Requirements:
Clear Roles, Responsibilities and Authorities for ES&H and
Competence Commensurate with Responsibilities
- Laboratory Director
- Program Directors
- Office of Assurance
- ES&H Program and ES&H Division Director
- ES&H Division Subject Matter Experts
- Safety Officers
- Safety Overview Committee and Citizen Committees
-
Managers and Supervisors, SLAC Contacts, and University Technical
Representatives
- Project Managers
- Employees and Non-employees
- Line Managers Who Oversee Facility Safety (Primarily Facility and
Area Managers) and Building Managers
- Directorate ES&H Coordinators
ISM Guiding Principles 2 and 3
Every individual performing work at SLAC must work safely and be familiar with and implement applicable laboratory safety standards as defined within this manual and other safety related documents. Clear and unambiguous lines of authority and responsibility for ensuring safety are established at all organizational levels. Institutional, functional, and individual responsibilities for environment, safety, and health at SLAC are defined in the following sections.
- Has the ultimate responsibility for safety at the laboratory and is responsible for the implementation of the
SLAC Integrated Safety and Environmental Management System.
- Chairs the ES&H Coordinating Council, through which all SLAC ES&H policy is approved (see Chapter 31, "Institutional ES&H Committees", for a complete description). Policy is driven by the SLAC Work Smart Standards set and is described chiefly in this
ES&H Manual through hazard- or process-specific chapters. Proposed policy can originate from the ES&H Division, the SLAC system of citizen committees (including the Safety Overview Committee and hazard-specific citizen committees), safety officers, or the directorates.
- Delegates to the chief operating officer responsibility and authority for ES&H policy implementation and operation of the ES&H program
- Appoints the chairs and members of the Safety Overview Committee (SOC) and citizen committees (CCs), and the chair of the Operating Safety Committee (OSC)
- Appoints safety officers for selected hazard categories
- Describe and effectively implement ISEMS through
directorate-specific ISEMS plans [doc] to be approved by the laboratory director. Such plans will be in sufficient detail to ensure all members of each directorate understand their roles, responsibilities, authorities and accountability under ISEMS.
- Investigate all high hazards or imminent danger situations to ensure that appropriate corrective actions and lessons learned are developed, implemented, and disseminated
Additional Responsibilities of the Chief Operating Officer
- Is responsible and has authority for ES&H policy
documentation and implementation. The chief operating officer (COO)
is also responsible for ES&H policy formulation, along with the
safety officers, SMEs, and citizen committees. See "Initiation and Approval of ES&H Policy".
- Oversees the operation of the ES&H Division
- Delegates to the ES&H division associate director responsibility and authority for maintaining SLAC ES&H policy and effectively delivering services, counsel, and expertise to help line management meet SLAC ISM, EMS, and ES&H objectives
The Office of Assurance administers both the quality assurance (QA) and program-specific contractor assurance systems. In so doing, it assures the laboratory director and DOE Stanford Site Office (SSO) that SLAC programs are safe, secure, adhere to ethical and compliant business practices, meet customer requirements, meet reasonable standards of formality, and meet requirements and standards specified in the contract between Stanford University and the DOE for operation of SLAC. The director of the Office of Assurance (OA) reports directly to the laboratory director to ensure independent assessments OA conducts are free from management influence of the organizations, programs, and facilities being assessed.
Key activities and responsibilities of OA:
- Maintain current performance information. Apprise the laboratory director throughout the performance year of performance against all contract performance measures, internal goals and metrics, and standards SLAC must or has agreed to follow. In so doing, line management is held accountable for desired performance levels and outcomes.
- Work closely with Operations programs to coordinate the development and maintenance of program-specific assurance systems, incorporate existing assurance activities and documents whenever possible, and avoiding duplication with requirements in other DOE standards.
- Maintain institutional standards for formality of operations, management descriptions, documents, procedures, and records. Verify adherence to such standards.
- Undertake appropriate independent assessments, validations, and other similar activities designed to confirm the efficacy of self-assessment activities. These will include verification of closeout of corrective actions and confirmation that such actions were effective.
- Serve as the primary point-of-contact with SSO on all matters of assurance. Work to make the SLAC and SSO assurance systems complementary where it is advantageous to do so.
- Formally document the overall assurance program as well as updating other existing documents that form part of the program.
DOE orders 414.1C, “Quality Assurance”, and 226.1, “DOE Oversight and Contractor Assurance Systems”, are the primary standards about which OA will form the SLAC assurance program.
The charter of the ES&H program (of which the ES&H Division is part) is to provide ES&H services, counsel, and expertise to help line management meet its obligations under SLAC’s integrated safety management and environmental management systems to protect workers, the public, and the environment. The program provides support and expertise in several ways:
- Directly from the ES&H Division and its program-specific SMEs
- From the SLAC system of ES&H-related committees (see Chapter 31, “Institutional ES&H Committees”, for a complete description)
- From safety officers designated by the laboratory director (see below and Chapter 2, “Work Authorization”, for more information)
- From SMEs outside of the ES&H Division who provide valuable support to SLAC safety policies and programs. Such SMEs will have an ES&H Division counterpart who helps ensure consistent application of ES&H policy.
