Introduction/Administrative News
The TRADE Industrial Hygiene/Occupational Safety Special Interest Group (IH/OS SIG) Steering Committee met on August 7, 2007 through a conference call meeting. IH/OS SIG Steering Committee Chair Ralph Hinterman, Argonne National Laboratory, facilitated the meeting in which the following Steering Committee members/guest participated:
Tom Cornell, Fluor Hanford Inc.
Bill Frede, Honeywell FM&T
Harvey Grasso, DOE National Nuclear Security Administration, Livermore Site Office
Ralph Hinterman, Argonne National Laboratory
Lowell Howard, Pacific Northwest National Laboratory
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
Rob Nicholas, Los Alamos National Laboratory (LANL)
Pat Tran, HS-12, Office of Worker Safety and Health Assistance
The following Steering Committee members notified the IH/OS SIG Chair/Coordinator that they could not participate in the meeting:
Michael Hurshman, S.M. Stoller,
John Peters, Brookhaven National Laboratory, and
David Weitzman, HS-11, Office of Worker Safety and Health Policy.
Welcome New SIG Sponsor - Office of Worker Safety and Health Policy
The IH/OS SIG Coordinator announced that the SIG has a new sponsor, the DOE Office of Worker Safety and Health Policy (HS-11) which is a part of the Office of Health, Safety and Security (HSS). HSS is Department’s central organization responsible for health, safety, environment, and security; providing corporate-level leadership and strategic vision to coordinate and integrate these vital programs. HSS is responsible for policy development and technical assistance; safety analysis; corporate safety and security programs; education and training; complex-wide independent oversight; and enforcement. David Weitzman and Dan Marsick, HS-11, are the new official DOE Advisories to the SIG. The sponsorship of HS-11 enables the SIG to continue its effort to function as a network to support safety and health efforts particularly in the area of preparing and disseminating training materials on the subject of safety and health for nanotechnology activities within DOE. This effort is needed for the rapidly expanding nanotechnology activities within the Department and will be consistent with best practices available from government agencies and the private sector and that anticipate, as much as possible, the requirements that will be established by the Department in title 10 Code of Federal Regulation part 851, Appendix A, section 11.
OSHA Revises the Electrical Standard
Pat Tran, DOE HS-12, shared information about the Subpart S of the 29 CFR 1910 Electrical Standard. This section was updated February 14th 2007. This is part S 1910.302 through 1910.308. According to OSHA, electrical hazards in the workplace still pose a risk of injury or death to employees. Revising the standard should prevent 1 to 2 additional deaths per year. Electrical violations are one of the top 10 violations for the last 5 years, according to the OSHA database. The 10 CFR 851 rule requires contractors to comply with the 2004 edition of the National Fire Protection Association (NFPA) 70E as well as the 2005 edition of the NFPA.
The OSAH rule focused on safety and design and installation of electrical equipment in the workplace. This is the first update since 1981. OSHA 2007 effort was provide an update for the general industry section which is the 1910 of the electrical standard. OSHA ensured that the update included the 70E as well as the National Electric Code (NEC). The scope of this revision of the subpart S does not apply to electric utility communication, transmission, ships, watercraft, aircraft, automobile, however it does apply to mobile homes and recreational vehicles. It does not apply to underground mines. It does create a grandfather clause for existing installations made after March 15th 1972. One new definition is for the word “overhaul.” OSHA is using this term in the standard in place of major replacement, modification, repair, or reapplication, which is used in the existing standard in the past to delineate when an electrical installation must meet the new requirements in the standard. This work applies to a new building or facility, a new wing, or an entire floor being renovated. A minor modification would not apply to this term or but a major modification would be defined as an overhaul. The revised standard also clarifies that the provision for lockout/tagout (a standard for energy isolation) to be lockable in addition to any requirement in the Subpart S.
