EHS Technical Assurance Program Update

1. EHS Technical Assurance Program Update August 8, 2008 Richard DeBusk, ESH Technical Assurance Manager and Michelle Flynn, OCA ESH Assurance Manager

2. Institutional Self-Assessment ProgramScope / Four Tiered System

3. Why implement ES&H TAP? DOE Order 226.1, DOE oversight policy requirements 10 CFR 851.10, Worker Safety and Health Program requirements Findings of ISMS reviews TAP assesses: ES&H technical program effectiveness both at the program-level and at the implementation-level, which includes: Regulatory compliance ISM implementation effectiveness Formal authorization compliance Corrective action effectiveness Lessons Learned effectiveness TAP replaces Integrated Functional Appraisals ES&H Technical Assurance Program Development

4. FY07 Activities Developed ES&H Technical Assurance Program Piloted program in 8 ES&H subject areas Developed 3-year implementation schedule Reported results in LBNL Annual ES&H Self-Assessment FY08 Activities through mid-year Implemented ES&H Technical Assurance program in 11 additional ES&H subject areas (19 total) Steering committee reviewed results, recommended improvements Refined reporting requirements ES&H Technical Assurance Program Development

5. Opportunities for improvement identified for ES&H programs Some non-compliances identified and communicated to divisions However, DOE technical reviews demonstrated ES&H TAP assessments: Require greater focus on regulatory compliance Not implemented soon enough for some ES&H programs Early Results of TAP Assessments

6. Finding: Some roles and responsibilities in the BioSafety program are less than adequate. Example: Interviews suggest that some PIs are not fully cognizant of BioSafety requirements. (paraphrase of finding) LBNL did not self-identify this non-compliance. TAP not implemented for bio-safety prior to DOE review. Example: BioSafety Program Assessment, May 2008

7. Finding: The Lockout/Tagout Program at LBNL is less than adequate. One example includes the fact that some equipment specific lockout/tagout procedures are deficient (the DOE inspector found two procedures in use for the same piece of equipment). (paraphrase of finding) LBNL did not self-identify this ISM/OSHA non-compliance in the implementation of electrical safety program requirements. TAP assessment plan line of inquiry was not evaluated in depth to reveal this implementation weakness. Example: Electrical Safety Review, February 2008

8. Strengthen leadership: Appoint Howard Hatayama chair of steering committee Appoint Richard DeBusk EH&S TAP manager Establish technical guidance committee (one rep from each EHS Group + OCA + Chair Safety Coord. Committee) Accelerate implementation in targeted areas Added independent assessments to the program Emphasize compliance (OSHA and ISM): Ensure assessment plans fully address regulatory compliance Focus of regulatory requirements in performing assessments Compliance feedback is a service provided by EH&S What does compliance mean? FY08 ES&H TAP Improvement Plan

9. ESH Compliance versus ESH Excellence – What Grade is Acceptable to You? A B C D F Safety excellence requires compliance with regulations combined with effective implementation at all levels in the organization. The focus is accident prevention not regulatory reaction. Compliance + ISM = Excellence “Regulations represent the minimum guidelines of what a company needs.” Hewlett Packard

10. Integration of Safety Codes/Regulations with ISM Safety (ESH) Programs cannot be considered fully compliant unless they are effectively implemented. Safety code/regulation 10CFR851* ISM *10CFR851 is one example requirement. Radiation safety, environmental, and other ESH program standards also require integration of the technical standards with implementation.