0. 2.     PROGRAM ADMINISTRATION

2.1     Organizational Structure and Responsibilities

DND-CAT has identified and evaluated the hazards its personnel are likely to encounter during operations in its spaces at the APS.  This analysis and the practices mandated by the APS have led to the following assignments of DND-CAT responsibilities.  (Key personnel assignments are listed in Chapter 4 of this document.)

2.1.1     Director

The DND-CAT Director has the ultimate responsibility within DND-CAT for ensuring that the safety, health, and environmental protection components of this program embrace all of DND-CAT’s activities at the APS. This responsibility includes ensuring that the work performed by DND-CAT members, guests, and on-site contractors providing services under DND-CAT auspices remains in accordance with the provisions of this program.  The Director works closely with the DND-CAT Safety Coordinator in identifying and resolving safety and environmental issues involving DND-CAT personnel, which arise as the result of interactions between DND-CAT personnel and other personnel at the APS.  The DND-CAT Director has the authority to stop any DND-CAT activity judged to be unsafe or environmentally unsound.  The Director is also responsible for the adequacy of accident and incident investigations.

2.1.2     Safety Coordinator

The DND-CAT Safety Coordinator advises the DND-CAT Director on safety-related matters and ensures that day-to-day operations are carried out in accordance with the practices and policies covered by this plan.  The Safety Coordinator sees to it that DND-CAT personnel complete their required training and that DND-CAT personnel properly execute the safety-related responsibilities assigned to them.  The Safety Coordinator is DND-CAT’s primary contact with the APS on environmental, safety, and health issues.

The Safety Coordinator is responsible for conducting monthly ES&H inspections of DND-CAT’s facilities at the APS using the Monthly Safety Inspection checklist.  (See DND-CAT GUIDELINES FOR INSPECTIONS)

2.1.3     Secretary

The DND-CAT Secretary is responsible for maintaining records related to safety and environmental protection. The Secretary also executes purchase orders for safety and protective equipment requested by authorized DND-CAT personnel.  The Secretary assists the DND-CAT Safety Coordinator by providing notification of all purchase requests for either safety-related or potentially hazardous equipment or hazardous materials.

2.1.4     Chemical Safety Coordinator

The DND-CAT Chemical Safety Coordinator is DND-CAT’s Chemical Hygiene Officer, and as such is responsible for assisting in identifying and implementing proper controls for the hazards associated with chemicals, gases, and nonbiological samples.  In particular, the Chemical Safety Coordinator participates in all inspections of chemical storage areas to help ensure that all safety-related equipment stocked by the DND-CAT is appropriate for its intended uses.  The Chemical Safety Coordinator is responsible for DND-CAT’s compliance with all mandatory APS requirements regarding the labeling and tracking of all chemicals, gases, and nonbiological samples in DND-CAT spaces at the APS.  (See Section 3.1 and DND-CAT Guidelines for the Management of Chemicals.)  The Chemical Safety Coordinator also takes steps to ensure that all wastes—particularly chemical wastes—are disposed of in accordance with APS requirements.  (See DND-CAT guidelines for Management of Hazardous Waste.)

2.1.5     LOM shop coordinator

The LOM Shop Coordinator is responsible for ensuring the safe usage of the LOM Shop. His/her specific responsibilities are to:

•       Provide adequate instruction to persons wishing to become Authorized Users;

•       Maintain, in an auditable form, copies of an Authorized Users List; and

•       Participate in the LOM Shop Coordinating Committee, composed of the LOM Shop Coordinators of the resident CATs. The committee’ charge is to resolve scheduling and housekeeping issues.

2.1.6     Electrical Safety Coordinator

The Electrical Safety Coordinator is responsible for ensuring that all DND-CAT personnel adhere to safe electrical design criteria and work practices.  (See Section 3.2 and DND-CAT Guidelines for Electrical Safety Work Practices.)  To carry out these responsibilities, the Electrical Safety Coordinator:

•       Reviews proposed experiments to verify that adequate safeguards will be in place to control electrical hazards;

•       Inspects electrical equipment to be used during experiments and temporary electrical installations to verify adherence to electrical safety design criteria;

•       Verifies compliance with ANL lockout and tagout procedures when these are required to control hazardous electrical energy;

•       Reviews and approves the procedures DND-CAT personnel are to follow when working hot (electrically)—that is, working on or near electrically energized components that have a potential of 50 volts or greater to ground—; and

•       Maintains clear and comprehensive records regarding electrical utilities, grounding diagrams, signal cables, etc., for all of DND-CAT’s facilities at the APS.

