The only official copy of this file is the one on-line. Before
using a printed copy, verify that it is the most current version by checking
the document issue date on the Life Sciences ES&H and Operations Support
website.
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BROOKHAVEN NATIONAL
LABORATORY
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NUMBER: LS-EMSD
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REV. 17 |
Life
Sciences Directorate
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DATE 12/12/07
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Prepared By: A. Emrick Reviewed By: J. Bullis, B. Colichio, S. Ferrone, W. Gunther, S.Stein |
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SUBJECT: Environmental
Management System Description |
Approved by: (Signatures on file) ALD, Life Sciences:
Carl W. Anderson Date
Gene-Jack Wang Date |
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Introduction
This purpose of this document is to define how the Life Sciences (LS) Directorate executes and maintains an Environmental Management System. Specifically, this information is complementary to the BNL EMS and provides details as to how various EMS activities are addressed in the LS Directorate.
Scope
The Life Sciences EMS applies to all activities performed in the Directorates areas of responsibility and any physical products or services provided to others. Areas includes the Biology Department (Buildings 421, 463, 496, 496A, greenhouse and agricultural fields) and the Medical Department (Buildings 490, 560, 801, 901-Imaging, 906 and 931) and all employees, collaborators, contractors, students and visitors who conduct work in those Departments.
Policy
A BNL site-wide Environmental,
Safety, Security and Health (ESSH) Policy has been established. The policy
is discussed in Environmental Protection
Training which all LS employees are required to take and is embedded in the
Guest Site Orientation Course which is
required of all guests conducting work. The LS Directorate adheres to this policy.
The policy is on the BNL website and is posted in Bldg 463, Biology Chairman’s
Office, Bldg. 490, Medical Chairman's Office, Life Sciences Associate
Laboratory Directorates Office, and Bldg. 801 Lobby.
Aspects
Determination
Environmental aspects (SBMS Identification of Significant Aspects and Impacts Subject Area) are identified through the Work Planning and Control for Experiments and Operations process, reviews of industrial processes (Process Assessments Subject Area) and the Facility Review Project. The identification is accomplished by having an Environmental Compliance Representative (ECR) included in the review process. New aspects are incorporated when identified and, at minimum, aspects are reviewed annually. The ECR with the EMS Representative incorporates aspect data into the environmental aspects table. The ECR and EMS Representative keep the table up to date by reviewing and revising as necessary when new activities and/or aspects are identified.
Environmental
Aspects Table (pdf)
Legal and Other
Requirements
All
legal and other requirements flow down through SBMS Subject Areas. The ECR, ESH
Coordinators, and LS EMS Representative are notified of changes in
environmental subject areas via the SBMS change
notification service. The ECR works with the LS EMS Rep to determine how
the change affects the Directorate, what needs to be implemented, and how the
affected individuals are notified. If it requires a significant change in
procedure the affected individuals, Chairmen, and/or ALD, Life Sciences will be
involved in the process. Minor changes are communicated to affected workers
through emails, memos, or meetings.
The
Environmental Services Division maintains permits; the LS Contact is the ECR.
Permits associated with individual buildings are listed in the Facility Use Agreements.
Objectives and Targets
and Programs
Institutionally, BNL has an Integrated Planning
Management System which defines a systematic approach to a holistic
development and review of the Laboratory's goals, objectives, desired outcomes,
and strategies for achieving these. The Integrated Planning process facilitates
the necessary decisions on resource allocation to achieve those results.
As part of that process BNL develops Critical
Outcomes and Performance Measures, which identify environmental goals,
objectives and performance measures. During the development of the COPM (see COPM Subject Area),
the views of interested parties are considered as well as legal and other
requirements and the significant environmental aspects within the organization.
To assist in the flow down of the COPM environmental goals, the ESD manager
produces an Annual
Environmental Priorities document. The Life Sciences Directorate uses the
COPM and Environmental Priorities document along with its own performance data
to establish its environmental objectives. The Directorate goals and objectives
are in the Life Sciences
Self-Assessment Plan. They are reviewed, revised, and approved at least
annually via the self-assessment process and the management review. The
management review is an evaluation of overall performance both qualitatively
and quantitatively, for purposes of identifying key improvement opportunities
in the Environmental Management System (EMS), which are then rolled into the
subsequent years Self-Assessment Program.
