PY 2006 EH&S Performance Criteria Table
Three major initiatives in PY06:
- More emphasis on safety communication between managers and employees. Things to emphasize include safety topics at regular group meetings, effective Division Safety Committees (or equivalent), and good definition of roles and responsibly for safety in Division ISM plans.
- More emphasis on management/employee interaction on ergonomic injury prevention
- More emphasis on safety inspections (or more simply managers walking and talking with their employees and discussing how work is performed safely and how safety can be improved) and a greater focus on observing safe work behaviors during inspections, as well as observing safe conditions. Also increased emphasis on the communication between managers and employees on the inspection itself and on the corrective action
Items that are new for PY-06 (bold) are not required until 1/1/06.
| Expectation | Validation | Rating | Division Systems |
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1. Define Work |
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E1. Line management regularly communicates ES&H policy, procedures, management safety expectations, and lessons learned to all staff. Division staff has clear lines of communication to convey ES&H issues, concerns, and suggested improvements to Lab and Division management. Examples of appropriate communications include:
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V1. |
3 out of 3 satisfied—green 2 out of 3 satisfied—yellow <2 out of 3 satisfied—red |
D1. 3 out of 3 satisfied—Green 1) There was one all-hands Division meeting during the performance year on 3/10/06. Safety was a primary agenda item. A meeting was called on 6/29/06 for all EETD PI's and Facility Managers where safety was the only topic. Focus was on line management responsibilities, participation, and communication; and on EHS027 Safety Walkaround training. Another similar meeting will be held on 8/9/06 for those who couldn't attend. Some of the larger research groups hold periodic group meetings where safety is normally an agenda item. Two of these where the DSC attended and discussed safety were on 7/11/05 for the Combustion Group, and on 12/12/05 for the Battery Group. These group safety meetings are encouraged by Division safety staff frequently during the year, and the PI's are encouraged to invite safety staff members to these meetings. Because of the nature and diversity of EETD research, Group and Department meetings are not the norm and are very difficult to hold. Many of our research groups are small and may be composed of only 1 or 2 people. Because of this, we have developed a strong and diverse safety communication program that targets specific groups, such as SAA Responsible Persons, PI's, Research Facility Managers, laser users, chemical users, or the Division personnel as a whole. These communications are discussed in more detail below. |
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2) Is a Division Safety Committee established (or equivalent) active in addressing employee safety issues and communicating safety information (how to avoid injuries) both to management and employees. |
2) The Division Safety Committee is composed of the Assistant Division Director for Space and EH&S (ADD) (chair), the DSC, the Deputy Division Director, the Division Business Manager, and the EH&S Division Liaison. This month we have added a Laboratory Safety Sub-Committee and a General Safety Sub-Committee. Each of these sub-committees have 6 or 7 members, including representatives from each relevant Department. The Safety Committee nominally meets quarterly or when issues arise. This performance year, significant safety agenda items were dealt with considerably more frequently than quarterly at the full Division Council meetings, which includes most of the Safety Committee members (minus the liaison and DSC) plus other senior Division staff. Thus the Safety Committee alone met only twice this performance year. The Committee discusses pertinent EH&S issues, and reviews the DSC's Quarterly Division Safety Report. Meeting minutes are posted on the EETD EH&S website. A direct communication link from the Safety Committee to senior Division management is provided through the Chair of the Safety Committee, who, as the ADD, is also a member of the Division Council, and by the DSC's quarterly safety reports. Communication from the Safety Committee down to employees is provided through numerous communication channels discussed elsewhere in this section. |
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3) Division ISM Plan have correct and adqeuate definition of EHS roles and responsibilities within the division. Personnel are familiar with their assigned roles and responsiblities and are performing them adequately. |