2.1.7     Laboratory Safety Captain

DND-CAT Laboratory Safety Captain reports to the DND-CAT Director and is responsible for maintaining safe, neat, and orderly operations in the laboratories at DND-CAT’s sector.  His/her responsibilities are listed below:

2.1.7.1     General Safety Responsibilities

1.     Ensure that all reasonable precautions are taken to minimize the safety, health, and environmental risks associated with activities being performed in the laboratory spaces.

2.     With the assistance of the DND-CAT Secretary, maintain an adequate inventory of personal protective equipment, as specified in the Laboratory Information Binder, for both visitors and DND-CAT personnel.  (See DND-CAT Guidelines for LOM Laboratory Information Binders.)

3.     Order an immediate halt to any activity that creates an imminent danger to life, health, or the environment.  Where appropriate, the Laboratory Safety Captain will also order the actions needed to abate the hazardous conditions resulting from the activity.  Once a safe work environment has been reestablished, the Laboratory Safety Captain will report the incident to the DND-CAT Director and Safety Coordinator.  If neither is present, the incident will be reported to the responsible party's supervisor or escort.

4.     Quickly address the action item lists issued by the safety-related committees discussed below or by the DND-CAT Safety Coordinator and inform the DND-CAT Safety Coordinator when the actions have been completed.

5.     Ensure that personnel using the laboratory are properly trained in the use of the laboratory’s equipment and facilities.

6.     Maintain a list of the hazards found in the laboratory.  This responsibility includes helping to maintain an inventory of the chemicals on hand.  (See Section 3.1 and DND-CAT Guidelines for the Management of Chemicals.)

7.     Ensure that required periodic inspections of safety-related equipment (such as eyewashes) and facilities (such as Satellite Accumulation Areas for hazardous wastes) are performed on schedule.  (See DND-CAT Guidelines for Inspections.)

8.     Maintain the Laboratory Information Binder described below.  (See DND-CAT Guidelines for Laboratory Information Binders.)

2.1.7.2     Chemical Laboratory Hazard Control

The Laboratory Safety Captain assigned to a chemical laboratory will also:

1.     Assist in identifying the proper handling procedures for the chemicals (including compressed gases and cryogenic liquids) and chemical wastes used or produced in the laboratory;

2.     Provide all DND-CAT personnel with an orientation on the safety practices at the laboratory;

3.     Ensure, with the support of the DND-CAT Safety Coordinator or Chemical Safety Coordinator, that all safety and protective equipment used in the laboratory is functioning properly and is appropriate for the materials being handled;

4.     Track all chemicals, gases, and chemical wastes used or produced in the laboratory; and

5.     Review the chemical, gas, and chemical waste storage areas monthly, keeping a log of the areas inspected, the inspection dates, any findings, and any actions taken.  (See DND-CAT Guidelines on Management of Chemicals, DND-CAT Guidelines for Personal Protective Equipment, DND-CAT Guidelines for Management of Hazardous Waste, and DND-CAT Guidelines for Inspections.)

2.1.7.3     Analytical X-ray Laboratory Hazard Control

The Laboratory Safety Captain assigned to an analytical x-ray laboratory will have the additional responsibility of being the custodian for the laboratory’s x-ray generators.  As custodian, the Safety Captain will

•       Ensure that operational procedures—including procedures that provide for protection against ionizing radiation—are established, posted, and executed;

•       Provide adequate instruction to persons wishing to become Authorized Users of the laboratory’s x-ray generators;

•       Maintain, in an auditable form, copies of an Authorized Users List;

•       Ensure that a properly maintained logbook for each x-ray generator is kept near the machine;

•       Approve individuals in writing as Authorized Users based on their demonstrated competence in using the laboratory’s x-ray generators;

•       Become familiar with and maintain a copy of the American National Standard N43.2-1977;

•       Review and, with the concurrence of ESH-Health Physics, approve modifications that could degrade the safety of the laboratory’s x-ray generators; and

•       Oversee the conduct of required radiation surveys and equipment tests, document the resulting determinations, and maintain related records in an auditable form.

