Version 2017-06-22/mv

BioCAT ESH PLAN

1. Purpose

BioCAT is committed to ensuring that all beam-line related activities are conducted in a safe and environmentally sound manner in accordance with the principles of Integrated Safety Management (ISM). This document (herein referred to as "this Plan") describes BioCAT's safety program which is implemented to fulfill this commitment.

2. Scope

To ensure that all beam-line activities are conducted in a safe and environmentally sound manner, this Plan defines

  1. the standards to be followed by the BioCAT organization and
  2. the safety responsibilities within the BioCAT organization.

3. References

All activities at Argonne National Laboratory (ANL) will conform to the requirements of the documents listed below---which are hereby incorporated by reference---except as provided for by variances or superseded by Advanced Photon Source (APS) procedures. All of the following are available through the BioCAT Safety Coordinator.

  1. ANL Laboratory Management System

  2. APS User Policies and Procedures

  3. ANL Hoisting and Rigging Manual
  4. ANL Hazardous Materials Transportation Safety Manual
  5. ANL Waste Handling Procedures Manual

4. Policies

4.1 General Policies

  1. All work will be sufficiently planned such that all hazards that cannot be removed by design have been identified and reduced to acceptable levels by using engineered and/or administrative controls.
  2. No person shall be inside an optical enclosure or experiment station when all the doors to that enclosure or station are closed.
  3. This ES&H Plan will be modified in accordance with the APS User Policy and Procedure for Environment, Safety, and Health Programs.

  4. Failure to conform with this plan may result in sanctions and/or loss of access to the BioCAT and APS facilities.
  5. BioCAT will cooperate with the APS to facilitate the oversight responsibilities of the APS, ANL, and the DOE.
  6. In accordance with the ANL Stop Work Authority Policy (ANL ES&H Manual 1.1.6), any person has the authority to stop activities that are perceived as unsafe or environmentally unsound. Subsequently, BioCAT acknowledges that the APS has the authority to order a halt to BioCAT activities that the APS---or other entities with oversight responsibilities---deem unsafe or not in compliance with written directives.

  7. In accordance with the APS Configuration Control Work Permit Policy and Procedure, no safety system under configuration control is to be modified without both BioCAT and APS approval.

  8. For each experiment to be performed at the BioCAT facilities, BioCAT will utilize the Experiment Safety Review Program embodied by the APS Experiment Safety Assessment Form System. BioCAT will encourage its Users to submit the ESAF no later than ten business days prior to the experiment start date to give ample time for the APS and BioCAT to review it.
  9. BioCAT will obtain the written approval of the APS Engineering Support Division Director or their designated alternate before engaging in any activity which poses a significant increase in risk of damage to:
    1. the health and safety of the employees and visitors to the APS,
    2. the environment, or
    3. the APS facilities.

4.2 BioCAT-Specific Policies

  1. Anyone who is not an employee of the APS must be classified into the following four roles if they are to spend time at the BioCAT facility:
    1. Staff

      1. Definition: A BioCAT Staff member is an individual who has a valid APS User badge, is employed full-time by the Illinois Institute of Technology, and has an office located in building 435B at ANL.

      2. Safety Oversight: BioCAT Staff members must maintain an up-to-date Job Hazard Questionnaire (JHQ) on file with the ANL Training Management System (TMS) and complete training requirements as determined by that system.

    2. User

      1. Definition: A BioCAT User is an individual who has a valid APS User badge and is named on an approved Experiment Safety Assessment Form (ESAF) to perform an experiment at the BioCAT facility.

      2. Safety Oversight:

        1. The Administrative Coordinator or their designated alternate will inform the User that they must contact the APS User Office prior to their arrival and complete APS-required training before being permitted to perform work at BioCAT.

        2. The User Liaison or their designated alternate will:

          1. Perform an initial review of the ESAF. If necessary, the User Liaison will involve other members of the BioCAT safety organization to resolve known or discovered issues.
          2. Initiate the approval process by a Staff Member named in Appendix A.2 who will conduct the final review.

