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FY07 Site OSH Internal Audit Closing final rev0

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Information about FY07 Site OSH Internal Audit Closing final rev0
Education

Published on January 8, 2008

Author: Marcell

Source: authorstream.com

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BROOKHAVEN NATIONAL LABORATORY :  BROOKHAVEN NATIONAL LABORATORY Institutional-Level Occupational Safety and Health OHSAS 18001 Internal Audit Closing Meeting February 9, 2007 Slide2:  All Directorates at BNL February 5-9th Life Sciences, Instrumentation, CAD, SMD, F&O, EENS, ERO, Physics, BES, and NSLS Limited Scope on Topics 4.2 ESSH Policy 4.3.1 Hazard and Risk Assessment 4.3.2 Legal and other Requirements 4.3.3 Objectives 4.4.1 Responsibilities and Resources 4.4.2 Training 4.6 Management Reviews Scope Slide3:  Evidence from interviews with employees that the key OSH elements of the NEW Policy are easier to remember. Some instances where people could not locate the ESSH policy on the web. Must enter “ESSH Policy”. “Safety Policy”, “ESH Policy”, “Environmental Policy” do not find the policy in BNL searches. SBMS does not have a direct link in Table of Contents (however it is on the left toolbar). OFI: Additional links to policy on the BNL Main Page. 4.2 ESSH Policy Slide4:  Posting of the new ESSH Policy on site was very good. Many organizations have made lists of where they posted the Policy. EENS and F&O are outstanding in document control of all their ESH posting at “ESH Bulletin Boards” maintained by their central ESH Group. Some instances of the older Policy still up as “personal” copies in offices, control rooms, etc. 4.2 ESSH Policy Other BNL Guidance/Requirement Issues:  Other BNL Guidance/Requirement Issues Observation: Implementation of subject area regarding ventilation less than adequate. HEPA filter testing not being performed of hoods where HEPA filter is in place. Hoods need to be locked out, or filters need to be removed, or annual testing to insure integrity of filter; or an exemption needs to be requested. People in general seem knowledgeable of BNL requirements regarding Personal Protective Equipment selection; OFI: Clarification is needed in guidance for HF gloves, conflict in dual recommendations currently exist. Slide6:  4.3.1 Hazard and Risk Assessment No instances of OSH Risk Assessment non-conformances. Some variability in opinion on the purpose of JRA (i.e. planning vs. worker communication/feedback). Several organization expressed interest in participation in a site level Foreign Travel JRA based on CIO. Noteworthy: NSLS has automated the Safety Approval Form which links records from proposal to startup to closure. Noteworthy: Physics has merged JRAs into the ESR with very good outcome. Advantage- risk assessment is now in prime ESH document researchers use. Physic’s JRA within the ESR:  Physic’s JRA within the ESR 4.3.1 Hazard and Risk Assessment:  4.3.1 Hazard and Risk Assessment OFI. Risk Assessment was not dated and signed. Initially identified in FY06 internal audit finding and not resolved. Resolved on 2/08/07. [CMPMS] OFI. ESR was split into two forms. Some information needed to be removed. Resolved. [CMPMS] Noteworthy: As a result of 851, EENS compiled lists of activities and source locations for hoods and alternative hoods. Slide9:  DOE requirements are tracked by SBMS Office. NFPA: Fire Protection legal requirements are being tracked by Emergency Services via a list serve subscription. OSHA, ASME,ANSI requirements: A procedure for Industrial Safety requirements have been recently finalized by SHSD Safety Engineering. Actual requirement reviews/ RODs have not been done. Tracking of Industrial Hygiene requirements is behind schedule due to resource issues. All line organizations had adequate subscription to SBMS change service. The notices of SBMS changes should be improved in content on the changed text and required actions. 4.3.2 Legal and other Requirements Slide10:  SBMS Minor NC: SHSD had classified Subject Area changes as ‘minor’ that were actually “major”. Notification of the change was not made. Minor NC: The “Subject Area” subject area’s Effective Date was not updated with an major change. OFI: The “Date Last Modified” could relocated to a prominent location on the first page of Subject Areas to make identification easier. 4.3.2 Legal and other Requirements Slide11:  Many line organizations still have vague OSH objectives. Physic had all very quantifiable targets. Environmental Restoration had their objectives as an appendix to their OSH Manual so it is a “neat, tight package”. OFI: EP did not have Objectives for NRTL and Arc Flash calculation projects for which they are a prime player. 4.3.3 Objectives Slide12:  R2A2 were appropriate in all organizations. Most organizations felt they had adequate internal resources allocated for their OSH programs. One organization wanted additional Industrial Hygiene/Safety consulting and would purchase that additional services from SHSD- this is being worked out. Some organizations do not feel that they have good integration with SHSD yet. 4.4.1 Responsibilities and Resources 4.4.1 Responsibilities and Resources :  4.4.1 Responsibilities and Resources Noteworthy: Several departments are taking initiative to fund S2 items which do not get lab funding (EENS; BES). Finding: At the site level, the OHSAS 18001 program is not properly resourced (personnel) for maintenance of the program. Slide14:  No significant issues on the OSH training were detected. The system for maintaining current training shared between the supervisor and Training Coordinator. In most divisions, the training coordinators actively pursue outstanding training. All organizations were using BTMS to track their training on site level training classes, and there was strong support on the value of BTMS and the JTA mechanism. Some organizations were using BTMS to track their organization level training and qualification program. OFI: There appears to be concern that inappropriate training is being mandatory for individuals – e.g. for electrical there is not a course that meets the scientific needs. 4.4.2 Training Slide15:  OFI: Training of line organization ESH personnel on new or revised subject area should be expanded to all subject areas. Noteworthy: Follow-up from incident in MO was taken and discussed at staff meetings by J. Fowler. Emphasis on use of PPE and safe work practices reflected in the staff meeting minutes. Noteworthy: CAD has generated a training link to prevent LOTO without appropriate up to date training. Noteworthy: J. Tullo of EP demonstrated outstanding knowledge of Document Control procedures Noteworthy: EP has an excellent Controlled Document methodology for its “Policy & Procedure Manuals”, including “red ink stamp”. 4.4.2 Training Slide16:  All organizations had conducted an OSH Management Review in 2006. All had combined the review with their EMS Review with favorable results. The content and format was variable between organizations. Some organization missed covering some required topics. Finding: SMD did not cover “Costs associated with OHS concerns” and “Stakeholders concerns” and the Minutes of the management review were not yet available. Needs to be completed. 4.6 Management Reviews Slide17:  OFI: A placeholder for required topics should be included in presentation for non-applicable topics. OFI: EMS and OSH guidance on Management review need to be synchronized. Topic for discussion: End of Fiscal year due date for line organization’s management review is difficult for scheduling personnel and does not allow full year reporting of statistics. 4.6 Management Reviews Document Control:  Document Control F&O An out of date ESH Concern Form was used. Forms used in the WWTF did not have Revision dates or number. Slide19:  The OHSAS 18001 program is far behind EMS in development and acceptance by line organizations. EMS 14001 is the basis of the environmental program of BNL, is well established, and is the implementation program of line organizations. OHSAS 18001 is an add-on and has not emerged as the key OSH program of most line organizations. OHSAS 18001 at the site program level is not adequately resourced by BNL to be sustained and improved. Line organizations have satisfactory OSH programs in place for compliance. Comments/ Conclusions

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