Chemical Safety Management Program

Suggested lines of inquiry and review approach

Performance Objective 1: Contractor Program Documentation

The site (or facility) has in place an up-to-date, comprehensive, and documented Chemical Safety Management Program.

• Has a current policy statement or equivalent directive has been issued that articulates management expectations regarding chemical safety management? Are these expectations consistent with DOE commitments and requirements for Chemical Safety Management?
• Are there specific written procedures available for the acquisition, storage, use, and disposal of chemicals and are the procedures kept current based upon self-assessment feedback?
• Does the written Chemical Safety and Life Cycle Management Program detail both roles and responsibilities for various personnel involved in the procurement, handling, use, and disposal of chemicals and similarly for site safety, industrial hygiene, and medical personnel?
• Has ownership of the Chemical Safety and Life Cycle Management Program been documented and communicated to employees?
• Have funding sources have been institutionalized to fully support the site's Chemical Safety and Life Cycle Management Program, commensurate with established site priorities?
• Do existing contracts reflect the essential elements of a complete Chemical Safety and Life Cycle Management Program, commensurate with the nature and the scope of the work encompassed by the contracts?
• Do auditable training records exist for employees trained in chemical safety management rules and procedures?
• Have applicable federal or state regulations, DOE directives or guidance documents, and industry standards (such as applicable ANSI standards) have been incorporated into the program?
• Have site-specific policies and practices been implemented where regulations, DOE directives or industry standards may be insufficient to mitigate risk?
• Has a complete set of chemical safety management and emergency services "performance measures" been adopted?
• Do the work packages reflect a well-developed planning process that incorporates potential chemical safety management concerns?
• Are there procedures or instructions in place to specify when review and approval are needed on project documentation to ensure that any chemical safety management concerns are addressed?
• Does a facility-specific procedure exist to implement a comprehensive chemical hazard management program? Does it reflect site-wide requirements and all applicable standards?
• What criteria are used to select appropriate standards and requirements (e.g., Work Smart Standards, Standards/Requirements Identification Documents, or others, as applicable) to address all chemical hazards?
• How does your occupational medicine group become aware of chemical usage and employee exposure to specific chemicals? What are their roles and responsibilities once an employee's exposure has been demonstrated?

Performance Objective 2: Contractor Program Implementation

2.1 Chemical Hazards: Chemical hazards on site (or within the facility) have been identified and evaluated in conjunction with a current and comprehensive chemical hazards analysis and self-assessment. (Chemical hazards are defined to include pure chemicals and chemical products per 29CFR 1910.1200)

• What is the process used to identify potentially hazardous chemicals that are used or stored in the facility?
• What hazard analyses are conducted for such chemicals and for chemical processes in the facility?
• What is the "driver" for these hazard analyses?
• Are "hands-on" employees involved in all chemical hazard analyses conducted by SMEs?
• Do environment, safety and health (ES&H) professionals conduct walk-downs of facilities in which chemicals are to be used or stored, prior to completing the hazard analysis?
• Is there a structured approach for determining adequate and appropriate controls for chemical hazards identified through the hazard analysis?
• Has the facility adequately implemented a job hazard analysis or similar process for work planning?
• Is life cycle management integrated into this process?
• Is identification (and reduction) of waste generation integrated into this process?
• Are waste types, quantities, and their associated hazards identified in the job hazard analysis and work planning process?
• Is there a process in place for identifying legacy chemicals?
• Is there a program to disposition unneeded chemicals?
• Are hazards of legacy chemicals (e.g., abandoned, residual chemicals in tanks and pipes with inadequate controls) properly identified and addressed?
• Have their potentially degraded storage conditions been considered?
• Have these chemicals been sampled and characterized? Are there adequate controls to prevent and mitigate adverse consequences?
• Are the containers of these chemicals periodically inspected and maintained?
• Are the hazards of these chemicals appropriately and sufficiently addressed in the facility's safety basis?
• What is the regulatory status of the legacy chemicals in the facility?
• Has the regulatory status of the legacy chemicals as hazardous waste been appropriately determined?
• Has pollution prevention (substitution with a non-hazardous material or reduction in quantity used) been considered, when applicable, as a way to prevent or mitigate chemical hazards?
• Are hazard assessments essential to emergency response established and maintained?
• Is the chemical inventory at a given storage location being properly updated as the inventory changes?
• Is the inventory inspection and surveillance conducted at an appropriate frequency?
• Do all chemical storage areas receive adequate coverage through periodic surveillance?
• Is a database or hardcopy file maintained of Material Safety Data Sheets (MSDSs) for chemicals used and stored at the work-site and at the facility?
• How is access to MSDS information provided to workers?
• Are MSDSs obtained prior to the introduction of a chemical to a facility?
• What is the process for determining potential hazards for a chemical when initially introduced into a facility? When is that process performed?
• When and how is a decision made to evaluate employee exposure to a chemical hazard?

2.2 Chemical Injury Prevention: Appropriate and effective controls are in place for mitigating the potential for injury or illness from exposure to hazardous chemical substances.

