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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

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.
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

RPM

REQUIREMENTS AND POLICIES MANUAL

Occurrence Reporting