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EFCOG/DOE Chemical Safety Issues Workshop November 3 -5, 1998 The Energy Facility Contractors Group (EFCOG) and the U.S. Department of Energy (DOE) held their first Joint Chemical Safety Issues Workshop November 3 -5 1998. The workshop was cosponsored by the EFCOG Safety Analysis Working Group (SAWG) newly formed Chemical Safety Subgroup and the DOE Office of Worker Health and Safety (EH-5.) It was hosted by the DOE-Albuquerque Operations Office (DOE-AL) and Sandia National Laboratory (SNL), and was held at the Energy Training Complex (ETC) at Kirtland Air Force Base in Albuquerque, NM. The purpose of the workshop was to catalyze the formation of a Chemical Safety Interest Group (CSIG) that will provide a forum for EFCOG and DOE line and environment, safety, and health (ES&H) managers and professionals to address chemical safety issues of Complex-wide concern and to work together with the EFCOG Chemical Safety Subgroup and other interested groups and individuals towards continuous improvement and excellence in chemical safety within the DOE. The workshop provided the opportunity to begin a dialogue on DOE's strengths and opportunities for improvement in chemical safety; to discuss best practices and lessons learned; and to initiate the work of the CSIG to determine and address priority follow-on actions identified at the workshop.
Introductions, welcomes, and opening remarks for the workshop were provided by Kenneth G. Murphy, DOE Office of Worker Protection Programs and Hazards Management Chemical Safety Team Leader; Douglas Heal, Chair of the EFCOG Chemical Safety Subgroup; and Thomas Blejwas, SNL. DOE management perspectives on chemical safety were provided by Bruce G. Twining, Manager of DOE-AL, and by Joseph E. Fitzgerald, Jr., DOE Deputy Assistant Secretary for Worker Safety and Health. In his brief remarks, Mr. Fitzgerald identified two issues that became the key issues for the workshop: the integration of nuclear and chemical safety in terms of hazard characterization, safety analysis, and control methodologies; and the incorporation of chemical safety into the integrated safety management systems that are currently under development at many DOE sites. The plenary speaker for the opening session was Joseph DiNunno, member of the Defense Nuclear Facilities Safety Board (DNFSB), who provided his thoughts on charting a path forward for chemical safety within the larger DOE initiative of integrated safety management (ISM). He concluded his thoughts with the following four points: 1) line management must have primary responsibility and accountability for safety; 2) DOE contractors must bring to the work place a demonstrated corporate expertise for doing hazardous work safely; 3) manuals and other documentation of good practices developed with government funds must be shared across the DOE complex; and 4) valuable gains in safety can be made in DOE by embracing an industry-consensus view of safety management and continuous improvement. Special guest speakers for the meeting included Bob G. Perry, Staff Consultant to the American Institute of Chemical Engineers (AIChE), Center for Chemical Process Safety (CCPS) and Robert Coffield, Technical Adviser to the Chemical Manufacturers Association (CMA). Mr. Perry presented industry perspectives on chemical safety, emphasizing that, through CCPS, the chemical process industries are able to tackle big issues using limited resources. The purpose of CCPS, he said, is to develop and disseminate engineering and management practices to prevent or mitigate the consequences of catastrophic events involving the release of chemicals that could harm employees, neighbors, and the environment. Since 1986, CCPS has published more than 35 guideline books advancing state-of-the-art process safety technology and management practices, and has organized more than a dozen international symposia on chemical process safety and process safety management. Mr. Coffield discussed the six codes of the CMA's Responsible Care© codes of management practices:
He provided perspectives on how well CMA members are measuring up to the expectations of these codes. Mr. Coffield stressed that the two most important goals of Responsible Care© are continuous improvement in ES&H performance and in community awareness and trust. He noted that the chemical industry is dealing with similar issues to those under discussion at the workshop and offered to work with the group to benchmark DOE's progress with large chemical companies down the road. He noted that the openness and sharing of the participants was commendable and the workshop very impressive. He reinforced Joseph DiNunno's statement that line management, beginning at the very top, must bear the responsibility and accountability for chemical safety. Following the opening plenary session, and for next two days, participants in the workshop divided into smaller groups as "issues teams" to attend their choices of ten break-out sessions in which they discussed specific chemical safety issues. The groups reconvened in plenary session each morning to present the summaries of the previous day's breakout sessions' discussions, and to