Meeting of APS Beamline Safety & Chemical Safety Coordinators July 6, 2012

Tom Barkalow

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Agenda

Description of recent chemical exposure incidents

APS policies & procedures related to beamline safety

Discussion of how the policies & procedures are being implemented

Discussion of possible new expectations

What can be done to improve?

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Argonne Non-APS Chemical Incidents

An experienced ESQ staff member moved a 6 year old Nalgene bottle by the neck to make room on a shelf and it disintegrated. Thought to contain dilute HF and not wearing gloves so was potentially exposed to HF. 911 after a delay. Calcium gluconate applied after a delay. Fortunately , no resultant injury or symptoms of HF exposure.

A post doc was filling a wash bottle with methanol from a gallon jug on top fo a flammable storage cabinet and at chest height. Dropped gallon container and spilled approximately one liter on his pants/leg. He reported to medical after cleaning up spill and looking up methanol on Wikipedia. Did not call 911 or report the spill to his supervisor. He was examined and sent to an ER for examination and observation. He showed no negative symptoms and was returned to work.

A third incident occurred at APS involving a chemical eye splash incident in Sector 15.

Argonne senior management decided to file an ORPS report due to this “cluster” of chemical exposure events

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Sector 15 Incident

An APS UofC post-doc user went into a hutch with the PI to troubleshoot an experiment. A small Teflon tube popped off a closed valve and the user was sprayed in one eye with approximately 50 microliters of 1,2 dichloroethane. She used an eyewash station to wash out her eye, but waited until the next morning (about 8 hours) to notify beamline staff. She was taken to an ER for examination and appropriate treatment. She had minor corneal abrasions and was given a prescription ointment to use as needed plus a referral to an ophthalmologist.

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Sector 7 Incident

On the day Argonne filed the ORPS report, a fourth incident occurred at APS Sector 7.

General user experiment was being setup in Sector 7. A chemical glovebox containing most of the experiment apparatus had been

wheeled into the hutch and various connections were being made. The apparatus had been flushed with toluene after it was last used in March 2012. An external Teflon tube connected to the glovebox with a swage lock fitting was

being placed into position to connect the open end to another external portion of the experiment when liquid flowed from the open end and splashed into a user’s eye.

User was immediately taken to an eyewash station and a 911 call made. Was taken to ER, examined, no injuries were found, and he was released with no restrictions.

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Views of Sector 7 Apparatus

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APS Policies & Procedures AP&P 3.1.07 Beamline ESH Program (APS_1410274) requires each partner user

group to prepare beamline safety plan.

A Model CAT Environment, Safety and Health Plan (APS_080064) is available to serve as a template for non-APS operated beamline safety plans (a comparable document exists for APS operated beamlines)– Requires various safety positions be established and staffed– Provides high level responsibilities for each position– Does not provide detailed responsibilities

AP&P 3.1.25 APS Experiment Safety Reviews (APS_1187022) specifies responsibilities and requirements for both user groups and beamline staff

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Statements from Beamline ESH Program Each partner user group operating a beamline:

– Shall allocate the resources required to support an effective beamline safety program,– Document its safety program, providing copies of the safety plan to the APS User Safety

Officer,– Notify the User Safety Officer of changes in the personnel assigned to carry out safety

roles defined in the safety plan,– At least once every twelve months, review the safety assignments and, as appropriate,

reassign responsibilities or create new roles, and– At least once every thirty-six months, review and, as necessary, revise the program and

plan to keep them commensurate with the group’s activities. The CAT/CDT/XSD Director shall be assigned the primary responsibility for ensuring

that an effective program is in place and for ensuring that the beamline safety plan accurately describes what the group intends to do and how it intends to do it. The APS recognizes the prerogative of the CAT/CDT/XSD Director to delegate the day-to-day management of responsibilities to other individuals and encourages each partner user group to do so, as delegation can help build a safety organization that will be able to more effectively formulate and implement safety policies and procedures.

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Safety Plan Requirements Define the key roles that must be carried out to effectively implement the safety

program, listing the responsibilities associated with and naming the individual assigned to each role.

State that the CAT/CDT/XSD Director assumes line management responsibility for safety.

Identify the CAT/CDT/XSD safety representative (the safety representative is the primary point of contact with the APS on safety issues).