• Are adequate controls identified for all chemical hazards?
• Are engineered controls preferred over administrative controls?
• Are administrative controls preferred over personal protective equipment?
• Are passive controls preferred over active controls?
• Do facility and warehouse control procedures properly implement chemical management procedures to ensure safe handling and storage of chemicals?
• Is prevention and source reduction of hazardous materials supported by appropriate procurement and inventory practices?
• Is there a procedure that ensures that chemicals stored in a given location are compatible? Is it adequately implemented?
• What processes are in place to ensure adequate input by ES&H professionals in the implementation of controls for chemical hazards, and in what manner are they implemented?
• What is the process for authorizing a chemical to be used on the site?
• What pollution prevention practices are conducted at the site?
• Is there a list of restricted chemicals?
• How is chemical storage and use policed?
• How are excess or waste chemicals disposed?
• What processes are in place to assure chemicals are not abandoned when work on a project ceases?
• What means are employed to ensure that the identified controls are implemented, and are operable and functioning so long as a chemical hazard is present?
• Is personal protective equipment required to be used for any activity involving hazardous chemicals?
• Has substitution of a less hazardous chemical been considered?
• Are engineering controls in place or planned for these operations? What other controls or measures are in place for these operations?

2.3 Personnel Qualifications: Personnel are appropriately qualified and trained to perform their work safely and responsibly when handling or working around potentially harmful chemicals.

• What are the qualifications of personnel performing the chemical hazard analysis?
• What are the qualifications of individuals performing standards selection?
• What training is provided to employees on the hazards of chemicals and chemical processes they work with, and on the controls that are most appropriate for those hazards?
• How frequently is this training provided?
• Is this training kept current?
• What is the frequency of refresher training provided for affected employees?
• Is training effectiveness measured? If so, how?
• What training is provided to supervisors and managers on management of hazards arising from chemical storage and use?
• Are requests for assistance and documents for information or review distributed to appropriately qualified and knowledgeable staff?
• Does the organization (internal or subcontractor) responsible for providing chemical safety management support use a training implementation plan to manage staff training and qualifications?
• Do position descriptions for points-of-contact or coordinators responsible for chemical hazards management appropriately reflect their duties and responsibilities relative to chemical safety management, as well as their training and subject matter competency?

2.4 Performance Improvement:  Data, statistics, "lessons learned" and other "feedback" from the site (or facility) Chemical Safety and Life Cycle Management Program are disseminated on site and used to correct identified deficiencies. This information is also made available for use by other DOE sites for their Chemical Safety and Life Cycle Management Programs.

• Has an effective issues tracking system been institutionalized, which encompasses all significant chemical safety issues and which complies with DOE O 414.1A, 'Quality' Assurance? This system should include a means to prioritize issues, to allocate funding on the basis of these priorities, and to implement "interim compensatory measures when there will be a significant delay with the implementation of corrective measures.
• Are changes to mission, operations, and conditions analyzed for needed changes to requirements? How are ES&H personnel involved in this process?
• Has the facility performed an assessment and gap analysis to identify significant gaps and deficiencies in its program?
• Does the facility maintain its corrective action plan up-to-date? Are the action items prioritized? Have the corrective actions completed been properly closed? Are open items being pursued according to their priority?
• Do post-job critiques and reviews reveal that chemical safety concerns were adequately handled, or if identified, they were adequately pursued and resolved?
• Is there evidence showing that lessons learned are properly used to improve work conditions or performance?
• Are assessment results communicated to senior management for their use in making informed determinations?
• Do managers routinely use feedback tools, such as, performance indicators; reviews; debriefs; and, lessons learned?
• Are occurrence reports evaluated for applicability and communicated to the right individuals?
• Are suggestions of employees and other professionals used to improve performance?

Performance Objective 3:  DOE Line Management Oversight

The Federal Field/Site Office Staff has assigned personnel with competence commensurate with the responsibility to oversee the Chemical Safety Management Program at a site(s) under their purview. A documented oversight program is implemented to verify the effectiveness of the Chemical Safety Management Program across a covered site, including at each affected nuclear facility.

• Is the oversight staff qualified to evaluate the site's Chemical Safety and Life Cycle Management Program?
• Are there specific oversight procedures in place for evaluating a site's Chemical Safety and Life Cycle Management Program?
• Are the responsibilities of site line management for chemical safety and chemical management clearly defined, documented, and understood?
• Are the roles and responsibilities of support staff and other personnel associated with the facility's chemical management program clearly defined, documented, and understood?
• Have the primary and secondary points of contacts been identified?
• Are the roles and responsibilities of personnel providing chemical safety management expertise and support properly integrated with the line management's responsibilities relative to operations?
• Who is responsible for controlling the hazards arising from chemical storage and use in the workplace? How are they held accountable?
• Is chemical safety management support staff sufficiently familiar with facility operations?
• Do they participate in routine inspections, assessments, and audits; in training; and in the categorization, analysis and development of corrective actions for occurrences?
• Do they participate in overseeing the implementation of selected controls and in follow-up inspections of those controls?
• Are the resources needed for providing an adequate level of chemical safety management support being communicated to the line management?
• Is management responsive to the resource needs and concerns identified by ES&H and other appropriate professionals?
• What is management's role in assuring that chemical exposures are evaluated and properly addressed?
• Are the managers, supervisors, and support staff sufficiently knowledgeable about pollution prevention and waste minimization (prevention and source reduction of hazardous materials), such that these are incorporated into their chemical hazard prevention and mitigation activities?

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