Contents
Approved by Jimmy Vo
Revised 10/2025
23.1 Policy
23.2 Scope
23.3 Applicability
23.4 Exceptions
23.5 Roles and Responsibilities
23.6 Definitions
23.7 Required Work Processes
- Work Process A. Planning Off-Site Work
- Work Process B. Procedure in the Event of Injury or Illness in the Course of Performing Off-Site Work
- Work Process C. Work-Related Boating, Diving, or Aviation Activities
23.8 Source Requirements
23.9 Reference Documents
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23.1 Policy
Lawrence Berkeley National Laboratory (Berkeley Lab) policy requires the prevention of injuries, illnesses, and environmental damage during the course of all work for which it is responsible, including off-site work. Off-site work includes all work performed at sites located away from the Berkeley Lab 1 Cyclotron Road main site, Donner Laboratory on the UC Berkeley campus, and leased facilities (refer to Section 23.6, Definitions, for a list of leased facilities). To authorize work at off-site locations, including field work and telework, Lawrence Berkeley National Laboratory (Berkeley Lab) divisions use the Lab’s formal work planning and control (WPC) processes implemented via the Activity Manager system, supplemented with an Off-site Work Safety Plan, as needed, to:
- Define the scope of work
- Analyze the associated hazards
- Develop appropriate controls
- Perform work within controls
- Obtain feedback for improvement
Radiological work authorizations, construction job hazards analysis, and subcontractor job hazards analysis (SJHA) may also apply to off-site work. Refer to the applicable chapter for more details.
These formal WPC processes are the means by which line management reviews and authorizes work and authorizes workers to perform work. Work may not proceed until authorized by management, and workers may not perform work until they are assigned to one or more work activities and have been authorized by line management. This includes unpredictable, short-term, or unusual work, all of which must be reviewed and authorized. Work is authorized following a risk-based approach. Work involving low or moderate hazards is authorized by line management. Work involving higher hazards requires concurrence of the Environment, Health, and Safety (EHS) Division in addition to line management authorization and supervisor approval.
This policy is intended to drive the development of site-specific and work-specific hazard analysis, to inform employees of actual or anticipated hazards, to identify the training and protective measures needed to perform work safely, to provide emergency information, and to serve as a safety training document. At Berkeley Lab, it applies to all off-site work, including field work and telework, performed under Laboratory direction, including work performed by subcontractors and non-construction subcontractors at any tier. Where non-construction subcontractor work takes place, SJHA may also apply.
23.2 Scope
Off-site work includes all work performed at sites located away from the Berkeley Lab 1 Cyclotron Road main site, Donner Laboratory on the UC Berkeley campus, and leased facilities (refer to 23.6 Definitions for a list of leased facilities).
23.3 Applicability
This policy applies to all Berkeley Lab employees, affiliates, and subcontractors performing work at off-site locations, including remote or field work locations and telework. All off-site work is required to be performed under an official work authorization (e.g. WPC Activity or equivalent) and, where applicable, an Off-site-Work Safety Plan, unless the work is performed under the primary direction of another entity, as stated in Section 23.4, Exceptions. Off-site non-construction subcontractor work may also need an SJHA (see Chapter 31 for clarification).
23.4 Exceptions
Where off-site work is performed under the primary direction of a non-LBNL entity (e.g., other DOE laboratory or university) the directing entity’s work authorization will apply as long as it is equally or more effective in assuring personnel and environmental safety. For these cases, the oversight/enforcement agency must be identified in the WPC Description of Work or Off-site-Work Safety Plan.
This policy does not apply to work performed at sites not managed by Berkeley Lab which have existing work authorization processes.