The OSHA Web site provides the summary of changes for the Subpart S. There is a table that provides a list of the new requirements compared to the old one in a table distribution of 1910.303 through 1910.308. The table shows what is changing without going into a lot of details. This revised standard is basically the Ground-Fault Circuit-Interrupters (GFCI) protection requirement. GFCI are mentioned that ties into 1926. In the 28 years of history, OSHA estimates that the GFCI has saved approximately 1,000 lives. OSHA has determined that GFCI are more effective means to protect employees. OSHA requires the use of GFCI when available. However, the final rule permits assured equipment grounding conductor program as an alternative to GFCI whenever approved GFCI are not available for the voltage and current. It is important to find GFCI before going into an assured program for protection. The final rule added to the construction site activity on the list permits for temporary wiring over 600 volts. The final rule also permits using ground structural metal frame of a building as equipment grounding conductor for existing installations. The final rule required equipment grounding conducting to be effective as well as permanent and continuous. OSHA added a new definition from the NEC language as effective grounding in the 1910.399. This Subpart S does not necessarily impact DOE much but does require some changes to the carnivals, circuses, fairs, and similar events. Some of the older definitions are no longer used. Electric sign has been removed. Qualified person was redefined simplify along the lines of the NEC. OSHA revised the appendix to reflect the most recent additions of the various national consensus standards. It also eliminates Appendix B and C because they were blank.
3rd Annual DOE Laser Safety Officer Advanced Training Workshop
The Laser Safety Officer (LSO) Advanced Training Workshop was held July 17-19 at Argonne National Laboratory. Bruce Murdoch provided information about the workshop. Bruce reported that the annual meeting is held at a DOE facility each year. This was their 3rd workshop. The primary purpose of this annual workshop was to bring together LSOs from the DOE research laboratory complex to share information and methodologies that will help optimize their laser safety programs. It was interesting to note that less than half of the people that attended this workshop were from the DOE complex. The workshop had eight vendors participating in the event displaying their training and laser safety equipment. They had a total of 118 participants, which is larger than ever before, and more than what they had planned for the event. The workshop included 2 ½ days of presentations with 25 speakers. They addressed frontiers of research, regulatory issues, and standards that have just come out or are in development.
There is a new standard that is in the preliminary stage which would apply to institutions doing research and development (R&D) work rather than industrial type work. Some participants thought some of the requirements in the standard are too strict for a R&D environment. They are trying to see if they can be a little bit more adaptable which can be put in writing. There are compliance issues with dealing with the new standard and still complying with 10 CFR 851 which specifically holds DOE to the old 2000 136.1 standard. Laser classification names are changing. DOE has to recognize the new standard, but if the DOE complex is going to comply with it, it could put them at odds with what is stated explicitly in 10 CFR 851. There will have to be some discussions about how to incorporate the new standard. There was a full day of discussions about research activities, development of high power laser laboratories, and the applications of nanoscience and x-ray interactions. They also discussed regulatory issues and specific safety control measures. The final day’s presentations focused on a variety of presentations from eyewear specialists. The interaction between the DOE LSOs and non-DOE LSO’s was productive. The 2008 workshop is planned for Albuquerque with LANL and Sandia National Laboratories possibly hosting it. They may put a cap on the attendance for the 2008 workshop so DOE LSOs are not grossly outnumbered by non-DOE LSOs participants.
Bruce noted there was a lot of discussion about how the ANSI standard would impact 851. Some labs want to drop their medical surveillance entirely but Argonne National Laboratory has no immediate plans to drop that initiative. There is a strong belief with the medical and legal departments that they do not want to reduce the medical surveillance no matter what the standard notes. There are other DOE facilities that are negotiating with their local DOE offices to adopt the new standard and to put in writing that they have to comply with the new standard.
There were discussions about signage including the eyeglasses posting requirement. The issue is that in some rooms there are more than one laser present. Some participants thought that the eyewear requirement should be listed at the entrance to the laboratory. Others have issues with this requirement because in some circumstances there are many lasers in one room and different eyewear requirements for different circumstances. The user would need to know which eyewear to use and be familiar with the procedures in the laboratory. The immediate plan is to post on the sign something like, “See SOP for eyewear requirements” or “Contact supervisor for eyewear requirements.”
Nanotechnology Safety and Health News
Dan Marsick shared news related to nanotechnology safety and health initiatives:
The Food and Drug Administration (FDA) Advisory Committee has encouraged FDA to draft some guidance for regulating nanotechnology related materials. The guidance probably would be issued within the next few months.
The Environmental Protection Agency (EPA) met in August to discuss a voluntary national nanoscale materials stewardship program. Several people from trade associations and non-profit groups attended the meeting. The non-profit groups are asking for more regulations. The International Council on Nanotechnology has called for a database to be established by EPA that would include known effects of nanomaterials.
An EPA meeting is planned for September 25 -26 that will focus on pollution prevention through nanotechnology.
DOE is working with a federal interagency group on nanotechnology that is trying to get their prioritization list finalized for research in nanotechnology safety and health. This prioritization list should be completed in a month or so.
