Laser Protection Safety Management Program

Suggested lines of inquiry and review approach

Performance Objective 1: Contractor Program Documentation

The site (or facility) is governed by an up-to-date, comprehensive, documented laser safety program.

Suggested lines of inquiry and review approach

• A current policy statement or equivalent directive has been issued that articulates management expectations regarding laser safety.
• Funding sources have been institutionalized to fully support the Site Laser Protection SMP, commensurate with established site priorities.
• Existing contracts reflect the essential elements of a complete laser safety program, commensurate with the nature and the scope of the work encompassed by the contracts.
• The elements of the laser protection engineering program can be found in a laser protection program manual (or equivalent documents).
• Laser safety roles and responsibilities are clearly delineated.
• Auditable training records exist for the laser safety staff (especially LSOs).
• Appropriate procedures and records are available which encompass the inspection, testing and maintenance of in-place laser protection systems, such as . beam blocks, perimeter guards etc.
• A file(s) exists which contains the documented resolution of all significant laser safety issues related to new research projects.
• Applicable regulations, DOE laser safety directives, and industry standards (such as applicable ANSI standards) have been incorporated into the program.
• Site-specific policies and practices have been implemented where DOE directives and industry standards may be insufficient to mitigate risk.
• A complete set of laser protection and emergency services "performance measures" have been adopted. This includes medical staff trained to recognize laser eye injuries.
• An effective issues tracking system has been institutionalized, which encompasses all significant laser safety issues and 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.

Performance Objective 2: Contractor Program Implementation

2.1 Laser and related safety hazards

Suggested lines of inquiry and review approach

• All facilities for which laser safety self-assessments are required have been identified.
• A site program exists governing the periodic updating of these documents.
• Laser hazard self-assessments are current as compared to the established schedule.
• The documents contain a complete description of the facility, including process operations and related hazards.
• The assessments describe the spectrum of laser prevention and protection features in relation to their ability to control laser injury and reduce risk.
• The information represented in typical self-assessment was confirmed by a facility tour as part of the assessment.
• Noted inconsistences in the site self-assessment are not significant.
• The site USQD process has been applied adequately with regard to laser safety issues that have arisen.

2.2 Laser Injury Prevention Procedures

Suggested lines of inquiry and review approach

• Laser and related hazards that are unique to DOE and are not addressed by industry standards are protected by isolation, segregation or special laser control systems (e.g. inert gas, explosion suppression).
• Passive laser safety features (such as interlocks) are favored over active systems. Engineering and design controls are favored over administrative controls.
• Laser protection systems are designed, installed and maintained such that their inadvertent operation, inactivation, or failure of structural stability will not result in the loss of vital safety functions, inoperability of safety class systems, or personal injury.
• The site has a program in place governing the review of research project design packages by a LSO.
• Projects cannot proceed without the (signature) approval of the LSO.
• The DOE field office and program office laser protection staffs are involved with the approval of significant projects involving laser safety.
• The utilization of industry standards was confirmed by a select review of research plans and specifications and self-assessment reports.
• Conformance with industry standards was confirmed on the basis of facility tours.
• Laser protection system inspection, testing and maintenance programs (scope and frequencies) conform to ANSI Z136.1, as amended by DOE Implementation Guidance.
• A QA/QC program on site, which complies with DOE O 414.1A, governs the specification, purchase, inspection, acceptance-testing, and maintenance of laser protection components and systems.

2.3 Personnel Qualification

Suggested lines of inquiry and review approach

• A program exists on site, which provides all users of Class 3 and 4 lasers with an appropriate level of laser safety training upon initial employment and on a regular follow-on basis.
• Appropriate laser safety training is provided to subcontractors who perform work involving significant laser risk.
• A documented program exists which identifies which employees are subjected to laser safety hazards that represent a unique risk.
• Special laser safety training has been reviewed by a LSO) and has been presented by an individual with more than a rudimentary level of knowledge of the risks involved.
• The staff is encompassed by a professional development or comparable program.
• During a given year, the staff has received an appropriate level of continuing education and training in accordance with their individual needs.

2.4 Performance Improvement

Suggested lines of inquiry and review approach

• Laser safety data and statistics are accurately and consistently documented and reported as part of the required annual summary of the fire protection program.
• Lasers and related events are accurately and consistently documented via the CAIRS and ORPS systems, as applicable.
• Site-specific documentation is available to confirm that small laser incidents are distributed within the contractor organization as "near misses."
• Documentation or other information exists to verify that the DOE field office and program office are informed of laser safety-related "near misses" and related information on a regular basis.
• The DOE "lessons learned" program is utilized to distribute information on lasers and related events that may have relevance elsewhere within the Complex.

Performance Objective 3: DOE Line Management Oversight: The Federal Field/Site Office Staff has assigned personnel with competence commensurate with the responsibility to manage and oversee the laser protection SMP across the site. A documented oversight program is implemented to verify the effectiveness of the laser protection SMP across the site and at each nuclear facility.

Suggested lines of inquiry and review approach

• Requirements for contractor assessments of site wide and facility specific laser protection SMPs with consideration to hazard categorization of the individual facilities.
• Requirements for Site Office assessments of contractor laser protection SMPs and Site Office performance in oversight of contractor laser protection SMP.
• Expectations for development, review, and approval of LHAs
• Expectations for incorporation of results of LHAs into DSAs.
• Organization and expectations for technical competence of fire protection professional and managerial personnel.
• Completion of scheduled formal assessments and other oversight activities
• Evaluation and communication of assessment results including expected actions for resolution of identified issues
• Development, tracking, and closure of corrective actions
• Evaluation of effectiveness of specific corrective actions
• Evaluation of effectiveness of the overall Laser Protection Program

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