0. 3.     HAZARD EVALUATION AND CONTROL

3.1      Chemical Hazards

3.1.1     Hazard Categories

The construction, operation, and maintenance of DND-CAT’s facilities and the conduct of experiments there involve the use of numerous substances that pose hazards.  Those hazards can occur during or result from:

•       Transportation,

•       Receiving and distribution,

•       Storage,

•       Usage (including chemical reactions), and

•       Disposal.

The types of hazards posed by the chemicals used at DND-CAT’s facilities include:

•       Toxicity,

•       Incompatibility (reactivity with other chemicals within DND-CAT’s facilities),

•       Strong oxidizing potential,

•       Thermal stress,

•       Explosivity,

•       Corrosivity,

•       Flammability, and

•       Undesirable environmental impact when not properly controlled.

The chemicals themselves can be categorized as:

•       Mineral acids—e.g., nitric acid, sulfuric acid, etc.;

•       Organic acids—e.g., acetic acid, etc.;

•       Compressed gases—e.g., air, nitrogen, etc.;

•       Bases—e.g., sodium hydroxide, etc.;

•       Cryogenic liquids—e.g., liquid nitrogen, etc.

These chemicals will be used for:

•       Cleaning parts,

•       Providing thermal stability, and

•       Preparing samples.

3.1.2     Hazard Controls

DND-CAT will control chemical hazards in its facilities by using the facilities and systems described below and in DND-CAT Guidelines for the Management of Chemicals

 

3.1.3     Chemical Control

DND-CAT Experiment Safety Reviews afford a means of ensuring that required engineered and procedural controls will be in place before a new chemical arrives at DND-CAT’s facilities.  It also alerts DND-CAT to the possibility that a researcher plans to bring in a chemical that is already available on site.

3.1.3.1     Engineered Controls

DND-CAT’s chemistry laboratory will be equipped with standard laboratory fume hoods, a glove box (nitrogen filled with no water or oxygen), vented gas cylinder storage cabinets, chemical storage cabinets, a drench shower and eyewash, and chemical spill kits appropriate for the chemicals to be handled in the laboratory.

DND-CAT’s sector will be equipped with portable laboratory fume hoods, attached to a sector chemical exhaust system.  It is the policy of DND-CAT that no hazardous gases will be exhausted into occupied spaces and that, where appropriate, gases will be scrubbed before they are vented to the exterior of the building. 

3.1.3.2     Hazard Communication

3.1.3.2.1     Labeling and MSDS

DND-CAT will comply with the requirements set forth in the ANL ESH Manual.

3.1.3.2.2     Hazardous Chemicals List

DND-CAT will maintain a current list of hazardous chemicals on hand.

3.1.3.2.3     Training

General hazard communication topics will be covered in documents provided to all incoming users by the APS and in the orientations conducted by DND-CAT and the APS User Office.  Chemical-specific training for resident DND-CAT personnel will be provided by DND-CAT.  Such training includes details obtained from the appropriate MSDSs and other sources.  Chemical-specific training for nonresident DND-CAT personnel will be the responsibility of their home institutions.

3.1.3.3     Chemical Hygiene Plan

The DND-CAT Chemical Hygiene Plan (see Section 2.9) consists of a set of chemical hazard-control measures appropriate to each laboratory environment.   The plan’s policies, controls, and procedures are responsive to requirements found in Title 29 CFR 1910.1450, Occupational Exposure to Hazardous Chemicals in Laboratories.  The Chemical Hygiene Plan for a specific laboratory is located in the laboratory’s Laboratory Information Binder.  (See DND-CAT Guidelines for LOM Laboratory Information Binders.)

3.1.3.4     Chemical Waste Disposal

The DND-CAT will dispose of all hazardous chemical wastes generated in the DND-CAT sector as described in DND-CAT Guidelines for Management of Hazardous Waste.

3.2      Electrical Hazards

3.2.1     Hazard Categories

The construction, operation, and maintenance of DND-CAT’s facilities and the conduct of experiments at those facilities involve the use of electrically powered devices.  The use and maintenance of these devices pose hazards resulting from:

•       Inadequate power distribution,

•       Poor equipment design,

•       Poor work practices, and

•       Inadequate records and configuration control.

