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Tier I Working Group 4 th Quarter FY 2010 November 5, 2010.

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Presentation on theme: "Tier I Working Group 4 th Quarter FY 2010 November 5, 2010."— Presentation transcript:

1 Tier I Working Group 4 th Quarter FY 2010 November 5, 2010

2 2 Overview  Year-end Wrap-up of FY 2010 Tier I Inspection Findings  Tier I and IFM  Finalization of Tier I Database Categories/Subcategories  Open Discussion (Issues & Good Practices)

3 3 Rollup of 4 th Quarter FY 2010 Tier I Inspection Findings

4 4 Data Roll-up and Review Tier I Findings by Fiscal Year

5 5 Data Roll-up and Review Tier 1 Findings By Category Fiscal Year=2010, Quarter=Q4

6 6 Data Roll-up and Review Tier I Directorate Findings Fiscal Year=2010, Quarter=Q4

7 7 Data Roll-up and Review

8 8 Tier I and IFM

9  The Facility Complex Organization is an integral part of the Tier 1 Program See ES&H (Tier 1) Inspections Subject Area  Facility Complex is also a “Line” Organization Facility Complex has their own spaces - MERs, shops, offices, etc. The Facility Complex needs to conduct their own Tier 1 inspections 9

10 Tier I and IFM  Line organizations responsible for the periodic self- inspection of their work areas Look for ESSH&Q vulnerabilities and conformance to the standards imposed under 10 CFR 851 Using capable and qualified staff Timely resolution of findings is a requisite step in the self- inspection process  The Line Organization’s Responsible Manager Designates the Team Leader Determines the level of training required by team appointees - Must recognize hazards and compliance violations 10

11 Tier I and IFM Responsibilities  The Core Team may vary, but typically includes: ESH Coordinator Facility Support Representative Environmental Compliance Representative F&O Facility Project Manager or designee Subject Matter Experts (SME)  Whenever possible, the Core Team should include: Principal Investigators/Supervisors Line Management, and Workers 11

12 Tier I and IFM  The Team Leader or designee is responsible for scheduling, conducting, and documenting/recording inspections  Responsible individuals/organizations address findings to ensure timely close-out 12

13 13 Finalization of Tier I Database Categories and Subcategories

14 14 I. Biohazards 1. No IACUC (Institutional Animal Care and Use Committee) or IRB (Institutional Review Board) approval as required 2. No labeling 3. No storage posting as required 4. Proper procedures not followed 5. Other

15 15 II. Chemical Safety: Labeling 1. Chemical contents/hazards not identified on labels or illegible labels 2. No CMS (Chemical Management System) Bar Coding/Static Inventory 3. Particularly Hazardous Substances (PHS) not labeled 4. Peroxide-forming chemicals not tested and not date-labeled 5. Other

16 16 III. Chemical Safety: Storage 1. Storage impedes fume hood operation 2. Container not in good condition 3. Corrosives not stored below eye-level 4. Particularly Hazardous Substances designated area not posted 5. Fume hoods not inspected, labeled, or used. 6. Legacy storage of chemicals no longer used/needed (outdated) 7. No explosion proof or flammable cabinet/refrigerator/freezer as required 8. No segregation of incompatibles 9. Nanomaterials are not stored properly in sealed containers when not in use 10. Containers storing nanomaterials are not labeled properly with the “Caution: Nanomaterial” label 11. Eyewash/shower not available (if corrosives present) 12. Other

17 17 IV. Chemical Safety: Use 1. Carcinogen reproductive hazard and/or acute toxin requirements not met 2. Hood sash not kept at proper height 3. Other

18 18 V. Compressed Gas/Cryogens 1. Cylinders stored on carts 2. Cylinders do not have status tags 3. Cylinders not capped when not in use 4. Cylinders not secured properly 5. Equipment/piping not appropriate for cryogen use (e.g., tubing or piping not rated for the regulator) 6. Flammable Gas Storage not posted 7. Piping not labeled or secured if over 10 ft or through wall penetration 8. In-service monitors/gauges not properly calibrated as appropriate and used (e.g., CO 2, flammable gas meters) 9. No required ODH posting 10. Oxidizers not separated from flammables (20 ft/fire wall) 11. PPE for cryogen transfer not available or not used 12. Static posting for cylinders not current/complete 13. Other

