Introduction/Administrative News
The TRADE Industrial Hygiene/Occupational Safety Special Interest Group (IH/OS SIG) Steering Committee met on April 24, 2007 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/guest participated:
Michael Chochoms, Los Alamos National Laboratory (representing Phil Grogin),
Deana Colley, Pacific Northwest National Laboratory,
Bill Frede, Honeywell FM&T,
Harvey Grasso, DOE National Nuclear Security Administration, Livermore Site Office
Ralph Hinterman, ANL-E,
Bob Kapolka, Oak Ridge Institute for Science and Education (ORISE),
Daniel Marsick, DOE, HS-11, Office of Worker Safety and Health Policy,
Deborah McFalls, ORISE,
John Peters, Brookhaven National Laboratory, and
David Weitzman, HS-11, Office of Worker Safety and Health Policy.
The following Steering Committee members notified the IH/OS SIG Chair/Coordinator that they could not participate in the meeting:
Tom Cornell, Fluor Hanford Inc. and
Michael Hurshman, S.M. Stoller.
Nanoparticle Update: Measuring, Evaluating, and Managing Exposures Seminar Overview (AIHA TeleWeb)
In March, Ralph Hinterman viewed the American Industrial Hygiene Association TeleWeb session on measuring, evaluating, and managing nanoparticles. Ralph stated we are slowly learning how to measure nanoparticles but still do not know enough about health effects from exposure to nanoparticles.
The Nanoparticle TeleWeb session focused on:
Practical measurement techniques for airborne nanoparticles in the workplace,
Relating nanoparticle exposures to respiratory dose or body burden,
Characterizing and controlling exposures to nanoparticles in the workplace, and
Regulatory and risk overview for managing nanomaterials along the product life cycle.
Participants acquired information about:
Different measurement methods used to identify and quantify concentrations of airborne nanoparticles,
Related particle deposition patterns in the respiratory tract to the estimation and body burden, and related various exposure metrics to exposure misclassification problems,
Specific techniques to distinguish engineered nanoparticles from incidental nanoparticles in real-world sampling environments,
Various factors of nanoparticle number, diameter, and surface area that may influence deposition and toxicity in the human respiratory tract,
How to characterize and control nanoparticles in the workplace, and
Approaches for evaluating and managing risks when handling nanomaterials in the presence of uncertainty.
Information about obtaining a copy of the aforementioned TeleWeb session can be found at: http://www.aiha.org/Content/CE/DL/telewebs.htm. Office of Enforcement 2007 Enforcement Coordinator Training Briefingand theEFCOG Price-Anderson Amendments Act (PAAA) Working Group Spring 2007 Meeting News
The EFCOG Price-Anderson Amendments Act Working Group Spring 2007 meeting was held at DOE/NNSA Nevada Support Facility, Las Vegas Nevada on April 17 -19, 2007. The Working Group Strategic Planning Committee also held a meeting on April 16, 2007. Slides of presentations made at the events have been posted at: http://www.efcog.org/wg/paaa/Events/SpringmMeeting07/PAAASpring07mtginfo.htm.
In response to a question about the role of an Enforcement Coordinator, related data were collected from the DOE Enforcement Process Overview document. According to the document, the roles and responsibilities of an Enforcement Coordinator are:
Being knowledgeable of the enforcement process and the requirements for information security and nuclear and occupational safety. In some organizations it may be appropriate to designate information security, nuclear safety, and worker safety leads to support the overall enforcement coordinator,
Maintaining a broad understanding of the activities and operations undertaken by their contractor/organization,
Serving as the focal point in the contractor’s organization for rule implementation and compliance, and championing excellence in the organization’s compliance assurance and continuous improvement efforts,
Through broad awareness of safety and information security issues and performance across the organization, identifying and reporting to management areas of weakness or systemic problems not otherwise recognized by the organization,
Ensuring that contractor managers are adequately trained in the regulatory screening and reporting program,
Monitoring contractor compliance assurance program effectiveness and progress in moving toward an assessment driven, continuous improvement-focused organization,
Managing or overseeing screening of problems, issues, findings, and conditions to identify noncompliance matters,
Ensuring timely screening of a broad set of issues from a variety of sources, such as events, performance assessment reports, nonconformance reports, radiological assessment reports, inspections, and audits, for potential regulatory noncompliance,
Being knowledgeable of reporting requirements and thresholds and having sensitivity for programmatic issues, negative trends, and repetitive issues,
Regularly performing, or ensuring regular performance of, assessments to evaluate implementation of the contractor’s processes for screening and NTS, ITAC, and internal reporting,
Ensuring proper and timely reporting of noncompliances into NTS, ITAC, and local tracking systems,
Ensuring validation of NTS and ITAC corrective actions prior to closure; verifying that corrective actions address the causes, are comprehensive, and have been completed; and marking NTS and ITAC reports as “complete” only when all actions have been validated,
Ensuring that comprehensive effectiveness reviews are conducted for NTS and ITAC issues when corrective actions have been completed,
Within the contractor organization, facilitating coordination and scheduling of responses to Office of Enforcement requests for information, onsite investigations, enforcement conferences, focused inspections, and investigations,
Actively participating in the dialogue between DOE and the contractor in any investigation, focused inspection, or compliance review to ensure that the facts and technical issues surrounding the noncompliance are understood, and that the actual or potential adverse impact on safety is properly considered, and
Regularly informing senior management of compliance issues, safety and security performance issues, enforcement actions elsewhere in the DOE complex, and the status of the regulatory screening and reporting program.