3) The Division ISM plan is updated at least annually. The latest update was on 6/19/06. A copy of the Plan is in Appendix 2. EH&S roles and responsibilities throughout the Division are clearly laid out. Description of Other Division Safety Communications The Division management chain (the Division Director, ADD, Division Council, Department and Program Heads, Group Leaders, Principal Investigators, and individual staff members) is used to communicate EH&S issues down the chain as well as providing feedback back up the chain. The DSC, ADD, and EH&S Division staff (including the EH&S senior management and Larry McLouth) communicate horizontally with the EETD management chain at whatever level is necessary. The Division has an EH&S web site which focuses on Division specific EH&S information (http://eetd.lbl.gov/EHS/EHS.html). The site contains the Division ISM Plan, Lessons Learned Notices, Safety Notes, Safety Committee charter and minutes, and other EH&S resources. In addition to the Division ISM Plan, staff and facility safety expectations, including research procedures, are covered in the Facility Notebooks. Our extensive Self-Assessment checklist and the HEAR database (which is updated at least annually by each of our research facilities) also communicate safety expectations. All AHD's are carefully reviewed annually and contain procedures and safety notes to maximize safety. The Division Senior Advisor (previously the Deputy Division Director) publishes a weekly electronic newsletter that is sent to all EETD staff. The newsletter, called "What's New in EETD" is also available (with back issues) on the Division web-site. Short safety articles are included in this newsletter from time to time, depending on issues at hand, but on the average, about every 5 or 6 weeks. See Appendix 5 for a sample issue. The DSC's Quarterly Division Safety Report (sample issue is attached in Appendix 3) contains current Division SA metrics status, pertinent EH&S information, and a discussion of current EH&S issues. The Quarterly Report is reviewed by the Safety Committee and is presented to senior Division management in a Division Council meeting. The DSC, ADD, and the EH&S Division Liaison meet nominally quarterly with the Division Council (senior management) to discuss the Quarterly Report and any other pertinent safety issues or policy matters. There were 4 such meetings with the Division Council during this performance period. However, this performance year, the Safety Committee Chair presented significant safety agenda items to the Division Council much more frequently. The DSC and the ADD typically meet about twice a month, or as issues arise, and actively communicate safety issues both up and down the Division chain of command by way of frequent visits with PI's, lab users, and senior management. It is Division policy to address safety issues and performance in every annual performance review. Performance Reviews are required to address training requirements, and a completion plan is required for any outstanding training. Through all the above activities and communication channels, the Division holds all staff accountable for EH&S. Also, there is an "Employee Responsibilities" document in the Division EH&S web site which describes safety responsibilities and expectations, such as stop work authority, reporting hazards, chemical and lab safety, supervisor duties, etc. All incoming EETD staff, including guests, are processed through the Bldg. 90 HR center where they are given the ISM brochure (PUB-811), a booklet on drugs in the workplace, RPM excerpts, information on the New Employee Orientation course, and information on the JHQ. |
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E2. Work planning for new and existing work includes environmental reviews. Review includes waste reduction, emission reduction, and/or resource conservation. |
V2. |
Complete #1 and #2 OR #3—green Complete #1 OR #2/3—yellow No progress—red |
D2. #1, 2, & 3 completed—Green (For further details on waste streams analyzed, see attached EETD Waste Minimization Program report in Appendix 4.) 1) We have identified and tracked for several years a number of waste streams that have waste minimization potential. Generally these waste streams are already using the most practical waste minimization procedures and equipment possible, and still allow research objectives to be met. We continue to monitor each year these waste streams and associated procedures in an attempt to identify further reduction possibilities. No additional waste reduction methods were found possible with any of the waste streams identified in PY05 to have potential opportunities for further waste reduction. |
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2) Divisions conduct documented environmental performance reviews for new experimental work. Waste reduction and resource conservation strategies are implemented, as applicable. Divisions include waste minimization and resource conservation in division project review protocols. |
2) Unlike most other Divisions, the nature of EETD's funding and research results in several hundred research proposals each year. It's not practical to track which of the research projects actually get funded (typically about one or two hundred) and then do a documented environmental performance review for each one. The Project Safety Review (PSR) forms, which are filled out for each new and renewed project, are scanned by the Division Safety Coordinator, and projects that might have waste minimization potential are noted for further investigation. Division oversight of activities in each of our 25 research facilities, rather than on a project by project basis, is our primary tool to identify waste minimization and resource conservation opportunities. This performance year, 2 new experimental research projects were identified as having potential for waste minimization. Details can be found in Sections 2.5 and 5.1 in the attached EETD Waste Minimization Program report in Appendix 4. |
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3) Divisions with no new work conduct an environmental performance review for at least one existing research or operations process and implement appropriate measure(s) |
3) Even though we have new work, we continue to conduct environmental performance reviews (focusing on waste minimization) for numerous existing projects. See discussion above. Other Division waste minimization activities:
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2. Identify Hazards |
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E3. Workspaces are inspected/observed and evaluated on a regular basis. All workspaces should be inspected. Manager's need only inspect a portion of the areas/employee-work-activities they are responsible for during each inspection (peer reviews between managers is encouraged), but all workspaces must be inspected during year. These inspections must be documented. Managers are encouraged to involve employees in these inspections. |
V3. % Division workspace inspected. Managers should document workspace inspections and deficiencies discovered. Deficiencies should be tracked in CATS (as appropriate). |
Satisfactory—green Partial—yellow Marginal—red |
D3. Satisfactory—Green 96% of the annual Self-Assessment checklist packages (which are at least reviewed and signed off by the PI's) were returned by the Division's research facilities during this review process. Also, 100% of the Division's lab space was inspected by the DSC at least once and typically about quarterly during the review period. All lab space was inspected in January by PI's and Division EH&S staff as part of Director Chu's Lab-wide safety initiative. All senior Division management (including the Division Director, Assistant Division Director, and Department Heads) have performed walkthroughs of various lab and office spaces. Most Division office space has been inspected by the DSC (and others) on a graded as-needed basis, and is partially documented. Most, if not all, laboratory PI's do undocumented safety walkthroughs of their labs on an average of almost every 2 months. (This is determined by a question in our annual self-assessment checklist package.) Deficiencies that are not fixed on the spot are tracked in CATS. |
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E4. Divisions review work activities to identify, analyze, and categorize hazards and environmental impacts for the associated work. Examples of hazard inventory include:
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V4. For all Division projects, programs, and operations, have hazards been identified and inventoried? Does inventory include non-routine, new work and modification of existing work? Is there documentation to show that appropriate levels of management are actively participating in the review of hazards? |
satisfactory—green partial—yellow marginal—red |
D4. Satisfactory—Green The Division's inventory of hazardous activities and equipment is maintained in the HEAR database. The online system was used in EETD's 25 research facilities to inventory hazards and authorizations during our PY06 Self-Assessment process. 96% of the Self-Assessment packages were returned during this review process. 100% of the facilities updated the HEAR information. (See Appendix 1, Table 3.) Our Project Safety Review (PSR) process also identifies hazards and checks that the HEAR form is current each year when the project is renewed and for each new project. A sample PSR form is attached in Appendix 5. Also very important are the DSC's numerous visits to each experimental facility during the year. Thus he is very familiar with existing and any new hazards and potential adverse environmental impacts. The above processes to identify hazards covers EETD's off-site work as well. However, considering the unique situations that can arrise with off-site work, EETD has developed an Off-Site Safety Review form to further assure the identification and control of off-site hazards. |
3. Control Hazards |
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E5. Divisions ensure engineering and other safety/environmental controls are in place and maintained. Examples of engineering controls include, but are not limited to:
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V5. Are engineering controls monitored as part of division self-assessment program? Are line managers held accountable for assuring that controls certified/checked, calibrated, and/or serviced prior to use within the required schedule? |
satisfactory—green partial—yellow marginal—red |
D5. Satisfactory—Green As per the EH&S Division, Industrial Hygiene Group, hoods are inspected by EH&S at least on a 2 year schedule (1 year if no monitors). Hoods were checked by EETD during the PY06 Self-Assessment. The Division Safety Coordinator also checks most fume hoods at least annually (as a verification of the IH inspections and the PI's self-assessment check). The few hoods that were found that weren't inspected within the required time period were reported to EH&S and have supposedly been inspected. Machine guards are checked annually in the Self-Assessment checklist and periodically by the DSC. There are no biocabinets in the Division. The small number of glove boxes in the Division are not formally tracked by the Division, but are on a 1 to 2 year inspection schedule by EH&S IH. The DSC also periodically checks glove boxes. A few glove boxes have low level safety issues and more significant experiment and material QA issues. For these glove boxes, inspection, maintenance, and safety procedures are documented in associated AHD's. The Division has no required toxic, flammable or other gas monitors. There is an H2S monitor and a few CO monitors in use, but none are of the type that can be calibrated. (See Appendix 1, Table 1.) Door interlocks for our laser labs are tested periodically by the laser users. Requirements for PPE are addressed in AHD's, in Specific Safety Procedures (SSP's), and by lab signage. One or two research groups may use LOTO procedures for electrical hazard control. Their training is up to date and the Lab Electrical Safety Engineer periodically reviews their operations. |