          3. Ensure that the ESAF has been approved.
          4. Submit the ESAF to the Floor Coordinator for verification and posting prior to beginning work.
          5. Verify that the experiment conforms to the posted ESAF.
          6. Verify that expired training indicated by the ESAF is completed.
    3. Contractor

      1. Definition: A BioCAT Contractor is any individual who is not a Staff member nor a User and is authorized by the Director to design, build, modify, repair, or install hardware or software for use at the BioCAT facility in accordance with the Policy and Procedure for Use of Third-Party Contractors at the APS (APS_1410423).

      2. Safety Oversight: The BioCAT Contractor Liaison or their designated alternate will:

        1. file a Purchase Order Request with the Administrative Coordinator.
        2. complete part 1 of the APS Work/Project Checklist (APS_1259683) and submit it to the Floor Coordinator.
        3. work with the Floor Coordinator to arrange a gate pass and safety training.
        4. ensure that the work conforms to the Job Description and see that it is completed in a safe and timely fashion.
    4. Visitor

      1. Definition: A BioCAT Visitor is any individual who cannot be classified under any of the above roles and has been invited by a BioCAT Staff Member to spend time at the BioCAT facilities.

      2. Safety Oversight: Any Staff member who escorts Visitors at the BioCAT facility has the following responsibilities:

        1. Ensure that a gate pass for the visitor has been arranged by the Administrative Coordinator.

        2. Ensure the visitor complies with this Plan.
        3. Alert the visitor to all hazards and precautions in their immediate vicinity.
        4. Remain with the visitor whenever the visitor is in a controlled area, including every chemical laboratory and every radiologically controlled area to which the visitor has authorized access.
        5. Ensure that the visitor does not inadvertently trigger an alarm.
        6. Escort the visitor to the proper shelter or gathering place during any emergency situation.
        7. Ensure that the visitor's emergency medical needs are met promptly.
  2. Sector Orientation
    1. BioCAT will provide Sector Orientation to all Staff Members, Users, and Contractors as required by the APS User Training Policies and Procedures.

    2. The content of BioCAT Sector Orientation for Users and Contractors can be found at the following link: http://www.bio.aps.anl.gov/safetycomp/orientation.html and is meant to be given as a walking tour of the facility.

    3. Sector Orientation will be presented to all Staff Members, Users, and Contractors after they arrive at the BioCAT facility and before they begin to work if any of the following are true:
      1. If they are new to BioCAT
      2. If recommended by the APS
      3. If significant changes have been made to the BioCAT facilities, policies, or procedures since the individual was last at BioCAT.
  3. In accordance with 29 CFR 1910.132, individuals working at the BioCAT facility will use the Personal Protective Equipment (PPE) appropriate for the hazard being managed.

5. BioCAT Safety Organization

5.1 Definition

Each member of the BioCAT safety organization, except the Director,

  1. is appointed by the Director and reports to the Director,
  2. ensures compliance with their specified sections of the references cited in Section 3,

  3. ensures compliance with the procedures listed in Appendix B and Appendix C.

  4. may maintain certain records,
  5. has certain responsibilities not covered by the references, and
  6. may require training above and beyond BioCAT Sector Orientation and the APS core training.

5.2 Roles

Those references enforced, records maintained, responsibilities performed, and training required that are not covered by Section 3, Appendix B, or Appendix C are listed below:

  1. The BioCAT Director has line responsibility for safety for all BioCAT activities performed at ANL and is responsible for evaluating and responding to non-compliance with this Plan in a graded manner. The Director also ensures that this Plan covers all relevant safety issues likely to be encountered at the BioCAT facilities and that the Plan is implemented.

  2. The BioCAT Administrative Coordinator is responsible for for maintaining records related to safety and environmental protection.

    • References: None.

    • Records Maintained:

      • Sector orientation records for BioCAT Staff and Users.
      • User Assessment (End of Run) Reports
      • IRB & animal care records

      • User Shipping Documents
    • Special Responsibilities:

      • Provides training oversight for Staff and Users
      • Orders safety related equipment.
      • Maintains the BioCAT First Aid Kit.
    • Required Additional Training: None.

