NSD Off-Site Facility Work Safety Policy

Disclaimer: The policies created for the Nuclear Science Division supplement Berkeley official policies. Berkeley Lab's official policies override any adopted or proposed policies for the Nuclear Science Division. 

POLICY

A. Purpose

This policy establishes guidelines to ensure a safe and healthful workplace for Nuclear Science Division (NSD) employees and affiliates working at off-site facilities. It incorporates the off-site safety program developed in the 2016 NSD Self-Assessment and addresses the unique challenges and hazards of off-site work. The policy ensures compliance with LBNL’s safety standards, Integrated Safety Management (ISM) processes, and Work Planning and Control (WPC) requirements. A list of off-site facilities and their safety ratings is included in Attachment B.

B. Exceptions

This policy does not include computer work at home or fieldwork, where there is no other safety program; those are covered by the LBNL ergonomic program and WPC, respectively.

C. Policy Statement

Off-site safety concerns for NSD workers generally involve travel to, often foreign, and work at facilities where there is a safety program, but the safety program is not under the control of LBNL and may be quite different from the LBNL safety program. Examples include work at Gran Sasso (Italy), CERN (Switzerland), FRIB (Michigan State University), and Brookhaven National Laboratory (New York).
Listed below are summaries of the LBNL policies that guide safety at off-site locations:

• WPC is not used to authorize off-site work when there is a host facility authorization process (commonly part of the safety program).
• NSD workers use the 5-step ISM process in their off-site work, but the controls, including training, are set by the host facility.
• NSD workers are expected to follow the host facility's safety and training requirements.
• NSD workers are expected to report any vehicle accident, injury, or illness per LBNL requirements.

In general, there are 4 different types of facilities NSD personnel could be working at:

1.   DOE National Laboratories that follow ISM and are equivalent to our system (Brookhaven, for example).
2.   Facilities that NSD has worked with for a long time and are deemed safe (CERN, for example), or can demonstrate equivalence to LBNL safety systems (FRIB, for example).
3.   Facilities that are safe for the most part, but there may be some challenges (Gran Sasso, for example).
4.   Facilities where NSD workers need to follow the LBNL safety program because the host safety program is not equivalent and has some very real safety challenges.

NSD uses the attached checklist (Attachment A) as a tool to help with the assessment of safety at facilities that are newly partnered with NSD.  To classify a facility into categories 2, 3, and 4 (above) the assessment should be conducted by the NSD Division Safety Coordinator (DSC) through site visits, review of the site’s online documents, or discussions via phone or video call.  The results will be discussed with the workers, line management, and other knowledgeable staff, and a consensus classification will be determined. EHS will be consulted as needed, especially on safety programs that seem lacking.

If an off-site facility is categorized as a level 3 or 4 in the above scheme, then NSD will use WPC to protect our workers by setting controls above and beyond what the host requires. Specific WPC activities would be developed for the off-site activities, detailing the hazards and controls. For a level 3 facility, WPC activities would focus on the areas found to be lacking. For a level 4 facility, WPC would be used for all activities at the facility.

In all cases, NSD workers follow host facility policies and requirements, but may also be required to follow the LBNL safety program or parts of the LBNL safety program. For all work situations, NSD workers can, and should, stop their own work if they feel unsafe. DOE national labs and some other host facilities have formal Stop Work policies, but even at those places that do not, any NSD worker can stop their own work and/or leave. The NSD worker is expected to alert his LBNL supervisor to the unsafe situation and get help from LBNL personnel (DSC, EHS, and line management) to address the issue.

NOTE: All work with radioactive materials and/or radiation-generating devices at Nuclear Regulatory Commission, Agreement State, or other regulated or licensed sites in the US or abroad requires authorization through a WPC activity.

D. Roles and Responsibilities

• Personnel: Follow host facility safety policies, complete required training, and use Stop Work authority if necessary. As needed, assist with safety assessments. Report vehicle accidents, injuries, and illnesses per LBNL requirements.
• Supervisors: Notify the DSC of pending work at off-site facilities. Assist with safety assessments. Ensure workers are authorized for off-site facility work activities and verify adherence to safety and reporting requirements.
• Division Safety Coordinator (DSC): Oversee implementation of this policy, conduct safety assessments, and address safety concerns.

E. Definitions/Acronyms

F. Implementing/Supporting Documents

• ES&H Manual: Chapters 1, 5, 6, and 24.
• Attachment A: Off-Site Safety Assessment Checklist.
• Attachment B: List of Off-Site Facilities Where NSD Staff Work.
• RPM Off-Site Work Authorization Policy.

G. Contact Information

For questions or clarification on this policy, contact:
Division Safety Coordinator (DSC):
Jeff Bramble
Email: [email protected]

H. Revision History