(Also see Section 3.3.)

2.1.7.4     Sealed Source Hazard Control

The Laboratory Safety Captain assigned to a laboratory that uses sealed radioactive sources will have the additional responsibility of being the source custodian.  As custodian, the Safety Captain will ensure that ANL and APS requirements for inventory, storage, and use of sealed sources are met.  (See Section 3.3 and DND-CAT Guidelines for the Management of Sealed Radioactive Calibration Sources.)

2.1.8     Beamline Safety Technician

The DND-CAT Beamline Safety Technician reports to the DND-CAT Director and is responsible for maintaining safe, neat, and orderly operations on DND-CAT’s beamlines.  This includes ensuring that preventive maintenance activities take place on schedule.  The Beamline Safety Technician, as an agent of the DND-CAT Director, works directly with Principal Investigators and helps them understand and fulfill their safety-related responsibilities.    The DND-CAT Beamline Safety Technician also:

•       Ensures that hazardous conditions created by Principal Investigators are corrected as soon as they are discovered;

•       Ensures that there is an adequate inventory of safety-related supplies and equipment that are appropriate for use at DND-CAT’s beamlines;

•       Assists with radiation surveys performed by ANL Health Physics personnel;

•       Ensures that DND-CAT’s radiation survey instruments are in good working order and in calibration;

•       Ensures prompt correction of safety and environmental protection deficiencies associated with beamline operation;

•       Brings issues outside his/her scope of expertise to the attention of the DND-CAT Director or Safety Coordinator; and

•       Supplies the DND-CAT Secretary with copies of all safety inspection reports.

(See applicable DND-CAT Guidelines.)

2.1.9     Safety Committee

The DND-CAT Safety Committee reports to the DND-CAT Director, who selects its members.  The DND-CAT Safety Coordinator is a permanent member; the others are DND-CAT members who serve for terms that end at different times.  The DND-CAT Director may designate additional individuals to serve as temporary committee members because of their special expertise.

The Committee is responsible for  ES&H inspections of DND-CAT’s facilities at the APS using the Annual Safety Inspection checklist.  (See DND-CAT GUIDELINES FOR INSPECTIONS)  It also reviews proposed experiments that require engineered or procedural safeguards that are not in place at DND-CAT’s facilities.  Individual  members of the Committee will be asked by the Director to inspect the facilities on an ad-hoc basis and will have the authority of  the Committee on these occasions.

The DND-CAT Safety Committee has the authority to suspend any activity at DND-CAT’s facilities that fails to comply with ES&H requirements or which significantly deviates from good laboratory practices.  The Committee will immediately notify the DND-CAT Director and the DND-CAT Safety Coordinator when suspending an activity.  If the Committee considers it appropriate, the matter will be treated as an incident requiring investigation, and an additional notice will be sent to the XFD ES&H Coordinator.

2.1.10     Principal Investigators

For the purposes of this plan, the term “Principal Investigator” means any DND-CAT member, Independent Investigator or other DND-CAT-authorized individual who is designing, building, or performing an experiment on a DND-CAT beamline.  Principal Investigators are responsible for working in a safe, orderly, and ecologically sound manner on their beamline and in its associated LOM spaces.  Principal Investigators must report hazards associated with their experiments to DND-CAT management in accordance with the APS Experiment Safety Review procedure.  They must also comply with DND-CAT-issued safety requirements and take the steps needed to ensure that all individuals who could be exposed to hazards as a result of the Principal Investigator's activities have the knowledge, opportunity, and equipment required to control the hazards.  Principal Investigators are accountable to the DND-CAT Director regarding their safety responsibilities.

2.1.11     Visitors

The term “visitors” includes scientists, engineers, vendors, students, etc., who have been invited by DND-CAT personnel to spend time at DND-CAT facilities but are not Principal Investigators.  All visitors who will spend more than five (5) working days at the APS during a calendar year or who will do hands-on work during a shorter visit and possibly become exposed to work-related hazards should consult with the DND-CAT Director and the DND-CAT Safety Coordinator to determine whether they need safety training beyond the standard APS User Orientation.

The DND-CAT Director and the DND-CAT Safety Coordinator will follow the practices set forth in Chapter 17-1 of the ANL ESH Manual to determine how to provide for the safety of contractors, service personnel, and vendors.  DND-CAT will also document the hazards associated with the various areas it occupies and provide this information to all who could come into contact with these hazards.

DND-CAT personnel who escort visitors in DND-CAT-controlled areas have the following responsibilities:

1.     Remain with the visitor whenever the visitor is in a controlled area, including every chemical laboratory and radiologically controlled area;

2.     Ensure that the visitor does not inadvertently trigger an emergency;

3.     Warn the visitor of hazards in DND-CAT-controlled spaces and describe required precautions;

4.     Make sure that the visitor uses all appropriate personal protective equipment and complies with dosimetry requirements;

5.     Accompany the visitor to “safe ground” during any emergency situation; and

6.     Ensure that the visitor's emergency medical needs are met as soon as possible.

2.2      Hazard Evaluations

DND-CAT will take a graded approach in evaluating the hazards associated with all of the activities to be performed in the spaces it occupies.  That is, evaluations will become more comprehensive as the likely severity of a mishap increases or the complexity of the process increases.

2.2.1     Installation, Support, and Maintenance Activities

DND-CAT has identified, at a generic level, the various activities DND-CAT personnel will routinely undertake during the development and maintenance of DND-CAT’s facilities and while supporting DND-CAT’s research activities at the APS.  DND-CAT has also identified the hazards it believes to be associated with these activities and the hazard control measures that will reduce the associated risks to acceptable levels.  Chapter 3 of this plan summarizes this information.  DND-CAT will continue evaluating hazards and selecting controls for these types of activities by consulting the XFD ES&H Coordinator.

2.2.2     Experimental Activities

DND-CAT has designed its APS facilities to safely accommodate a variety of research and development activities.  To supplement this generic level of design, DND-CAT will obtain sufficient information about the experimental work planned in its sector to determine if its existing facilities and procedures allow the work to be done safely.  DND-CAT will evaluate the hazards associated with the experimental activities and select appropriate controls.  If this evaluation indicates that an experiment cannot be performed safely with existing controls, the DND-CAT Safety Committee will follow the Experiment Safety Review guidance provided by the APS to determine what additional controls are necessary.  DND-CAT will also identify the types of information and training needed by the experimenters to satisfy APS safety requirements and put engineered and procedural controls to best use.  If the existing controls appear sufficient, the experiments will be approved contingent on the successful completion of any training the experimenters are required to take.  Only after the DND-CAT Safety Coordinator or the DND-CAT Director has granted approval will an experimenter be authorized to work at the APS.

2.2.3     Experimental Safety Review

The DND-CAT Safety Coordinator has the responsibility of reviewing all beamline experimental proposals.  The Coordinator, with the DND-CAT Director’s approval, may designate other members of the DND Staff to perform this function along with any restrictions.   In this case, the DND  CAT shall  keep the APS informed as to who may evaluate and approve experimental safety approval forms.  The safety review is conducted after the experimenter notifies DND-CAT of all of the experimental hazards associated with the experiment on the Experimental Safety Approval Form.   The DND-CAT Safety Coordinator or designate assesses the hazards and either approves, disapproves, or defers the experiment (see DND-CAT Guidelines for Experimental Safety Review).    There is no minimum time between when an experimental form is submitted and the actual experiment; however,  the proposal will be rejected if the Safety Coordinator or designate does not have adequate time to evaluate the hazards.

DND-CAT will follow all follow all policies and practices mandated by the APS.  When clear documentation is provided by the APS outlining safe procedures,  DND will incorporate the procedures into its practice and optionally update this Safety Plan if updating doesn’t duplicate documentation.

