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Requirements (Section 5)

SLAC ES&H and ISM Policies (5.1)

As part of ISM and as described in both the SLAC ISEMS Description and Chapter 1, "General Policy and Responsibilities", of the ES&H Manual, line managers are fully responsible for and accountable to the laboratory director, through their management chain, for safe work performance. Further, line managers shall authorize work activities at SLAC following the five ISM core functions:

1. Define work scope. The tasks that are to be accomplished as part of any given activity must be clearly defined.
2. Analyze hazards. Once tasks are defined, hazards and risks to workers, the public, and the environment associated with the activity must be determined.
3. Establish controls. SLAC will follow a control hierarchy:

• Elimination or substitution of the hazard where feasible and appropriate
• Engineering controls will be sought next to mitigate or eliminate hazards.
• Work practices and administrative controls (such as signs and procedures) will be implemented wherever hazard elimination or engineering controls cannot be implemented.
• Only when hazards are low and where further engineering or administrative controls are not feasible will hazards be mitigated or eliminated through the use of personal protective equipment (PPE). PPE is infrequently the only control. It is common for PPE to be used in conjunction with both engineering and administrative controls.

1. Perform work within controls. Work is performed within controls established by ISM Core Function 3.
2. Continuous feedback and improvement. The activity and its associated controls must be continually examined to determine if the controls are effective. If they are not, line management must make changes.

Activities range from simple one-time tasks to large accelerator operations. Line management applies the five ISM core functions to all levels.

The process described in the sections that follow is based on the guiding principle that only line management authorizes work. At many hazard levels, an ES&H policy chapter in this ES&H Manual describes how ES&H standards applicable to a particular hazard are to be used to ensure work is done safely and to implement the five ISM core functions. Line management is obligated to follow the process described in each of these chapters.

For work authorization involving higher hazard levels, ES&H policy may require line management to gain approval from safety officers or citizen committees (see Chapter 31, "Institutional ES&H Committees"), or secure permits from SMEs in the ES&H Division or elsewhere at SLAC.

Individual ES&H policy chapters describe the approval roles and the thresholds at which work requires approval. In cases of accelerator operations, DOE hazard analysis and safety assessment document rules may come into play. While these are all necessary steps to ensuring work is done safely, only line management truly authorizes work.

How Line Management Authorizes Work (5.2)

Work authorization must be preceded by the implementation of ISM core functions 1 through 3. Chief in this process is hazard abatement/mitigation. Line management must ensure that all identified and potential hazards are prevented or abated/mitigated in a timely manner. For existing hazards, the line must

• Prioritize and implement abatement/mitigation according to risk to workers
• Implement interim protective measures pending final abatement
• Protect workers from dangerous safety and health conditions
• Consider the interaction between workplace hazards and other hazards such as radiological

Hazards must be prevented or abated in a timely manner. Following requirements of ES&H standards, policy, and requirements documents (especially the ES&H Manual) will in most all cases adequately mitigate hazards. For hazards not adequately mitigated, line management will follow a hazard mitigation hierarchy:

1. Elimination or substitution of hazard where feasible and appropriate
2. Engineering controls where feasible and appropriate
3. Work practices and administrative controls that limit worker exposures
4. Finally, personal protective equipment (PPE)

The discussion of how work is authorized at SLAC is presented in order of complexity, from routine work with low risk of exposure to hazards to complex activities with significant exposure to hazards. The final section describes how work is jointly authorized in cases where internal resources conduct work in areas and facilities run by other organizational elements of SLAC.

The ES&H Division is immediately available to line management for hands-on assistance in the analysis and mitigation process. Services the ES&H Division provides include training in the completion of forms, reviewing hazards, or facilitating group assessments and reviews. ES&H also supplies a library of tools, information, and resources to support the processes described below.

Work Authorizations for Individuals (5.2.1)

Job Hazard Analysis and Mitigation

Line management uses the job hazard analysis and mitigation (JHAM) process for planning safe work by identifying task steps and their hazards, establishing tailored controls to mitigate hazards, documenting results, and monitoring effectiveness - the intent of the integrated safety management system (ISMS). In work-planning and development of hazard elimination, hazard controls, or other forms of mitigation, supervisors should consider

• Potential upset conditions, accidents, and what if scenarios and their consequences
• Potential additional hazards caused by controls themselves, individually or in combination. For example, excessive PPE can cause heat exhaustion and combining controls can have unintended negative effects.
• How work activities of one scope do not adversely affect the safe work of another
• Including instructions in the JHAM on worker response to unexpected conditions
• Incorporating relevant lessons learned/feedback into active and in-development JHAMs in a timely manner

The JHAM is also used to document that line management authorizes work, though individuals will generally receive daily work instructions from their management chain. (For higher hazard work, additional work authorization may be required as described in the following sections.)

