DRAFT
Contents
Approved by Jimmy Vo
Revised 2/2022
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 Illness or Injury During Off-Site Operations
- Work Process C. Work-Related Boating or Diving Operations
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 at all locations it has responsibility for, including off-site activities. Off-site activities include all work performed at sites located away from the Berkeley Lab main site and satellite locations, which include Donner Hall, Potter Street, and the Joint BioEnergy Institute (JBEI). To authorize work at off-site locations, Lawrence Berkeley National Laboratory (Berkeley Lab) divisions must develop a process to plan for the safety of workers and the environment in the off-site location. The division process should be included in the division’s Integrated Safety Management (ISM) Implementation Plan. The process should follow the principles of ISM:
- Define the scope of work
- Analyze the associated hazards
- Develop appropriate controls
- Perform work within controls
- Obtain feedback for improvement
The Off-Site Work Authorization Policy is implemented through the Work Authorization processes at the division level (e.g., Work Planning and Control (WPC) activities and Subcontractor Job Hazards Analysis (sJHA)). Each division assesses its work activities, identifies activities where personnel are working remotely off-site, and develops a process to plan for their safety. This policy applies to work conducted in remote or field locations. It is intended to drive the development of site-specific and work-specific hazard analysis, to inform employees of present 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 field work performed under Laboratory direction, including work performed by subcontractors at any tier.
23.2 Scope
Off-site activities include all work performed at sites located away from the Berkeley Lab main site and satellite locations, which include Donner Hall, Potter Street, and the Joint BioEnergy Institute (JBEI).
23.3 Applicability
This policy applies to all Berkeley Lab employees, affiliates, and subcontractors performing work off-site.
23.4 Exceptions
This policy does not apply to work performed at a non-DOE off-site facility by a subcontractor working under the jurisdiction of an oversight/enforcement agency other than the DOE. For these cases, the oversight/enforcement agency must be identified.
23.5 Roles and Responsibilities
| Role | Responsibilities |
| Personnel proposing off-site operations | Must give their division director written notification of the nature and scope of the project. |
| 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. |
| Division Director | Reviews and approves off-site operation’s Level 3 Activity Manager activity. |
23.6 Definitions/Acronyms
| Term | Definition |
| OSSEPP | Off-Site Safety and Environmental Protection Plan |
| 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 Illness or Injury During Off-Site Operations
Work Process C. Work-Related Boating or Diving Operations
Work Process A. Planning Off-Site Work
- To authorize work at off-site locations, Berkeley Lab divisions must develop a process to plan for the safety of workers and the environment in the off-site location.
- The division process should be included in the division-specific ISM Implementation Plan.
- The process should follow the principles of ISM:
- Define the scope of work
- Analyze the associated hazards
- Develop appropriate controls
- Perform work within controls
- Obtain feedback for improvement
- The process may specify that the Environment, Safety and Health oversight of the work performed is under the jurisdiction of an agency other than the DOE. An example 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:
- How to send people and equipment to the site
- Using or monitoring third-party equipment at the site
- The lack of available safety infrastructure and support when plans go wrong
- Off-site operations planning should include material-handling considerations for accessing, setting up, and taking down off-site equipment. Contingencies for different or substandard utilities also should be made (e.g., nonconforming electrical wiring in a building being monitored). Procedures for contacting emergency support personnel should also be made.
- Examples of successful division processes include the Off-Site Safety and Environmental Protection Plan (OSSEPP) process used by the Earth Sciences Division, and the Field Work Hazard Assessment Form process used by the Environmental Energy Technologies Division.
Work Process B. Procedure In the Event of Illness or Injury During Off-Site Operations
When Berkeley Lab employees are injured or become ill during off-site operations, the following procedure should be followed:
- Employees should obtain appropriate treatment by a local physician or hospital staff
- Berkeley Lab Health Services, ext. 6266, should be informed so that the proper injury/illness report can be prepared
- Health Services forwards this injury/illness report within the EHS Division and to the Berkeley Lab Risk Manager when applicable
- The EHS Division determines whether the injury/illness is work-related
Work Process C. Work-Related Boating or Diving Operations
Supervisors of employees planning to engage in work-related boating or diving operations or aviation activities must contact the EHS Liaison for their division 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)
- Joint BioEnergy Institute Environment, Safety, and Health (ES&H) Responsibilities Matrix, November 9, 2007
- 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 |
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