ISM Core Function Teams Assessment Plan
January 2008
Appendix 12 – Core Function #3 – Develop and Implement Controls
Recommended Activities and Lines of Inquiry
General to the Assessment
· Review the JLab ISM Website and provide feedback on content
· Review the JLab ISMS Program Description and provide feedback on content
Document Reviews
· Are documents being used the most current version?
· Are forms being used the most current version and are they filled out properly?
· Is collected data dispositioned in accordance with the procedure or applicable program document?
· Are there conflicting requirements between procedures and program documents applicable to the activity being reviewed?
Observing the Conduct of Activities
· Attend pre-job briefing
· Review work control document applicable to activity being performed
· Is it clear which document(s) or procedure(s) is applicable to the activity being conducted?
· Can the work control document be followed as written?
· If not, is the activity stopped until the work control document is revised (if necessary)?
· Is authorization received prior to commencing conduct of activity?
· Are all hazards addressed in the work control document or hazard analysis document?
· Are hazard controls specified in the work control document being followed?
· Record observations and questions and verify facts either during the observation or after with the goal of being able to make a positive statement about what was observed in the report.
Interviews
· Strive to ask open ended questions rather than yes/no questions
· Conduct interviews either before observing activities, after observing activities, or both
Assessment Report
· While reviewing documents, observing activities, and conducting interviews keep in mind the information that will be needed to make a concise and complete statement in the report related to the objectives of the assessment focus area
Core Function Specific
From the U.S. DOE, Office of Independent Oversight, Criteria Review and Approval Document - Work Planning and Control Implementation Inspection Criteria, Approach, and Lines of Inquiry (11/26/07)
Inspection Criteria: Management systems for work control are developed and effectively implemented for work activities that ensure development of adequate hazard controls for performing the work safely and mitigating environmental impact.
Inspection Criteria: Line management has established processes for identifying and tailoring controls for hazards associated with all facilities, operations, and work activities.
Inspection Criteria: Hazard controls are established based on an analysis of hazards, vulnerabilities, and risks in the work environment (e.g., radiological, chemical. industrial, physical, and natural phenomena).
Inspection Activity: Review work planning and control processes and procedures. Interview personnel including project personnel, group leaders, subject matter experts, managers, work control managers, foremen, supervisors, environmental, safety and health support personnel, and operations/technician personnel.
Inspection Activity: Review selected safety requirements, hazard control plans, sampling results, permits (radiological work permits, industrial hygiene/industrial safety), work documents, procedures, pollution prevention opportunity assessments, and monitoring protocols. Observe work activities.
Inspection Activity: Interview facility managers, project leaders/supervisors, workers, and ES&H personnel.
Inspection Lines of Inquiry:
· Are standardized hazard controls developed and used in an appropriately graded approach based on project/work complexity and risk, performance frequency, and hazard analysis results?
· Do controls encompass each phase of work performance and all aspects of the work, including potentially abnormal or emergency situations?
· Are the knowledge, skills, and abilities of the work force considered when selecting the form of controls'?
· Are the types of controls (engineering, administrative, and personal protection equipment) applied in the correct sequence and with an appropriate technical basis?
· Are the hazard controls comprehensive and adequate for maintaining planning efficiency while ensuring acceptable hazard mitigation or elimination?
· Are corresponding training requirements incorporated into controls and hazard assessments'?
· Are thresholds identified for involvement of ES&H personnel in the tailoring or implementation of hazard controls?
· Are workers/supervisors stop work authorities and responsibilities clearly defined for unexpected hazards or safety concerns?
· Do procedures address liaisons and interfaces between organizations to ensure conflicts and overlapping work activities are properly coordinated and resolved?
· Are control sets sufficiently analyzed to ensure they do not conflict or introduce additional hazards?
· Do controls sufficiently provide notification and afford protection to co-located workers who may either be present or traverse the areas potentially impacted by the activity?
· Is independent safety review of the adequacy of controls provided for higher hazard activities?
· Are workers involved in the development of controls?
· Are parameters clearly defined and established in appropriate facility procedures? Are hazard controls sufficient to ensure that facility and other operating limits are not exceeded?
