Analysis and Work Authorization | Publication date: | 2/1/2022 | Effective date: | 7/30/2015 |
POLICYA. PurposeLawrence Berkeley National Laboratory's (Berkeley Lab's) Hazard Analysis & Work Authorization Policy ensures that all work is performed in a safe manner by: - Ensuring that work planning is performed prior to starting work by:
- Defining the work scope.
- Analyzing associated hazards.
- Developing controls such that hazards are identified and mitigated.
- Providing work authorization processes tailored to the type of work that ensure that controls, procedures, and resources are in place. These processes may include:
- Work Planning and Control (WPC) activities in Activity Manager for work done by workers and affiliates.
- Subcontractor Job Hazards Analysis (sJHA).
- Construction subcontractors' ES&H submittal package (Construction JHA).
- Temporary Work Authorization (TWA).
- Radiological Work Authorization (RWA).
- Facility Work Authorization.
- Ensuring that the process and authorizations are documented prior to starting work.
B. Persons AffectedBerkeley Lab employees, visitors, affiliates, and subcontractors who perform work in technical areas or on construction sites C. ExceptionsThose not performing hands-on work (i.e., those performing work tasks commonly performed by the public), who work 100% at a site not managed by the Berkeley Lab, or who work 100% of the time on the UC Berkeley Campus. D. Policy Statement- Safety of all operations at Berkeley Lab is managed according to the principles outlined in the Integrated Environment, Safety, & Health Management Plan: Integrated Safety Management (ISM) System. Using these principles, line management is responsible for assuring safety of its operations by identifying work hazards and developing and implementing tailored controls prior to authorizing work to proceed. The EHS Division collaborates with line management to identify hazards and controls by:
- Identifying appropriate safety standards and requirements.
- Providing institutional tools, procedures, and methods to facilitate control of hazards and compliance with requirements.
- Providing subject-matter-expert support.
- Work authorization, a key principle in safe work planning, is a hazard review and management approval process designed to ensure that procedures, controls, and resources are in place before the work begins. All work at Berkeley Lab proceeds under authorization. Institutional authorization processes have been developed and tailored to facilitate line management authorization activities under a variety of administrative circumstances as follows:
- For Berkeley Lab employees and affiliates, line management authorization for routine work is granted using the Work Planning and Control (WPC) program documented in Chapter 6 of the ES&H Manual.
- Operations in a particular facility, under certain circumstances, may require authorization. Appendix B of the Work Planning and Control program provides general guidance on facility-based authorizations.
- The TWA process may be used only for laser system service/maintenance as allowed in the Laser Safety program of the ES&H Manual.
- For non-construction subcontractors, the sJHA – Subcontractor Job Hazards Analysis (sJHA) program is used to ensure that all non-construction subcontractor work is performed safely and in accordance with Berkeley Lab requirements. For construction activities, Work Process C, Review Selected Subcontractors' EHS Submittal Package(s), of the Construction Safety program is used to ensure that construction subcontractors adequately evaluate hazards and implement safety controls.
- Radiological Work Authorization and Permit Programs are described in Section 21.6, Radiological Work Authorization and Permit Programs, of the Radiation Safety program.
E. Roles and ResponsibilitiesRole | Responsibility | Employees, visitors, and affiliates | - Perform only work for which they are authorized and qualified.
| Principal investigators, managers, line management supervisors, and work leads | - Identify the hazards associated with the work to be performed.
- Supply the controls necessary to perform the work safely.
- Assure that employees under their supervision are authorized under appropriate authorization systems and are appropriately trained (Berkeley Lab training requirements as defined by assigned activities or assigned by the EHS Training Program (see also the EHS Training website).
- Assure that all work under their control is evaluated to determine the level of authorization required by this program, and that proper authorization is obtained before beginning work.
- Assure that all work under their control is performed in compliance with the controls specified for that work.
- Assure that authorizations for work under their control are reauthorized as required, including whenever work changes significantly.
| Project Leads, Activity Leads, and Activity Lead Designees | - Implement work and worker authorization processes as required by the ES&H Manual Work Planning and Control program. This includes defining work scopes, analyzing hazards, and assigning and authorizing workers.
| Division directors | - Assure that all work spaces are evaluated at least annually for identification of hazards and implementation of controls.
- Assure that all work has obtained line management, formal, or facility-based authorization, as required.
| Facilities Division | - Assures work by construction subcontractors is properly evaluated and authorized under construction subcontractors' ES&H submittals (Construction JHA documents).
- Prepares the appropriate NEPA/CEQA documentation.
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F. Definitions/AcronymsTerm | Definition | Line management authorization | An authorization that is administered by the responsible division doing the work. Examples include the Work Planning and Control (WPC) activities (in Activity Manager), Subcontractor Job Hazards Analysis (sJHA) for non-construction subcontractors, and Contractor JHA for construction subcontractors. | Formal authorization | A written document, authorized by the responsible division with EHS (or with a chartered safety committee) review and concurrence, that describes the scope of work, required procedures and controls, authorized materials and equipment to be used, and staff authorized to conduct the work. Examples include Radiological Work Authorizations and research involving human or animal subjects. | Facility-based authorization | Hazards analyses and controls are based on the facility as a whole rather than on an individual operation. Examples include Safety Analysis Documents, air and water discharge permits, and NEPA/CEQA analyses. |
G. Recordkeeping RequirementsRecord | Database/Retention Location | Owner | WPC Activities | Activity Manager | EHS | sJHAs | sJHA Database | EHS | RWA | RADAR | EHS | TWAs | Maintained by the authorizing division | Authorizing Division | Construction JHA packages | Construction Project Documents | Facilities Division | Facility-Based Authorizations | Maintained by the host Division | Host Division | EHS Training Records | EHS Training Database | EHS |
H. Implementing DocumentsWork Planning and Control Subject Matter Contact
sJHA - Subcontractor Safety Assurance Program Manager
Construction Safety
Radiation Protection
Biosafety Officer
EHS Division
J. Revision History
Date | Revision | By Whom | Revision Description | Section(s) Affected | Change Type | 1/2/2012 | 0 | J. Heim | Reformat for wiki (brief) | All | Minor | 12/18/2012 | 1 | J. Heim | Reformat for wiki (policy) | All | Minor | 1/14/2014 | 1.1 | W. Wells | Revise as Policy Overview | All | Minor | 8/31/2015 | 2 | A. Peterson | Policy revised to sync with new program | All | Major | 2/1/2022 | 2.1 | J. Heim | Periodic review: minor clarifications to the policy text. | All | Minor |
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