hazards shall be evaluated and an agreed-upon set of safety standards and requirements shall be established which, if properly implemented, will provide adequate assurance that the public, the workers, and the environment are protected from adverse consequences.

   Hazard controls tailored to work being performed. Administrative and engineering controls to prevent and mitigate hazards shall be tailored to the work being performed and associated hazards.

   Operations authorization. The conditions and requirements to be satisfied for operations to be initiated and conducted shall be clearly established and agreed upon.

Functions:

   Define the scope of work. Missions are translated into work, expectations are set, tasks are identified and prioritized, and resources are allocated.

   Analyze the hazards. Hazards associated with the work are identified, analyzed, and categorized.

   Develop and implement hazard controls. Applicable standards and requirements are identified and agreed upon, controls to prevent/mitigate hazards are identified, the safety envelope is established, and controls are implemented.

   Perform work within controls. Readiness is confirmed and work is performed safely.

   Provide feedback and continuous improvement. Feedback information on the adequacy of controls is gathered, opportunities for improving the definition and planning of work are identified and implemented, line and independent oversight is conducted, and, if necessary, regulatory enforcement actions occur.

In addition, in 2006, and in recognition of a gap within the management system, DOE identified four supplemental safety culture elements. These, as described in DOE Manual DOE M 450.4-1 (DOE, 2006), are as follows:

   Individual attitude and responsibility for safety. Every individual accepts responsibility for safe mission performance. Individuals demonstrate a questioning attitude by challenging assumptions, investigating anomalies, and considering potential adverse consequences of planned actions. All employees are mindful of work conditions that may impact safety, and assist each other in preventing unsafe acts or behaviors.

   Operational excellence. Organizations achieve sustained, high levels of operational performance, encompassing all DOE and contractor activities to meet mission, safety, productivity, quality, environmental, and other objectives. High reliability is achieved through a focus on operations, conservative decision making, open communications, deference to expertise, and systematic approaches to eliminate or mitigate error-likely situations.

   Oversight for performance assurance. Competent, robust, periodic, and independent oversight is an essential source of feedback that verifies expectations are being met and identifies opportunities for improvement. Performance assurance activities verify whether standards and requirements are being met. Performance assurance through conscious, directed, independent previews at all levels brings fresh insights and observations to be considered for safety and performance improvement.

   Organizational learning for performance improvement. The organization demonstrates excellence in performance monitoring, problem analysis, solution planning, and solution implementation. The organization encourages openness and trust, and cultivates a continuous learning environment.

More information about the DOE ISM system can be found at www.directives.doe.gov.

The DOE ISM system is only one example of an EHS management system, and many others exist. It is important that each organization develop a management system to meet the needs of the organization. Small organizations or those that do not handle particularly hazardous materials should not be tempted to “over-engineer” the system. If the burden of organizational oversight and management of the ESH program is not appropriately tied to the organizational risk, then the safety program may lose credibility in the eyes of the people it supports.

2.B CHEMICAL HYGIENE PLAN

The foundation of all management system approaches is the identification of EHS concerns, which if not adequately controlled, can result in employee injury or illness, adverse effects on the environment, and regulatory action. One of the most critical EHS aspects for laboratories is the requirement for chemical safety, which in the United States is specifically regulated by OSHA Laboratory Standard, 29 CFR § 1910.1450, Occupational Exposure to Hazardous Chemicals in Laboratories. This standard was created to minimize employee exposure to hazardous chemicals in the laboratory and sets forth guidelines for employers and trained laboratory personnel engaged in the use of hazardous chemicals.3

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329 CFR § 1910.1450 (1990), http://www.osha.gov/.



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