Compliance Planning for M

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• Compliance Planning for MC
• 1/13/04

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Our Lab Director,Deputy Director and Division
Director have told us

• Safe, compliant, and well kept research areas
  are a management expectation and are an
  important part of the answer to improving our
  safety record

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As a starting point for improving current
mechanisms for maintaining safe work spaces, a
new role called the Laboratory Space Manager
has been created.
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ORNL is Establishing the Laboratory Space Manager
Role to

• Improve the way we manage our activities within
  our research spaces
• Reinforce line ownership and accountability for
  safety
• Ensure that our daily actions do not get
  consumed by immediate outcomes without adequate
  consideration of safety
• Emphasize proactive and open self-assessment
  with careful consideration of unanticipated
  changes in work
• Markedly improve the safety, compliance, and
  orderliness of our research spaces

Responsible ESH performance is a business
imperative
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Interim Roles, Responsibilities,
Accountabilities, and Authorities (R2A2s) for the
Laboratory Space Manager have been defined in
the Standards-Based Management System. R2A2s
for Level 2 (Division Directors) and Level 3
(Group Leaders/Supervisors) have also been
adjusted for clear lines of authority and
responsibility in the area of safety in the
workplace.
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According to the R2A2s defined for the role,
Laboratory Space Managers have responsibilities
to

• Have general knowledge of work being performed in
  assigned laboratory spaces and the work
  authorized by the Research Safety Summaries
  (RSSs).
• Participate in development of RSSs for the
  assigned laboratory space. Ideally in the
  conception of the RSS, but this can also be
  through review and commenting on the RSS.
• Verify, with the assistance of subject matter
  experts (SME), that hazards are controlled as
  described in authorized RSSs and as allowed by
  the Facility Use Agreement for the laboratory
  space.
• Serve as the primary communication liaison for
  relevant ESHQ and operations between Laboratory
  users and Level 3 managers.
• Restrict unescorted access to the assigned
  workspaces to only those authorized individuals
  who meet the applicable training and
  qualification requirements.
• Communicate existing laboratory hazards and
  controls to FO staff or subcontractor staff
  before their work is conducted in the laboratory.
  Work with Ron Baldwin, Bobby Hackler, and Jewel
  Brown.

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R2A2s further establish that the Laboratory Space
Manager is to

• Periodically and regularly observe work
  activities in their assigned space and act to
  correct any deficiencies observed (e.g., failure
  to follow procedures, practices, postings, and
  permits).
• Limit RD work in the laboratory to work that has
  been reviewed and authorized through the Research
  Hazard Analysis and Control process. Limit
  subcontracted work in the laboratory to that
  which has been reviewed by a SME as a part of the
  procurement process.
• With appropriate SME assistance, periodically
  conduct self-assessments of the workspace.
  Correct deficiencies noted during
  self-assessments or external audits if resources
  are available. Report deficiencies that are
  beyond existing resources to division management.

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R2A2s further establish that the Laboratory Space
Manager is to (contd)

• Set Laboratory user expectations to maintain a
  clean and orderly laboratory/experimental space.
• Notify their immediate Group Leader/Supervisor,
  and any other Group Leader/Supervisor with
  research in the area, of any concerns or
  conditions that could impact activities or
  operations within the assigned laboratory.
• Report facility or equipment problems within the
  assigned laboratory to their GroupLeader/Supervis
  or.

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The Laboratory Space Manager is given authority
to

• Approve or disapprove the introduction of new
  activities or the modification of an existing
  activity within the laboratory/experimental
  space. This includes subcontracted activities.
  That is, if an activity is not on an RSS, the LSM
  should not permit the activity (if it introduces
  new hazards to the area) until the RSS reflects
  the hazards and controls.
• Stop work on any laboratory space equipment,
  activity, or operation when continued operations
  would be deemed unsafe or result in an
  environmental concern.
• Approve or revoke access for any internal or
  external user of the assigned workspaces. If
  there is any question about a persons training
  and GL approval of work utilize this authority.
• Take actions to correct deficiencies or improve
  work practices.

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Initial Milestones for Divisions and Laboratory
Space Managers

• Review all identified laboratories and
  experimental spaces for implementation of SBMS
  requirements and general housekeeping practices
  for continued operation
• Convert laboratory/experimental entrance postings
  to compliant lab-wide standards for hazard
  identification, entrance requirements, and
  listing of contacts
• Authorize all ORNL laboratory/experimental
  spaces for continued operation or place them in
  standby/inactive status by 01/31/2004

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Areas Exempt from Scope of Program Implementation

• The focus of the Laboratory Space Manager
  program is on RD and research operations support
  laboratories. The following spaces are exempt
  from the actions being implemented by the
  program
• Institutional spaces, utility areas, and common
  areas
• Areas where work is performed that is covered by
  the Operations, Maintenance Services work
  control process
• Rooms or space where only office-type work is
  performed

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What is the process for authorization of the
laboratory/experimental space?

• Ensure our hazard identification, hazard control,
  general housekeeping practices, and management of
  waste in the laboratory/experimental space are
  adequate.
• Be knowledgeable on the RSS, the work performed
  in the area, use the checklist to verify safe
  conditions.
• Provide a copy of the completed Checklist and
  Authorization form to Neena Woods by 1/29.

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Who has responsibility for space authorization?