The environmental objectives for the LS Directorate are defined in the Life Sciences Self-Assessment Plan. A summary is provided as an attachment to the plan. The main goal is to maintain compliance to environmental subject areas and to evaluate and disposition the waste minimization and pollution prevention opportunities that are identified in the Work Planning Process Assessments. Self-assessment, Tier I inspection programs, and annual compliance audits are performance indicators for compliance. Pollution prevention and waste minimization opportunities are typically identified during annual experimental safety review and environmental review of industrial processes, through routine work planning activities, Tier I inspections and communications with staff. The Experimental safety review coordinator and Environmental Compliance Representative maintain tracking systems for environmental corrective actions and improvement opportunities that are identified during experimental review and process evaluations. The EMS Rep, Pollution Prevention Rep, and ECR work together to disposition the pollution prevention opportunities.
The LS Environmental Management Program will be reviewed annually via a management review. This is identified and tracked through the Life Sciences Self-Assessment Plan. Management will concur with any mid-year changes. The EMS Rep will track progress and completion on all environmental performance measures and tasks identified in the Self-Assessment Plan via meetings with, at minimum, the ECR, and others as required (based on responsibilities). Mid-year changes may be required if a new aspect is identified or circumstances change.
Resources, Roles,
Responsibility and Authority
The EMS Management Representative is
appointed by the ALD. The EMS Reps responsibilities are documented in the Reps
R2A2 and include the maintenance of the EMS within the Directorate. The EMS Rep
is also responsible for formulating the objectives and targets with Line
Management and ensuring their concurrence and for reporting on the performance
of the EMS to Line Management.
For all Directorate employees, environmental responsibilities are included in each employee’s R2A2. Line Managers and staff are responsible for implementing the EMS requirements. Line Management is ultimately responsible for the identification and reporting of environmental hazards. This is done by the reporting of any new experiments or modifications to existing experimental activities to the Experimental Safety Review Coordinator or, for routine work, to a work control coordinator (as required Work Planning and Control for Experiments and Operations Subject Area).
Line Management is also responsible for reviewing
the environmental management system including recommendations for
improvement. This is mainly done at the annual management review
meetings.
Competence,
Training and Awareness
The
Training and
Qualification Management System Description defines BNLs training policy.
Basically, training is identified through experimental safety review, routine
work planning and location assessments by using the Job Hazard Training Assessment Tool.
Required BNL training is tracked through the Brookhaven Training Management
System (BTMS). Job specific training for employees/collaborators performing
work with potential for impact is accomplished by BNL required training,
read-and-sign, emails, postings, and/or briefings. The LS Training Coordinator
tracks required BNL and LS Directorate training using the BTMS. Supervisors
track any specific Standard Operating Procedure training they have within their
programs. Supervisors must ensure that their employees/collaborators
training is complete before they can work on any given task where the activity
can cause a significant environmental aspect.
Communication
Communication
is covered in the SBMS by the following:
Correspondence and
Commitment Tracking Subject Area.
External Communications
Mgmt System Description
Internal
Communication Mgmt System Description
The LS Directorates Level I and II managers
have their administrative assistants as their contact person for the CCTS
system. Communication internal to the Directorate is accomplished through the
following: meetings, website, emails, experimental safety review meetings,
routine work planning walk downs, and memos.
Documentation
This document and all documents incorporated
by reference or attachment to this document satisfy the EMS documentation
requirements.
Control of
Documents
Internal Controlled Documents Subject Area is used for LS documents (Attachment 1 below). Directorate-level documents are posted on the Life Sciences Operations web site (i.e. self-assessment plan, EMS System Description). The EMS Representative is responsible for the maintenance of EMS documents as defined in the LS Documents Table and to notify the appropriate staff upon modification. They are reviewed as needed, and at minimum annually and, when appropriate, after an occurrence or audit finding. Documents internal to a group (ie BLIP, BLAF, TPL, etc) are controlled by the group.
Operational Control
Each facility has in place a Facility Use Agreement, which defines the operating envelope of the building. Suppliers/Contractors abide by our EMS as it applies to the work they are doing in our facilities as required in their contract (see BNL Procurement Operations Manual, Section III-A). The work is screened via the Work Planning and Control for Experiments and Operations, and/or industrial process evaluations (Identification of Significant Aspects and Impacts Subject Area).