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E6. Divisions ensure administrative controls are in place and maintained. Examples of administrative controls for self-authorized work include:
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V6. Are hazards controlled for all Division projects/activities? Are administrative controls reviewed annually and when work is modified? This includes work under formal authorizations (e.g. AHDs, RWAs) and self-authorized work (i.e. Division approval only). Are line managers held accountable for terminating or suspending operations when approvals are lacking, authorizations have expired, or training is not current? |
satisfactory—green partial—yellow marginal—red |
D6. Satisfactory—Green The procedures for developing and implementing hazard controls vary depending on the category of the hazard. Controls for hazards categorized as moderate and higher are implemented by way of formal authorizations, such as AHD's, RWA's, SSA's, X-Ray authorizations, etc. Formal authorizations are reviewed at regular intervals, depending on the authorization: AHD's are reviewed annually, RWA's and SSA's every 18 months, and X-Ray authorizations every 5 years. (See Appendix 1, Tables 2 & 8.) Administrative controls for our low hazard work are implemented by way of internally reviewing at least annually our self-authorized work (work not requiring formal authorizations). In other words, Division approval only is required for self-authorized or low hazard work. As spelled out in the EETD ISM Plan, this Division approval is accomplished primarily by the process of updating and reviewing the HEAR database. Self-authorized work is also documented and authorized with the PSR, and occasionally with the Specific Safety Procedure (SSP) form or the Facility- and Task-Specific Training form in the Facility Notebook. PUB-3000, Chapter 6 is used as guidance for internal authorizations. In addition, we conduct regular joint reviews with EH&S specialists of specific EH&S issues and hazards. Line managers are held accountable for these hazard controls. All staff know they have the authority to stop work if unsafe conditions exist, including improper controls. Line management authority to suspend operations has been utilized from time to time when authorizations are not complete for new projects, or not renewed for continuing projects. We state in each of our AHD's that if training is incomplete, the employee can only work if under supervision. |
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E7. Divisions ensure that ergonomic hazards (computer, laboratory, and material handling) are adequately controlled and that employees are knowledgeable and engaged in this process including the early reporting of ergonomic pain or discomfort (before an injury):
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V7. Division has an effective ergonomic safety program as evidenced by:
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satisfactory—green partial—yellow marginal—red |
D7. Satisfactory—Green EETD injury rates are quite low, but 4 of the 6 total injuries during this performance year were ergonomic related. An EETD Ergonomics Action Plan was drafted in 1999 and has evolved over the past few years. Highlights of the plan and current accomplishments are as follows: The Division requires ergo training (EHS-060) for personnel who work at a computer for more than an average of 4 hours per day, and is considering expanding this requirement to all personnel who use a computer at all. 260 Division personnel currently have had ergo training. 45 of these were completed in PY06 (compared to 35 in PY05). 100% of the required EHS-060 courses have been completed. EETD has an in-house team of EHS-061 trained evaluators. EH&S evaluators are used for more critical evaluations where there are injuries, discomfort, or other complexities involved. In-house evaluators are primarily used for the routine evaluations and follow-up work. The immediate goal is to have evaluations completed for all approximately 182 active career or term EETD staff by the end of this upcoming year. Staff or EH&S requests for ergonomic evaluations are given first priority. 242 Division personnel have currently had ergo evaluations (EHS-068). 95 of these were completed in PY06 (compared to 60 in PY05). All ergo corrective actions have been completed except for a few of the most recent evaluations. The EETD Ergonomics Committee created guidelines for workstation upgrades, including the development of a pre-approved equipment list. EETD was the first Division to participate in the cost sharing pilot program for workstation ergonomics upgrades offered in December 2002 by Deputy Lab Director Sally Benson. The Division contributed 40% of the cost of the upgrades for 51 workstations. All of the DSC's quarterly safety reports to senior management include a discussion of ergonomic issues and status. The Division Director and senior management well aware of the ergonomic issues. No EETD staff are required to take EHS052. |
| E8. Divisions maintain an accurate chemical inventory. | V8. % of chemical owners OR % of locations are updated in the Chemical Management System during the performance year (each division specifies an inventory process). |
90-100%—green 80-90%—yellow <80%—red |