23.5 Roles and Responsibilities
| Role | Responsibilities |
| Activity Lead | Develops the formal Work Planning and Control Activity and reviews Chapter 31 to determine if an SJHA is needed. |
| Division management | * Adhere to the policy and work processes in ES&H Manual Chapter 6 * Develop supplemental Off-site Work Safety Plans, as needed * Adhere to SJHA requirements, as needed |
| EHS Liaison/Health and Safety Representative | May visit off-site operations, and/or schedule visits by appropriate subject matter experts. Coordinates Level 3 Activity Manager reviews in conformance with the Work Planning and Control (WPC) process. |
23.6 Definitions/Acronyms
| Term | Definition |
| Off-site work | Work, including field work and telework, performed at locations other than the Berkeley Lab 1 Cyclotron Road main site, Donner Laboratory on the UC Berkeley campus, and leased locations. Refer to the On-site Work definition for locations. |
| On-site work | Work performed at the Berkeley Lab 1 Cyclotron Road main site, Donner Laboratory on the UC Berkeley campus, and all leased locations. As of October 2025, leased locations include: * Potter Street – 717 Potter St, Berkeley, CA * EmeryStation East (ESE) – 5885 Hollis St., 3rd and 4th Floor, Emeryville, CA * Richmond Warehouse – 2100 Atlas Road Ste A, Richmond, CA * Computing Sciences – Bloomington, Indiana |
| Off-site Work Safety Plan | A fillable template for planning research / work being performed off-site. |
| SJHA | Subcontractor Job Hazards Analysis |
| WPC | Work Planning and Control |
23.7 Required Work Processes
Work Process A. Planning Off-Site Work
Work Process B. Procedure in the Event of Injury or Illness in the Course of Performing Off-Site Work
Work Process C. Work-Related Boating, Diving, or Aviation Activities
Work Process A. Planning Off-Site Work
- To authorize work at off-site locations, including field work and telework, Lawrence Berkeley National Laboratory (Berkeley Lab) divisions use the Lab’s formal work planning and control (WPC) process Activity Manager, described in Chapter 6 Work Planning and Control, supplemented with an Off-site Work Safety Plan, as needed.
- Include an Off-site Work Safety Plan and embed it in the WPC Activity Manager Description of Work or attach it to the activity. Off-site Work Safety Plan may include:
- Contact information for site personnel
- Emergency response information
- Site- and work-specific hazards and controls
- Work alone requirements
Refer to the Off-site Work Safety Plan template (under development) for specifying, when applicable, that the Environment, Safety, and Health oversight of the work performed is under the jurisdiction of an agency other than DOE. An example of this is work performed by a licensed electrician installing a current monitoring device in a commercial building in California as part of a widespread power consumption investigation project. Oversight of this work is under the jurisdiction of Cal/OSHA.
- Logistics for safe off-site work planning should address:
- Transporation
- Equipment usage
- Contingency plans
- Refer to the Off-site Work Safety Plan for off-site operations planning, contingencies, materials handling, procedures of emergency contact, and other resources.
- Research-related work that involves off-site field work may incur unique hazards (which may require corresponding unique controls) not typically found in indoor laboratory settings. For additional support in addressing these hazards, contact EHS.
- Work which requires certified or licensed individuals (such as a licensed engineer or certified electrician) to perform such work may not take place until the official documentation demonstrating their qualifications can be produced.
Work Process B. Procedure In the Event of Injury or Illness in the Course of Performing Off-Site Work
When Berkeley Lab employees are injured or become ill while conducting official business at an off-site location, the following steps shall be initiated:
- Obtain treatment by a local physician or hospital staff. In cases where the site is remote, the WPC Activity (or Off-site Work Safety Plan) must specify how an injury requiring medical attention will be provided and by what means.
- Follow the Lab’s policy and work processes for reporting and reviewing work-related injury and illness, contained in Chapter 5, Injury Response and Review.
Work Process C. Work-Related Boating, Diving, or Aviation Activities
Supervisors of employees planning to engage in work-related boating, diving, or aviation activities must contact their division’s EHS Liaison for guidelines and safety procedures relevant to their specific operation.
- For off-site work related to boating or diving operations: Work must be reviewed by EHS Division for each vessel before the off-site work begins.
- For the procurement of off-site work-related aircraft or aviation services: See Berkeley Lab’s Aviation Safety Policy for roles and responsibilities.
23.8 Source Requirements
- 29 CFR 1910, Subpart T, Commercial Diving Operations
Other Driving Requirements
- Memorandum of Partnership Agreement between UCB and LBNL Concerning Environment, Safety and Health Policies and Procedures (March 9, 2017)
- U.S. Department of Transportation, Coast Guard, Series 323, Rules and Regulations for Small Passenger Vessels (Under 100 Gross Tons)
- U.S. Department of Transportation, Coast Guard, Series M6672.2, Navigation Rules: International-Inland
23.9 Reference Documents
| Title | Type |
| Subcontractor Job Hazards Analysis (sJHA) Program | Program |
| Work Planning and Control | Program |
| Radiation Safety Program | Program |
| Safe Work Authorizations Program | Program |
| Off-site Work Safety Plan | Document |
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