Emergency
Preparedness and Response
In support of the Emergency
Preparedness Subject Area, the Life Sciences Directorate has developed
local emergency plans for each of its buildings. These are reviewed, at
minimum, annually (as per Subject Area) and revised if necessary. They are also
reviewed and revised, if necessary, based on the results of an occurrence. The Events/Issues
Management Subject Area provides guidance for conducting critiques of
emergency preparedness exercises as well as for conducting critiques of events
involving industrial safety or hygiene, conduct of operations, and/or areas of
general programmatic breakdown. The Directorate has Local Emergency Plans for
Buildings 463 and 421 (Biology), 490(Medical), 560 (MRI), 801 (Medical-TPL
Operations), 901 (Imaging), 906 (PET), and an SOP on Emergencies for Building
931 (Medical-BLIP Operations Manual). Each hazardous waste 90-Day area has a
posted contingency plan. There is also an annual exercise of the BNL Emergency
Plan.
Monitoring and Measurement
The
Life Sciences
Self-Assessment Plan describes the monitoring and measuring activities for
the Environmental Management System objectives and targets and for
environmental compliance, which is accomplished via Tier I inspections, annual
experimental safety reviews, and annual process assessments.
The
Life Sciences Self-Assessment Plan also describes specific monitoring and
measurement activities for performance on those activities, products and
services that have significant aspects in support of BNLs Critical Outcomes and
Performance Measures (see Performance Evaluation and Measurement Plan).
Life
Sciences relies on Environmental and Waste Management Services Division
(EWMSD), Radiological Controls Division (RCD) and Safety and Health Services
Division (SHSD) for environmental, safety, and health regulatory support and environmental
monitoring. LS has an ECR to assist in management of the communication process.
LS has an RCD Facility Support Representative and Technicians for health
physics and industrial hygiene support. Our Facility Support Representative
performs and maintains all personnel monitoring and calibration equipment
records. ESD maintains all monitoring and calibration equipment records for the
environmental monitoring they conduct. The Subject Areas for Environmental
Monitoring and Calibration
defines what environmental monitoring is required and what calibration of the monitoring
equipment is required. BNL, through EWMSD publishes an annual Site Environmental Report which
rolls up all the environmental monitoring data.
Evaluation of Compliance
Evaluation
of compliance is done through EWMSD Targeted Assessments and the ongoing Tier I
program as well as other internal and external assessments such as those
conducted by the DOE, DEC, Independent Oversight Office, etc (identified in the
Life Sciences Self-Assessment Plan).
Nonconformity, Corrective Action and Preventative Action
The
Directorate follows the SBMS Nonconformance
and Corrective/Preventative Action Subject Area. All employees report
non-conformances or improvement opportunities to any member of the ES&H and Operations Support Team.
A graded-approach is used to evaluate, track and close the report using the
guidance set forth in the Graded Approach for
Quality Requirements Subject Area. Major non-conformances will be forwarded
to the ES&H Coordinator to be evaluated (as per the Investigation of
Incidents, Accidents, and Injuries Subject Area) and tracked to closure
using existing systems such as the BNL ATS,
the ORPS and incorporated into the Lessons Learned
System.
Control of Records
Environmental
records are defined, inventoried, and maintained and retained for as long as
required as defined in the Records Management
Subject Area.
Environmental Assessments
The
Life Sciences
Self-Assessment Plan includes the substantive requirements of the Environmental
Assessments Subjects Area. The Life Sciences Self Assessment Manager is
responsible for tracking completion on self-assessment activities and reporting
status to Line Management.
Compliance
(Tier I) Audits for facilities that have a potential to impact the environment
are conducted quarterly via the ESH&Q (Tier
I) Inspections Subject Area. Annual audits are conducted for those facilities
that have no potential environmental impacts. The Tier I coordinator is
responsible for these audits (coordinating, documenting, following up on
issues). In addition, the ECR conducts Environmental Process Evaluations, which
also include a compliance assessment component and are performed annually, upon
modification to a process or as a result of a related occurrence. These
assessments are also augmented by compliance audits focused on particular
operations or particular regulations when past performance or other factors
warrant it. All planned environmental assessments are identified and scheduled
in the annual Self Assessment Plan. Line Management or the ES&H and
Operations Support staff may schedule additional, unplanned, audits if
necessary.
An
EMS system assessment will be conducted annually as scheduled in the Life Sciences
Self-Assessment plan and as defined in the Environmental
Assessments Subjects Area. The EMS Rep is responsible for coordinating the
assessment, reporting of results (to management via the management review) and
follow-up. The frequency of these audits will be annual at a minimum however
the schedule may vary based on the importance of the activity and past
performance.
Management
reviews will be conducted annually and will include, at minimum, the ALD,
Medical and Biology Chairmen, LS ECR(s), and EMS Project Mgr. It will be
coordinated and documented by the LS EMS Representative. The agenda is defined
in the Subject Area on Environmental
Assessments.