Introduction/Administrative News
The TRADE Industrial Hygiene/Occupational Safety Special Interest Group (IH/OS SIG) Steering Committee met on June 6, 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:
Michael Chochoms, Los Alamos National Laboratory (LANL) (represented Phil Grogin)
Deana Colley, Pacific Northwest National Laboratory
Tom Cornell, Fluor Hanford Inc.
Ralph Hinterman, ANL-E
Dr. Daniel Marsick, DOE, EH-52, Office Of Worker Protection Policy and Programs
Deborah McFalls, Oak Ridge Institute for Science and Education (ORISE)
John Peters, Brookhaven National Laboratory (BNL)
David Weitzman, DOE, EH-52, Office Of Worker Protection Policy and Programs
The following Steering Committee members notified the IH/OS SIG Chair/Coordinator that they could not participate in the meeting:
Phil Grogin, LANL
Michael Hurshman, S.M. Stoller
Bob Kapolka, ORISE
Rob Nicholas, LANL
10 CFR 851 Rule Implementation Workshop
The 10 CFR 851 rule codifies the Department's worker protection program requirements established in DOE Order 440.1A, Worker Protection Management for DOE Federal and Contractor Employees. Related to this new rule, the Office of Environment, Safety and Health (EH) is holding 851 Implementation Workshops across the DOE complex. The first workshop was held at ANL-E in May with plans to hold more workshops in early fall. The May workshop provided an opportunity for participants to ask questions, voice concerns, and to let DOE know what additional issues need to be addressed. DOE EH reported the availability of a “Frequently Asked Questions” section on their Web site that includes responses to questions received by Headquarters (HQ) related to the rule (http://www.eh.doe.gov/health/rule851/851final.html). It also includes unanswered questions that responses have not been formulated yet for, to help decrease duplication of questions being submitted to HQ. It was reported that 851 prototype compliance inspections will occur at the Pantex Plant, Oak Ridge National Laboratory (ORNL), and the Hanford site. Dan Marsick will be a member of the DOE Team for the ORNL inspection visit. Once these site visits are completed, it is anticipated more responses will be forthcoming from HQ on the unanswered questions.
DOE and DOE Contractors Partnering Workshop
The DOE and DOE Contractor Partnering Workshop was held in conjunction with the May 2006 American Industrial Hygiene Conference and Expo. Dan Marsick reported several people attended the meeting. Bill McArthur, EH-52, led the meeting as the HQ representative.
Rule 10 CFR 851was published February 9, 2006 which must be fully implemented by the DOE contractors no later than February 26, 2007. The methods for implementing the Health and Safety requirements of 10 CFR 851 Subpart C must be documented in a written Worker Safety and Health Program and approved by the DOE head of the field element. The May DOE Workshop focused on assisting DOE and DOE contractors in understanding what should be in their written Safety and Health Program and included an open discussion of the DRAFT 10 CFR 851 Implementation Guide. The Implementation Guide will cover all aspects of the new worker safety and health rule. An open discussion allowed the Office of Worker Protection Policy and Programs to obtain input in the form of best practices and lessons learned from field safety and health professionals in order to assure that the guide provides appropriate guidance.
10 CFR 851 Guidance Document
As noted previously, DOE has developed a Draft Implementation Guide to assist DOE and DOE Contractors in the implementation of 10 CFR 851. David Weitzman reported there was a new revised working draft of the guidance document available on the DOE EH Web site (http://www.eh.doe.gov/health/rule851/851final.html) for review and comment. This new draft is redlined to identify what revisions were made from comments received from the first version. It is anticipated that the document will go to RevCom for review in mid-June. It is anticipated the draft will be finalized and published around mid-September. In the new version, an additional example was included of a format for a written Worker Safety and Health Program that all contractors will be submitting to their DOE Head of field element for approval. One example had already been included in the first draft with an Integrated Safety Management Program (ISM) description that was a crosswalk of what elements may already be in a contractor’s ISM program that could be included in their written Safety and Health Program.
General Discussion about 10 CFR 851 Rule
As noted previously, there will be an 851 prototype compliance inspection visit at ORNL which is scheduled for the last week in June. Dan Marsick noted the inspection will mainly focus on laboratory and maintenance areas. The DOE Team for the ORNL visit will include:
Les Bermudez (HQ)
Dennis Kubicki (HQ)
Dan Marsick (HQ)
Cathy Stachowiak (Oak Ridge Operations Office)
Phil Wilhelm (HQ)
Other safety and health professionals as appropriate
No formal report will be generated of the inspection findings but the findings will be presented to ORNL on the last day of the visit. ORNL is considering holding a teleconference on June 30 to discuss the inspection findings and other 851 relate issues for interested parties since they will not be able to accommodate requests from other sites to send representatives to observe the on-site inspection process.