3.2.2     Hazard Controls

3.2.2.1     Power Distribution

Since the National Electrical Code does not permit the use of extension cords during experimental operations, DND-CAT has planned for an adequate number of well-placed electrical power outlets along its beamlines and in other areas it controls.  Approval by either the DND-CAT Safety Coordinator or Electrical Safety Coordinator is required prior to any use of extension cords.

3.2.2.2     Design Criteria

All electrical systems and equipment installed either permanently or temporarily at DND-CAT’s facilities at the APS will meet applicable specifications set forth in the latest edition of the National Electrical Code (NFPA 70), the OSHA electrical safety standards (Title 29 CFR, Part 1910, Subpart S) and the ANL ESH Manual, unless the deviations have been reviewed and approved by the APS.  DND-CAT will consider commercially available electrical and electronic equipment approved by nationally recognized testing laboratories as acceptable for use at the APS if the equipment is installed and used as intended by the manufacturer.  Commercially available equipment that is modified before installation must meet the specifications, or undergo the APS review, noted above.

DND-CAT will decide, on a case-by-case basis, whether to allow usage of equipment manufactured in accordance with foreign standards or approved by foreign testing organizations.  DND-CAT advises users to prepare documentation that describes the design of the equipment and any modification made to adapt it for use at the APS.  In questionable situations, DND-CAT will seek the concurrence of the APS.

3.2.2.3     Configuration Management

DND-CAT will maintain drawings and specifications that describe the current configuration of  permanently installed electrically energized equipment and electrical power distribution at its beamlines.  Such records will identify the amount of current drawn by each component and the electrical circuit supplying power to each component.  The records will also identify equipment that is not grounded.  Historical records may or may not be maintained, at DND-CAT’s discretion.

3.2.2.4     Experiment Safety Reviews and Equipment Inspections

As part of the Experiment Safety Review process, DND-CAT will review all electrical equipment to be used in experiments in its sector.  DND-CAT will make reasonable efforts to verify that such equipment has been constructed in accordance with the design standards referenced in the "Design Criteria" paragraph above.  At a minimum, DND-CAT will inspect the equipment before it is electrically energized at the APS.  The experimenter will be expected to provide, upon request, design documentation that answers questions that cannot be answered by visual inspection.  Where appropriate, DND-CAT may require the experimenter to demonstrate the safety of the equipment through testing.  Where appropriate, DND-CAT will inspect electrical equipment again after installation on the beamline to ensure that installation has not compromised the integrity of any pre-existing beamline safeguards.

3.2.2.5     Required Work Practices

DND-CAT and its personnel will:

•       Maintain up-to-date drawings and instructions for the operation, maintenance, and testing of electrical equipment and ensure that they are readily available to those who need them;

•       Provide appropriate barriers, shields, and warnings if experimental operations preclude grounding the electrical or electronic equipment; and

•       Comply with APS requirements for isolating energy sources using lockout and tagout procedures and the requirements for working hot (electrically).

For detailed procedures, see DND-CAT Guidelines for Electrical Safety Work Practices.

3.2.2.5.1     Lockout/Tagout Procedures

DND-CAT supervisors and Principal Investigators will evaluate all planned work to determine whether lockout/tagout procedures are needed to control hazardous electrical energy sources.  Where a need exists, the supervisor or Principal Investigator will inform the personnel at risk to use the APS lockout/tagout procedures described in DND-CAT Guidelines for Electrical Safety Work Practices, which are derived from Chapter 7-1 of the ANL ESH Manual.

3.2.2.5.2     Working Hot

DND-CAT supervisors and Principal Investigators will evaluate all planned work to determine whether a need exists to work on or near live components having a potential of 50 volts or greater to ground.  Where a need exists, the supervisor or Principal Investigator will inform the personnel at risk to follow the APS Working Hot (Electrically) Procedure described in DND-CAT Guidelines for Electrical Safety Work Practices, which is derived from Chapter 9-1 of the ANL ESH Manual.  DND-CAT will develop written procedures covering exempted work (i.e., routinely performed electrical or electronic testing and research and development activities).

3.2.2.5.3     Personal Protective Equipment

DND-CAT will provide appropriate personal protective equipment as described in DND-CAT Guidelines for Electrical Safety Work Practices.

3.3      Ionizing Radiation

3.3.1     Hazard Categories

DND-CAT activities will expose persons and the environment to the following hazards associated with ionizing radiation:

•       Ozone production,

•       Prompt radiation from x-ray generators,

•       Prompt radiation from sealed radioactive sources,

•       Contamination (leakage from sealed sources),

•       Dispersible radionuclides, and

•       Transportation of radionuclides.

3.3.2     Hazard Controls

3.3.2.1     Ozone Abatement

DND-CAT will abate the production of ozone, so far as is practical, by discouraging the use of experimental setups that require an x-ray beam to pass through air.  Where the beam must pass through air, DND-CAT will assess and control ozone exposures by following the guidance provided by the APS.  DND-CAT will limit ozone exposures by using local or general exhaust systems in experimental stations where ozone is generated.

3.3.2.2     Training

DND-CAT personnel will comply with the training requirements set forth in the U.S. Department of Energy’s Radiological Control Manual.  DND-CAT will rely on the APS User Training Management System to determine the level of training an individual requires. DND-CAT personnel who have received equivalent "core" training at other U.S. Department of Energy facilities will still receive the APS-specific portions of the APS-administered radiological safety training.  DND-CAT personnel will also comply with the radiological safety training requirements set forth in Chapter 5-14 of the ANL ESH Manual.

3.3.2.3     Shielding and the APS Personnel Safety System (PSS)

DND-CAT will comply with the shielding specifications issued by the APS and will verify the effectiveness of the shielding by using survey meters.  Where calculations or a survey indicates the need for additional shielding, supplementary shielding will be installed and managed in accordance with APS guidelines.

It is the policy of DND-CAT that no shielding or personnel safety system installed by the APS or included in an APS-approved configuration shall be modified, removed, or disabled and that no equipment, system, or apparatus shall be operated outside of its designed safety parameters without a formal review by the applicable AOD safety committees and the written approval of the AOD Associate Division Director for Operations.

3.3.2.4     Time and Distance

In keeping with the ALARA principle, DND-CAT will encourage those working in the APS experiment hall to keep their exposures to a minimum by remaining in radiologically controlled areas only as long as absolutely necessary.

3.3.2.5     Dosimetry

DND-CAT personnel will participate in the radiological dosimetry program managed by the ANL ESH Division and will follow the procedures issued by the APS.

3.3.2.6     Monitoring Instruments

DND-CAT will purchase radiological survey instruments only after APS review and approval.  DND-CAT will attempt to ensure the continued reliability of those instruments, in part, by participating in the calibration and maintenance program administered by ANL ESH-Health Physics personnel.

3.3.2.7     Radioactive Source Control and X-ray Generator Usage

DND-CAT will participate in the APS Sealed Source Inventory Program by following relevant procedures issued by the APS.  DND-CAT will also take steps to ensure that persons planning to move radioactive materials to the APS are aware of relevant U.S. Department of Transportation requirements.

Users of DND-CAT facilities must have prior approval from DND-CAT to bring in or use dispersible radionuclides and must adhere to all requirements specified by DND-CAT for their transport and use.

DND-CAT has implemented an x-ray laboratory safety program.  Refer to the “XFD X-ray Laboratory Safety Manual” and the “DND-CAT Addendum to the XFD X-ray Laboratory Safety Manual”.

3.3.2.8     ANL and APS Support Programs

DND-CAT will make full use of APS and ANL programs that contribute to the control of radiological hazards.  These programs include:

•       U.S. Department of Energy-accredited personal dosimetry,

•       Survey instrument calibration and maintenance,

•       Radiological training,

•       Transportation safety, and

•       The Sealed Source Inventory Database.

3.4      INSTALLATION, Maintenance  and OPERATIONAL Activities

The DND-CAT hazard evaluation and control effort with respect to installation and maintenance activities is based on the following concepts:

•       DND-CAT line management is responsible for planning and implementing the hazard controls required to ensure safe construction, modification, and maintenance of the DND-CAT beamlines and support facilities;

•       When necessary, line management will involve in the planning effort those DND-CAT members and nonmember support personnel who are best qualified to anticipate the hazards that will be present during the installation and maintenance activities.