open the floor for the raising of related issues of concern. The ten issues initially addressed in individual breakout sessions formed the basis for determining priority follow-on actions to be undertaken by the CSIG and the EFCOG Chemical Safety Subgroup. Participants in each of these breakout sessions were asked to identify one to three items specific to their sessions' title issues on which they wanted to see more information or improvement. In addition, participants in all breakout sessions were asked to consider the larger, overriding priorities that could be addressed in future cooperative efforts. The ten agenda-driven issues discussed in the break-out sessions and the associated priority items identified by the teams were: 1) Chemical safety as part of ISM. Mechanisms to ensure incorporation of chemical safety into the ISM systems that are currently under development at many DOE sites must be resolved and implemented to ensure the permanent inclusion of chemical safety as an integral part of the ISM process. Practices developed and used by the chemical industry for ISM verification were discussed along with the basic need for clear direction and upper management support as a key issue to be pursued by the group. Three priority issues were identified for action. These included identifying DOE's chemical safety expectations for the integrated safety management of chemical activities at DOE sites, obtaining support for chemical safety as a management priority, and examining the use of relative risk probabilities and consequences when incorporating chemical safety into ISM. 2) Chemical safety during facility transition. Facility transition to safe storage or decontamination and decommissioning (D&D) can require the removal of significant quantities of hazardous chemicals. In aging facilities, characteristics of residual hazardous chemicals are often unknown. In addition, new chemicals may be introduced during cleanup operations, resulting in potential reactions among incompatible chemicals and adverse effects to workers, the facility, the public and/or the environment. In this session, participants discussed these and related issues, and identified and examined best practices for handling these problems. Three priority issues were identified for action. These included "near misses" associated with the characterization of "legacy" situations and the loss of available expertise through attrition and the management of chemical safety basis. 3) Chemical safety in laboratories. Laboratory issues at the "bench-scale" level are common throughout the DOE, yet they are frequently deferred for issues that are considered to be more important, often because of their magnitude or visibility. This session looked at bench-scale laboratory issues, vulnerabilities, and concerns that are shared by many DOE sites; examined possible solutions; and explored ideas for sharing information and solutions. Two priority issues were identified for action, both regarding the principal investigators (PI's) on research projects – one on determining the extent of responsibility to be given PI's for hazards analysis and control and the other on building cooperative relationships between PI's and safety professionals. 4) *Chemical information management and lessons-learned. The DOE chemical safety home page, with links to related web sites, enable users to access a broad range of chemical safety information on work planning, hazards analysis and control, management systems, and management tools. This session included an overview of the DOE chemical safety home page and other chemical-safety-related web sites. Participants explored how to improve the DOE home page through sharing of industry and DOE "best practices." Several participants in this session addressed chemical inventory issues and lessons learned at their respective sites. A participant representing the Society for Effective Lessons Learned Sharing (SELLS), a committee comprised of volunteers from various DOE Operations Offices, sites, contractors, and programs that share the common goal of improving information exchange across the DOE and with external public and private organizations, gave an overview of that group's work and the tools they maintain for use by the DOE complex in posting and retrieving lessons learned information. Issues surrounding the need to update, review, and analyze the constantly changing base of chemical safety information were discussed. Two priority action items were identified – identification of "best practices" for a chemical management system, and the use of "lessons learned" information throughout the ISM life cycle and the work process. *[This session was originally titled "Access to Chemical Safety and Lessons Learned Information."] 5) Chemical safety in work planning. Exchanging ideas and lessons learned in planning work with chemicals improves the effectiveness of safety programs and prevents accidents, injuries and illnesses. Participants in this session explored issues that arise during work planning and began a dialogue on the need for a DOE-wide program to address chemical safety in work planning. This group identified one priority action item – to more fully develop the draft checklist/guidance document for chemical safety in work planning. 