Introduction/Administrative News
The TRADE Industrial Hygiene/Occupational Safety Special Interest Group (IH/OS SIG) Steering Committee met on May 2, 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 participated:
Deana Colley, Pacific Northwest National Laboratory
Tom Cornell, Fluor Hanford Inc.
Phil Grogin, Los Alamos National Laboratory (LANL)
Ralph Hinterman, ANL-E
Michael Hurshman, S.M. Stoller
Bob Kapolka, Oak Ridge Institute for Science and Education (ORISE)
Deborah McFalls, ORISE
Rob Nicholas, LANL
John Peters, Brookhaven National Laboratory
10 CFR 851 Rule
The rule, 10 CFR 851, 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 is developing a schedule for 851 Implementation Workshops to be held across the DOE complex. The first site to host a workshop is ANL-E which will occur May 11-12. Other workshop locations being considered are:
Oak Ridge: Hosted by ORISE
Albuquerque/Santa Fe: Hosted by LANL
During this meeting, it was reported that workshops beyond the ANL-E event may not occur until later summer or early fall. It was noted that DOE would prefer to hold these workshops after they have resolved several issues of concern with the rule and developed an agenda for the workshops. This decision is also based on concerns the Office of Enforcement has about having sufficient information to present regarding their approach to the new rule. It was reported that Office of Enforcement is expected to have more information available to share during these workshops after they complete two upcoming onsite 851-related reviews, with the 1st one scheduled for the last week in June at the Oak Ridge National Laboratory. Another one is scheduled for the Pantex Plant. Contractors have expressed concerns about the workshops being held so late in the fiscal year since they are drafting their health and safety program plan now for submission to DOE for approval, as required by 851.
Bob Kapolka attended the Energy Facility Contractors Group (EFCOG) Integrated Safety Management (ISM) Working Group Semi-Annual Meeting in Albuquerque, New Mexico in April where the new rule was also discussed. The following 851-related information was discussed at that meeting:
The Contractors’ 851 health and safety program plans would be approved by their local field office but variances to the plans would be approved by Headquarters (HQ). It is anticipated that very few variances would be granted.
Contractors had questions about what a written 851 health and safety program plan should look like. They are hoping the 851 guidance document will address their questions about the written program.
It was noted that practice-driven documents, such as an ISM description document, should not be in an enforcement document. It was agreed that 851 was strictly an enforcement program.
Under 851, there is a question about if DOE is going to approve the sites’ subcontractors’ health and safety plans. If their plans have to be approved by DOE, this could greatly impact getting the work done at facilities such as ANL-E that uses a lot of subcontractors.
It is not clear if grandfathering in buildings and equipments currently not in compliance will occur under the new rule. If this is not allowed, the question then arises about who will pay for the improvements to bring the site into compliances. Most sites have old buildings and equipment that could be questioned under the 851 rule.
On the question of the need for new training, one Steering Committee member noted that at their site, no new training was expected but that the training already in-place would be strengthened or improved. An example of a training program that might be improved would be lockout/tagout training.
The Office of Environment, Safety and Health has developed a Draft Implementation Guide for 10 CFR 851. This guide incorporates elements of the existing DOE Order 440.1A Guides as well as additional information. This guide is intended to assist DOE and DOE Contractor personnel in the implementation of 10 CFR 851. DOE anticipate posting the draft guide officially in the DOE Directives system by the end of May for formal comments. Persons who would like to offer suggestions should contact Bill McArthur, EH-52, at Bill.McArthur@hq.doe.gov.
It was agreed that the SIG will share information as available to aid DOE contractors in implementation of 851 for their site.
EFCOG ISM Working Group Semi-Annual Meeting
The EFCOG ISM Working Group Semi-Annual Meeting was held at the DOE/NNSA Energy Training Complex, Albuquerque, New Mexico on April 24 - 28, 2006. Steering Committee Advisory Chair Bob Kapolka attend the meeting. As noted previously, the 851 rule was discussed with the contractors having many questions and concerns.
It was noted at the meeting, that there was not enough positive lessons learned being shared. A concept discussed was “Just in Time Lessons Learned.” Lessons learned would be reviewed right before startup of work so it is fresh on the worker’s mind. It was suggested that contractors should be going outside DOE also for lessons learned information.
Bob was very impressed with the presentation of the keynote speaker from General Electric (GE). According to the speaker, GE managers’ careers were won or lost based on safety performance. GE goes beyond lagging indictors to also use leading indictors for safety performance evaluations. The key to the success of their safety program was manager and employee involvement. An example of management/employee involvement is their Volunteer Protection Program (VPP) as well as their international based safety programs. They currently have 103 OSHA VPP recognized sites. GE initiated its own Global Star program for those countries where VPP programs do not exist. Presentation slides (Creating a Culture of Safety Excellence) about their safety program can be viewed at: http://www.eh.doe.gov/ism/.
There were discussions about what was an acceptable level of risk. Why do we take risk at work? Participants discussed the core function of integrated safety management. Some thought that within the DOE complex, there is still a disconnection between work planning and work controls. We are not identifying all the hazards well enough during the planning stage.
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 851Implementation 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 June 6, 2006, 1:15 – 2:45 EST, conference call number is: (301)903-7074.
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
