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LBNL Progress in Implementing 10CFR851 Worker Safety and Health Program

This report highlights the progress of LBNL in implementing the 10CFR851 Worker Safety and Health Program, including program gaps identified and closed, CATS review process, and NTS reporting. It also covers the status of various safety issues and the timeline for completing the Written Safety & Health Program (WSHP). The report outlines the phases of revising PUB.3000 to address gaps and ensure compliance with safety provisions.

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LBNL Progress in Implementing 10CFR851 Worker Safety and Health Program

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  1. LBNL Progress in Implementing 10CFR851 Worker Safety and Health Program Presented to Safety Coordinators/EHS Liaisons November 10, 2006

  2. 10CFR851 Progress Report • LBNL is slightly behind schedule (~2 weeks) to implement the standard • Draft Worker Safety and Health Plan Completed • Program gaps being identified/closed (PUB 3000 changes) • CATS review and NTS reporting process established, continuing with trial process until 1/1/07. Starting real reporting 1/2/07.

  3. Non-Compliance Reporting (Trial Period) • Weekly LBNL/BSO review of 851 non-compliances • Continuing to average about 40 CATS each week • 6 NTS reports in a 20 week period (1 more being drafted) • Blackberry Canyon walking path inadequate (closed) • Fall hazard due to gap in work platform in AFRD (closed) • B50 Roof fall protection (open) • B26 Scaffold fall protection (closed) • Penetration Permit Program less than adequate (open) • Electrical safety violation in B55 (open) • Fall Protection Program less than adequate (drafting) • Currently reporting about 1% • Trial ends January 2007

  4. Written Safety & Health Program (WSHP) • 1st Draft • 851 Steering Committee review complete • DOE review 11/8, general review 11/10 • Comments due, DOE review and teleconference 11/21 • 2nd Draft • Draft complete 12/4 • Comments due, DOE review and visit to discuss 12/11 • Final Draft • Draft complete 1/10/07 • Comments due, DOE review and visit to discuss/audit of implementation status 1/22/07 • LBNL WSHP will be approved by Lab Director by 2/26/07 • LBNL must be in compliance with all provisions of our plan and 851 provisions/851 is enforceable 5/25/07

  5. PUB 3000 • Two phase revision of PUB 3000 to address gaps • Phase I (November and December) • November • Chapter 3, Health Services (October actually) • Chapter 4, Industrial Hygiene • Chapter 5.3, Shop Safety • Chapter 18, LOTO • Chapter 24, Training • December • Chapter 1, Policy • Chapter 8, Electrical • Chapter 10, Construction Safety • Chapter 12, Fire Protection • Chapter 25, BioSafety • Chapter XX, Hazard Analysis and Control • Phase II (January and February)

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