By Mike Grissom
In SLAC’s Integrated Safety Management System (ISMS),
Guiding Principle 6, Core Functions 2 and 3 refer to hazard controls.
• Guiding Principle 6: Hazard Controls Tailored to Work
• 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
Self-Assessments by Staff
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
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).
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
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.
Peer Reviews by Technical Experts
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.
Compliance Audits by Regulators
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.
You or Your Work May be Impacted
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
• 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
• 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: