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Comment: policy re-directed to ES&H manual chapter 15

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Deck of Cards
idOccurrence Reporting
Card
defaulttrue
labelBrief

Title:

Occurrence Reporting

Publication date:

114/1015/20172022

Effective date:

54/1115/2012

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

2022

BRIEF

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

ES&H Manual Chapter 15

Contact Information: ORPS Coordinator, EHS Division

To Read the Full Policy, Go To ES&H Manual Chapter 15

Contact Information: ORPS Coordinator, EHS Division

I. Contact Information

ORPS Program Manager

EHS Division

J.

Revision History

Card
labelPolicy

Title:

Occurrence Reporting

Publication date:

114/1015/20172022

Effective date:

54/1115/20122022

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

Date

Revision

By whom

Revision Description

Section(s) affected

Change Type

4/15/20221.3M. FlynnPolicy re-directed to ES&H Manual Chapter 15All Minor

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

Card
labelDocument Information

DOCUMENT INFORMATION

Title:

Occurrence Reporting

Document number

07.03.001.000

Revision number

1.23

Publication date:

114/1015/20172022

Effective date:

54/1115/20122022

Next review date:

114/1014/20222027

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

Show If
grouprpm2-admins
Card
labelAdditional Information

ADDITIONAL INFORMATION

Title:

Occurrence Reporting

Document number

07.03.001.000

Revision number

1.23

Publication date:

114/1015/20172022

Effective date:

54/1115/20122022

Next review date:

114/1014/20222027

Policy Area:

Incident Review and Reporting

RPM Section (home)

ESH

RPM Section (cross-reference)

none

Functional Division

EHS

Author name/contact info

ORPS Program Manager



Revision 0 publication date

1/2/2012

Retirement date

n/a

Prior reference information (optional)

PUB-3000 Chapter 15



Inputs from more than one Functional Area?

No

List additional Functional Areas & contacts




Inputs from more than one Policy Area?

No

List additional Policy Areas & contacts




30-day notification needed?

No

30-day start date

n/a

30-day end date

n/a



LDAP protected?

No



Need TABL reminders?

No

Frequency

n/a

Brief reminder text:

n/a



Approval Sheet for this revision received (date) [Note: author is responsible}


Labels or tags:

  • Incident Review and Reporting, ESH

New terms that need to be added to Glossary/Acronym list:

  • (list items not found and context (Policy Area name) – full definition would be included in Policy)

Implementing Documents restricted to department/functional use

(optional – these will be used for tracing between requirements and associated documents)

Side bars: Side bar 1 location (cite by Policy Section # - for example: Section 4.E.2)

Sidebar 1 text:

Sidebar 2 location

Sidebar 2 text:

Sidebar 3 location

Sidebar 3 text: