the NTS Reporting System
Changing the composition of the ORNL board to include more appropriate professionals that determine what goes into the NTS Reporting System
ISM will be referenced and referred to in the 851 required worker safety and health written program but will be kept separate as a program.
Questions regarding the ORNL inspection visit can be directed to Debbie Jenkins at jenkinsdl@ornl.gov.
EM 10 CFR 851 Implementation Workshop
Andria Dutcher, Battelle, Grand Junction, was among about 40 people that attended the EM 10 CFR 851 Implementation Workshop held in Denver, Colorado. Several presentations were made by DOE EM and EH Officials. It was note by a DOE Official that the type of 10 CFR 851 related questions received from their contractors were almost exclusive about:
Codes of records
How to handle variances
Definitions of terms used in the rule
DOE Official David Weitzman gave an overview of the information posted on the DOE 10 CFR 851 “Frequently Asked Question’s” Web site at: http://www.eh.doe.gov/health/rule851/851final.html. He also reported there were two informal issue papers that should be on the Web site in the near future that will focus on codes of records and other related matters.
Other information shared at the meeting also included:
Implementation Guide should be finalized in mid-November
Intent of the rule is to use existing health and safety plans to demonstrate compliance of the rule
Subcontractors are required to have an approved worker safety and health plan which could be difficult to achieve. DOE suggested imposing the site contractor’s plan onto the subcontractor. This suggestion may create some issues for the contractors with their larger subcontractors that already have advanced safety and health plans in-place.
Reporting to the NTS System is voluntary at this time but has incentives to report to the system
Program and plans are different. A program is the worker safety and health program and the plans are everything that implements the program.
Office of Enforcement is expecting the contractors to have an issue management system in-place for internal tracking. The system should screen for the priority, list the corrective action, and decide what type of causable action should be done. They are going to be looking for trending of smaller issues, repetitive issues, and programmatic issues they want the contractors to self identify.
DOE is addressing what the compliance schedule would be for new contracts that will be put in-place after February 2007
DRAFT 10 CFR 851 Guidance Document
Dan Marsick reported that the Guidance document should be completed within the next few weeks. Several comments from the Energy Facility Contractors Group (EFCOG) were received that David Weitzman is incorporating into the guide. David is also considering comments from Harvey Grasso about baseline evaluations. Harvey’s comments/concerns were:
A baseline for classical IH hazards (chemical exposure, noise exposure, non-ionizing radiation) purposes is pretty well defined in the IH Practices Standard. It should characterize work, potential hazards and potential exposures that have known, suspected or even not currently obvious future health consequences. For other personnel protection specialties the temporal relationships as well as the actual health outcomes from exposures or events are generally better understood. Because of this, a baseline evaluation for non-IH hazards should be different. For instance there is no reason to maintain a long term record or detailed measurement of a tripping, electrical, explosive, unguarded machinery, confined space (unless it includes chemical exposures) or vehicle hazard exposure. The risk of health effects end after the exposure ends. But for noise, some biological agents, chemicals and radiations the risks of effects and the potential for the discovery of new effects can last for years. This is the reason for OSHA medical and IH record keeping requirements. It can also be beneficial in the worker compensation arena.
It's clear that there is a need for two different levels of detail for facility baseline evaluations:
An IH baseline and perhaps radiation baseline because exposures have long term and yet to be discovered consequences. The IH baseline should characterize work, controls, potential hazards and potential exposures and be maintained as a running record of these potential exposures for long-term analysis.
Personnel safety issues that lack long term consequences if an acute injury does not occur. The baseline for acute safety hazards probably should describe the hazard and define the risks for purposes determining the cost correction and prioritizing the correction of hazards with immediate potential effects. There is little purpose in maintaining record of these hazards if there are no immediate effects.
Harvey agreed to draft text on baseline evaluations that is suitable for inclusion into the 851 Implementation Guide.
DOE EH Reorganization
Dan Marsick reported that the EH reorganization will be effective October 1 under the new program name of Office of Health, Safety and Security. Glenn Podonsky will become the new Chief Officer of the organization. Dan will continue to report to Bill McArthur who will report to Pat Worthington. It is not clear how the new reorganization would impact the enforcement of the 851 rule. The Office of Enforcement will also become part of the Office of Health, Safety and Security.
EH 10 CFR 851 Implementation Workshops
The Steering Committee had anticipated the Office of Environment, Safety and Health (organized into Office of Health, Safety and Security effective October 1) would hold workshops across the DOE Complex. The implementation workshops would allow DOE federal and contractor staff to learn about the new Rule, ask questions, and provide assistance in the implementation of 10 CFR 851. It was anticipated that the EH 851 Workshops would be scheduled after October 1 for the following locations:
Albuquerque
Richland
Oak Ridge
Since this conference call meeting, information has been received that EH may not hold any future workshops. DOE has held some conference calls meetings with contractors these past few months to address questions about compliance with the 851 rule. PAAA information related to the 851 rule will be shared at the upcoming EFCOG Price-Anderson Working Group Fall 2006 Meeting sponsored by Sandia National Laboratories. The meeting will be held at Kirtland Air Force Base, in Albuquerque, New Mexico, October 31 - November 2, 2006. Additional information about the meeting can be found at: http://www.efcog.org/index.html.
Future Steering Committee Conference Call Meeting
The next Steering Committee Conference Call meeting is scheduled for October 3, 2006, 1:15 – 2:45 EST, conference call number is: (202)287-1321.
For additional information, please contact: Deborah McFalls, IH/OS SIG Coordinator
Oak Ridge Institute for Science and Education
P. O. Box 117, MS 10
Oak Ridge, TN 37831-0117