D8. 90-100%—Green 100% of EETD's chemical owners have updated their chemical inventories during PY06. PIs and Facility Managers are reminded, especially during the annual self-assessment process, to update their chemical inventories. To specifically encourage compliance, a question in the annual Self-Assessment Checklist asks each PI how many chemicals in his facility are not barcoded and entered into the chemical inventory. Of the 5406 chemical containers in EETD, only 0.5% (27 containers) are not yet barcoded and entered into the inventory system |
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E9. Division-specific OSHA instances from the 2004 OSHA inspection are corrected in a timely manner. |
V9. % completion rate by January 1, 2005 of OSHA instances from 2004 OSHA inspection. |
100%—Green <100%—Red |
D9. 100%—Green 100% of EETD's OSHA findings from the 2004 OSHA inspections were closed by 1/1/06. |
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E10. Division laser safety program is effective in controlling exposure to laser hazards. |
V10. Laser safety program is effective as evidenced by:
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satisfactory—green partial—yellow marginal—red |
D10. Satisfactory—Green EETD has 4 active laser AHD's and 4 inactive laser AHD's. All 8 have had their annual AHD reviews and updates in the last month. Each of the 4 active laser AHD's had onsite reviews and laser inventory updates in May 2006. In attendance for these onsite reviews were the Lab LSO, the DSC, the PI, and most, if not all, of the laser users. EETD has no laser users or operations on campus. |
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E11. Divisions control chemical, radiological, and bio hazards during lab moves and when PIs depart (change of accountability). |
V11. Divisions have in place a control process to ensure continuity of accountability of hazardous materials during lab moves and for departing PIs |
satisfactory—green partial—yellow marginal—red |
D11. Satisfactory—Green EETD requires all PI's who are moving or departing to be accountable for their chemicals, waste, and lab clean-ups. We have had an "EETD Policy on Vacating Space" posted on our EH&S website for several years. The policy describes the responsibilities of the PI who is vacating space, and also states that the Division has the right to place a lien on the PI's account(s) to cover the costs of clean-up, identifying unknown chemicals, etc. Our EETD policy also references Lab policy on this matter in the RPM, and includes a link to lab clean-out information in the Chemical Hygiene and Safety Plan. |
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E12. Divisions ensure that peroxide forming chemicals are effectively controlled. |
V12. Does the Division have a program to control peroxide forming chemicals? |
satisfactory—green partial—yellow marginal—red |
D12. Satisfactory—Green 100% of EETD's peroxide forming chemicals had confirmed CMS entries, proper labeling, and the required tests. The CMS database is used to track peroxide formers in EETD. During the Self-Assessment process, all PI's with peroxide formers were sent a copy of the peroxide former inventory, and they were asked the following questions:
They were also reminded of precautions related to peroxide formers and procedures if they have any suspicious containers. Specific results can be found in Appendix 1, Table 11. |
4. Perform Work |
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E13. Work is performed within the ES&H conditions and requirements specified by Lab policies and procedures. |
V13. Work within authorization: % SAA compliance (including MWSAAs, RWCAs) |
Regulatory driven >90%—green >75%-<90%—yellow <75%—red |
D13. >75%-<90%—Yellow 75% of the 8 SAA's inspected during the OCA inspections were in compliance. EETD has 28 SAA's. It should be noted that 91% of our SAA's were in compliance during the quarterly Waste Management inspections (105 total SAA inspections) for PY06. This is an improvement over the 88% Waste Management inspection compliance rate in PY05. See Appendix 1, Table 9 for details on the performance of each SAA. |
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% Authorization compliance (e.g. RWAs, RWPs, AHDs) |
Regulatory driven >90%—green >75%-<90%—yellow <75%—red |
>90%—Green 100% compliance for 1 active RWA's (Appendix 1, Table 8) 100% compliance for 7 SSA's & GLA's (Appendix 1, Table 8) 100% compliance for 19 AHD's (Appendix 1, Table 2) |
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# of environmental violations from external agencies and unplanned environmental releases above reportable quantities |
Regulatory driven 0—green 1—yellow 2 or more—red |
0—Green None. |
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% compliance QA waste samples |
Regulatory driven >95% or only 1 failure—green >92%-<95%—yellow <92%—red |
<92%—Red 88.7% normalized % pass QA performance rate (578 containers were received, 66 were tested, 8 containers failed; 87.9% QA sampled containers compliant.) (Appendix 1, Table 10) |
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# Waste Management issued NCARs |
Regulatory driven 0—green 1 or more—red |
0—Green None. |
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E14. Staff is properly trained. |
V14a. % completion of JHQs or equivalent system. |
>90%—green >85%-<90%—yellow <85%—red |
D14a. >90%—Green 97% of EETD personnel have completed the JHQ. (We have exempted 6 personnel who have been employed less than 1 month. 96% of all EETD personnel (without exemptions) have completed the JHQ.) (See Appendix 1, Table 6.) |
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V14b. Based on JHQs or training profiles, % completion rate for required courses. |
>90%—green >85%-<90%—yellow <85%—red |