19 19 VI. Electrical Safety: Distribution 1. Arc flash labels missing on equipment 2. Breakers or disconnects not labeled 3. Cable trays overloaded (guidance > 50%) 4. Electrical distribution panels/disconnects blocked [1] 5. Electrical distribution panels not labeled 6. Electrical distribution panels: inadequate working space (i.e., ~36-42” deep [depending on voltage] x 30” wide x 6.5’ high) unless working space limitations sticker is affixed 7. Exposed conductors (bare wires) 8. Flexible cords used as permanent wiring 9. Ground Fault Circuit Interrupter (GFCI) protection not within 6 ft. of sinks/wet areas 10. GFCI does not trip [1] Minimum 36 front (42 for 480), 30 width, 6.5 feet height. See Electrical Safety Subject area for more criteria

20 20 VI. Electrical Safety: Distribution (Cont.) 11. Improper grounding/bonding 12. Junction boxes not secured 13. LO/TO tags: improper, outdated, not durable, illegible, not completely filled out 14. Loose or missing covers on panels, raceways, or outlets 15. Missing knockouts/hardware 16. Wiring in hazardous areas not reviewed or not in compliance 17. Other

21 21 VII. Electrical Safety: Equipment 1. Daisy chaining of extension cords/power strips 2. Electrical plugs not grounded 3. Frayed power cords, extension cords, or heater tapes 4. Hand tools not grounded or not double insulated 5. Inappropriate use of extension cord 6. Missing or damaged strain relief 7. Missing covers/exposed wires 8. Not NRTL listed or EEI inspected 9. LO/TO non-compliance 10. Portable GFCI does not trip 11. Loose or missing covers on panels, raceways, or outlets 12. Other

22 22 VIII. Electrical Safety: Programmatic 1. Other

23 23 IX. Environmental 1. Article 12 non-compliance, e.g., Tank inspection forms, tank labels missing, overfill alarm not functioning 2. Environmental monitoring equipment non-functioning/maintained/calibrated 3. Evidence of spills; not properly cleaned up 4. Faucets not equipped with vacuum breakers/equivalent backflow prevention device 5. Hazardous materials by sinks/floor drains 6. Hoses hanging below sink rim without anti-siphon device 7. Process exhaust near air inlet 8. Process ventilation not permitted (lab hoods are exempt) 9. No secondary containment for storage of hazardous liquid materials (e.g. fuel, hydraulic oils, and paint) 10. No Secondary Containment (e.g. trays) for hazardous liquids [1] [1] Moved here from CSS per S. Ferrone who said this is a RCRA violation under the Hazardous Waste SBMS.

24 24 IX. Environmental (Cont.) [1] Per S. Ferrone, this is both an environmental problem if any oil/gasoline spills onto the ground and is a safety concern if gasoline spills and there is a fire. 11. No sink disposal posting for allowable/pre-approved sanitary discharges 12. Non-compliance with air emissions permits (e.g. logs are not up-to-date, emissions not on permit) 13. Unlabeled/unknown chemical containers 14. Vehicles and equipment not parked on paved or stone-covered areas [1] 15. Used oil is near a floor drain or is uncontained 16. Other

25 25 X. Fire Safety 1. Cutting and welding areas: no current permit 2. Emergency exit doors malfunctioning 3. Emergency lighting inoperable 4. Emergency lighting not located where required [1] 5. Emergency planning postings (i.e., Local Emergency Plan, Shelter-in-Place, Indoor Assembly Area) missing or not current (i.e. postings list individuals who are no longer in the building) 6. EXIT signs missing, not posted appropriately, not illuminated if required 7. Fire doors impaired, not inspected, or not labeled 8. Fire extinguishers blocked, incorrect type, incorrect placement, poor condition 9. Fire extinguisher sign if needed is missing or not visible 10. Fire wall penetrations not sealed [1] Exit corridors and stairs for spaces with more than 2 exits, and exterior egress at different levels

26 26 X. Fire Safety (Cont.) 11. Flammable/combustible materials block or impede egress path or access to exits 12. Excessive accumulation of combustible materials 13. Hazard Information Placards missing, incorrect, incomplete, or out of date. (Note: These placards have to be updated annually.) 14. Non-compliant flammable liquid cabinets 15. Sprinkler heads not free of obstruction (18” clearance) 16. Stairways, hallways, passageways/aisles and access to emergency exits not free of obstruction or inadequately lit 17. Other

27 27 XI. Housekeeping 1. Areas not free of insects, rodents, pests 2. Custodial issues (i.e., cleaning floors, emptying trash) not addressed 3. Egress paths not kept clear, i.e., floors, aisles, emergency egress 4. Floors not dry or free of debris 5. Excessive materials accumulated in laboratory hoods or on work benches 6. Other Housekeeping 7. Handrails and treads not adequate or in poor condition 8. Improper or excessive storage of materials/equipment/heavy equipment 9. PPE improperly stored 10. Non-industrial and non-lab areas (i.e., locker rooms, wash rooms, toilets, drinking fountains, kitchens, conference, and common areas) not maintained in a safe, sanitary and clutter-free condition 11. Leaking chemical containers or piping 12. Proper width of aisles and corridors not maintained [1] [1] Width equal to or greater than width of doorway

