Integrative Safety Management (ISM) Plan
The Life Sciences Division will conduct its operations in a manner that protects the health and safety of its employees and guests, that does not endanger the environment, and that is consistent with applicable LBNL, University and government agency policies and regulations. LBNL's EH&S policies and requirements are contained in the LBNL Regulations and Procedures Manual (RPM), LBNL Publication 3000: The Health and Safety Manual, and in the LBNL Operating and Assurance Plan (OAP).
Scope of Plan
The Life Sciences Division has an annual budget of approximately $58.5M and 500 employees and guests. Most of the Division's research is performed by small research groups under the direction of a principal investigator. These groups are organized into departments and centers by the nature of their research interest. The Division's research is conducted in 10 different buildings, including one on campus (Donner Laboratory), and one near the foot of Ashby Avenue in the City of Berkeley (Potter Street).
The Life Sciences Division home page, including an organizational chart, appears at: http://www.lbl.gov/lsd/.
The size and geographic distribution of the division means that effective safety management, with the full involvement of Division Management, Safety Coordinators, Safety Committee, and the currently implemented program of Safety Leads are even more critical to safe work than they would be in a smaller and/or more compact division.
This Life Sciences Division Integrated Safety Management (ISM) Plan covers all Life Sciences Division workers, including employees, students, guests and visiting scholars, regardless of compensation or work location. LBNL work performed on the UC Berkeley campus must conform to the "Partnership Agreement Between UCB and LBNL concerning Environment, Health and Safety Policy and Procedures."
To assure prompt response and service, the Life Sciences Division provides safety support to Genomics Division staff located in LBLN Bldg. 84. This arrangement is detailed in an MOU between LSD and JGI.
The Life Sciences Division currently has two research groups located in campus space (Kunxin Luo, Abby Dernburg).
The mechanisms for insuring Life Sciences Division activities comply with LBNL EH&S polices and requirements are as follows:
Accountability
The Division Director, reporting directly to the LBNL Director, is ultimately responsible for all activities within the Life Sciences Division. Principal Scientists are responsible and accountable directly to the Division Director for assuring that all activities under their direction are carried out in a safe manner, in accord with all LBNL EH&S policies and requirements. This responsibility and accountability cannot be delegated. Principal Scientists are accountable for assuring the safety of their staff and operations, the protection of the environment, and compliance with EH&S requirements. They must consult with qualified specialists (e.g. the Life Sciences Division ES&H Coordinator, and/or EH&S Division) where needed, to acquire technically correct information about safety and environmental protection consistent with Laboratory EH&S policy and regulatory requirements.
While Principal Investigators and supervisors are responsible for assuring that EH&S requirements are followed by their subordinates and visitors, Life Sciences Division employees and guests are also individually responsible for following the EH&S requirements that pertain to the hazards of their work.
Principal Investigators are responsible for periodic and detailed inspections of their workspace, in support of which the Division Director and Deputy Director do as-needed inspections of selected workspaces. In further support of this, annual walkthroughs are conducted with each Principal Investigator to update their space-hazards data. The Division Director, in company with the division Safety Coordinators, does walk through inspections of all division research spaces twice each year. A representative of the Department of Energy will be invited to observe.
Employees and guests are expected to work safely, watch out for the safety of others, and to cooperate with Life Sciences Division and LBNL EH&S efforts. If they have any questions or concerns about the safety or environmental impact of an activity, they have the obligation to report unsafe operations, and, if necessary, to exercise the laboratory's Stop Work policy, and to resolve the concern before proceeding with associated work.
The supervision of students is of particular concern. Students often arrive without prior laboratory experience, stay for short periods of time, and may have rapidly evolving job assignments. Supervisors of students must assure that each student receives appropriate training and close, daily supervision from staff who are present in the laboratory on a regular basis.
Safety awareness and practice is a required work expectation of all Life Sciences Division staff. In this we must strive for research efficiency within the bounds of sound safety practice and common sense.
Development and Enforcement of Life Sciences Division EH&S Policies
The Life Sciences Division Safety Committee consists of members of every major Division research group (20 representatives from the Life Sciences Division and 4 representatives from the Genomics Division, plus the Division Safety Coordinator and deputy, who is also the Division representative to the LBNL Safety Review Committee). These representatives include Principal Scientists and research staff, and serve the Division in promoting general EH&S awareness and practice. In addition, EH&S Division staff are included in the distribution of meeting announcements and minutes, and attend as their interest or expertise may suggest. The EH&S Division Liaison for LSD regularly participates in these meeting. The committee meets monthly, as necessary, except for December.
Members of the Life Sciences Division Safety Committee serve as primary points-of-contact during Self Assessment activities and inspections. During such assessments, contact may also be made with the Principal Scientist, the Department Head, or the LSD or JGI Division Directorate, on an as-needed and graded basis.
Everyone who does work in the Life Sciences Division is a part of the division's safety management chain. This chain links every staff member and participating guest, from the individual worker through each supervisor and mentor to senor management, including the Division Director.
To support the division safety program and Self Assessment activities each Life Sciences Division Principal Investigator assigns a primary safety contacts ("Safety Lead") for each of their LSD laboratory spaces. These Safety Leads frequent these laboratories on a daily basis, are familiar with their processes and hazards, and serve as the point of contact for question regarding integrated safety management (ISM) and compliance. Appointing a Safety Lead serves to spread a culture of safety more broadly throughout the workplace, however as the designated supervisor, the PI retains direct line management responsibility for the safety of all employees, users and quests.
