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REQUIREMENTS AND POLICIES MANUAL

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    Title:

    Occurrence Reporting

    Publication date:

    11/10/2017

    Effective date:

    5/11/2012

    BRIEF

    Policy Summary

    Berkeley Lab's Occurrence Reporting policy addresses the reporting of certain environmental, health, and safety incidents at Berkeley Lab by:

    • Categorizing occurrences per DOE's system
    • Notifying the Berkeley Site Office
    • Using the Occurrence Reporting and Processing System (ORPS) to report occurrences

    Who Should Read This Policy

    All Berkeley Lab divisions and departments, including affiliates and subcontractors performing work for the Laboratory

    To Read the Full Policy, Go To:

    The POLICY tab on this wiki page

    To Read the EHS Program Details, Go To:

    http://www.lbl.gov/ehs/pub3000/CH15.html

    Contact Information

    ORPS Program Manager
    EHS Division

    Title:

    Occurrence Reporting

    Publication date:

    11/10/2017

    Effective date:

    5/11/2012

    POLICY

    A. Purpose

    The Occurrence Reporting policy of Lawrence Berkeley National Laboratory (Berkeley Lab) addresses the reporting of certain environmental, health, and safety incidents at Berkeley Lab. It details the types of incidents that must be reported and the requirements for reporting these incidents.

    B. Persons Affected

    All Berkeley Lab divisions and departments, including affiliates and subcontractors performing work for the Laboratory

    C. Exceptions

    Work covered under a Memorandum of Understanding involving the Department of Energy (DOE) and Berkeley Lab, such as that governing work in some areas of the University of California (UC) at Berkeley campus, may be excluded from the requirements of this policy.

    D. Policy Statement

    1. Berkeley Lab strives to prevent all injuries and illnesses; environmental damage; significant business, facility, and community disruptions; and regulatory noncompliance. If these types of occurrences happen, Berkeley Lab will determine if they meet Department of Energy (DOE) O 232.2A (Occurrence Reporting and Processing of Operations Information) criteria, and if so, notify DOE and prepare and submit occurrence reports as documented in this Environment, Safety and Health (ES&H) Manual Chapter.
    2. Berkeley Lab determines whether any occurrences must be reported to DOE per DOE Order 232.2A, and if so, must follow DOE reporting requirements. These requirements include:
      1. Reporting the issue to the Environment/Health/Safety (EHS) Division
      2. Collecting facts and determining whether the event or condition meets one or more of DOE's reportable criteria. Divisions make this determination.
      3. Categorizing the occurrence per DOE Order 232.2A. Divisions make this determination.
      4. Notifying the DOE Berkeley Site Office (BSO). EHS completes this notification.
      5. Submitting details into the DOE Occurrence Reporting database. EHS completes this action following approval from the divisions.
      6. Where required, submitting more detailed final reports with information on causes and corrective actions to DOE. EHS completes this step following approval from the divisions.

    E. Roles and Responsibilities

    Role

    Responsibility

    Employees, Affiliates, and Subcontractors

    Report unsafe or abnormal events and conditions (hereafter referred to as "occurrences") in a timely manner, according to Berkeley Lab policy and the applicable division's policies and procedures

    Supervisors and Activity Leads

    Ensure that employees understand workplace health and safety reporting responsibilities. When a supervisor or activity lead learns of an occurrence, he or she must ensure appropriate authorities are notified, including the division safety coordinator and the EHS Division.

    Division Directors Note: A division director is sometimes referred to as a facility manager for purposes of the DOE Occurrence Reporting Program.

    • Meet the requirements of DOE Order 232.2A — including categorization, notification, investigation, and reporting — for occurrences at their facilities or operations
    • Provide appropriate resources to report events in a timely manner, investigate causes, and institute corrective actions to prevent recurrence
    • Decide whether an occurrence is DOE reportable. When occurrence categorization is unclear, or for management concerns, EHS can assist with this determination.
    • Approve final reports before EHS submits them to DOE. Division directors may assign designees from their organizations to help implement these procedures. 

    Division Designees Note: Appropriate candidates for division designees include deputy division directors, division safety managers, or division safety coordinators. These individuals may be listed as points of contact for DOE-reportable occurrences within divisions (see http://www.lbl.gov/ehs/orps/pdf/divisionORPS.pdf for a list of points of contact). If no division designee is chosen, the division director is responsible for implementing these procedures.