Dan recommended reviewing the American National Standards Institute (ANSI) Occupational Health and Safety Management Systems Standard (ANSI-AIHA Z210 2005) that includes a check list for a health and safety program. This check list could be useful as a resource for health and safety program audit and review processes. The standard includes good reference materials in the appendices.
Dan Marsick noted one question repeatedly asked is about guest worker responsibilities for complying with their host site’s safety and health program plan. Ralph Hinterman noted guest worker/user compliance issues were a concern to ANL-E because of the many guest workers permitted on their site. When this concern was raised at the May DOE 10 CFR 851 Rule Implementation Workshop, Ralph was left with the understanding from the HQ’s response that if your guest worker was not in compliance, your site was in non-compliance of 851. David Weitzman noted that his understanding is that the site will not be considered in non-compliance if the user does not follow the site’s safety and health program plan if the host site has provided for the person:
Appropriate supervision
Proper training
Safe working conditions
According to David, the site would not be cited with a violation of the rule if there was an accident. It is clear from these different understandings, that this issue needs additional clarification from HQ.
It is being reported that sites do not see any major changes in training needs based on the release of the 851 rule. Some minor changes will need to be made to some training materials but no major changes are anticipated. Ralph Hinterman noted that a site’s Internal Assessment Team for Compliance of 851 will need to be trained to ensure the proper focus of assessments.
DOE EH Potential Reorganization
Being considered within DOE and with Congress is possible reorganization of the DOE Office of Environment, Safety and Health. It is not clear at this time how the office will be reorganized but it is anticipated that the Office of Price-Anderson Enforcement (EH-6) will move to a new program office. More details about the reorganization are expected to be announced within the next month.
National Response Team Meeting
The National Response Team is directed by the Department of Homeland Security. The Worker Safety and Health Group of the National Response Team meet once a year in Washington DC. Dan Marsick attended their 2006 meeting that was held at the DOE Forrestal Building. The meeting included presentations about:
Avian and Pandemic Flu
Electronic Health and Safety Plan
Hurricanes Katrina and Rita - Worker Safety and Health Lessons Learned
Mould Issues
Nanotechnology
Respiratory Program Update
Dan will provide electronic copies of presentations if they become available.
2nd Annual Laser Safety Officers' Workshop
The “2nd Annual Laser Safety Officers' Workshop”will be held at BNL, July 11-13. Dan Marsick will be attending this workshop. About 40 people have already registered for the workshop. Organizers of the workshop include:
Ken Barat (Lawrence Livermore National Laboratory, Workshop Director)
Chris Weilandics (BNL)
Jack Preses (BNL)
More details about the workshop are available on the Web (www.bnl.gov/lsow/).
Supplied Air Suit Policy Meeting Respirator specialists hold a workshop every two years and stay in contact through bi-monthly conference call meetings. Some of the specialists who care for the respirators also are responsible for supplied air suits. Supplied air suits are mainly used in decontamination activities but are also used at Oak Ridge for product activities. The supplied air suits have an air line hose leading into them which provides both breathing and cooling air for the enclosed occupant. At one time, DOE sponsored a testing laboratory for such equipment at LANL. The laboratory was closed in 2000 due to lack of funding. After the testing laboratory closed, DOE made sites aware that they would have to make their own arrangements for testing. The sites decided to not have additional tests completed but to instead use suits already certified.
There is now a need for new supplied air suits but there are no facilities to test them. A DOE technical standard was written in 2003 to help address this issue. Now it has come to point where the technical standard may have to be applied to the acceptance of supplied air suits that are not National Institute for Occupational Safety and Health (NIOSH) certified. A meeting is being held the week of June 19 at the Savannah River Site (SRS) to discuss the standard and how it can be applied to some of the newer supplied air suit configuration for DOE complex use. There is a new suit now available called a powered air purifying suit. It is a suit with an attached powered air purifying respirator. It allows a decontamination worker to work in a suit that does not have an attached air line hose. However, policy has not been developed for such a suit. The June meeting will focus on policy for supplied air suits with attached respirators. Dan was asked to consider testing the suits for use with nano size particles and biological particles. He was asked to also consider non-certificated NIOSH respirators for use.
IH/OS SIG Steering Committee 2006 Workshop
The Steering Committee had previously agreed to hold their IH/OS SIG Steering Committee 2006 Workshop in conjunction with the suggested LANL-hosted 851Rule Implementation Workshop. Workshop plans will go forward once the date has been selected for the LANL-hosted workshop.
Future Steering Committee Conference Call Meeting The next Steering Committee Conference Call meeting is scheduled for July 18, 2006, 1:15 – 2:45 EST, conference call number is: (301)903-6471.
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
