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This report by HSS Office of Health, Safety, and Security provides an overview of workplace exposure monitoring for non-radiological hazards. It includes DOE requirements, guidance, positive attributes, weaknesses, and opportunities for improvement.
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HSS Office of Health, Safety and Security Independent Oversight Status Report on Workplace Exposure Monitoring ISM Workshop 2007
HSS Office of Health, Safety and Security Background • Review Conducted January 2006 - June 2007 • Included Eight Sites • Integrated With Routine ES&H Inspections • Focused on Workplace Monitoring for Non- Radiological Hazards Page 2 of 9
HSS Office of Health, Safety and Security DOE Requirements • DOE Order 440.1A, Worker Protection Management for DOE Federal and Contractor Employees, 1998 • 10 CFR 851, Worker Safety and Health Program, May 2007 • DOE Order 440.1B, Worker Protection Management for DOE Federal Organizations, May 2007 Page 3 of 9
HSS Office of Health, Safety and Security DOE Guidance • DOE Guide 440.1-8, Implementation Guide for Use With 10 CFR 851 Worker Safety and Health Program • DOE Guide 440.1-3, Occupational Exposure Assessment, March 1998 • DOE-Std-6005-2001, Industrial Hygiene Practices, April 2001 Page 4 of 9
HSS Office of Health, Safety and Security DOE Guidance Cont. • Mulhausen, JR and Damiano, J. A Strategy for Assessing and Managing Occupational Exposures, AIHA Press, Fairfax, Va., 1998 • Occupational Safety and Health Administration Technical Manual, TED 01.00.015 • National Institute for Occupational Safety and Health Analytical Methods Page 5 of 9
HSS Office of Health, Safety and Security Positive Attributes • Processes Were Established For Identifying and Analyzing Hazards • All Sites Utilized Accredited Laboratories • IH Staffs Were Knowledgeable and Experienced • Record Keeping Generally Met Requirements With Noteworthy Systems at INL and NTS Page 6 of 9
HSS Office of Health, Safety and Security Weaknesses • Inadequacies In Procedures, Policies or Guidance • Baseline Exposure Monitoring Not Completed • Exposure Assessment and Work Control Processes Not Linked • Assessment Frequencies Not Based On Potential Risk • Recommendations Not Incorporated Into Work Documents Page 7 of 9
HSS Office of Health, Safety and Security Weaknesses • Subcontractors Lacked Procedures, Monitoring, Equipment and Trained Staff • Some Data Contained Errors or Omissions • Lack of Technical Basis • Thresholds Were Too High • Lack of Self-assessments Page 8 of 9
HSS Office of Health, Safety and Security Opportunities For Improvement • Better Define Mechanisms In Programs and Procedures • Improve the Consistency of Implementation • Integrate Feedback and Improvement Processes Page 9 of 9