D12b. >90%—Green 93% of all required courses have been completed. (See Appendix 1, Table 6.) |
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E15. Division ensures that student safety issues are effectively addressed. |
V15. Does the division have an effective safety program for students? This includes assuring students have completed their JHQs and required training, and their work conditions and work performance are safe. |
satisfactory—green partial—yellow marginal—red |
D13. Satisfactory—Green Student safety expectations and enforcement are the same as all other staff. Students are expected to fill out the JHQ and complete training. Until training is completed, they must be supervised by a trained person. The DSC has reviewed the JHQ and training records for all summer students. Mentors and students have been notified for those few cases where there are JHQ or training deficiencies. The notices emphasize proper supervision. The vast majority of students have completed all their training, including non-basic courses such as electrical, gas, chemical hygiene, and hazardous waste. |
5. Feedback and Improvement |
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E16. ES&H deficiencies identified from workspace inspections, self-assessment activities, SAARs, Occurrence Reports, environmental inspections, and external appraisals are corrected in a timely manner. |
V16. % completion rate of LCATS corrective actions (Levels 1, 2, and 3) implemented as scheduled. This includes corrective actions from SAARS and ORPS. |
>90%—green >80%-<90%—yellow <80%—red |
D16. Score To Be Determined 94% Closure rate for Level 1+2+3 combined (112 findings) This figure is calculated after exempting 14 open findings that were significantly delayed by EH&S or Facilities, are essentially out of EETD's control, and are currently awaiting Facilities action. All but 1 of these 14 are institutional. Supporting details will be provide upon request. 82% Closure rate without the above exemption. (see Appendix 1, Table 7) |
| E17. ES&H programmatic deficiencies identified from Management of ES&H (MESH) Reviews, Integrated Functional Appraisals (IFAs), and previous Division Self-Assessments are corrected in a timely manner. | V17. Opportunities for improvement identified during the previous self-assessment cycle (Div. Self Assessment, IFA, and MESH) are implemented in a timely manner. |
>100%—green >90-100%—yellow <90%—red |
D17. 100%—Green Programmatic corrective actions from previous agency inspections, SA, IFA, and MESH reports are as follows: 1. FY05 SA Report: "The Division achieved compliance in only 44 out of 50 SAAs (88%) from two rounds of inspections." Deficiency Correction: Our PY06 SAA compliance rate from 105 quarterly SAA inspections by Waste Management was 91%. This is an improvement over the 88% score from Waste Management inspections during PY05. However OCA's spot inspections of 8 SAA's during PY06 resulted in a compliance rate of only 75%. The Division increased its SAA compliance and oversight efforts this performance year. The DSC sends a Quarterly SAA & Waste Management Newsletter to all SAA responsible persons and PI's with SAA's. (See Appendix 5 for a sample.) The DSC's spot checks of SAA's were increased. Division management was involved in several cases where particular research groups had repeating or serious SAA problems. Also with these problem groups, special waste management meetings were held with group members, PI's, the relevant Department Head, and Division EH&S personnel. One such meeting included the EH&S Waste Management Group Leader and our Waste Generator Assistant. 2. FY05 SA Report: "One NCAR for improper disposal of CA-regulated waste was cited during the performance year." Deficiency Correction: EETD had no NCAR's during PY06. |
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E18. Division employees report injuries and near miss events and the Division performs thorough review of all staff injuries, accidents, and near-miss events including analysis of conditions that led to injury. Corrective actions to prevent recurrence are identified and effectively implemented. |
V18. Has Division ensured that accident causes and corrective actions for first aid and recordable injuries are effectively identified on SAARs? Are corrective actions implemented to prevent recurrence? Is management actively promoting the early reporting for all injuries and near miss events? |
satisfactory—green partial—yellow marginal—red |
D18. Satisfactory—Green The DSC and EH&S Division Liaison review all SAAR's to assure that accident causes and corrective actions are adequately defined. As specified in the Division ISM Plan (see Appendix 2), it is Division policy to have an accident investigation meeting with each injured person, their supervisor, the DSC, and the EH&S Division Liaison. The ADD will also be involved in these meetings and discusses findings with the Division Safety Committee for DOE recordable injuries. On rare occasions, an exception to this accident investigation policy has been made at the request of the injured employee, but at least the employee and the DSC will meet in those few cases. Identification of accident causes and corrective actions entered on the SAARs report are typically revised and improved during the investigation and followup meetings. Each accident and injury file is kept active by the DSC until corrective actions are implemented. All meetings with accident and injury discussions include active promotion of early reporting, with a particular emphasis on ergonomic issues. |
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