Indicate that the partner user group shall conduct its activities in a manner that conforms to the environment, safety, and health requirements of Argonne National Laboratory and the Advanced Photon Source. In part, this requires that, except as provided for by variance, the group complies with the policies and procedures made mandatory in the:– Argonne Lab Management System procedures and ESH legacy documents:

• ANL Environment, Safety & Health Manual,• ANL Waste Handling Procedures Manual,• ANL Hoisting and Rigging Manual,• ANL Hazardous Materials Transportation Safety Manual, and

– APS User Policies and Procedures relating to environment, safety and health

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Safety Plan Requirements (cont’d)

Affirm the partner user group’s willingness to cooperate with APS, ANL, and DOE representatives engaged in oversight activities.

Acknowledge that the APS has the authority to order a halt to activities that the APS, or other entities with oversight responsibilities, deem unsafe or not in compliance with requirements.

State that the partner user group will comply with the APS User Policy and Procedures covering radiation safety shielding configuration control.

In the pre-MOU version of the plan, state that the partner user group will accept APS designed safety interlocks and will allow the APS staff to install these on the beamlines and other experimental facilities as appropriate.

Affirm that the partner user group will carry out an experiment safety review program that conforms to the requirements set forth in the APS User Policy and Procedure covering the subject.

Commit the partner user group to obtaining review by, and written approval from, the AES Division Director before changing its operations, facilities, equipment, or procedures in a way that might reasonably be thought to increase the risk of significant adverse impact on APS facilities, the environment, or any person.

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Model CAT ESH Plan – Safety Position Examples The CAT Safety Coordinator reports to the CAT Director and is responsible for

implementing and overseeing conformance with this safety plan. The CAT Safety Coordinator is to ensure that the CAT has access to the ANL-E ESH Manual and the other identified standards and to assist CAT members and users in meeting the requirements of these standards.

The CAT Chemical Safety Coordinator is appointed by the CAT Director and is responsible for chemical safety, including chemical waste management, and ensuring compliance with ANL and OSHA chemical safety standards in all of the CAT's facilities. The Chemical Safety Coordinator is also responsible for the CAT's proper use of the ANL Chemical Management System. The Chemical Safety Coordinator is to be aware of ANL ESH Manual defined chemical safety requirements.

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APS Experiment Safety Reviews An experiment cannot be started without:

1. The ESAF/EHCP having been completed by the experimenters,2. Review and approval by both APS Safety (Experiment Safety Review Board for beamline

experiments and a Divisional ESH Coordinator for nonbeamline experiments) and the experimental facility management, and

3. The Experiment Authorization Form (EA), including endorsements, has been completed and posted.

Researchers wishing to conduct experiments at the APS are responsible for:– Preparing an EHCP by completing an electronic ESAF on the APS web pages that:

• Defines the scope of the experiment, disclosing all materials (samples, reagents, equipment, etc.), facilities, and processes that will be used at the APS

• Identifies hazards associated with their activities• Defines the safeguards consistent with ANL and APS standards• Lists the experimenters that will be working at the APS• Lists the start and end date of the experiment

– Submitting the ESAF and the EHCP to the APS far enough in advance of the experiment so that the APS can verify that the proposed controls are adequate and consistent with applicable requirements

– Working within the scope of and in conformance with the EHCP

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APS Experiment Safety Reviews (cont’d)

Experimental facility management (the organization responsible for the day-to-day operations of the facility where the experiment will be performed) is responsible for:– Assisting experimenters in identification of safeguards consistent with the safe operation

of beamline facilities– Identifying to the APS plans that are beyond the experimental facility management’s

expertise to evaluate and for which APS and/or ANL support is sought– Approving EHCPs only after determining that they appear to:

• Identify all significant risks to personnel and the environment• Define a hazard control strategy capable of reducing risks to acceptable levels• Include adequate hazard control verification requirements

– Verifying safeguards and all required training are in place and endorsing the EA

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How Are These Responsibilities Being Implemented? Have several safety coordinators discuss their duties and how they carry them out

Solicit input form other beamline staff

Discuss

Do same for Chemical Safety Coordinators

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Discussion of Some Suggestions Received

Use of chemical safety goggles versus safety glasses

Involvement of student users in preparing experiment safety analysis

Assignment of laboratory owners and monitoring chemical use in fume hoods

(Note time may not permit full discussion to be completed.)

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What Can Be Improved?

Request suggestions and hold general discussion.