2.3      Orientation and Training

DND-CAT will require its personnel to complete the APS User Orientation provided by the APS and the complementary DND-CAT-administered Sector Orientation.  (See DND-CAT Guidelines on the DND-CAT Sector Orientation.)  DND-CAT and the APS will jointly establish additional training requirements for individuals as necessary. 

2.3.1     Identifying Training Needs

DND-CAT will consult with the Office of the XFD ES&H Coordinator for specific training requirements and recommendations for DND staff and members.  DND-CAT line management may also specify training requirements for DND-CAT personnel based on other criteria.

2.3.2     Exemptions to Training

Exemptions from some required training normally provided by the APS or DND-CAT may be granted based on an individual’s prior education and experience combined, in some cases, with the results of an examination.

2.3.3     Training Records

APS shall have the responsibility of tracking the training given to each individual, whether that training was provided by the APS, DND-CAT, or another entity.    APS shall provide this information to DND upon request.

2.4      Compliance with Regulations

DND-CAT will comply with all applicable regulations of:

•       The Occupational Safety and Health Administration (OSHA),

•       The U.S. Environmental Protection Agency (EPA), and

•       The U.S. Department of Transportation (DOT).

2.5      APS Guidance Documents and Reviews

DND-CAT will adhere to all APS safety-related specifications for the design of DND-CAT’s facilities and equipment.   The CAT will follow a graded approach in documenting its efforts to characterize hazards and select hazard controls.  In accordance with APS design review procedures, DND-CAT will:

•       Make appropriate documents available to the APS,

•       Consider all comments offered by the APS, and

•       Implement required design changes.

DND-CAT understands that the APS will continually issue and revise procedures relevant to DND-CAT’s management of environmental, safety, and health concerns. DND-CAT will incorporate such procedures into its safety program as they become available.

2.6      Organizational Communications

2.6.1     Newsletter

The DND-CAT Newsletter will serve as a vehicle for communicating the importance the CAT attaches to safety issues.  The newsletter will also be used to report changes in the DND-CAT’s Safety Plan.

2.6.2     Safety Meetings

During the operational phase, DND-CAT staff members will hold ad hoc meetings to discuss safety related issues.  Any concerns that require further investigation that are brought up at the meeting will be documented.

Any DND-CAT staff member is empowered to convene an immediate safety meeting at any time.  In this case, the DND-CAT Director or designate may issue a stop work order to hold the meeting.

2.6.3     Copies of Safety Plan

A written copy of this safety plan will be maintained by the DND-CAT Secretary and will be made available to each DND-CAT member.  DND-CAT will also make this document available via the World Wide Web.  It can be found at http://www.dnd.aps.anl.gov/.

2.6.4     Laboratory Information Binders

Laboratory Information Binders are located at the entrance to each laboratory and summarize the hazards and controls associated with operations performed in that laboratory.  (See DND-CAT Guidelines on Laboratory Information Binders.)

2.7      Employee Involvement

DND-CAT encourages responsible input from its members and other users regarding safety concerns that have yet to be effectively addressed.  DND-CAT personnel at every level will be represented on the DND-CAT Safety Committee.  Anyone who feels a safety concern has not been dealt with appropriately should inform the DND-CAT Director, DND-CAT Safety Coordinator, XFD ES&H Coordinator, or XFD Director.

2.8      Managing Configuration Changes

Before making any change that could affect the performance of an existing engineered hazard control, DND-CAT will review and approve the planned change.  The purpose of this review is to determine whether additional engineered controls, procedures, training, or information needs to be provided.  DND-CAT will then record the changes and, as appropriate, post warnings to alert personnel who could be affected.  Similar requirements apply to changes in the distribution of utilities (electricity, pipes, fluids, and ventilation), the installation of temporary experimental facilities and equipment, and the startup of previously unreviewed systems and activities that could introduce new hazards.  DND-CAT will consult the XF&D ESH Coordinator when starting activities that can introduce new hazards.

It is DND-CAT’s policy that no shielding or personnel safety system installed by the APS or included in an APS-approved configuration shall be modified, removed, or disabled and that no equipment, system, or apparatus shall be operated outside of its designed safety parameters without a formal review by the applicable XFD safety committees and the written approval of the XFD Associate Division Director for Operations.

