POLICY

A. Purpose

Due to the risks posed by hazardous materials at the Lawrence Berkeley National Laboratory (LBNL), special approval, acquisition, and management practices are needed to ensure personnel safety and the Lab’s compliance with Department of Energy (DOE) requirements. The DOE maintains approval authority for certain scientific research involving hazardous materials at DOE National Laboratories, including LBNL. Depending on the severity of risk associated with the restricted substance, acquisition approval may require some or all of the following:

• Written approval by DOE following asset characterization and risk determination as required by DOE O 470.3C. This includes dispersion modeling conducted by the Security and Emergency Services Division.
• Additional physical security safeguards for the laboratory and/or facility housing the material.
• Research leadership approval and additional training for personnel needing access to the material.

This policy establishes the approval required before acquiring hazardous materials that meet the thresholds outlined above, in accordance with:

• DOE Order 470.3C, Design Basis Threat (DBT),
• DOE Order 471.7, Controlled Unclassified Information,
• DOE Order 151.1E, Comprehensive Emergency Management System, and
• LBNL institutional requirements.

B. Persons Affected

This 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 the disposal of hazardous materials at LBNL.

C. Exceptions

There are no exceptions. All use of hazardous materials must follow the review and approval process defined in this policy.

D. Policy Statement

All hazardous materials meeting the following definitions and/or criteria must be screened prior to being brought into an LBNL facility:

1. In accordance with DOE O 151.1E, hazardous materials include hazardous biological agents and toxins, radioactive or radiological materials that emit ionizing radiation, and solid, liquid, or gaseous substances that are toxic, explosive, flammable, or corrosive, or that could otherwise adversely affect the health and safety of workers, the public, the environment, or site operations if released or lost from control.
2. Any substance regulated by the United States Department of Transportation per 49 Code of Federal Regulations Parts 100-185.
3. Any substance identified by the United Nations Model Regulations on the Transport of Dangerous Goods, as noted in Section 14 of the vendor's Safety Data Sheet.

D.1  General

1. All LBNL hazardous materials must be reviewed (screened) and, if required, approved prior to acquisition, arrival, and use at LBNL. Approval may include the DOE-Berkeley Site Office (BSO) Field Element Manager, DOE-BSO Officially Designated Federal Security Authority, and the area Division Director and Associate Laboratory Director.
2. All hazardous materials must be received, stored, used, and disposed of in compliance with DOE Orders and the conditions outlined by the DOE approving authority, and in accordance with Environment, Safety, and Health chemical management policies and procedures.
3. 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, Criteria and Review Approach Documents 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 process in 10 CFR 830 and the Unreviewed Safety Issue process outlined in DOE Order 420.2C Safety of Accelerator Facilities.

Updates or additional analysis may be required when changes occur that affect the hazards considered in the Security and Emergency Services Division’s existing DOE-approved deliverables (e.g. All-Hazards Survey), including:

• A proposed or discovered change in 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 the 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 identified in an approved WPC activity and/or DOE-approved deliverable. Example: consolidating hazardous material(s) into larger containers, such as a chemical bath or storage tank.
• Modifications to equipment, systems, or controls that alter the scope, initial conditions, or assumptions of the WPC activity and/or DOE-approved deliverables, and could affect the hazards or scenarios previously evaluated. Example: Modifying a toxic gas manifold system.
• Situations where previous hazard analyses are determined to be inadequate or no longer representative of the facility configuration (e.g., analysis does not match the facility configuration due to a “discrepant as-found” condition).

E. Roles and Responsibilities

F. Resources

For 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.

For further information on the appropriate acquisition, approval, and handling of hazardous materials at LBNL, see chemical management policies and procedures in Environment, Safety and Health Manual, 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 further information on identifying 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 and security, email [email protected] or contact your supervisor or Division Safety Coordinator.

G. Recordkeeping Requirements

None

H. Implementing Documents

I. Contact Information

• SES Hazards Analysts: [email protected]
• EHS Chemical Hygiene & Safety SME
• EHS Gases: Compressed/Hazardous/Toxic SME

J. Revision History

DOCUMENT INFORMATION

Source Requirements Documents

• DOE Order 151.1E, Comprehensive Emergency Management System
• DOE Order 470.3C, Design Basis Threat (OUO)