Title: | Hazardous Material Management | Publication date: | 5/19/2023 | Effective date: | 5/19/2023 |
POLICYA. PurposeDue to the risk associated with hazardous materials, special approval, acquisition, and management practices are needed to ensure both the safety of personnel and the Lawrence Berkeley National Laboratory's (LBNL’s) compliance with Department of Energy (DOE) requirements. The DOE maintains approval authority for certain scientific research involving hazardous materials at DOE National Laboratories to include LBNL. Depending on the severity of risk associated with the restricted substance, acquisition approval may require some or all of the following: - Institutional approval following analysis to ensure proper work planning elements are in place so that the requested chemical may be safely brought on site, used and stored.
- Dispersion modeling to assess the consequences of an airborne chemical release, models are then compared against DOE approved thresholds.
- DOE approval when dispersion modeling results exceed airborne concentration thresholds.
This policy establishes the approval necessary prior to the acquisition of hazardous materials that meet these requirements, in accordance with DOE Order 470.3C, Design Basis Threat (DBT) Official Use Only (OUO), DOE Order 151.1D, Comprehensive Emergency Management System, and LBNL institutional requirements. B. Persons AffectedThis policy applies to any individual using or supporting the use of hazardous materials at an LBNL facility. This includes those who work with, assess, approve, handle, procure, acquire, store, or facilitate disposal of hazardous materials at LBNL. C. ExceptionsThere are no exceptions. All use of hazardous materials must follow the review and approval process defined in this policy. D. Policy StatementHazardous Material is defined by DOE/NNSA NA-40 Office of Emergency Operations. In accordance with DOE Order 151.1D as “Any hazardous biological agents and toxins; any radioactive or radiological material that emits ionizing radiation or solid, liquid, or gaseous material that is toxic, explosive, flammable, corrosive, that emits ionizing radiation; or otherwise could adversely affect the health and safety of the public or the workers or harm the environment.” Also, hazardous material is any substance regulated by the U.S. Department of Transportation per 49 CFR Parts 100-185 or United Nations Model Regulations on the Transport of Dangerous Goods, as noted in Section 14 of the vendor Safety Data Sheet (SDS). All hazardous materials meeting this definition and/or criteria must be screened prior to being brought into an LBNL facility, but not all hazardous materials invoke additional requirements within DOE Order 151.1D and DOE Order 470.3C. D.1 General- All LBNL hazardous materials must be reviewed (“screened”) and, if required, approved prior to acquisition, arrival, or use at LBNL. Approval may include the DOE-BSO Field Element Manager (FEM), DOE-BSO Officially Designated Federal Security Authority (ODFSA), and the area Division Director and Associate Laboratory Director.
- All hazardous materials must be received, stored, used, and disposed of in a manner that is compliant with DOE Orders and the conditions outlined by the DOE approving authority and in accordance with EHS chemical management policies and procedures.
- Any significant change to hazardous material inventories, as defined below, must be assessed to determine if approvals are required prior to the significant change.
D.2 Significant Change- Per the DOE NA-40 Office of Emergency Operations CRAD Handbook (2021), a significant change is defined as, “A change (such as new operations, new inventories, and process changes) to a degree that consequences would result in a noticeable increase in impacts.”
- A significant change is determined using principles from the DOE Unreviewed Safety Questions (USQs) process in 10 CFR 830 and Unreviewed Safety Issue (USI) process outlined in DOE Order 420.2C Safety of Accelerator Facilities [DOE Order 151.1D, Attachment 3, CRD 2.e]:
- A proposed or discovered change in the hazardous material inventories or operational hazards, either permanent or temporary, that would exceed those currently analyzed or bounded by the authorized Work Planning and Control (WPC) activity and/or DOE approved deliverable.
- Any change in control configuration with a potential to increase consequence, likelihood, or overall risk, or reduce the reliability or effectiveness of design features, controls, procedures, or processes used to prevent or mitigate hazards in a proposed or existing DOE approved deliverable.
- Modifications to equipment or controls that alter the scope, initial conditions, or assumptions of the WPC activity and/or DOE approved deliverable; or
- Previous analyses were discovered to be inadequate (e.g., the analysis does not match the facility configuration due to a “discrepant as found” condition).
E. Roles and ResponsibilitiesRole | Responsibility | Any individual seeking to acquire hazardous chemicals at an LBNL facility | - Understands the risks associated with hazardous materials they purchase or allow onsite and minimize risk through elimination, substitution, reduction, use of administrative controls, and use of personal protective equipment.
- Utilize the LBNL Work Planning and Control system to ensure administrative and engineered controls are in place prior to receiving or use of hazardous materials.
- Uses appropriate channels to request approval prior to obtaining hazardous materials.
| DOE Berkeley Site Office (BSO) | - Approves purchase of hazardous materials, in accordance with DOE requirements.
| Research Division Line Management | - Provides approval of all planned research activities associated with hazardous materials and accepts the associated risks on behalf of LBNL.
| | Environment Health and Safety (EHS) Division | - Oversees the Chemical Management Program and Work Planning and Control program.
| Security & Emergency Services (SES) Division | - Assists in determining if a hazardous material of interest will trigger additional review and approval requirements.
- Composes Emergency Planning Hazards Assessments (EPHAs) and Security Risk Assessments (SRAs) for hazardous materials, as required by DOE requirements.
- Identifies and applies the controls necessary to protect materials and enable the research activity to continue in accordance with DOE Orders.
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F. ResourcesFor further information on the appropriate acquisition, approval, and handling of hazardous materials at LBNL see chemical management policies and procedures in EHS Manual (PUB-3000), including Chapter 13, Gas Safety and Chapter 45, Chemical Hygiene and Safety Plan. Additional information can also be found on the Restricted Chemicals website and Chemical Safety website. For the further information to compliantly identify hazardous materials that require additional controls, see the Guidance on Hazardous Material Assessments. For more information on this policy or hazardous materials definitions for emergency management and safeguards & security, email [email protected] or contact your supervisor or Division Safety Coordinator. G. Recordkeeping RequirementsNone H. Implementing DocumentsJ. Revision HistoryDate | Revision | By whom | Revision Description | Section(s) affected | Change Type | 5/19/2023 | 0 | D. von Damm | New policy | All | New |
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