•       Because preliminary hazard evaluation efforts have indicated that installation and maintenance activities will pose a relatively small number of hazards, a programmed database will be used to help identify hazards and select controls.

•       Additional hazard controls will be implemented, and hazard evaluation and control documentation will be promptly revised, to address unanticipated hazards encountered during the installation activities.

Outside contractors must assess the hazards associated with their work and submit a document to the contract manager that identifies the hazards and planned controls.  (See Chapter 17-1 in the ANL ESH Manual and the ANL Manual of Construction.)  DND-CAT will generally accept as sufficient any plans developed by contractors that have been reviewed and approved by the ANL ESH Division.

3.4.1     Hazard Categories

DND-CAT has identified the following installation, modification, and maintenance activities as major sources of hazards:

•       Hand and portable-power tool usage;

•       Hoisting and rigging and other material handling;

•       Work from elevated surfaces;

•       Work posing pressure-related hazards;

•       Work with hazardous materials, including cryogenic liquids and compressed gases;

•       Hot work (fire hazards);

•       Work on or near electrically energized components; and

•       Exposure to ionizing radiation.

3.4.2     Hazard Controls

3.4.2.1     Identification and Training Needs

The DND-CAT Safety Coordinator will request guidance from the APS  on the specific training requirements for DND Staff and members.

 

3.4.2.2     Training

DND-CAT will manage the training needs identified by the APS either by arranging for the training through the APS or by conducting the training itself.

3.4.2.3     Required Certifications

Some tasks, such as waste certification and some hoisting and rigging operations, may only be performed at the APS by an individual having ANL certification for the task.  DND-CAT will comply with APS-issued guidance for such activities.  (See DND-CAT Guidelines for Hoisting and Rigging Operations  and DND-CAT Guidelines for the Management of Hazardous Waste.)

3.4.2.4     Hand Tool and Portable Power Tool Usage

DND-CAT recognizes that the misuse of hand tools and portable power tools is a source of injury even for experienced workers.  For this reason, DND-CAT will require training of all members who are likely to routinely use such tools at the APS.  (See DND-CAT Guidelines for Hand Tool and Portable Power Tool Usage.)

3.4.2.5     Activities Requiring Safe Work Permits

As appropriate, DND-CAT personnel will obtain the following safe work permits before undertaking the corresponding activity:

3.4.2.5.1     Working Hot (Electrically)

This type of permit is required prior to work involving potentially injurious electrical circuits.  DND-CAT will also follow relevant guidance provided by the APS.  Chapter 5-4 of the ANL ESH Manual provides more detailed information, including a description of exempted activities.  Also see DND-CAT Guidelines for Electrical Safety Work Practices

3.4.2.5.2     Open Flame and Spark-Producing Operations
This type of permit is required prior to any open flame or spark-producing activities.  Chapter 11-4 of the ANL ESH Manual provides more detailed information.
3.4.2.5.3     Fire Protection System Impairment

This type of permit is required prior to any planned impairment of the fire protection system or any component thereof.  Chapter 11-5 of the ANL ESH Manual describes the mechanism for obtaining a permit.

3.4.2.5.4     Radiation Work

This type of permit is required prior to any radiation work satisfying one or both of the following criteria:

•       The job is not frequently done or has never been done before; and/or

•       The radiological conditions are unknown and are likely to pose a significant hazard.

Chapter 5-4 of the ANL ESH Manual provides more detailed information.

3.4.2.6     Safety Equipment

3.4.2.6.1     Material Handling Equipment

DND-CAT members will use material handling devices to aid in the movement and positioning of heavy or awkward equipment and materials.  The DND-CAT Safety Coordinator will review requisitions for such equipment to ensure that the requisition specifies compliance with relevant ASME B-30 Series standards.  (See DND-CAT Guidelines for Hoisting and Rigging Operations.)

3.4.2.6.2     Fall Protection

The DND-CAT Safety Coordinator must approve every fall-protection device used by DND-CAT personnel at the APS.  As a rule, new purchases of such devices require the Safety Coordinator’s signature, and previously purchased items require inspection prior to their initial use at the APS.  Devices must satisfy the requirements in Chapter 12-1 of the ANL ESH Manual.  DND-CAT will ensure that persons receive training before they use fall-protection devices.