The ES&H division associate director coordinates technical/SME support from within the laboratory to ensure consistent implementation of SLAC ES&H policy (see chapters 2 and 31). Other specific responsibilities assigned to the ES&H division associate director are to
- Propose, document, and implement SLAC ES&H policy, mainly within the ES&H Manual
Note: Proposing new ES&H policy is a shared responsibility (see "Initiation and Approval of
New and Revised ES&H Policy"). The ES&H Coordinating Council approves ES&H policy.
- Maintain the SLAC Work Smart Standards set set, ensuring it is relevant to current SLAC operations, and be primarily responsible for interpreting standards. The WSS set is reviewed annually following a re-assessment of hazards of SLAC operations. Changes to the WSS set must be incorporated into the contract between Stanford University and the DOE for operation of SLAC.
- Maintain necessary SMEs to administer SLAC safety and environment programs driven by laboratory policy and the WSS set
- Establish a rigorous incident and “close-call” analysis process that ensures line management identifies root causes, puts in place corrective actions to prevent a recurrence, and informs the SLAC community at large
- Represent SLAC during ES&H-related external inspections and reviews
- Administer the SLAC ES&H self-assessment program including setting ES&H performance measures, conducting oversight, and providing formal quarterly reports to SLAC management and Stanford University on ES&H performance against goals and contract performance measures (see Chapter 33, “Line Management Self-assessment”).
- Implement an employee ES&H suggestion and ES&H concern program
- Provide services (described in other chapters of the ES&H Manual and other safety- and environment-related documents):
- Central services – radiation safety, waste management, environmental remediation, environmental monitoring, fire department, health, chemical safety, industrial safety, and environmental compliance
- ES&H training
- Lessons learned
- Emergency preparedness – drills, training, site readiness, and business resumption planning
Reporting and accountable to the ES&H division associate director, ES&H Division SMEs
- Manage the ES&H program assigned to them
- Provide advice and counsel on all ES&H issues within their program areas
- Formulate ES&H policy in their program areas. When approved by the ES&H Coordinating Council, the policy is incorporated into the ES&H Manual
- Approve certain high-hazard work where the laboratory director requires special assurance as to the safety of line management operations. This approval authority is limited to those high-hazard activities described in the ES&H policy of the relevant chapter in the ES&H Manual.
- Serve on and work closely with the related citizen committee (See Chapter 31, "Institutional ES&H Committees")
Where the laboratory director has special concerns with a particular set of hazards, he/she may appoint a SLAC employee who possesses special expertise to be a laboratory safety officer (SO). As of this writing, the director has appointed SOs in radiation safety, laser safety, electrical safety, and pressure/vacuum vessel safety. SOs
- Are accountable directly to the laboratory director
- Formulate ES&H policy in their areas of expertise. When approved by the ES&H Coordinating Council, the policy is incorporated in the ES&H Manual
- Provide advice and counsel directly to line management on all ES&H issues within their areas of expertise
- Approve certain high-hazard work where the laboratory director requires special assurance as to the safety of line management operations. This approval authority is limited to those high-hazard activities described in the SO appointment letter and the ES&H policy of the relevant chapter in this manual. The SO’s approval is one of the necessary inputs for line management to authorize work.
- Hear requests for variances from ES&H requirements within their areas of expertise (see "Requesting a Variance from SLAC ES&H Requirements")
- Serve as ex officio members of and work closely with the related citizen committee (see Chapter 31, "Institutional ES&H Committees")
The SLAC Safety Overview Committee and citizen committees objectively review environment, safety, and health issues of major and significant new
- Experiments and projects
- Test beams
- Facility modifications
- Facility construction
to help promote a safe and environmentally sound operation and to verify conformance with SLAC policy. Each committee oversees a particular discipline and is composed of experts in that field or other SLAC employees who have experience and proven judgment abilities. The laboratory director assigns authority to the Safety Overview and various citizen committees to review designs and procedures for significant new experiments, projects, test beams, facility modifications or new construction to ensure that
- Hazards have been adequately analyzed
- Controls are designed that eliminate or sufficiently mitigate hazards
- ES&H has been adequately integrated
Line management must gain approval of the SOC and CCs before authorizing work for which SOC and CC reviews are required (see Chapter 2, "Work Authorization", and Chapter 31, "Institutional ES&H Committees", which discuss in greater detail the thresholds where SOC and CC reviews are required). Roles, responsibilities, and authorities are also discussed in greater detail in Chapter 31.
Managers and supervisors must
- Fully implement ISEMS as described within institutional ES&H policy documents and their directorate-specific ISEMS plans
- Authorize projects and other work only in accordance with SLAC ES&H policy, especially Chapter 2, "Work Authorization", and hazard-specific ES&H policies
- Provide all employees and non-employees (visiting scientists, subcontractors, students, or guests) a safe workplace and the necessary tools, equipment, other resources, training and time to do work safely
- Systematically assess hazards of employees' jobs by completing job hazard analysis and mitigation (JHAMs) and reviewing area hazard analyses (AHAs) pertaining to their work area (see Chapter 2, "Work Authorization"). From these, establish controls that mitigate or eliminate hazards. These must be done jointly with employees as their involvement in safety and environmental integration and work planning is key.