• Approval for laboratory/experimental space
  authorization is provided by both the Laboratory
  Space Manager (LSM) and the Group Leader(s)
  responsible for work conducted in the space.
  Ultimate responsibility for space authorization,
  however, is vested with the Division Director who
  owns the space. Think of laboratory/experimental
  space authorization in the same way that
  divisions approve and authorize execution of
  research in the RD Work Control process.
• The 01/29/2004 authorization is a one-time event.
  Divisions and LSMs, however, are responsible and
  accountable to continuously maintain authorized
  status in the future.

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Use Laboratory Space Authorization Form to
Document Approval of Space for Continued Use

• A Laboratory Space Authorization form has been
  developed to create a record (by dated signature)
  of Laboratory Space Manager/Group Leader approval
  and Division Director authorization of
  laboratory/experimental space. This form also
  serves as an instrument to authorize and document
  corrective actions and then manage those
  corrective actions.
• This form must be completed for each
  laboratory/experimental space by 01/31/2004
• Completed forms must be maintained as a
  record of space authorization by Division
  offices
• Information (conditions and corrective actions)
  summarized by these completed forms is
  recommended as input to Division performance
  assessment programs.

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Refer to Laboratory Space Validation Report for
Identified Laboratory Space Managers and Space
Authorization Status

• The Laboratory Space Validation Report
  assists divisions with management of information
  related to Laboratory Space Manager (LSM) program
  implementation. This tool compares data in the
  Research Hazard and Control System (RHACS) with
  the Space Allocation Management System (SAMS).
  It is utilized to assign responsibility for lab
  spaces to Lab Space Managers and Group Leaders
  and to track completion of the authorization
  process for each lab.
• When you complete the Authorization form, and
  provide the form to Neena Woods, the RSS POC,
  (Jamie Bain) will ensure the Validation Report is
  entered into the RSS/RHAC System.

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Use the Laboratory Space Manager Self-Assessment
Tool to Evaluate Space

• A Laboratory Space Manager Self-Assessment Tool
  has been created to assist the Laboratory Space
  Manager (LSM) with the task of reviewing all
  assigned laboratories and experimental spaces for
  implementation of SBMS requirements and good
  housekeeping practices.
• The MC ESH Group has developed a short for
  targeted at Division Specific hazards and
  controls. This form will be provided to the MC
  LSMs.
• Use either form in doing your self-assessment.

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Ensure Subject Matter Expert Involvement in
Assessment Process

• Recognize the limitations of your own
  expertise and the expertise of other persons
  involved in reviewing work to identify hazards
  and specify controls. Make sure that you
  appropriately involve subject matter experts
  (SMEs) in your assessment of laboratory/experiment
  al space. Through involvement of SMEs you
  collectively expand expertise and avoid
• Failures to identify hazards
• Inadequate hazard control

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MC ESH Support for LSM
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MC ESH Support for LSM (continued)
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Ensure Laboratory/Experimental Space Entry
Postings Are Correct

• MC Management developed uniform posting a few
  years ago. We will continue to use this posting
  format.
• This format is currently acceptable and may be
  adopted as the final posting format.
• A new label has been made to meet new contacts
  listing requirements. (For contact information,
  clearly identify the following persons and list
  ORNL phone numbers
• - Laboratory Space Manager
• - Group Leader(s) conducting work in the space
• - Division Director owning the space

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Lab entrance signs continued

• The new label is available from Neena Woods (or
  the ESH support).
• The LSM should prepare a new label for each lab.
  
• Provide the completed label to Ron Baldwin and he
  will have the label applied to your lab entrance.
• The Activity must be completed before the end of
  the month.
• Ensure that door-mounted windows are clear, or
  that request for replacement has been entered in
  FAMMIS (exceptions might be laser labs,
  classified or proprietary activities, etc.)-Do
  this through Ron.

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Some Helpful Hints

• Housekeeping is a very important consideration
  for authorization. The Leadership Team expects
  significant, visible improvements in housekeeping
  and continued maintenance of good housekeeping
  within our laboratory spaces. A good metric is
  Could you take your Divisions most important
  sponsor to the lab for a tour or demonstration
  and not be embarrassed?
• Moving unused materials into our hallways and
  creating life safety code violations or other
  hazards to our employees is not acceptable.
• Utilize SBMS-defined processes for ALL material
  disposition dont let schedule demands or
  priorities result in compliance violations.
• Coordinate materials disposition through Jamie,
  Ron, and Susan Lewis. Items must be green tagged
  and require some special certifications relative
  to hazardous materials such as asbestos, PCBs and
  radioactive components.

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LSM role

• Review all identified laboratories and
  experimental spaces against SBMS requirements and
  ORNL housekeeping standards for continued
  operation
• Work with Ron Baldwin to ensure postings of
  entrances are correct.
• Authorize all ORNL laboratory/experimental
  spaces for continued operation or place them in
  standby by 01/31/2004 and maintain this
  authorized status by
• Participating in development of Research Safety
  Summaries for the assigned laboratory space.
• Serving as the primary communication liaison for
  relevant ESHQ matters regarding the space
• Restricting unescorted access to the assigned
  workspaces to authorized individuals only
• Periodically and regularly observing work
  activities in assigned space and acting to
  correct any deficiencies
• Limiting RD work in the laboratory to work that
  has been reviewed and authorized through the
  Research Hazard Analysis and Control process
• Setting laboratory user expectations to maintain
  a clean and orderly space.
• Report facility or equipment problems within the
  assigned laboratory.

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• Questions????

LSM Web-based training, if you did not complete
the live session training (only) http//train.ornl
.gov/wbt/lsm/index.htm Authorization Form and
ORNL Checklist https//sbms.ornl.gov/eshAudit/Mai
nMenu.cfm MC Checklist will be distributed to
LSMs by email today