In SLAC’s Integrated Safety Management System (ISMS), Guiding Principle 6, Core Functions 2 and 3 refer to hazard controls. Specifically:

• Guiding Principle 6: Hazard Controls Tailored to Work Being Performed

• Core Function 2: Analyze the Hazards

• Core Function 3: Develop and Implement Hazard Controls

These sections state: Administrative and engineering controls to prevent and mitigate hazards shall be tailored to the work being performed and associated hazards.

To verify that the hazards’ control process is functioning properly, a variety of inspection programs exist:

• Self-assessments by staff

• Peer reviews by technical experts

• Compliance audits by regulators

Depending on who is performing an inspection, inspections also may be called audits, self-assessments or operational awareness activities. These inspection programs have staff involved in an assessment of some part of SLAC’s ISMS program throughout the year. Examples of activities conducted in a typical year are shown below. Findings from these inspections have led to enhancements of the ISMS system and to fixing specific problems that have led to an enhanced control of hazards at SLAC.

On a continuing basis, safety inspections are made by Building Managers who are appointed by, and report to, their Division’s Associate Director (AD). The Building Manager program is described at http://www-project.slac.stanford.edu/bldgmgr/.

Periodically each AD makes a safety inspection of the areas for which s/he is responsible. These inspections are reported in the quarterly report of each AD to the ES&H Coordinating Council (ES&HCC). See: http://www.slac.stanford.edu/esh/committees/eshcccha.html

Since 1996, all staff members have participated in the site-wide standdowns (referred to as Safety and Environmental Discussions and later as ‘Talk Walk Clean’ events). The self-assessment function of the standdowns was emphasized in recent years with the offering of a ‘Walk’ option (see https://www-internal.slac.stanford.edu/esh/vpp-isms/historical/).

Findings identified by standdown activities are analyzed, appropriate corrective actions determined and responsible persons identified to complete the corrective action by specified dates. The online system for viewing the status of items identified is called the ‘Self-Assessment Tracking System’ (SATS), which may be accessed from the standdown program Web site.

Once a year, some aspect of the SLAC ISMS program is reviewed by the ES&H Sub-committee of the Scientific Policy Committee (SPC). The ES&H Sub-committee is composed of two members of the SPC (one of whom serves as the subcommittee Chairperson) and outside technical experts from sister DOE laboratories. For the May 2002 review, ‘ISMS: Line Management Responsibility,’ the outside experts were the ES&H Managers for LBNL, FNAL and TJNAF. The reports of this subcommittee are provided to the President of Stanford University for review and determination, with the SLAC Directorate, of appropriate corrective action.

Twice a year, outside technical experts are contracted to inspect SLAC facilities with an eye on the general topic areas of worker protection (safety and health) and environmental protection (including management of hazardous and radioactive material). In recent years, the URS Corporation, Inc. has provided this service. During these inspections, experts such as industrial hygienists and environmental engineers, visit buildings and projects throughout the site. Results of the inspections are collated by finding type and location, corrective action determined, and assignments made to a person or organization (such as the ES&H CC, for site-wide items) responsible for completing the corrective action by a specified date. The online system for viewing the status of items identified is called the ‘Quality-Assurance Tracking System’ (QATS), which may be accessed from the the standdown program Web site.

The principal regulator for SLAC is the DOE. Staff from the DOE Stanford Site Office (SSO) and Oakland Operations Office (OAK) conduct informal inspections, called operational awareness reviews, periodically throughout the year. If a finding warrants immediate action under the expectations of the SLAC ISMS program, corrective action may be required by the Director of the SSO. Special inspections, such as the DOE Type B Accident Investigation Board Review activity in February 2003, are done on an ‘as needed’ or ‘for cause’ basis. Corrective action for findings from DOE inspections is normally managed by the SLAC organizational element where the finding occurred. The ES&H Division provides a review of ES&H items, including adequacy of corrective action.

For environmental programs, SLAC is regulated by a number of external (that is, non-DOE) regulators who visit the SLAC site at various intervals during a typical year. For example, hazardous material and waste management is inspected annually by the San Mateo Department of Environmental Health Services. Findings from these compliance audits must be dealt with on a timely basis (specified by the regulatory body) and, if the finding is considered serious enough, a ‘notice-of-violation’ (NOV) or similar order directing correction of the non-compliance item may be issued, and may include the imposition of a monetary penalty. Similar regulatory functions are provided by inspections from the Bay Area Air Quality Management District (BAAQMD) and the Regional Water Quality Control Board (RWQCB) for air and water programs.

Later this year SLAC will likely experience two special inspections related to a Congressional initiative to evaluate the costs of externally regulating worker protection and radiation protection activities at the Office of Science laboratories. The Federal Occupational Safety and Health Administration (FedOSHA) and the US Nuclear Regulatory Commission (NRC) will be performing these inspections. FedOSHA is expected to be on site for 1-2 weeks with a team of about 10 inspectors. The NRC is expected to be on site for 1-2 weeks with a team of about five inspectors. Both of these inspections will be conducted as ‘compliance audits’ with the findings reported to the Office of Science to assist in evaluating the costs of external regulation. For this special process, no NOVs or fines will be imposed. More information on this important inspection activity will be provided in future issues of TIP detailing how individuals and managers can more fully participate in the ISMS process.

An effort is made to minimize the impact of the many inspections on SLAC staff and operations by coordinators, often ES&H Division subject matter experts or Divisional ES&H Coordinators. To facilitate this process, a staff person is normally designated to serve as the principal SLAC point-of-contact for the inspection. Efforts are and will be made to:

• Determine as completely as possible the scope of the inspection.

• Ensure inspectors are properly trained and escorted.

• Contact residents of buildings to be inspected as far in advance as practicable.

• Document findings in inspected areas with photographs where appropriate.

• Report summaries of inspections to the responsible persons on as timely a basis as possible.

Details about the SLAC ISMS program, including the Safety Management System document, are available on the Web at: http://www.slac.stanford.edu/esh/isms/