November 5-7, 2007, the 4th International Congress Nanobiotechnology will be held in San Francisco, California. Information about this meeting can be viewed at: nanotechcongress.com/.
November 15-17, 2007, the Nanotechnology and Occupational Health and Safety Conference will be held in Santa Barbara, California. Information about this meeting can be viewed at: cns.ucsb.edu/nanoconference/.
Deborah McFalls reported the following SIG nanotechnology news:
The Employee Communication Package - Nanotechnology training (ORC Worldwide) and the Nanotechnology Safety training (Washington State Department of Labor and Industries) have been posted on the DOE Technology Supported Learning (TSL) Index. The TSL Index resources can be viewed at: orau.gov/eh/training/tsl_Index/tsl_index.htm.
On February 27, 2007, the directors of the DOE’s five Nanoscale Science Research Centers chartered an Environment, Health, and Safety Working Group to develop a recommended strategy for establishing an ES&H program for nanotechnology research that protects workers, the environment, and the public. The working group, with input from health and safety experts in the Department, developed such guidance, Approach to Nanomaterial ES&H (June 15, rev. 2), for application to all of the Nanoscale Science Research Centers. The document focuses on:
- Conceptual Foundations,
- Routine R&D Laboratory Operations,
- Medical Surveillance,
- Transportation of Nanomaterials,
- Management of Nanomaterial-Bearing Waste Streams,
- Management of Nanomaterial Spills, and
- Example Industrial Hygiene Sampling Protocol.
The approach embodies Integrated Safety Management, reinforces compliance with the DOE Policy 456.1, “Secretarial Policy Statement on Nanoscale Safety”, expects adherence to site-specific implementation plans for P 456.1, and conforms with the general principle in the National Research Council’s Prudent Practices for Handling Hazardous Chemicals in Laboratories, by treating nanomaterials as though they are a toxic and otherwise hazardous material until empirical evidence shows otherwise. The SIG notes their appreciation to the DOE Nanoscale Science Research Centers Environment, Health, and Safety Working Group for sharing this document through the IH/OS SIG Web site.
DOE Worker Safety and Health Standards Response Line
Dan Marsick provided details about the DOE Worker Safety and Health Standards Response Line that can be accessed at 1-800-292-8061 or at: hss.energy.gov/HealthSafety/WSHP/il/. This response line is not a new initiative. It has been in existence since at least 1991 but many people do not know of its existence. The original intent was to answer technical questions, not necessarily policy questions, on particular OSHA standards or DOE orders. It used to be fairly busy with about 3 requests a day but the requests are now down to about 3 a month. The line does serve a useful purpose in that it channels requests for interpretations of DOE orders or OSHA standards to subject matter experts that help formulate a response to the technical inquiries. The response time can vary from a week to a month.
Most of the requests are fairly technical and involve some unique interpretations of the standard compared with the earlier requests. The field offices have some good personnel that are able to use their judgment in most cases to solve most of their safety and health questions. Sometimes they will have a difficult request such as a recently one about confined space on forced air ventilation. For a question like the one mentioned they will bring in subject matter experts at Headquarters and any relevant field people to find a reasonable interpretation. A lot of the 851 technical questions are being directed to the response line. For the most part, DOE encourages people not to see the interpretations for requests on the response line as a legal tool but to use it as sophisticated technical advice. They are cautioned that the interpretations are only professional judgments.
DOE has posted almost 2,000 interpretations on their Web site.
DOE 10 CFR 851News
Deborah McFalls provided news about 851 for David Weitzman who was unable to attend due to a conflict with another meeting. Deborah reported the Contractor Worker Safety and Health Poster is available both in English and Spanish on the DOE Web site at: hss.energy.gov/HealthSafety/WSHP/rule851/851final.html.
It is anticipated that later in August there will be a draft revision of the Occupational Medicine section of G440.1-8 “Implementation Guide for use with 10 CFR 851 Worker Safety and Health Program.” The draft revision should be posted on the DOE Web site.
Deborah also reported that there was another planned 851 televideo conference scheduled for August the 29th, 2:00 - 4:00 pm EST. They will focus on lessons learned and on the challenges of implementing the occupational medical part of 851.
Future Steering Committee Conference Call Meeting
The next Steering Committee meeting is scheduled for September 6, 2007, 1:15 – 2:45 pm EST, conference call number 301/903-6256.
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