    • Must be familiar with the procedures described in this chapter
    • Assist line managers and staff in meeting occurrence-reporting requirements, including communicating with EHS to ensure proper DOE notifications are completed
    • Should notify EHS of an occurrence as soon as possible to get guidance through the occurrence-reporting process.

    Environment/Health/Safety Division

    • Oversees the occurrence-reporting process to ensure it is properly managed
    • Assists divisions as needed to respond to, mitigate, categorize, and investigate occurrences, and to support division directors and their designees with DOE occurrence reporting
    • Completes the required DOE notifications and submits the required DOE reports into the online DOE Occurrence Reporting database
    • Reports any observed occurrence to the appropriate person within the EHS Division

    Office of Institutional Assurance & Integrity

    • Provides oversight for the Issues Management Program
    • Maintains the Corrective Action Tracking System (CATS) and reviews Root Cause Analysis reports, Extent of Condition Review reports, Corrective Action Plans, and Effectiveness Review Reports prior to issuance and approval
    • Oversees the Causal Analysis Program. The products of these programs are used, when applicable, in the preparation of Final Reports.

    F. Definitions/Acronyms

    Term

    Definition

    Condition

    "Any as-found state, whether or not resulting from an event, that may have adverse safety, health, quality assurance, operational, or environmental implications. A condition is usually programmatic in nature; for example, errors in analysis or calculation; anomalies associated with design or performance; or items indicating a weakness in the management process." (Definition from DOE Order 232.2A)

    Event

    "Something significant and real-time that happens (e.g., pipe break, valve failure, loss of power, environmental spill, earthquake, tornado, flood, injury)." (Definition from DOE Order 232.2A)

    Occurrence

    "Events or conditions that adversely affect, or may adversely affect, DOE (including NNSA) or contractor personnel, the public, property, the environment, or the DOE mission." (Definition from DOE Order 232.2A)

    G. Recordkeeping Requirements

    Role

    Recordkeeping Requirement

    Subject Matter Expert

    Occurrence Reports (as of April 2012, stored online at https://www.lbl.gov/ehs/orps/reports/index.shtml)

    Office of Contractor Assurance

    Root Cause Analysis Reports

    H. Implementing Documents

    Document Number

    PUB-3000 Reference

    Title

    Type

    07.03.001.001

    Chapter 15

    Occurrence Reporting

    Program

    PUB-5519(1)

     

    Issues Management Program Manual System

     

    PUB-5519(2)

     

    Causal Analysis Program Manual System

     

    PUB-5519(3)

     

    Data Monitoring and Analysis Program Manual System

     

    PUB-5519(4)

     

    Lessons Learned and Best Practices Program Manual System

     

    I. Contact Information

    ORPS Program Manager

    EHS Division

    J. Revision History

    Date

    Revision

    By whom

    Revision Description

    Section(s) affected

    Change Type

    11/10/2017

    1.2

    A.F. Peterson

    Revisions to incorporate changes to DOE order

    All

    Minor

    2/15/2013

    1.1

    L. Young

    Updated SRD list

    Document Information

    Editorial

    5/11/2012

    1

    A.F. Peterson

    Reformat for wiki (policy)

    All

    Minor

    1/2/2012

    0

    A.F. Peterson

    Reformat for wiki (brief)

    All

    Minor

    DOCUMENT INFORMATION

    Title:

    Occurrence Reporting

    Document number

    07.03.001.000

    Revision number

    1.2

    Publication date:

    11/10/2017

    Effective date:

    5/11/2012

    Next review date:

    11/10/2022

    Policy Area:

    Incident Review and Reporting

    RPM Section (home)

    ESH

    RPM Section (cross-reference)

    none

    Functional Division

    EHS

    Prior reference information (optional)

    PUB-3000 Chapter 15

    Source Requirements Documents

    • DOE Order 232.2A, Occurrence Reporting and Processing of Operations Information, Attachment 1, Contractor Requirements Document
    • DOE Order 225.1B, Accident Investigations, Attachment 1, Contractor Requirements Document
    • Issues Management Policy, RPM document number 04.02.003.000

    Implementing Documents

    Document Number

    PUB-3000 Reference

    Title

    Type

    07.03.001.001

    Chapter 15

    Occurrence Reporting

    Program

    PUB-5519(1)

     

    Issues Management Program Manual System

     

    PUB-5519(2)

     

    Causal Analysis Program Manual System

     

    PUB-5519(3)

     

    Data Monitoring and Analysis Program Manual System

     

    PUB-5519(4)

     

    Lessons Learned and Best Practices Program Manual System

     

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