2.9      Chemical Hygiene Plan

DND-CAT has developed a Chemical Hygiene Plan (see DND-CAT Guidelines for Laboratory Information Binders) to satisfy APS and OSHA requirements, in accordance with the guidelines established by Chapter 4-2 of the ANL ESH Manual.  (A copy of Chapter 4-2 is available from the DND-CAT Safety Coordinator.)

2.10     Hazard Communication Program

DND-CAT has woven elements of its hazard communication program throughout this ES&H plan.  DND-CAT believes that these elements address all OSHA and APS requirements.

2.11     Program Evaluations

2.11.1     Self-Surveillance

(See DND-CAT Guidelines for Inspections.)

2.11.1.1     Informal Observations by DND-CAT Personnel

All DND-CAT personnel have the responsibility to notify DND-CAT line Directors of hazardous conditions and observed unsafe actions.

2.11.1.2     Periodic Inspections

Principal Investigators and Laboratory Safety Captains will inspect all active work areas at least once each APS scheduled operating run.  The DND-CAT Safety Coordinator may participate in these weekly inspections.  Significant findings will be reported to the XFD ES&H Office.  (See "Records" paragraph below.)

2.11.1.3     Safety Committee Inspections

The DND-CAT Safety Committee will conduct ES&H inspections of all DND-CAT facilities located at the APS. The DND-CAT Safety Coordinator should include individuals with special expertise as temporary members of the committee on an as-needed basis.

A report of each safety inspection will be submitted to the DND-CAT Director.  After the Director approves the report, it will be filed with the DND-CAT Secretary who will send a copy to the AOD ES&H Coordinator and post it on the World Wide Web (accessible only to DND-CAT members).

If during the course of an inspection the DND-CAT Safety Committee observes any activity at DND-CAT’s facilities that violates ES&H regulations or acceptable laboratory practices, it may order an immediate suspension of the activity.  Notice of the suspension will be communicated immediately to the DND-CAT Director  and an ES&H Incident Report will be given to the DND-CAT Secretary and AOD ES&H Coordinator. The suspension will remain in effect until compliance is reestablished or a review of the issue by the DND-CAT Safety Coordinator confirms that proper guidelines are being met.  

A review by a committee formed by the AOD ES&H coordinator may replace the inspections of the DND-CAT Safety Committee at the discretion of the DND-CAT Director.

2.11.1.4     Records

DND-CAT will forward all significant findings to the APS ES&H Coordinator who shall have the responsibility of maintaining these documents.   Remedial action and follow-up will also be reported to the APS ES&H Coordinator.

2.11.1.5     Annual Self-Appraisal

The DND-CAT Safety Coordinator will prepare an annual written self-appraisal for the DND-CAT Director at the end of each calendar year.  The report will be written at a summary level and will address the DND-CAT's performance in each of the major areas covered in this plan (for example, “Accidents and Incidents,” “Orientation and Training,” etc).  In addition, the Safety Coordinator should report any significant changes that were made to the ES&H plan during the course of the year and recommend actions to address outstanding deficiencies.  After review by the DND-CAT Safety Committee, the report will be forwarded to the DND-CAT Director who will direct appropriate changes in DND-CAT safety procedures.

2.11.2     AOD and APS Oversight

DND-CAT will fully cooperate with the oversight activities of the AOD ES&H Coordinator, other APS safety personnel, and APS User Safety Committees.  The CAT understands that APS Floor Coordinators and the AOD ES&H Coordinator will remain watchful for possible safety problems.  DND-CAT members will deal candidly with these individuals and will make every effort to address their concerns promptly.

2.12     Accidents and Incidents

If an unplanned event occurs which has adverse or potentially adverse effects, DND-CAT will investigate it as described in the DND-CAT Guidelines for Accident Investigations, and will implement the corrective actions needed to ensure that similar accidents or incidents do not occur in the future.

DND-CAT recognizes that the APS requires prompt notification of some types of incidents.  The DND-CAT Director will be responsible for this notification.