6) Common threads and lessons learned in recent chemical occurrences and identified vulnerabilities. Recent chemical-related accidents that resulted in fatalities or significant impacts may have had commonalities that can be examined and used to prevent future recurrences. Participants in this session discussed the status of DOE's chemical vulnerabilities, perceived vulnerabilities and related issues, including the use of lessons learned and tracking, trending, and analysis information. Three priority action items were identified for further work – determining a means of ensuring that all chemical vulnerabilities are identified and addressed; identifying ways to best communicate/exchange technical information, controls, and corrective actions on vulnerabilities; and addressing the loss of corporate knowledge. 7) Chemical reactivity and incompatibilities. Information about special chemical hazards, including information about uncommon reactive chemicals or hazardous chemicals unique to DOE, can be useful for preventing accidents at DOE sites. Participants in this session examined issues related to the collection, dissemination, and use of such information as an integral part of the DOE complex-wide effort to reduce chemical vulnerabilities. They also discussed the development and use of chemical interaction matrices and their usefulness for hazard assessment and for preventing chemical accidents. This group identified two priority items they will address – the lack of adequate information resources and the lack of qualified technical resources. 8) Integrating chemical safety and nuclear safety. Chemical and nuclear safety share commonalities in terms of hazard characterization, safety analysis, and control methods. However, their respective regulatory requirements and safety documentation can be very different. Opportunities exist to handle chemical and nuclear safety issues efficiently, cost-effectively, and simultaneously to meet applicable requirements in both areas. Traditional chemical and nuclear safety documentation can be tailored and coordinated to address facility-specific hazards. This session focused on dealing with chemical and nuclear safety issues simultaneously in a seamless and integrated manner. The group identified three key issues for priority action – examining the use of Technical Safety Requirements (TSR's) or TSR-like controls for chemical hazards in nuclear or non-nuclear DOE facilities; determining a methodology for handling the combined consequences of different chemicals and of chemicals with radionuclides; identifying best practices for chemical hazards analysis where chemicals are present at levels below currently regulated threshold quantities. 9) A road map of requirements for chemical safety. Deficiencies in ES&H in some DOE chemical safety programs are linked to the need for clarification of DOE, U.S. Environmental Protection Agency (EPA), and Occupational Safety and Health Administration (OSHA) compliance objectives and guidance in achieving them. This session explored the development of a road map of existing chemical safety requirements and compliance objectives for use in work planning, for identifying applicable requirements and tracking their implementation, for laboratories, legacy operations (including D&D and facility transition), and current chemical process operations. This group discussed existing approaches to dealing with the broad base of requirements DOE and DOE contractors must address. They identified and combined two priority actions to address – the identification of existing models, systems and approaches being taken to the compilation of applicable regulatory requirements/compliance objectives and intents to be made available through a clearinghouse network of examples and tools for use DOE-wide; and the subsequent examination of the need for a specific compilation (or "Road-map") of regulatory requirements/intents by type of operation and/or hazard. 10) Chemical life-cycle management and best practices. In this sessions, participants discussed issues related to the development, implementation, and continuous improvement of a chemical management system, including identification of the principles and elements of such as system; discussion of examples of best practices; and determination of methods to track new developments in safety management and technology. Participants also explored current chemical life-cycle management issues at DOE sites and best practices that can be shared. This team identified three priority actions – establish a team to validate the draft Chemical Management System Guide on the Chemical Safety Web Page; identify best management practices for chemicals; and define the stages of life cycle management. On the final day of the workshop, all participants reconvened in a plenary session to discuss and determine their two top priorities and greatest needs. These priority items, along with other items identified in the breakout session, will be the focus of the CSIG and the EFCOG Chemical Safety Subgroup during fiscal year 1999. They are:
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