  3. The BioCAT Safety Coordinator is the primary point-of-contact for all safety issues at BioCAT and coordinates the activities of all the other members of the BioCAT safety organization.

    • References: All references listed in this section.

    • Records Maintained:

      • BioCAT Sector Orientations
      • This BioCAT ES&H Plan

      • BioCAT Safety Incident Reports
    • Special Responsibilities:

      • Ensures that all BioCAT activities conform to the BioCAT ES&H Plan.

      • Initiates actions required to reduce existing hazards below acceptable levels in a timely fashion.
      • Performs or delegates another member of the safety organization to perform sector-specific orientation.
      • Serves as alternate member of the safety organization when a member is unavailable or doesn't exist for a particular issue.
    • Required Additional Training: None.

  4. The BioCAT User Liaison is a BioCAT staff member assigned to be the liaison between a particular group of Users and the BioCAT facilities. They are the primary point of contact for the group for all issues and will ensure that the work performed by the group to whom they are assigned conforms to the ESAF and BioCAT ES&H Plan.

    • References:

      • APS Experiment Safety Review Process (APS_1187022)
      • All references listed in this section that are related to the specific experiment for which they are the BioCAT liaison.
    • Records Maintained: None.

    • Special Responsibilities:

      • Initiates discussions with the Safety Coordinator or appropriate member of the safety organization for resolution of safety-related issues.
      • Ensures the ESAF for the given experiment is completed and approved before the experiment is to begin.
      • Verifies that the ESAF accurately describes the given experiment.
      • Verifies that Users have completed delinquent training indicated by the ESAF.
    • Required Additional Training:

      • ESH371: Electrical Safety Training - General
      • ESH377: Electrical Safety Awareness
      • ESH387Z: Small Quantity Exception Hazardous Materials
  5. The BioCAT Contractor Liaison is a BioCAT staff member assigned to be the liaison between a Contractor and the BioCAT facilities. They will ensure that the work performed by the Contractor to whom they are assigned conforms to the BioCAT ES&H Plan.

    • References:

      • Policy and Procedure for Use of Third-Party Contractors at the APS (APS_1410423)
      • All references listed in this section which are related to the specific work for which they are the BioCAT liaison.
    • Records Maintained: None.

    • Special Responsibilities:

      • Initiates discussions with the Safety Coordinator and Floor Coordinator or appropriate member of the safety organization for resolution of safety-related issues.
      • Completes the APS Work/Project Checklist (APS_1259683) and submits it to the appropriate APS Floor Coordinator.
      • Ensures that the contractor does not perform work without an approved APS_1259683 and Contractor Safety Training (options are mini- and full- Contractor Safety Courses -- for most contractors, the Mini- is adequate and can be taken at the User Office).
      • Ensures the work conforms to the Job Description listed.
    • Required Additional Training: None.

  6. The BioCAT Biological Safety Coordinator oversees the handling and disposal of biological materials at BioCAT.

    • References:

    • Records Maintained:

      • Listing of biological samples currently on-site.
      • IBC Experiment Registration Forms
      • BioCAT Experimental Procedures and Safety Measures Protocols
    • Special Responsibilities:

      • Assists in formulating, implementing, and administering all biological sample-holding procedures.
      • Assists in maintaining the BioCAT Bio-Chemical laboratory.
    • Required Additional Training: None.

  7. The BioCAT Chemical Safety Coordinator oversees the handling and disposal of chemicals at BioCAT.

    • References:

      • Relevant OSHA regulations
    • Records Maintained:

      • MSDS sheets for all chemicals stored.
    • Special Responsibilities:

      • Participates in inspections of all on-site chemical storage areas.
      • Recommends and initiates changes to existing facilities to remedy non-conformance issues.
      • Maintains the BioCAT Bio-Chemical Laboratory.
      • Maintains the BioCAT Satellite Waste Collection Facility
    • Required Additional Training:

      • ESH196: Hazard Communication
      • ESH456: Chemical Waste Certification
      • ESH574: Chemical Waste Generator
  8. The BioCAT Electrical Safety Coordinator oversees all electrical work at BioCAT.

