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Off-Site Work Authorization Policy

    Title:

    Off-Site Work Authorization Policy

    Publication date:

    5/22/2013

    Effective date:

    12/1/2001

    BRIEF

    Policy Summary

    To authorize work at off-site locations, Berkeley Lab divisions must develop a process to plan for the safety of workers and the environment in the off-site location. The division process should be included in the division's ISM Implementation Plan. The process should follow the principals of ISM:

    • Define the scope of work
    • Analyze the associated hazards
    • Develop appropriate controls
    • Perform work within controls
    • Obtain feedback for improvement

    Who Should Read This Policy

    Berkeley Lab employees, affiliates, and subcontractors

    To Read the Full Policy, Go To:

    The POLICY tab on this wiki page

    Contact Information

    Safety Compliance Program Manager
    Technical Support Services Group
    EHSS Division

    Title:

    Off-Site Work Authorization Policy

    Publication date:

    5/22/2013

    Effective date:

    12/1/2001

    POLICY

    A. Purpose

    Berkeley Lab policy requires the prevention of injuries, illnesses, and environmental damage at all locations it has responsibility for, including off-site activities. Off-site activities include all work performed at sites located away from the Berkeley Lab main site and satellite locations, which include Donner Hall, Potter Street, the Joint BioEnergy Institute (JBEI), and the Joint Genome Institute (JGI).

    The Off-Site Work Authorization Policy is implemented through the Work Authorization processes at the division level (e.g., Activity Hazard Document [AHD], Radiological Work Authorization [RWA]) and Job Hazards Analysis (JHA, sJHA). Each division assesses its work activities, identifies activities where personnel are working remotely off site, and develops a process to plan for their safety. The process should be included in the division Integrated Safety Management (ISM) Implementation Plan.

    This policy applies to work conducted in remote or field locations. It is intended to drive the development of site-specific and work-specific hazard analysis, to inform employees of present hazards, to identify the training and protective measures needed to perform work safely, to provide emergency information, and to serve as a safety training document. At Berkeley Lab, it applies to all field work performed under Laboratory direction, including work performed by subcontractors at any tier.

    B. Persons Affected

    Berkeley Lab employees, affiliates, and subcontractors

    C. Exceptions

    Work performed at a non-DOE off-site facility by a subcontractor that is working under the jurisdiction of an oversight/enforcement agency other than DOE. For these cases, the oversight/enforcement agency must be identified.

    D. Policy Statement

    1. To authorize work at off-site locations, Berkeley Lab divisions must develop a process to plan for the safety of workers and the environment in the off-site location.
      1. The division process should be included in the division-specific ISM Implementation Plan.
      2. The process should follow the principals of ISM:
        1. Define the scope of work
        2. Analyze the associated hazards
        3. Develop appropriate controls
        4. Perform work within controls
        5. Obtain feedback for improvement
      3. The process may specify that the Environment, Safety and Health oversight of the work performed is under the jurisdiction of an agency other than DOE. For example, work performed by a licensed electrician installing a current monitoring device in a commercial building in California as part of a wide spread power consumption investigation project. Oversight of this work is under the jurisdiction of Cal/OSHA.
    2. Logistics for safe off-site work planning should address:
      1. How to send people and equipment to the site
      2. Using or monitoring third-party equipment at the site
    3. The lack of available safety infrastructure and support when plans go wrong
      1. Off-site operations planning should include material-handling considerations for accessing, setting up, and taking down off-site equipment. Contingencies for different or substandard utilities also should be made (e.g., nonconforming electrical wiring in a building being monitored). Procedures for contacting emergency support personnel should also be made.
      2. Examples of successful division processes include the Off-Site Safety and Environmental Protection Plan (OSSEPP) process used by the Earth Sciences Division, and the Field Work Hazard Assessment Form process used by the Environmental Energy Technologies Division.
    4. When Berkeley Lab employees are injured or become ill during off-site operations, the following procedure should be followed:
      1. Employees should obtain appropriate treatment by a local physician or hospital staff.
      2. Berkeley Lab Health Services, ext. 6266, should be informed so that the proper injury/illness report can be prepared.
      3. Health Services forwards this injury/illness report within the EHSS Division and the Berkeley Lab Risk Manager when applicable.
      4. The EHSS Division determines whether the injury/illness is work-related.
    5. Berkeley Lab division directors are responsible for determining whether a written Activity Hazard Document (AHD) is needed for off-site work as well as for AHD reviews and approvals. When the division director has reviewed and approved the AHD, the AHD becomes the principal safety document for the off-site project or activity. For an example of an AHD, refer to the Berkeley Lab Safe Work Authorizations program.
    6. Supervisors of employees planning to engage in work-related boating or diving operations, or aviation activities must contact the EHSS Occupational Safety Group, ext. 2976, for guidelines and safety procedures relevant to their specific operation.
      1. For off-site-work-related boating or diving operations: A completed Application for Vessel Use form must be reviewed by the Occupational Safety Group for each vessel before the off-site work begins.
      2. For the procurement of off-site-work-related aircraft or aviation services: See Berkeley Lab's Aviation Policy and Procedures for roles and responsibilities.

    E. Roles and Responsibilities

    RoleResponsibility

    Personnel proposing off-site operations

    Must give their division director written notification of the nature and scope of the project, including an AHD (if necessary)

    EHSS Liaison/Safety Representatives

    • May visit off-site operations, and/or schedule visits by appropriate subject matter experts
    • Coordinates AHD reviews in conformance with the AHD review process

    Division Director

    • Determines whether a written AHD is needed
    • Reviews and approves off-site operation's AHD

    F. Definitions/Acronyms

    TermDefinition

    AHD

    Activity Hazard Document

    JHA

    Job Hazards Analysis

    OSSEPP

    Off-Site Safety and Environmental Protection Plan

    RWA

    Radiological Work Authorization

    sJHA

    Subcontractor Job Hazards Analysis

    G. Recordkeeping Requirements

    Variable, depending upon specific authorization type selected.

    See requirements for the specific authorization type.

    H. Implementing Documents

    Document Number

    Title

    Type

    07.02.003.001

    Safe Work Authorizations Program

    Program

    07.08.001.001

    Radiation Safety Program

    Program

    07.02.001.001

    Job Hazards Analysis (JHA) Program

    Program

    07.02.004.001

    Subcontractor Job Hazards Analysis (sJHA) Program

    Program

    I. Contact Information

    Safety Compliance Program Manager
    Technical Support Services Group
    EHSS Division

    J. Revision History

    Date

    Revision

    By whom

    Revision Description

    Section(s) affected

    Change Type

    5/22/2013

    1

    W. Wells

    Re-write for wiki

    all

    Minor

    DOCUMENT INFORMATION

    Title:

    Off-Site Work Authorization Policy

    Document number

    07.02.002.000

    Revision number

    1

    Publication date:

    5/22/2013

    Effective date:

    12/1/2001

    Next review date:

    5/14/2016

    Policy Area:

    Safe Work Authorization

    RPM Section (home)

    ES&H

    RPM Section (cross-reference)

    none

    Functional Division

    EHSS

    Prior reference information (optional)

    PUB-3000 Section 5.5

    Source Requirements Documents

    29 CFR 1910, Subpart T, Commercial Diving Operations

    Other Driving Requirements

    • Partnership Agreement Between UCB and LBNL Concerning Environment, Health and Safety Policy and Procedures , March 15, 2004
    • JGI Memorandum of Understanding (Regarding ES&H), November 7, 2006
    • Joint BioEnergy Institute Environment, Safety, and Health (ES&H) Responsibilities Matrix November 9, 2007
    • U.S. Department of Transportation, Coast Guard, Series 323, Rules and Regulations for Small Passenger Vessels (Under 100 Gross Tons)
    • U.S. Department of Transportation, Coast Guard, Series M6672.2, Navigation Rules: International-Inland
    • ES&H Documentation and Approvals (Safe Work Authorization Program)

    Implementing Documents

    Document Number

    Title

    Type

    07.02.003.001

    Safe Work Authorizations Program

    Program

    07.08.001.001

    Radiation Safety Program

    Program

    07.02.001.001

    Job Hazards Analysis (JHA) Program

    Program

    07.02.004.001

    Subcontractor Job Hazards Analysis (sJHA) Program

    Program

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