3.4.2.6.3     Work Area Demarcation, Warnings, and Controls

The supervisor of each installation or maintenance activity will ensure that the boundaries of the work area are marked whenever appropriate and that adequate warnings are in place.  (See DND-CAT Guidelines for Work Area Demarcation, Warnings, and Controls.)

3.5      Commissioning  Activities

DND-CAT will comply with all APS policies and procedures related to the preparation for and verification of beamline commissioning readiness. DND-CAT has reviewed the APS document covering commissioning readiness (Advanced Photon Source Experimental Beamline Commissioning Readiness Process) and understands its own role in planning some commissioning activities.  DND-CAT believes that it will be able to effectively control anticipated commissioning hazards using the processes set forth in the APS document.  If DND-CAT becomes aware of any hazard not covered by the APS plans, it will immediately inform the AOD Associate Director for Operations and the AOD ES&H Coordinator.

3.6      Experiment Safety

Most hazards associated with the preparation and conduct of DND-CAT experiments at the APS have been addressed under the topical hazard evaluations listed above.  DND-CAT will follow the experiment safety review guidance issued by the APS to ensure that sufficient controls are in place before experimental work begins.

3.7      USER LOM Shop Operations

3.7.1     Hazard Categories

Common machine shop hazards can result in eye injuries, cuts, amputations, contusions, fractures, and other injuries; respiratory problems; and skin disease.

3.7.2     Hazard Controls

DND-CAT will reduce risks through usage of the following controls:

3.7.2.1     Personal Protective Equipment (PPE)

DND-CAT expects all personnel and visitors to wear safety glasses with side shields at all times while in the User LOM Shop.  In addition, DND-CAT expects machine shop users to comply with all other posted PPE requirements while working with machinery.

3.7.2.2     Training and Authorization

A person may use the User LOM Shop after demonstrating the appropriate skills and obtaining authorization from the User LOM Shop Coordinator or alternate.  When necessary, some level of orientation will be provided to those requiring use of a machine.

3.7.2.3     Equipment Purchase Reviews

New machines for the User LOM Shop will not be ordered without review and approval of the requisition by the User LOM Shop Coordinator and the APS.  The DND-CAT Safety Coordinator will ensure that required power transmission and point-of-operation guarding is specified in the order.

3.7.2.4     Guarding

DND-CAT personnel will be instructed not to modify or circumvent machine guarding, including point-of-operation guarding, on any machine in the User LOM Shop, including machines owned by DND-CAT.  DND-CAT personnel will report troublesome guards to the User LOM Shop Coordinator, APS Floor Coordinator, or DND-CAT Safety Coordinator.  DND-CAT will consult with the APS Floor Coordinator when attempting to resolve the problem.

3.7.2.5     Postings

Machine-specific requirements for User LOM Shop equipment will be listed on a nearby posting.  DND-CAT personnel are expected to satisfy all such requirements.  The posting will also list the names of those authorized to use each machine and contact information for individuals who wish to gain authorization to use a machine.

3.8      Office Safety

3.8.1     Hazard Categories

The most significant hazards present in DND-CAT’s office spaces are:

•       Ergonomic stresses,

•       Housekeeping,

•       Electrical safety hazards, and

•       Fire hazards.

3.8.2     Hazard Controls

3.8.2.1     Repetitive-Stress Awareness

DND-CAT will informally provide its personnel with information about the potential problems associated with the use of computer keyboards and the measures that can be taken to reduce the risk of repetitive-stress injuries.

3.8.2.2     Housekeeping

DND-CAT will advise all personnel of the need to maintain an orderly office environment with clear paths of egress.

3.8.2.3     Electrical Safety Guidance

DND-CAT will plan the distribution of electrical power in its office spaces to minimize the need for extension cords.  If an extension cord must be used, it will be selected and located in accordance with the DND-CAT Guidance for Electrical Safety Work Practices.

3.8.2.4     Fire Hazard Safeguards

DND-CAT will ensure that heat-producing appliances are kept away from combustible materials.  It will also screen requisitions for heat-producing equipment that might be used in offices, to ensure that the equipment incorporates appropriate safeguards.