Policy on Safety and Health
1. Purpose
The purpose of this policy is to ensure the ongoing protection of people and property from injury or loss by actively identifying and/or recognizing hazards, taking appropriate steps to evaluate and mitigate those hazards, and actively seeking to enhance the Safety & Health (S&H) program as required by 10 CFR 851 using the event review and analysis process.
This policy is not a contract and is not intended to create any obligations on Fermi Research Alliance, LLC (FRA). This policy may be terminated or changed by FRA at any time, with or without notice.
2. Scope
This policy applies to all Fermilab activities and operations carried out under the approved management systems at the Fermilab site and all leased spaces. Individuals assigned to work at locations other than the Fermilab site or leased spaces that fall under the operational cognizance of another management organization are expected to follow the local worker S&H programs established for those locations.
3. Applicability
This policy applies to FRA and all its employees, users/affiliates, and subcontractors.
4. Effective Date and Date Reviewed/Updated
This policy went into effect on June 1, 2019 and its most recent update was effective on September 11, 2024.
5. Policy
Fermilab will provide a safe and healthful workplace for employees, users/affiliates, visitors, and contractors and their subcontractors. The S&H Program describes how Fermilab maintains compliance with applicable standards and local, state and federal legal requirements and the contract between Fermilab Research Alliance and the U.S. Department of Energy.
Fermilab strives for the prevention of injury or illness and continual improvement in safety performance and health management. To the maximum extent practicable, all hazards shall be eliminated or effectively managed through Engineering and/or Administrative Controls. Where Engineering or Administrative Controls are not feasible, Personal Protective Equipment (PPE) shall be provided by the organization at no cost. Where hazard abatement resources are limited, priorities shall be assigned to manage and resolve the most serious problem(s) first.
Employees, visitors, users, affiliates, contractors, and subcontractors must be trained to perform work at Fermilab. The training requirements are defined for workers and users in Fermilab Environment, Safety and Health Manual (FESHM) Chapter 2070 — Environmental, Safety, and Health (ES&H) Training Program. Supervisors or designated points of contact are responsible for developing an Individual Training Needs Assessment (ITNA) for all of the personnel they supervise. All required training must be completed before workers are allowed to commence work and potentially be exposed to the hazards associated with the work they will be performing. All personnel are responsible for participating in defining their necessary training with their supervisor, successfully completing all required training and applying training on the job.
All applicable Fermilab safety and health requirements, in addition to standard OSHA requirements, shall be transmitted to contractors and their subcontractors prior to their arrival on site. Reviewed work packages must be in place prior to the work on site to ensure safety and health hazards are effectively managed throughout the duration of the work. Construction site inspections must be formally conducted and tracked to monitor adherence to all regulations.
A comprehensive occupational health surveillance program shall be in place to identify and monitor potential hazards in the workplace. This must include medical surveillance programs where appliable, and will entail at a minimum, industrial hygiene-monitoring efforts to document actual exposure levels, and radiation-monitoring programs to keep exposures As Low As Reasonable Achievable (ALARA). These programs are explained in more detail in the FESHM, which also includes the Fermilab Radiation Control Manual (FRCM).
The event review and analysis process shall be conducted following the requirements of Quality Assurance Manual Chapter 12140 (QAM 12140) — Event Response Program. The results of completed analyses will be captured in an issues-management tracking system. This gives the laboratory the ability to learn from and understand the drivers behind incidents or events and to make operational improvements and reduce the probability of recurrence.
6. Definitions
- As Low as Reasonably Achievable (ALARA): ALARA is an approach to manage and control exposures (individual and collective) to the workforce and to the general public at levels as low as is reasonable, taking into account social, technical, economic, practical, and public policy considerations. As used in this document, ALARA is not a dose limit, but a process that has the objective of attaining doses as far below the applicable limits as is reasonably achievable.
- Engineering Control: An Engineering Control protects workers by removing hazardous conditions or by placing a barrier between the worker and the hazard. Examples include local exhaust ventilation to capture and remove airborne emissions or machine guards to shield the worker.
- Administrative Control: Administrative Controls are changes in work procedures to reduce the duration, frequency, and severity of exposure to hazardous chemicals or situations. Administrative Controls include work practice controls that are intended to reduce the likelihood of exposure by changing the way a task is performed.
- Personal Protective Equipment (PPE): PPE is equipment worn to minimize exposure to hazards that cause serious workplace injuries and illnesses.
- Safety Conscious Work Environment (SCWE): SCWE is a subset of safety culture related to a work environment in which everyone at Fermilab feel free to raise safety concerns to management (and/or a regulator) without fear of retaliation.
- Chief Safety Officer (CSO): The CSO owns the ES&H Management System, establishes and maintains ES&H policies, assesses line organizations for compliance, and seeks program improvements and implements those improvements where possible.
- Individual Training Needs Assessment (ITNA): An ITNA is a questionnaire completed by management that determines Individual Training Plans (ITP) based on the job tasks associated with the individual’s position.
7. Responsibilities
ES&H Senior Director/Chief Safety Officer (CSO):
- Maintains liaison and transparency with the Fermi Site Office (FSO) on Fermilab ES&H activities and actively communicates any identified deficiencies in DOE requirements.
- Provides oversight for documenting, implementing, and maintaining this policy.
- Leads and develops ES&H programs in collaboration with line organizations to ensure compliance and promote responsible ES&H practices.
- Provides the appropriate level of rigor and resources to implement and maintain the SH.
- Leads and actively supports an open reporting culture (Safety Conscious Work Environment, SCWE) and the implementation of human performance improvement principles.
Division, Section, and Project Heads/Requirements Owners:
- Actively support an open reporting culture (SCWE) and principles of human performance improvement.
- Ensure that sufficient resources are provided to their areas of responsibility to adequately support both process and personal safety.
- Assign personnel to activities that possess the experience, knowledge, abilities, and training to perform effectively and safely.
- Ensure their personnel are involved in event reviews.
- Ensure line management relays effective and timely communication of safety policies, procedures, and expectations to all personnel within their areas of responsibility.
- Ensure line management facilitates regular safety meetings and briefings to discuss potential hazards, safety performance, and improvement initiatives.
- Ensure line management actively encourages and maintains open lines of communication, ensuring that safety concerns and feedback from personnel are promptly addressed and acted upon.
Employees, Users/Affiliates, Visitors, Contractors, and Subcontractors:
- Comply with all procedures, instructions, and directives contained within the FESHM to assure and sustain a safe and healthful workplace.
- Participate in identifying and mitigating hazards.
- Perform all activities in a planned and safe manner.
- Continually demonstrate a questioning attitude and readily stop/pause work or decline to perform an assigned task because of a reasonable belief that the task poses an imminent risk of death, or serious physical harm or other hazards to the worker. No one will be subjected to reprisal for taking such an action or for raising a concern.
8. Authorities
U.S. Department of Energy Prime Contract No. DE-AC02-07CH11359
Title 10 CFR 851, Worker Safety and Health Program
Title 10 CFR 835, Occupational Radiation Protection Program
9. Owner
The ES&H Senior Director/CSO is the S&H Requirement Owner and the owner of this policy. Responsibility for ensuring that this policy is reviewed, updated, and communicated rests with the ES&H Director/CSO.
10. Review Cycle
This policy shall be reviewed every three years.
11. Communication Plan
The requirements of this policy shall be communicated by the ES&H Senior Director/CSO to all employees, affiliates, and users and periodic training shall be provided to requirement owners and ALD/senior/office/project directors. This policy shall be available on the Fermilab policy website. The ES&H Senior Director/CSO is responsible for the communication of this policy.