Self Assessment in the Life Sciences Division is further supported by the active participation of the four primary LSD building managers in the Potter Street, Donner, 64/55, and 84/74 Facilities. This participation includes periodic walkthroughs of their facility with the division safety coordinator, and includes participation of research staff and Principal Investigators as documented in the Self Assessment log. The purpose of including building managers is to provide a second perspective for Self Assessment walk-around inspections of division work and spaces, and to provide the division with significantly greater depth and distribution of experience in the area of safety management.
In addition, the Division Safety Coordinator and Deputy Safety Coordinator complete safety checklists for all LSD spaces each six months. Separate checklists are used for laboratory and office/shop spaces.
The Safety Coordinator is responsible for maintaining the Life Sciences Division Safety Plan on behalf of the Division Director, and assuring that the Division's ongoing program of Self Assessment is conducted in all Division spaces. Meetings of the Safety Committee serve to promote and explain the plan, the Division safety program and its' associated activities, as well as to afford members of the committee the opportunity to participate in this process. In addition, the coordinator serves on the Life Sciences Division Advisory Committee, to assist the Division Director in assuring that safety issues are discussed in a regular and timely manner.
Scope of Work Authorized
The Life Sciences Division conducts research not limited to but primarily including cancer biology, molecular and nuclear medicine, radiation biology and DNA repair, subcellular structures, and genomics.
Life Sciences Division staff areas of expertise include genetics, biology and medicine, chemistry and pharmacology, radiation biophysics, as well as a number of other disciplines. The Division uses a broad range of generally low risk scientific devices and instruments including gel electrophoresis systems, scintillation counters, centrifuges, light and electron microscopes, and cell culture incubators. Relatively higher risk devices such as Class 3B and 4 lasers, X-ray sources, the Cobalt-60 Source and the Biomedical Isotope Facility (BIF) are individually covered by Activity Hazard Documents (AHD's) or, as is the case with BIF, by the Final Safety Analysis Document (FSAD) and the Accelerator Safety Envelope document.
Research activities proposed in Field Task Proposals, Work for Others, and other funding venues are reviewed by the Principal Investigators for any increase in hazard, which would require additional safety controls and/or documentation (Chapter 6, Pub. 3000). PI's have responsibility for the identification and mitigation of research activities which have potential hazards.
Each Principal Scientist prepares (or collaborates with Division Safety Coordinator, EH&S Division staff, etc.) EH&S documentation and obtains all required approvals for potentially hazardous or regulated work as defined in Chapter 6 of Publication 3000 (The Health and Safety Manual) prior to start of work. The National Environmental Policy Act/California Environmental Quality Act (NEPA/CEQA) process requires that Principal Scientist must sign off that no further documentation (copies w/ DSC) is required (or specify what is required) before a proposal may be submitted for funding. Such documents may include Human and Animal Use, Radiation Work Authorizations, and Activity Hazard Documents.
Special approval is required to add personnel to a Biological Use Authorization or to modify the level of risk of the work covered by the authorization between formal renewals. A description of the changes is sent by the Authorization holder to the LBNL Biosafety Officer and the Life Sciences Division Safety Coordinator (DSC). The DSC determines the training requirements resulting from the modification and ensures that all personnel listed on the authorization complete their training prior to conducting the new tasks.
The need and application of appropriate hazard documentation is confirmed, primarily by the division Self Assessment efforts, but reinforced and supported by the Laboratory Self Assessment Program and the Integrated Functional Appraisal. Principal Investigators should refer to Pub. 3000: the LBL Health and Safety Manual, Chapter 6, Appendix B in order to determine if a hazard may be sufficient to need an authorization. PIs are encouraged to seek the assistance of EH&S Division subject matter experts in this process.
Finally, Principal Investigators and laboratory managers are to advise the division safety coordinator of plans to vacate space or relocate operations no less than two months in advance of such action. The purpose of this notification is to allow time for the disposal, cleanup and/or packaging of any radioactive or hazardous chemical materials. Such materials include unused items, items prepared for use, as well as items destined for disposal as waste.
Qualification and Training
It is the responsibility of the Principal Scientist to determine training needs and to document that each employee or guest under his or her supervision has training and orientation appropriate to the hazards of their work, or as required by law. Until such training has been completed, the employee must only work under the direct supervision of an individual appropriately trained. Training may include EH&S class work and at-the-bench training and must be documented in the LBNL Training Database or in laboratory logs or notebooks.
All employees and guests that work in the division for more than 30 days in a calendar year are required to discuss the hazards of their work and workplace with their supervisor, in accord with the Job Hazard Assessment process, typically in annual group meetings. These meetings are moderated by the supervisor with assistance from a division safety coordinator. Following these group meetings, individuals complete their Job Hazard Assessment profiles, following which it goes to their supervisor for review. The results of this process are a group discussion and review of workplace hazard and safety communication, plus a safety training curriculum, specific to each individual, agreed and reviewed by both the worker, and their supervisor.
Supervisors must be especially attentive to student training; assuring that each student completes the JHA and training appropriate for their work and is provided appropriate on-the-job training, including introduction to other supervisory staff that can provide continuity of support and oversight.
The Division Safety Coordinator tracks the completion and yearly renewal of the JHAs, and training, advises division management, and contacts the responsible supervisor to remind them about specific missing, incomplete or out-of-date JHAs or training obligations.
Formal EH&S class work is mandatory as specified in PUB-3000, most critically in the areas of in radiation protection and hazardous waste management, but also for a broad range of other hazard concerns, as provided in the LBNL Training web-page http://www.lbl.gov/ehs/training/index.shtml. Additionally, a number of formal classes offered by EH&S are recommended for supervisors and research staff.
Last revised: 11/14/08