This process, completed in partnership by supervisor and the individual, prompts the specific controls, procedures, and personal protective equipment necessary to safely complete a project, task, or work activity by seeking the participation of those who will perform the work.

Through the JHAM process, specific permits, approvals, and requirements (see following sections) and training in addition to that driven by the SLAC Training Assessment (also in following sections) may be identified. It also reflects current SLAC ES&H policy with respect to the work and hazards present in the job functions performed by an employee. Line management may need to refer to SLAC ES&H policy relevant to the hazards faced by workers to ensure no additional reviews and approvals are necessary. (See the JHAM web page for a sample JHAM and instructions for filling out the JHAM form.)

Routine JHAM

Every individual must have a JHAM document covering their routine activities. As part of the annual performance review for employees, each supervisor certifies that he/she and the employee have carried out the JHAM process. The JHAM process is also performed any time an individual's job function or working conditions change. Copies of the current routine JHAM document are retained by the employee and supervisor.

Non-routine JHAM

Any activity that a worker is assigned that is not described within their current routine JHAM is non-routine work and the non-routine JHAM process must be carried out prior to beginning that activity. The employee and supervisor each retain a copy of the non-routine JHAM document which is valid for the duration of the work and a copy must be available at the worksite. If the described work becomes a part of the employee's regular work portfolio it is incorporated into their routine JHAM.

Area Hazard Analysis

An area hazard analysis (AHA) is a formalized process by which line management and its personnel identify hazards associated with the physical environment, as opposed to the activities, of areas within which individuals work. AHAs are completed once then reviewed annually or when conditions in the area change. The official versions of AHAs are centrally maintained and managed by ES&H. Content is supplied by facility managers and those responsible for the safety of areas (see "Area Hazard Analysis").

SLAC Training Assessment

In addition to these hazard analysis steps, line management ensures workers have competence commensurate with their work responsibilities by conducting a training assessment through the use of the SLAC Training Assessment (STA). This tool is used to evaluate the training necessary to address and mitigate the hazards a worker may encounter in the course of his/her work (see Chapter 24, "Training"). Line management holds employees accountable for completion of required ES&H training. The STA is reviewed annually on the occasion of the employee's performance evaluation or at any time an employee's job function or conditions change. Use of the STA creates a permanent training record, maintained by the ES&H Division, for use by the supervisor and employee.

Licenses and Certifications

In addition to required training, line management also ensures workers possess required licenses and certifications if their work requires it. In most cases, it is the SLAC Work Smart Standards that drive requirements of licenses and certifications. Examples include crane, hoists, and rigging licenses and certification, forklift operator licenses, and hazardous material transporter licenses.

Daily Shift Meetings

These meetings are conducted by management with supervisors and workers for the purpose of reviewing the status of accelerator operations and previous shift activities, assigning and coordinating activities for the current shift, reviewing procedures and relevant JHAMs, and providing a forum for discussion of issues and problems. Certain programs use these meetings to strictly control the activities in their facilities, that is, no work is allowed that is not covered in the morning meeting.

Focused Work Requiring Formal Work Authorization (5.2.2)

Line management may authorize work activities that are subject to approval, permits, or clearance forms issued by SLAC safety officers, ES&H Division SMEs, or SMEs elsewhere at SLAC.

Note: While such approval, permits, or clearance are required by SLAC ES&H policy, line management alone "authorizes" the work to be done and remains fully accountable for safe work performance.

Examples from ES&H policy chapters in the ES&H Manual or other SLAC ES&H policy documents include

• Beam Authorization Sheets (see Chapter 9, "Radiological Safety")
• Confined Space Entry Permit (see Chapter 6, "Confined Space")
• Energized Electrical Work Request and Approval Permit (EEW) (see Chapter 8, "Electrical Safety")
• Excavation Clearance Form (see Chapter 11, "Excavation Safety")
• Laser Safety Authorization for use of Class IIIB and Class IV lasers (see Chapter 10, "Laser Safety")
• Radiation Safety Work Control Form (that stems from the SLAC Guidelines for Operations described in Section 5.2.4 Work Requiring Facility Safety Assessment Documents) for changing configurations that are deemed "safety significant".
• Radiological Work Permit for work in certain radiological control areas (see Chapter 9, "Radiological Safety")
• Welding, Brazing, or Open Flame Cutting Permits (see Chapter 12, "Fire and Life Safety")

Not all work requires approval, permits, or clearances. Line management consults appropriate ES&H Manual hazard-specific policy chapters or other SLAC ES&H policy documents in which thresholds are defined.