28 28 XI. Housekeeping (Cont.) 13. Shelved items placed in disorderly manner causing potential for item to fall when nearby items are being retrieved 14. Stairways, hallways, passageways/aisles and access to emergency exits not free of obstruction or inadequately lit 15. Excessive material or equipment 16. Materials, chemicals, and equipment no longer needed have not been excessed or disposed of 17. Unoccupied storage buildings/areas not maintained, cluttered, or not used to the best advantage 18. Unsanitary conditions of eating food prep areas 19. Recyclable waste containers inadequate in size and design or overflowing 20. Containers not provided for recyclable paper, recyclable cans/bottles, sharps, and trash 21. Work area cluttered or dirty 22. Work areas (inside or out) not returned to clean and orderly condition upon completion of maintenance or repair work 23. Other

29 29 XII. Industrial Hygiene Issues 1. Ergonomic concerns not addressed 2. Hazard assessments not completed where required 3. High-noise areas not assessed or posted 4. Indoor air quality issues not addressed by Industrial Hygiene/Safety and Health Services Division Rep 5. Laser-controlled area interlock not tested within last 6 months 6. Laser Standard Operating Procedure not reviewed within the last year 7. Surface contamination from hazardous metals 8. Required hazard-specific monitoring not completed, documented, or communicated 9. Other

30 30 XIII. Machine Shop Safety 1. Anti restart devices not installed on machines 2. Machine guarding non-compliant 3. Machines not secured (i.e. to floor, table) 4. Other

31 31 XIV. Material Handling and Equipment Safety 1. Extreme temperature warning not posted 2. Forklift unsafe or not inspected 3. Non-ANSI or non-OSHA compliant ladder (fixed and portable) 4. Material-handling equipment – improper operation or maintenance, overdue inspection (i.e. cranes, hoists, slings) 5. Pressure or compressed gas system not reviewed 6. Scaffolding not properly installed, secured, and maintained 7. Other

32 32 XV. Outside and Grounds 1. Automatic door opener buttons for handicapped accessibility non-functional 2. Facility Project Manager placard missing, displays inaccurate information 3. Butt stops of non-approved type, not emptied 4. Refuse collection containers (recyclable metal/cardboard/C&D debris, trash) not present, inadequate in size or design or are overflowing 5. Exterior lighting not provided, inadequate, or non-functional 6. Handicapped/ADA parking requirements not met (if required) 7. Modular building/trailer skirts not intact 8. Outside areas or roofs not maintained clear of rubbish, leaves, weeds, or snow/ice 9. Pest/rodent/wildlife issue (i.e. animal or insect nests observed) 10. Poor condition of stairs, ramps, walkways outside the building 11. Trees/shrubs near sidewalks, parking lot, road not trimmed or damaged 12. Trenches, pits, or sumps not covered, barricaded, or otherwise protected (i.e., to prevent slips/trips/falls) and free of any liquid accumulation 13. Other

33 33 XVI. Personal Protective Equipment (PPE) 1. Appropriate PPE in hazard areas not available, not sanitary, or in poor condition (e.g. electrical, chemical, cryogen, etc.) 2. Eye protection not used, unavailable, or in poor condition 3. Face shield and gloves for cryogens not worn, unavailable, or in poor condition 4. Proper gloves not used, unavailable, or in poor condition 5. Hard hat and safety shoes required but not posted or used as required 6. Hearing protection not used, unavailable, or in poor condition 7. Improper selection of respirator 8. PPE for cryogen transfer not available or not used. 9. PPE not stored in a clean and sanitary manner 10. PPE not available, stored, or used appropriately 11. Proper Footwear in Labs/Industrial areas not worn 12. Lab coats/uniform not worn when required 13. Other

34 34 XVII. Radiation Safety 1. Access not controlled where required 2. Not wearing TLD badge or dosimeter when required (potential PAAA) 3. Area posting(s) not current or incorrect 4. Calibration of survey and dosimetry equipment not current 5. Custodian not assigned (Radiological Materials Area [RMA] sealed source, etc.) 6. Fixed contamination not properly identified or labeled 7. Improper storage or labeling of sources and rad materials 8. Radiation survey levels not updated or incorrect 9. Radiation Work Permits not current, posted or used 10. Sealed source log not current as to location/usage of sources 11. X-ray compliance – not posted, interlock, log 12. Other