    • References:

      • none
    • Records Maintained:

      • Schematics and descriptions of existing equipment.
    • Special Responsibilities:

      • Participates in inspections of areas with electrical safety issues.
      • Oversees reviews of all electrical equipment to be used at the beam-line.
    • Required Additional Training:

      • ESH371:Electrical Safety Training - General
      • ESH375: NFPA 70E
      • ESH377: Electrical Safety Awareness
  9. The BioCAT Mechanical Safety Coordinator oversees mechanical work performed at BioCAT. The roles of LOM Shop Coordinator and Hoisting and Rigging Safety Coordinator fall under this heading.

    • References:

    • Records Maintained:

      • Maintenance history of shop equipment.
    • Special Responsibilities:

      • oversees the work performed in the LOM shop.
      • Ensures that shop equipment is in safe, working order.
      • Recommends and initiates repairs to equipment that is found unsafe or unusable.
      • Provides BioCAT-specific training to users qualified to operate shop equipment.
      • Ensures that the operators of the shop equipment conform to the BioCAT ES&H Plan.

      • Provides BioCAT-specific training to users who are authorized to operate a chain-fall hoist.
    • Required Additional Training:

      • APS20920: Manlift Aerial Work Platform Operator Training
      • APS21111: Incidental Crane Operator Training
      • ESH114: Lockout/Tagout
      • ESH117: Ladder Safety
      • ESH520: Fall Protection
  10. The BioCAT Radiological Safety Coordinator oversees the handling and storage of all radioactive materials at BioCAT and is also the Laser Control Area Supervisor overseeing the use of lasers at the BioCAT facility.

    • References:

      • Policy for Conducting Radioactive Sample Experiments in APS Experiment Enclosures
      • Management of Sealed Radioactive Calibration Sources
      • ANSI Z136 (The Z136 series of laser safety standards are copyrighted documents)
    • Records Maintained:

      • Listing of all BioCAT lasers and their locations.
      • Required Standard Operating Procedures.
      • Ophthalmology reports for qualified users.
    • Special Responsibilities:

      • Maintains radioactive sample lock-box key.
      • Oversees drafting of SOP.
      • Schedules training and optometry examinations when required.
      • Participates in LCA review with APS and ANL Laser Safety Officer.
    • Required Additional Training:

      • ESH120: Laser Safety Training
      • ESH124: Laser Alignment OJT
      • ESH700: Radiation Worker Level 1
  11. The BioCAT Transportation Safety Coordinator oversees transportation of all materials to and from the BioCAT facilities.

    • References:

      • Applicable sections of 49 CFR 171-178

      • Transportation of Small Quantities of Hazardous Materials (APS_1410268)
      • User Shipments from the APS (TU-28)
    • Records Maintained:

      • Shipping Orders
      • Material Move Orders
      • Hazardous Material Manifests/Cargo Lists
    • Special Responsibilities: None.

    • Required Additional Training:

      • ESH387: Basic Hazardous Materials Modular Training
      • ESH387Z: Small Quantity Exception Hazardous Materials
      • ESH455: Infectious Substances Transportation

Appendix A

A.1 Safety Organization Members

Role

Personnel

Director

Tom Irving

Administrative Coordinator

Carrie Clark

Safety Coordinator

Mark Vukonich

User Liaison

Srinivas Chakravarthy, Weikang Ma

Contractor Liaison

Any BioCAT Staff Member

Biological Safety Coordinator

Mark Vukonich

Chemical Safety Coordinator

Mark Vukonich

Electrical Safety Coordinator

Rich Heurich

Mechanical Safety Coordinator

Rich Heurich

Laser Safety Coordinator

Weikang Ma

Radiological Safety Coordinator

Will appoint one if needed/ no sealed sources present

Transportation Safety Coordinator

Mark Vukonich

A.2 BioCAT Staff with Experiment Safety Approval Authority

As Director of BioCAT, I authorize the following personnel to conduct hazard evaluations, specify required control measures, and generate official approvals for experiments to be conducted at BioCAT owned facilities at the APS.