Work Consisting of Major and Significant New Experiments, Projects, Test Beams, Facility Modifications, and Facility Construction (5.2.3)

SLAC's Safety Overview Committee and other citizen committees objectively review environment, safety, and health issues of major and significant new

• Experiments and projects
• Test beams
• Facility modifications
• Facility construction

These reviews help promote a safe and environmentally sound operation and 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 Committee (SOC) and other citizen committees (CCs) 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 tailored and designed to eliminate or sufficiently mitigate hazards
• ES&H has been adequately integrated and conforms to SLAC ES&H policy

A citizen committee review may also include

• Inspecting operations and projects
• Interpreting industry standards, in conjunction with the ES&H Division
• Recommending appropriate procedures and policies
• Reviewing accelerator facility procedures, reviewing safety training programs
• Verifying that design processes comply with safety regulations

Line management must gain approval of the SOC, CCs, and in some cases of specially designated safety officers before authorizing work for which SOC and CC reviews are required. Project proponents must refer to Chapter 31, "Institutional ES&H Committees", which discusses in greater detail the thresholds where SOC and CC reviews are required, and the specific CC charters.

Both safety officers and the CCs have work approval authority. The two work together as described in

• Hazard-specific chapters of the ES&H Manual where work approval authorities of the SOs are described
• Chapter 31, "Institutional ES&H Committees", wherein the charters of the individual CCs spell out how the committee interacts and works with the SOs

Where a project involves new construction, the SOC and CCs will be asked to evaluate the project to ensure all ES&H issues are satisfactorily addressed. However, Chapter 42, "Subcontractor Construction Safety", addresses in detail how safety is ensured throughout the design and construction process.

Work Requiring Facility Safety Assessment Documents (5.2.4)

SLAC's major scientific facilities are accelerators or accelerator-related. New accelerators and accelerator-related projects, in addition to requiring citizen committee review (discussed above and in Chapter 31), may need additional analysis, review, and formal approval.

As driven by the DOE Order 420.2B, "Safety of Accelerator Facilities", accelerators, accelerator-related facilities and accelerator experiments may require line management to complete a pre-work safety assessment document (SAD). An SAD requires formal approval and defines the accelerator safety envelope (ASE) from which detailed requirements are set for controls, worker qualification standards, and detailed written procedures. At SLAC, accelerator SADs are complemented by the SLAC Guidelines for Operations, a high-level ES&H policy document that describes in detail the safety requirements in accelerators and accelerator related facilities.

SADs must be maintained current and consistent with controls, major safety equipment, and the physical configuration of the accelerator facility. As any of these elements change, the SAD must be updated. Additionally, SLAC commits to a biennial review of SADs to ensure currency. This process formally implements ISM core functions 1 through 5 and ensures risks and hazards to the workers, public, and the environment are acceptably controlled.

An accelerator readiness review (ARR) demonstrates the readiness of the accelerator or accelerator-related facilities to both SLAC and the DOE Stanford Site Office (SSO) prior to start-up. ARRs are generally limited to initial startup and operation. However, as facilities go through major upgrades, the program director should confer with SSO to reach a joint decision on the need for an additional ARR as well as an amendment to the SAD.

Work Coordination with Line Management of Operating Facilities and Buildings (5.2.5)

An additional and important work authorization process is that in which one element of SLAC must enter a facility, area, or building under the control of another SLAC organizational element. In such cases, the organization doing the work is primarily responsible for conducting such work safely. Often, this involves the Conventional and Experimental Facilities (CEF) Department.

While this process ensures the work itself is done safely, it is equally important to consider the impact on a facility, area, or building in which such work is done. Authorization to do work having a significant potential for impact must be obtained from line management of the facility, area, or building where the work is to be done. Authorization is documented using a form such as the one used for High Energy Physics accelerator facilities (Sample Facility Work Authorization Form: Work Authorization for the Linac, PEP-II, FFTB, and Associated Buildings). Directorate-specific ISM plans and departmental procedures define which line managers within each directorate and department may authorize such work. The SLAC Guidelines for Operations describes in detail the safety requirements in accelerators and accelerator-related facilities and may prescribe as well a Radiation Safety Work Control Form.

Written authorization is not always needed for routine tasks. The facility or area manager may authorize it at the 8:15 am Main Control Center meeting for work involving Linac-related accelerator activities. Such work authorization is recorded in Artemis, a system used for managing accelerator maintenance activities.

