This section is reserved for meeting notes from the Industrial Hygiene/Occupational Safety Special Interest Group (IH/OS SIG) Steering Committee conference call meetings normally held every 4 to 6 weeks. Available are the current year’s notes as well meeting notes for the past several years.
The Industrial Hygiene/Occupational Safety Special Interest Group (IH/OS SIG) Steering Committee met on May 18, 2021 through a conference call meeting. Bob Weeks, Los Alamos National Laboratory (LANL) facilitated the meeting in which the following Steering Committee members/guests participated:
Topics covered in this meeting were:
Robin Keeler, DOE-AU-11, gave an update on the following:
The next AU-11 WebEx will be held on July 21, 2021, from 2:00 pm to 3:00 pm EDT. The topic is Nanomaterials in Construction, and will be presented by CPWR’s Director of Nanomaterials Research, Gavin West, and Dr. Bruce Lippy.
The American Industrial Hygiene Conference and Expo's (AIHce's) annual meeting, which will be held May 24–26, 2021, will be a virtual meeting. AU-11 usually hosts the DOE Federal and Contractors Industrial Hygiene Meeting in conjunction with AIHce, but will not be doing so this year. However, they will be hosting a virtual meeting on June 16, 2021, from 1:00pm to 4:00pm EDT. The agenda is being finalized and will be sent out this week. Questions can be directed to Robin at email@example.com.
The DOE COVID-19 Hub is available at https://www.energy.gov/covid/coronavirus-doe-response, and has COVID-19 information, the DOE Workplace Plan, FAQs, and stats.
Also, more detailed COVID-19 information is available on DOE’s Powerpedia pages at https://powerpedia.energy.gov/wiki/Portal:COVID-19. All DOE employees (contractors and feds) have access to Powerpedia.
AU-11 is reviewing OSHA’s draft preamble and Emergency Temporary Standard (ETS) on COVID-19 and will be comparing it to requirements in 10 CFR 851 for any potential issues. Future information and/or WebExs offering guidance may be offered after the ETS is published in the Federal Register.
NNSA is in the midst of a long-term infrastructure rebuilding and replacement phase. The challenge is that some line items take too long to deliver and cost too much. For example, a project that received CD-0 in FY 2021 would expect to be authorized for construction in FY 2027. Furthermore, the CD-2/3 proposal for the Y-12 emergency operations center (EOC) was 644% more than that paid by county governments.
The plan was to conduct a pilot to challenge the current norms in order to create a new, streamlined process for this class of commercial, low-risk, low-cost construction. Authority has been delegated to the Project Management Executive (PME) (NA-50) as the ultimate decision-making authority for the project in the pilot. The PME provides status reports directly to the NNSA Administrator (NA-1) quarterly.
NNSA leadership initially approved four pilot projects—three EOCs and one fire station—in the fall of 2019. The goal of the pilot was to streamline NNSA's delivery of commercial-like, line-item construction projects by challenging current norms including acquisition, contracting, project management, and safety. Safety relied on a newly developed NNSA approach, now known as OSHA+. Based on the results of the initial projects, the pilot was expanded by the NNSA acting Administrator in March 2021 to include an additional six projects slated for FY 2021–2022.
The Deputy Secretary approved a change to DOE Order 413.3B, Program and Project Management for the Acquisition of Capital Assets, to raise the applicability threshold for the Order to projects costing above $50 million. The intent of the "pilot" is to meet the expectations established in Executive Order 13777, Enforcing the Regulatory Reform Agenda and the NNSA Governance and Management Framework, and "to challenge the current norms to the greatest extent possible in order to create a new, streamlined process for this class of commercial-like, low-risk, low-cost construction."