· Have facility safety requirements been clearly translated into facility, building, system, and equipment specific information that are available and usable by workers within the facility?
· Are appropriate hazard controls from hazard analyses and permits included in approved work documents and are they adequately implemented'?
· Are standardized hazard controls developed and used in an appropriately graded approach that considers work complexity, performance frequency, and magnitude of the risks'?
· Are work documents complete with adequate procedures, instructions, and/or drawings, and are bounding conditions and limitations clearly specified?
· Are permits appropriately tailored, specified and integrated into the work package (e.g., Lockout/Tagout, radiological work, confined space, hot work, energized electrical, elevated work, and asbestos abatement)?
· Is the reliability of hazard controls for higher risk activities assessed and failure consequences determined and considered?
· When project/work scope and tasks are changed, are the hazard controls reviewed for impacts?
· Are training requirements for personnel needed to perform the work in accordance with established controls clearly defined, specified and implemented'?
· Are appropriate analytical parameters and data quality objectives included in sampling and analysis programs?
· Are the required administrative and engineering controls in place at locations where waste is generated and stored (for example, signs identifying less-than-90-day storage areas) per internal and external requirements?
· Are signs and postings clear and current with regard to hazards and entry requirements?
· Is there appropriate linkage between tasks, hazards, and hazard controls in work control documents?
· Are workers and appropriate environment, safety, and health professionals included on planning teams and involved in hazard control development? Are minimum thresholds identified, based on the hazards and risks, which require the involvement of ES&H and waste management personnel and subject matter experts when developing work packages and during work activities?
· Do environmental, waste management, radiological, health, safety, and operations personnel have an adequate understanding of each other's requirements and processes to minimize environmental impacts and meet regulatory requirements?
· Are the roles and responsibilities for ES&H subject matter experts, and reviewers well documented, and are development and implementation or controls established and understood?
Potential assessment activities applicable to this core function
Partial List of JLab Documents/Processes Applicable to this Core Function
· ES&H Manual Chapter 3210
· Standard Operating Procedures
· Operational Safety Procedures
· Temporary Operational Safety Procedures
· Training
· Laser Operations Directives
· Experiment Safety Approval Form
· Accelerator Operations Directives (AOD)
· Conduct of Operations
· Experiment Safety Assessment Document
· Radiation Safety Assessment Document
· Subcontractor Safety Plan
Interviews – Potential Questions
Q: How do you apply a graded approach for applying hazard controls based on the work complexity and risk?Q: Do your hazard controls ever include specialized training? If so, how is this implemented?
Q: If a unique or high-hazard risk identified, is there a different type of review conducted? / A: Any risk not typically encountered at the Lab could undergo the USI process.
Q: What is the JLab “authorization basis”? / A: The JLab authorization basis starts with the Final Safety Assessment Document (FSAD). This document looked at the overall operation of the accelerator and related programs and evaluated potential risks to personnel and the environment both on and off site. This evaluation led to the establishment of safety envelopes for both the accelerator and the free electron laser. The safety envelop provides the boundaries within which all those systems need to operate to ensure safe operations.
Note: the FSAD is currently being updated.
Q: How is this authorization basis translated into facility, system and equipment specific information? / A:
Q: How do we ensure that the hazard controls are clearly communicated? / A: Hazard controls are communicated in a variety of ways. For the majority of tasks, there is a written (or electronic) work package that is present at the work location. We also conduct pre-job briefings where hazard controls are discussed.
Q: When project/work scope and tasks are changed, how are the hazard controls reviewed for impacts? / A:
Q: How are workers involved in hazard control planning? / A: Yes, workers are involved in planning the work, review the hazard analysis, and review and discuss the controls.
Q: How do we ensure that ESH&Q personnel have an understanding of all the work occurring at the Lab? / A:
Q: How do we measure the effectiveness of subcontractors’ hazard controls? / A:
Q: Describe some environmental controls you have seen placed on a work activity. / A: Spill kits, special containers for regulated waste, pollution prevention analysis to see if we can replace or reduce the amount of hazardous materials used.
Q: How are these standards and requirements flowed down to subcontractors? / A;
Appendix 12 2
CF#3 Lines of Inquiry Page 2