Having this joint work authorization process is important for many reasons. It creates a shared responsibility for doing work safely - shared by those responsible for the overall safety of facilities, areas, and buildings and by those who conduct the work. It also allows local management to inform individuals in its facilities, areas, or buildings of any conditions or issues that would influence their safety.

Stopping Unsafe Activities (5.3)

This section describes an individual's (individual means employees and non-employees alike) responsibility to stop activities that pose an imminent hazard (see Section 4, “Definitions”). It further describes how an individual may resolve concerns over work that poses a lesser hazard. It also describes line management's authority and responsibility to respond to all such incidents.

Individual Responsibility to Stop an Activity Posing an Imminent Hazard (5.3.1)

An individual involved in an activity that poses an imminent hazard to him/her, others, the public, the environment, or property has the responsibility to stop that activity. An individual should also refuse to perform an assigned activity if doing so will present an imminent hazard.

An individual observing an activity presenting an imminent hazard has the authority to alert workers (includes employees and all classes of non-employees) engaged in that activity. The workers who are alerted are to stop their activity to discuss safety concerns. If either party has unaddressed concerns following the discussion, supervisors of either party (university technical representatives in the case of subcontractors) or SLAC security are to be contacted.

When an employee in the local bargaining unit believes an imminent hazard activity has not been adequately resolved within the line organization, he/she may refer it to the shop steward or Local Safety Committee. (Information on this authority as it applies to bargaining unit employees can be found in the latest version of the Agreement between the Board of Trustees of the Leland Stanford Junior University and United Stanford Workers.) Individuals not in the local bargaining unit should refer such unresolved activities to the ES&H division associate director.

Special Authority to Stop an Activity Posing an Imminent Hazard (5.3.2)

The laboratory director assigns authority to the following individuals to stop immediately an activity anywhere on-site or for SLAC-sponsored activities off-site that present an imminent hazard to SLAC individuals, the public, the environment, or property:

• Managers and supervisors
• Safety officers (limited to their area of responsibility)

Responding to Unsafe Work Not Presenting an Imminent Hazard (5.3.3)

The SLAC ISM system is designed to eliminate work hazards or to have mitigated them to an acceptable level using agreed-to worker/public safety and environmental protection standards. However, any individual having a concern over the safety of work he/she or others is performing or will perform should address it with his/her supervisor, UTR, or SLAC contact. If a bargaining unit employee's concern is unaddressed, he/she should consult with the shop steward or Local Safety Committee. All other individuals with unaddressed safety concerns should consult with the ES&H division associate director.

Line Management Response to a Stop Activity Incident (5.3.4)

The manager /supervisor responsible for the conduct of an activity posing an imminent hazard and for which individual stop activity authority has been requested or exercised must

• Immediately relay notification of the stop activity to the SLAC facility manager and the ES&H division associate director
• Respond to the cease-activity action or request and investigate the incident. He/she will be aided by an investigator appointed by the ES&H division associate director
• Conduct a hazard assessment and determine what corrective actions may be necessary
• If warranted, re-authorize the work
• Consult with the SLAC Occurrence Reporting and Processing System (ORPS) program manager for inclusion in the DOE ORPS and the local lessons learned program
• Submit an incident report to the ES&H Coordinating Council (Refer to Chapter 1, “General Policy and Responsibilities” in this manual for additional information about the ES&HCC.)

Stop Work versus Stop Activity (5.3.5)

The DOE ISMS guide (DOE Guide 450.4-1, "ISMS Guide", in Section 1.4.1, "Worker Safety") requires our ISM system to show a "meaningful management commitment to empowering workers to exercise their stop work authority". In meeting this requirement, SLAC uses the term stop activity versus stop work because the latter has 1) special meaning under the Federal Acquisition Regulation to stop all work initiated under a SLAC subcontract and 2) been used at SLAC for many years for that purpose.

Stopping Subcontractor Activity/Work (5.3.6)

Stopping unsafe activities can involve subcontractors and stop work orders always involve subcontractors. Both topics are generally more complex than when stopping unsafe activities only involving employees. For more detail, see Work Authorization: Subcontractor Stop Activity/Work Requirements [pdf].

Expressing Concerns and Worker Feedback Mechanisms (5.3.7)

Stopping unsafe activities and the dialogue between worker and supervisor describe one method by which individuals can express concern or provide feedback about work planning. For a complete description of worker feedback mechanisms, see the SLAC ISEMS Description.

continue to Exhibits (6)