Requirements: Integration of Environment, Safety, and Health

Adequately protecting workers, the public, and the environment, like research integrity, scientific discipline, and fiscal responsibility, is a product of culture and sound management. To achieve a truly integrated systems approach to doing work safely, environment, safety, and health (ES&H) concerns must be an integral part of work from initial planning through final execution.

SLAC uses ISM’s seven guiding principles (GPs) and five core functions (CFs), discussed below, to achieve ISM. All are reflected in the detailed policies and procedures of the laboratory. As roles, responsibilities, and authorities are discussed below, it is important to understand SLAC’s organization: See the SLAC Organization Organizational Chart

Principal investigators, managers, and supervisors are expected to incorporate these principles into the management of their work activities largely through directorate-specific ISEMS plans and work authorization processes. While these principles apply to all work, their exact implementation must be tailored to the complexity of the work and the severity of the hazards.

Line Management and Individual Responsibilities, Authority, and Accountability for ES&H

ISM Guiding Principle 1

Each SLAC line manager (laboratory director down to and including the first-line supervisor) and each individual (employee and non-employee alike) working at SLAC is accountable for

• Protecting the public, workers, and the environment
• Integrating ES&H into work
• Active and rigorous communication on ES&H and ISEMS

Responsibilities for safety are shared by all. However, line management has a special responsibility to model safety behavior, establish patterns, and set goals for safety consistent with a strong safety culture.

ES&H considerations must be part of all planning processes, commencing with identification of work scope, identification of hazards, what standards apply, what controls are to be implemented, the competencies required to work safely and in an environmentally sound manner, and finally the assurance that each of these elements are in place before work is authorized to proceed. In addition, safety must be a primary consideration in all that individuals do, even non-job specific activities like walking, driving, or riding a bicycle.

SLAC’s line management focuses on safe accomplishment of mission, understanding assignments, and carrying out the core safety management functions correctly and efficiently. These principles are dependent both upon management commitment and individual involvement and accountability. Management commitment is demonstrated by

• The documented ISMS, EMS, and ES&H policy statements that are communicated throughout the organization
• Managers’ accountability for safety performance
• The visible presence of managers addressing safety issues
• Fostering employee involvement in development and implementation of the ISEMS
• Emphasizing the importance of individual accountability for performing work safely and in an environmentally sound manner

Individuals should be actively and continually involved in the development and deployment of the ISEMS processes that address workplace safety, public safety, and environmental protection. They must continually examine ISEMS processes for on-going improvement and actively pursue improvements with their supervisors.

Individual accountability for performing work safely is a key to the success of the SLAC ISEMS.

Clear Roles, Responsibilities and Authorities for ES&H and Competence Commensurate with Responsibilities

see separate page for Roles & Responsibilities

Balanced Priorities

ISM Guiding Principle 4

DOE and SLAC invest in programs and projects in pursuit of SLAC's scientific missions. Balanced priorities, that is, keeping the need for investments in safety equal in importance to scientific objectives, are ensured by both organizations. The first section below discusses how safety is balanced with program proposals contained in DOE field task proposals (FTPs), DOE line-item requests, or proposals to other sponsors through work for other (WFO) applications. The second section discusses how ES&H is balanced with program needs in the annual infrastructure investment process. In this process, a pool of funds is created each year by taxing the program dollars received from DOE and other entities.

FTPS, WFO Proposals, and Line Item Requests

Individual DOE FTPs, DOE line-item requests, and WFO proposals must include funding sufficient to ensure proposed work will be performed safely and in an environmentally sound manner. SLAC programs that submit FTPs and WFO proposals are directly responsible for this as are SLAC managers at all review levels. Line item requests submitted to DOE's Office of Science (larger, usually facility-level investments) will follow DOE acquisition management orders to ensure the same.

Annual Infrastructure Investment Process

ES&H considerations are an integral part of planning infrastructure improvement. The annual SLAC Infrastructure Review Committee (IRC) process issues a call for proposals each spring. The SLAC directorates complete activity data sheets (ADSs) describing the work they want done in support of their programs. The ES&H Division and the RPM committee assign a risk prioritization model (RPM) score to help prioritize the proposals lab-wide. RPM scores consider the ES&H impacts associated with each ADS proposal. The ES&H Coordinating Council reviews the ADSs, the assigned RPM score, and the overall prioritization. When their review is complete, the ADSs are sent on to the IRC and ultimately to the laboratory director for approval.

Identification of ES&H Standards and Requirements

ISM Guiding Principle 5

Each standard in the current set of work smart standards was selected for one of three reasons:

• It is a legal requirement
• It significantly contributes to the health and safety of workers and the public, or
• It enhances environmental protection

These standards are selected by teams of ES&H SMEs and representatives from the directorates and must be approved by the DOE Stanford Site Office (SSO). The ES&H Division maintains the WSS set which forms the basis for the hazard-specific ES&H policy in the ES&H Manual and other safety- and environment-related documents. The WSS set is incorporated into the DOE-Stanford University contract for operation of SLAC and creates a binding agreement that SLAC will follow all work smart standards.

Establishment and Tailoring of Hazard Controls

ISM Guiding Principle 6

Administrative and engineering controls to prevent and mitigate hazards are to be appropriately tailored to the work being performed and the risk of harm.

The tailoring process

• Identifies controls for specific hazards
• Establishes boundaries for safe operation
• Describes how controls are implemented and maintained

Tailoring controls is described within the work authorization process in Chapter 2, "Work Authorization", and more precisely in other hazard-specific chapters of this ES&H Manual.

Authorization Basis

ISM Guiding Principle 7, ISM Core Functions 1 through 5

Chapter 2, "Work Authorization", describes how work is authorized following ISM core functions.

Initiation and Approval of New and Revised ES&H Policy and Requirements

New

New policy will be developed following the steps listed below, with the close coordination of the ES&H Division. New or amended ES&H policy can be authored and initiated by

• ES&H Division SMEs
• SMEs outside the ES&H Division
• Safety officers
• Citizen committees, including the SOC
• The directorates

The steps are these:

1. Author and ES&H Division SMEs develop content.
2. Stakeholders, selected by the author and the ES&H division associate director, review content and assess feasibility.
3. Author responds to comments and revises draft.
4. Author invites comments laboratory-wide. At this stage, the draft policy is to describe a proposed implementation plan that acknowledges new requirements will require a period to be met fully. Directorate ES&H coordinators review proposed policy and ensure key staff members of their directorate review and comment.
5. Author responds to comments and revises draft. If changes are substantive, a second laboratory-wide review cycle may be warranted. The decision is left to the ES&H division associate director.
6. ES&H division associate director and COO review revised text and comment and response record, check for concurrence, and forward proposed policy to the ES&H Coordinating Council.
7. The ES&H Coordinating Council approves/disapproves proposed policy. Where the policy is approved, an implementation date will also be identified by the ES&H Coordinating Council, recognizing that some period is likely to be required for SLAC management and staff to conform to the new policy.
8. The ES&H division associate director incorporates policy into the ES&H Manual or other ES&H-related document and publicizes the new policy.

Comment and response records will be accessible.

Revised

The associate director (AD) of ES&H will ensure that revision to ES&H policy which he/she judges to be major and substantive go through the eight-step process described in the previous section. When changes are not substantive and major, the AD of ES&H may approve and implement revisions without further review or ES&H Coordinating Council approval. In all such cases, he/she will provide notice to the ES&H Coordinating Council and, as appropriate, provide general notice to the laboratory population of the change. Approval authority for format, style, and production changes can be delegated by the AD of ES&H to staff within the ES&H Division. (See “About This Manual” for more details.)

All ES&H Manual chapters will be reviewed annually to assess the need for revisions. A record shall be kept by the ES&H Division documenting this process.

In all cases of new or revised ES&H policy, implementation, including the effective date, will indicated.