  1. Tom Irving
  2. Srinivas Chakravarthy
  3. Mark Vukonich



<signed> Tom Irving, CAT Director

Appendix B -- BioCAT-Specific Safety Procedures

BioCAT has evaluated the hazards that may reasonably be expected in normal operations. The following unmodified APS Standard Procedures listed below will be followed to mitigate some of those hazards. The remainder will be handled via BioCAT-specific procedures detailed in Appendix C.

Appendix C---BioCAT Specific Procedures

The following procedures, specific to BioCAT, will be implemented to handle hazards not addressed in Appendix B

  1. Specification of Radioactive Sample Storage Location (2004 Sep 30)
  2. Specification of Hazardous Biological Sample Storage Location (2005 Feb 15)

C.1---Specification of Radioactive Sample Storage Location (2004 Sep 30)

BioCAT has equipped 18ID-C with a wall-mounted safe that will be used as the temporary repository for radioactive samples which have been approved by the APS and BioCAT.

C.2---Specification of Hazardous Biological Sample Storage Location (2005 Feb 15)

For those biological samples that do not require specialized containment by the ANL IBC, BioCAT has equipped its biochemical laboratory with a lockable cabinet. This cabinet may be used for storage of those samples which have been approved by the APS and BioCAT for experiments to be performed at at the BioCAT facility.

C.3---Specification for Posting ESAFs

1) Print Approved ESAF(s) which the experiment(s) will be operating under -- posting more than one ESAF is allowed, but you should tell the Floor-Coordinator that you are doing so

2) Check the User Training. All Users listed on the ESAF must have all of their training up-to-date before the ESAF is posted and the experiment begins. You must check to see that this has been done. If there is a blank space where an expiration date should be, and they have completed their training, please write 'ok' and initial with the first and last letters of your name. If they are absent, please draw a line through the line item of their training and mark 'absent' next to their name.

3) If there are Users who are absent. Sign in to the electronic ESAF System and those absent Users as 'Off-Site' or 'Remote'

4) There are two parts to the ESAF -- the 2 signed pages, and the unsigned details of the experiment. Put the unsigned details of the experiment into the sleeve on the hutch door and take out the old ESAF. Give the old ESAF to Carrie. Put the two signed pages in a magnetic clip on the D-Hutch Control Panel.

5) Use the Floor-Coordinator Webpage to notify the Floor-Coordinator that the ESAF should be posted.

C.4---Specification of Improved Hazardous Chemical Disposal Process Knowledge (2017 June 22)

Those Users generating Hazardous Waste for storage in the BioCAT Satellite Waste Accumulation Area will be asked to fill out a form providing for improved communication regarding the process knowledge of hazardous chemicals that they wish to leave with BioCAT for accumulation and disposal in the BioCAT Satellite Waste Accumulation Area. Hazards will be determined according to the MSDS Sheets and according to the OSHA definition, as follows:

From the Institute for Hazardous Materials Management Website: "OSHA's definition includes any substance or chemical which is a "health hazard" or "physical hazard," including: chemicals which are carcinogens, toxic agents, irritants, corrosives, sensitizers; agents which act on the hematopoietic system; agents which damage the lungs, skin, eyes, or mucous membranes; chemicals which are combustible, explosive, flammable, oxidizers, pyrophorics, unstable-reactive or water-reactive; and chemicals which in the course of normal handling, use, or storage may produce or release dusts, gases, fumes, vapors, mists or smoke which may have any of the previously mentioned characteristics. (Full definitions can be found at 29 Code of Federal Regulations (CFR) 1910.1200.)

EPA incorporates the OSHA definition, and adds any item or chemical which can cause harm to people, plants, or animals when released by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment. (40 CFR 355 contains a list of over 350 hazardous and extremely hazardous substances.)"

BioCATESHPlan (last edited 2017-06-27 15:33:09 by vukonich)