This change has important implications for construction projects that fall into this category. This means that projects with costs less than $50 million do not have a clear delivery model they must follow. Major factors to consider include:
DOE's direction and intent for the pilot was to use federal safety regulations and adhere to appropriate building codes. NNSA's direction and intent was to develop a "graded" approach for the implementation of safety and health requirements "tailored" explicitly to the projects in the pilot. The pilot does not intend to weaken DOE safety requirements, but, rather, uses a tailored approach in meeting safety requirements. This approach recognizes the low-risk nature of the projects and, therefore, removes unnecessary burden on entities building the construction projects in order to support the objectives of the pilot. Additionally, the pilot will strive to maintain the philosophy and principles of integrated safety management (ISM) while implementing a more commercial-like approach to the proposed construction projects.
One challenge is that DOE safety requirements, which are intended for high-hazard, one-of-a-kind, and/or immature technology development, are being applied to non-nuclear, non-complex, commercial construction. Another challenge is that DOE safety requirements are seen as duplicative and confusing. However, there is an opportunity for DOE and NNSA to continue the significant investment they have made in the implementation of ISM and the development of a safety conscious work environment.
The proposed solution to these challenges is to leverage OSHA requirements with some additions/tailoring to support a new, streamlined process for this class of commercial, low-risk, low-cost construction to successfully support the construction of projects in the pilot.
NNSA's approach was to conduct a detailed review of DOE rules and directived. Three assumptions made with regard to this approach were:
NNSA developed and adopted an OSHA Plus approach to the pilot. This hybrid approach utilizes OSHA requirements augmented with appropriate reporting requirements, accident provisions, and enforcement requirements of 10 CFR 851. This approach takes advantage of OSHA requirements with which contractors are familiar and provides an ISM-like methodology.
The advantages to this approach are that it allows for continued partnership between the M&O and NNSA, tailoring of applicable directives or alternative approaches, and the use of a "graded" approach to be fully described in the Project Execution Plan (PEP). It also increased the number of bidders and provided a cost-effective approach to construction of low-risk, nonhazardous facilities, which supports timely construction of safety facilities.
The application of this approach in the request for proposal (RFP) calls for the Construction Contractor (CC) to develop a written Construction Safety and Health Plan (CSHP) that provides for safety over all aspects of the construction activities to be performed. The plan will be reviewed and approved by the Construction Manager (CM) and Federal Project Director (FPD) prior to commencement of any work covered by the plan.
With regard to application to the scope of work (SOW), the CSHP includes OSHA’s core elements of recommended practices for S&H programs in construction. These include, but are not limited to, management leadership; worker participation; hazard identification and assessment; hazard prevention and control; education and training; OSH program evaluation and improvement; and coordination and communication for employers on multiemployer worksites. Because the construction site is on a DOE site, the plan will also describe actions that controlling employers, such as general contractors, prime contractors and construction managers, subcontractors, and temporary staffing agencies (and their workers), should take to ensure protection of everyone on the job site. The CSHP will specifically address health hazards, such as silica, asbestos, and welding fumes, that are common to construction activities and work controls that will be used to mitigate such hazards. The CC will identify competent persons required for workplace inspections of the construction activity, where required by OSHA standards, and will make frequent and regular inspections of the construction worksite to identify and correct any instances of noncompliance with project safety and health requirements.
With regard to machinery/vehicle safety in the SOW, every person operating machinery and mechanized equipment, all-terrain vehicles (ATVs), utility vehicles (UVs), or other specialty vehicles, shall be properly trained, qualified (license/certificate/permit) and designated by the employer in writing to operate such equipment. With regard to reporting, the CC will develop and communicate as part of the written CSHP a procedure for workers to report any injuries, illnesses, incidents (including near misses/close calls), hazards, or safety and health concerns without fear of retaliation. They also will include an option for reporting hazards or concerns anonymously and will make this information available to the CM upon request.
