POLICY

A. Purpose

Lawrence 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:
  • Job Hazards Analysis (JHA) for work done by workers and affiliates
  • Task-based Job Hazards Analysis for unpredictable, short-term, or unusual work done by workers and affiliates
  • Subcontractor Job Hazards Analysis (sJHA)
  • Construction subcontractors' ES&H submittal package (Construction JHA)
  • Activity Hazard Documents (AHDs) for higher-hazard work
  • Temporary Work Authorization (TWA)
  • Biosafety Work Authorization
  • Radiological Work Authorization (RWA)
  • Facility Work Authorization
• Ensuring that the process and authorizations are documented prior to starting work

B. Persons Affected

Berkeley Lab employees, visitors, affiliates, and subcontractors who perform work in technical areas or on construction sites

C. Exceptions

Those not performing hands-on work, 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

1. Safety of all operations at Berkeley Lab is managed according to the principles outlined in LBNL PUB-3140, 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:
   
   1. Identifying appropriate safety standards and requirements
   2. Providing institutional tools, procedures, and methods to facilitate control of hazards and compliance with requirements;
   3. Providing subject-matter-expert support
2. 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:
   

   1. For Berkeley Lab employees and affiliates, line management authorization for routine work is granted using the Job Hazards Analysis (JHA) program. Work Process A discusses the JHA, and the Job Hazards Analysis program provides detailed requirements.

   2. Operations in a particular facility, under certain circumstances, may require authorization. Work Process B provides general guidance on facility-based authorizations, while Appendix C of the Safe Work Authorizations program in the ES&H Manual provides a precise process for each type of facility-based authorization.

   3. Formal authorizations are generally required for more extensive or inherently dangerous work. Trigger levels for such authorizations are located in Appendix B of the Safe Work Authorizations program in the ES&H Manual. Work Process C describes the process for formal authorizations.

   4. The Temporary Work Authorization (TWA) process, which is described in Work Process C.2, may be used if it:

      1. Is not a permanent component of ongoing work
      2. Does not involving elevated hazards
      3. Is of a short-term duration (two weeks or less)
      4. Has a limited and clearly defined scope
   5. For non-construction subcontractors, the 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.
   6. For construction activities, Construction Safety Program Work Process C is used to ensure that construction subcontractors adequately evaluate hazards and implement safety controls.
   7. The Biosafety Authorization System (BAS) database is an inventory of Berkeley Lab Biosafety Work Authorizations, including Biological Use Authorizations (BUAs), Biological Use Registrations (BURs), and Biological Use Notifications (BUNs).
   8. Radiological Work Authorization and Permit Programs are described in ES&H Manual Section 21.6, Radiological Work Authorization and Permit Programs.

E. Roles and Responsibilities

F. Definitions/Acronyms

G. Recordkeeping Requirements

H. Implementing Documents

I. Contact Information

Activity Hazard Document Guidance and JHA Subject Matter Contact

sJHA - Subcontractor Safety Assurance Program Manager

Construction Safety

Radiation Protection Biosafety Officer

EHS Division

J. Revision History

DOCUMENT INFORMATION

Source Requirements Documents

• Title 29, Code of Federal Regulations, Section 1910.119, Process Safety Management of Highly Hazardous Chemicals
• DOE Order 420.2C, Safety of Accelerator Facilities
• DOE Order 435.1, Radioactive Waste Management (only those sections/subchapters adopted into the current Contract 31 ESH Standards set)
• California Public Resources Code, Section 21000 et seq. (CEQA, California Environmental Quality Act)
• Title 19, California Code of Regulations, Section 2770.5, List of Substances
• Title 22, California Code of Regulations, Section 66260.1 et seq., California Hazardous Waste Regulations

Other Driving Requirements

• Title 42, United States Code, Section 4321 et seq. (NEPA, National Environmental Policy Act)

Implementing Documents