JHAMs must be done whenever a new employee or supervisor is assigned and
reviewed/updated each year in conjunction with the employee evaluation process.
- Supervisors will create and communicate
ES&H expectations for each employee and
- Discuss and set institutional ES&H goals for employees early in the performance period or shortly after a change in supervisor or for newly assigned employees
- Specify ES&H training following the process described in Chapter 24, “Training”
- Hold employees accountable for completion of required ES&H training
- Hold employees accountable for performing work safely and in accordance with established hazard controls and the ES&H Manual
- Prominently describe safety performance in annual personnel performance evaluations
- Make safety a prominent topic at staff meetings. This should include meaningful safety briefings, discussing SLAC Today articles on safety, lessons learned, and so on
- Ensure safety aspects of each job are evaluated and that positions are filled only with candidates having requisite competence
SLAC contacts and university technical representatives (UTRs) assigned to non-employees generally have the same obligations as a supervisor:
- Require training for guests or subcontractors appropriate to the hazards they will encounter following the process described in the Chapter 24, “Training”
- UTRs will always oversee construction subcontractors and require training sufficient to ensure safe operations and compliance with SLAC ES&H policy (see chapters 24, “Training”, and 42, “Subcontractor Construction Safety”)
- Responsible and accountable for all ES&H aspects of their projects
- Oversee UTRs, especially the ES&H aspects of their performance expectations
- Authorize commencement of project work following Chapter 2, "Work Authorization"
- Document and implement technical and safety requirements
- Control change processes and ensure ES&H considerations (hazards, hazard controls, and work authorizations) are reassessed when work scope changes
- Thoroughly understand and competently perform the five ISM core functions as steps to sustained safe work performance:
- Define work scope
- Analyze work for hazards
- Put in place controls that mitigate or eliminate hazards
- Do work within controls
- Continuous feedback and improvement of work practices to improve safety
While these five ISM core functions lay a foundation for safe work, no amount of safety documentation, work authorization, personal protective equipment (PPE), or controls can ever assure safety without each individual (employee and non-employee alike) being personally responsible for safety. Individuals must always keep the ISM core function five-step approach to working safely foremost in their minds as they conduct daily work at SLAC.
- Be knowledgeable of the laboratory policy on stopping unsafe work and unsafe activities (see Chapter 2, "Work Authorization") or Article VII.A.6, "Refusal to Perform Assigned Work", in the Collective Bargaining Agreement between Stanford University and United Stanford Workers, Local 715.
- Attend new employee safety orientation training (see Chapter 24, "Training"). Additionally
- Employees, in consultation with their supervisors, must complete a Job Hazard Analysis and Mitigation Form (JHAM) and conduct a SLAC Training Analysis (STA) within 30 days of employment and fulfill all training requirements identified in their SLAC Training Analysis (see Chapter 24, "Training"). They must also demonstrate an understanding of the requirements of the ES&H manual chapters applicable to the work they will perform.
- Subcontractors must complete contractor-specific safety orientation and training (if required) before they perform any work.
- Users must complete the facility-specific safety orientation and training before beginning the "hands-on" portion of their experiment.
- Proceed with work only after line management has authorized work. Work only within controls specified by the JHAM or other work authorizations.
- Ensure the safety, security, and emergency preparedness of their respective facilities, areas, or buildings
(See the Building Manager
Program Manual)
- Coordinate construction and maintenance activities, especially electrical hardware installations
- Act as the liaison with visitors and regulatory agencies visiting the respective buildings
Line managers who oversee facility safety and building managers are
designated in directorate-specific ISEMS plans (see
Procedures and Forms for a template).
- Reporting directly to their program director, serve as the primary point of contact and program director’s personal representative within their directorate for all matters concerning the implementation of ISEMS and the laboratory’s ES&H policies. However, line management is fully responsible and accountable for ISEMS implementation.
- Support line management as it meets responsibilities under institutional and directorate policy, plans and procedures
- Working with line management and at times work approval bodies (SOs, CCs, SMEs) facilitates and resolves ES&H issues
- Administer their directorate ISEMS program as described in the directorate’s ISEMS plan
- Help maintain documentation required by the
directorate-specific ISEMS plan [doc] and Chapter 33, “Line Management Self-assessment”
- Ensure proposed ES&H policy is reviewed by key staff members within their directorate and comments are provided to the policy’s author
- Maintain an awareness of project and program status within the directorate so as to support line management as early as possible when work scope changes
- Support line management in identification, analysis, and control of hazards
- Schedule directorate self-assessments, constitute peer review teams (see Chapter 33, “Line Management Self-assessment”), and track deficiencies until closed out
- Participate in external reviews
- With the program director, help define roles of department and lower-level ES&H coordinators
- Meet periodically with the ES&H division associate director
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