35 35 XVIII. Security 1. Door locks malfunctioning where required 2. Doors with self-closing features not closing properly 3. Personnel not wearing ID Badge 4. Property Protection Area postings not current and logbooks not up to date 5. Unsecured/free access to buildings during off-hours 6. Other

36 36 XIX. Unsafe Practices 1. Imminent danger - climbing without fall protection 2. Imminent danger - failure to tie down ladders or using cable tray for climbing 3. Not wearing PPE during hazardous work 4. Working on or near exposed conductor violations 5. Nanomaterial does not comply with nanomaterial waste requirements. 6. Using broken or damaged tools or ladders 7. Other

37 Findings Reported Under Unsafe Practices  IO: Finding: A room in the basement that had no windows and no way of indicating if anyone was working inside while the door was closed. Resolution: Placed a sign stating that no work should be done in the room while the door was closed.  ITD: Finding: A wooden ladder in very poor condition and still in service was located in the basement. Resolution: Threw out the ladder.  Chemistry (Per D. Cabelli, these are unsafe issues, and not necessarily unsafe practices.) Q3 Findings: Step stools needs new rubber feet. Remove or post area in back by mat – trip hazard Resolution: All of the stepstools were fixed for the following Tier I. Q4 findings: Remove or post area in back by mat – Trip hazard. Heavy items on top shelf. Lead on wooden counter in vault is too heavy; should be removed or supported.

38 38 XX. Waste 1. 90-day area is not inspected on a weekly basis using an SBMS or SME- approved weekly checklist 2. Haz Waste Contingency Plan is not posted inside room and in nearby location, or is not current, or 90-day Rules postings not present. 3. Incompatible wastes are not separated 4. Rad Waste area not being inspected on a monthly basis and/or checklist not being completed 5. Rad Waste area postings not present (90-Day Rules postings and RCD area postings) 6. Rad inventory sheet not present 7. For Regulated Medical Waste, open sharps box/sharps sticking out of container 8. For Regulated Medical Waste, biohazardous symbol not present on Regulated Medical Waste container 9. For Regulated Medical Waste, use of a non-biohazardous bag 10. For Regulated Medical Waste, use of a non-sturdy, non-approved red sharps container

39 39 XX. Waste (Cont.) 11. Secondary containment not present or inadequate for liquid wastes (does not hold: 10% of total volume of all containers or 100% of the largest container— whichever larger) 12. Container not properly labeled (MISSING red haz waste label and/or MISSING/illegible chemical descriptions – chemical symbols/secret formulas used) 13. Incompatible wastes being stored together 14. UNP (unbound engineered nanoparticles) nanomaterial does not comply with the nanomaterial waste requirements. 15. Battery types mixed together (e.g. Lead-acid vs. NiCd) and terminals are not taped to prevent shorts 16. Fluorescent Light Bulbs not stored to prevent breakage and container is open 17. Universal Waste posting missing 18. Waste not properly labeled. 19. Other

40 40 XXI. Working Environment: Department 1. Eyewash/shower pathways not obstructed, travel distance > 10 seconds and > 100 feet, not well maintained 2. Eyewash tags not completed with proper dates 3. Dirt present in and around eyewash or covers on eyewash fountains 4. Piping not labeled 5. Refrigerators/freezers not labeled, malfunctioning, or storing non-food items with food 6. Safety signs & postings illegible, missing, or in poor condition 7. Work area barricades (when applicable) not in place and not maintained in good condition 8. Other

41 41 XXII. Working Environment: Plant 1. Broken hardware on doors, windows or machines (other than security) 2. Emergency shower/eye wash inspections not done annually 3. Exposed building insulation 4. Floor load ratings not posted or incorrect 5. Improper (non-compliant) handrails or tread, or no anti-skid tread on stairs 6. Inadequate general ventilation, heat and/or AC 7. Inadequate lighting in work area 8. Lack of toe-boards or missing or improper railings 9. Leaks (i.e., roofs, basements) causing potential safety issues are not properly contained or repaired 10. Missing floor or ceiling tiles (> 10%)

42 42 XXII. Working Environment: Plant (Cont.) 11. Out of date or missing inspection certificates in elevators 12. Utility piping (i.e., steam, water) not labeled 13. Walking and Working Surfaces not kept clean and free of debris 14. Walking and Working Surface issue concerning building floors 15. Portable ladders not secured when not in use 16. Other

43 43 XXIII. Other 1. Environmental, Safety & Health, Security and Quality Issues that cannot be otherwise categorized 2. No findings found

44 Open Discussion (Issues & Good Practices) 44

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