The NNSA lead SME worked directly with the Field Office (NPO) and the M&O (CNS) to conduct a detailed review of the environment, safety, and health (ES&H) specification in the RFP/SOW at the Y-12 Fire Station (FS). To fully apply the OSHA+ model required a significant rewrite of the ES&H specification. Moving next to the LLNL EOC, they used the lessons learned from the Y-12 FS work and applied it to the ES&H specifications in the LLNL EOC RFP/SOW. Then, they worked with the site and DOE-AU on a variance to adopt CAL-OSHA in lieu of similar OSHA requirements within the OSHA+ model. Next, they used the lessons learned from the Y-12 and LLNL work and applied them to the ES&H specifications in the Sandia National Laboratory (SNL) EOC RFP/SOW.
Cost savings have been illustrated in all four projects with estimated average cost avoidance/savings of $8.8M primarily due to streamlined acquisition, technical, quality, and ES&H.
The main lesson learned from this pilot project is that the application of OSHA Plus is a cultural change that requires communication on multiple levels and with many different organizations. Other lessons learned include:
In its simplest form, human performance improvement (HPI) is a series of behaviors carried out to accomplish specific task objectives (results). Behaviors + Results = Human Performance.
Some elements of HPI discussed included:
Integrated safety management (ISM) and HPI integrate well together. The ISM steps are to define the scope of work, analyze hazards, develop and implement controls, perform the work, and gather feedback and make improvements. With regard to HPI, in these steps, errors in defining work can lead to mistakes in analyzing hazards. Without the correct hazards identified, errors will be made in identifying adequate controls. Without an effective set of controls, minor work errors can lead to significant events. Finally, if the response to the event only focuses on the minor work error, the other contributing errors will not be addressed.
ISM and HPI tools can be grouped into three areas: task level hazards analysis and work planning (e.g., task preview, pre-job brief, self-assessments), work execution (e.g., self-checking, checking and verification practices, observations), and worker feedback (e.g., post-job reviews, reporting errors, self-assessments).
Slightly different than ISM, which identifies hazards and controls (what to avoid), Human Performance also looks at "what must go right." TO accomplish this focus, the risk-important actions and critical steps must be identified. Risk-important actions are procedure steps or actions that expose products, services, or assets to the potential for or actual harm. Critical steps are actions that will trigger immediate, irreversible harm if done incorrectly (with error).
At LANL, HPI is not a program. Instead, it is a set of concepts and principles associated with a performance model that illustrates the organizational context of human performance. It is a system that comprises a network of elements that work together to produce repeatable outcomes: organizational factors, job-site conditions, individual behaviors, and results. Their principles, tools, and practices are integrated into LANL processes, such as Conduct of Operations, Conduct of Maintenance, and Conduct of Research.
Human performance is important at LANL because errors can result in HARM to people, equipment and facilities, the environment, and LANL's reputation.
LANL, similar to several DOE facilities, embraced HPI in the 1990’s along with INPO (Institute of Nuclear Power Operations). LANL's HPI strategy is to continue what has been started (engaged employees, learning teams, HPI training), improve what exists (HPI practitioners, HPI website, integrate HPI), and plan for the future (empower people, continuous improvement). The desired result is that reducing errors (anticipate, prevent, catch, and recover from active errors at the job site) and managing controls/defenses (identify and eliminate latent organizational weaknesses that provoke human error and degrade controls against error and the consequences of error) leads to zero significant events.
HPI is not unique to DOE. HPI is used widely in the energy sector, the medical field, the airline industry, and the forest service, just to name a few. It also is used in everyday life, such as in preparing a food recipe (procedure use and adherence), making a shopping list (placekeeping), checking your car's fuel gauge (verification practices), and bookmarking a book or magazine (flagging).
More information on HPI can be found in DOE-HDBK-1028-2009 and at the DOE National Training Center:
Because the DOE Federal and Contractors Industrial Hygiene Meeting is being held in June, the IH/OS SIG will not host a Steering Committee meeting in June. As a result, the next Steering Committee Conference Call meeting is scheduled on Tuesday, July 20, 2021, from 1:30 pm to 3:00 pm EDT.