10 CFR 851 Rule Update
David Weitzman provided an update on news related to the 10 CFR 851 rule.
The occupational medical service provider section has the attention of key personnel at Headquarters. Discussions are underway about how to address implementation difficulties related to the medical provider section for small contractors and subcontractors. Some are suggesting a text change to the related section of the rule to address these implementation difficulties. DOE management has agreed a rule change will be necessary. At this time, contractors can request a variance to that section of the rule. After this conference call meeting, a May 14 memo from Glenn Podonsky, Office of Health, Safety and Security, was released that speaks to these medical provision concerns of the rule (http://www.hss.energy.gov/HealthSafety/WSHP/rule851/Final_851_PSO_Memo.pdf).
Another outstanding issue concerns the small service contractor that comes on the site to do mundane services such as picking up dumpster trash, shredding paper, etc. The rule was not intended to cover this type of work. Discussions are underway at Headquarters about on how to address this issue.
Hazard Analysis Tool
10 CFR 851.21 and 851.22 require DOE contractors to identify workplace hazards, assess the risk of associated worker injury and illness, and implement a hazard prevention and abatement process to address the hazards. For existing hazards identified in the workplace, contractors must prioritize and implement abatement actions according to the risk to workers [851.22(a) (2)(i)]. The relative level of risk must be assessed for each identified hazard to ensure that hazard abatement efforts and resources are focused first on addressing the most serious workplace hazards. Several DOE sites have developed tools (some of which are automated) for identifying hazards, analyzing the hazards, and assigning a value to the level of risk of the hazards. These tools are useful for comprehensively reviewing all possible hazards of an activity, setting priorities for abatement of hazards, and for determining an appropriate level of work control to apply to activities that present the hazard. These tools can be very efficient but users should be careful to truly analyze the identified hazards and not simply "check the boxes."
A hazard analysis tool in use at a DOE site has been modified and made available as an example for possible use by other DOE sites. The hazard analysis tool is available at: http://hss.energy.gov/HealthSafety/WSHP/rule851/hazard_tool.html. Other approaches to identifying hazards and assessing risks also may satisfy 10 CFR 851 requirements.
Nanotechnology News
Dan Marsick reported the Office of Science was developing a technical standard for working with nanoparticles, and his office, Office of Worker Safety and Health Policy, was developing the related notice. Dan reported about 80 percent of nanotechnology work being done within the DOE community is being done outside of the DOE Nanoscale Science Research Centers. Joint EFCOG/DOE Chemical Management 2007 Workshop News
The Chemical Safety Topical Committee held their ninth annual Joint Energy Facility Contractors Group/DOE Chemical Management Workshop in Washington, D.C. March 13-15, 2007. Over 230 people registered for the workshop. Around 80 attended in person and the remainder participated through videoconference format. Workshop topics included general chemical management, beryllium, supplied air suits, and nanotechnology as well as other items of interest. The Chemical Management workshop was approved by the American Board of Industrial Hygiene (ABIH) for 2.5 certification maintenance (CM) points (Approval # 07-378) http://www.hss.energy.gov/HealthSafety/WSHP/chem_safety/ws2007/abihletter.pdf. Presentation materials were posted at url: http://www.hss.energy.gov/HealthSafety/WSHP/chem_safety/ws2007/presentations.html. A request for a DVD of the meeting should be made directly to Daniel Marsick at E-mail address: Dan.Marsick@eh.doe.gov.
IH/OS SIG Steering Committee Annual Workshop
The IH/OS SIG Steering Committee annually workshop will be held in conjunction with the American Industrial Hygiene Conference and Expo (AIHce Expo 2007) on June 8, 2007, 8:30-11:45 EST at the Marriott Philadelphia Hotel. Committee members who cannot attend in person are encouraged to participate through teleconference format. The ABIH has approved 0.5 CM points for workshop participants (Approval # 07-1525). This is in addition to CM points that may be gained by attendance at the AIHce 2007 Expo.
Future Steering Committee Conference Call Meeting
The next Steering Committee meeting is scheduled for June 8, 2007, 8:30 – 11:45 EST.
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
