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LIFE SCIENCES OPERATIONS

LIFE SCIENCES OPERATIONS. Management Review October 3, 2001. INTRODUCTION. Purpose: Provide Senior Managers with enough information to answer the following questions.. Are the Life Sciences environmental management systems effective in achieving environmental policy commitments?

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LIFE SCIENCES OPERATIONS

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  1. LIFE SCIENCES OPERATIONS Management Review October 3, 2001

  2. INTRODUCTION • Purpose: Provide Senior Managers with enough information to answer the following questions.. • Are the Life Sciences environmental management systems effective in achieving environmental policy commitments? • Is the EMS effective in achieving our objectives and measures? • Is the EMS adequate in terms of : • identifying significant environmental aspects and impacts? • resource allocations? • communication? • performance objectives and measures?

  3. Operations Management Review Agenda AGENDA: • Life Sciences Organization • EMS • Work Planning and Control • Training and Qualifications • Environmental Goals/Objectives Progress to Date • Assessment Results • Mgr. evaluation of EMS • Other S&H issues • Building Management • Discussion

  4. Life Sciences Operations Organization • Bill Gunther, Special Ass’t ALD • Ann Emrick, EMS, Training, ESR, WCM • Bob Colichio, ESH • Jim Bullis, ESH BLIP/TPL, Bldg. Mgr. 801 • Steve Ferrone, Environmental Compliance • Dennis Ryan, Radiation Control • Rich Sautkulis Building Manager, BO • Chris Harris, Bldg. Mgr. 490 • Henry Schnakenberg, Bldg Mgr., 931

  5. LS EMS Significant Aspects • Industrial Waste • Hazardous Waste • Radioactive Waste • Mixed Waste • Regulated Medical Waste • Radioactive Regulated Medical Waste • Atmospheric Discharges • Liquid Discharges • Chemical Storage/Use or Radioactive Material • Soil Activation • Soil Contamination

  6. Benchtop Experiments (ESRs BO: 22, MO: 15, NASA: 22) Experimental Review Benefits: All Hazards (aspects) & controls identified in ESRs Tier I & self-assessmentscompliance assurance Pollution Prevention opportunities identified in ESRs also QA elements Issues: Need more Value in process for scientific staff and Incorporation of new short-term collaborators Industrial (Routine/non-experimental) Processes (Avg. ~2 work permits/bldg/mo) Benefits: Good Graded approach, Aspects & controls identified in 1.3.6 process Issues: Std. Operating Procedures need formal approval process. (ie BLAF, RTF) LS Work Control Program LS Work Control Program

  7. LS Work Control Program • Hazard Assessment—implementation in progress • Benefits: • replaces SADs (TPL, RTF, WBC) except BLIP • removes old legacy documents • Incorporates safety envelope into FUAs • BLIP: keep accelerator SAD. • Issue: SAD upgrade not on schedule as per Critical Outcomes FY01 Schedule • Environmental “Industrial” Processes– 16 evaluations • Reviews conducted by ECR annually and upon modification

  8. ESH&Q Training and Qualification New Employee/guest Training Profile • Average Time Spent in Training Medical: FY00 16 hrs/ FY01 10hrs Biology: FY00 12 hrs/ FY01 7hrs • Most courses online now. Can be taken anywhere. General Employee Training to go online soon. Rad is exception Exptl Review Location Reqmts Non ESH Trg

  9. ESH&Q Training and Qualification • FY01 Performance Measures: BNL Goal >90% Training Completion Employees MO ~98%; BO ~99%; DJ (Directorate staff) 100% BNL Goal>80% Required Training Completion for Guests MO ~91% (RTF 87%, CRC 90% ); BO ~99%; DJ N/A • Issues: Potential impact of new peoplesoft system? RTF Rotating Staff Staff must be reminded many times to take lapsed training courses. Incorporation of SOP training into program? Maintenance of CRC JTAs and incorporation of new staff

  10. LS ESH&QIntegration & Awareness • INTEGRATION • Work Control Program: ESR includes all ESH&Q hazard identification (including “E” aspects). Routine work screening • Tier I program includes all ES&H compliance • Self-Assessment includes all objectives/targets (Operations, Business, Science, Environmental) • Records & documents identified & maintained • Brookhaven Training System used to assign and track required ESH Training • AWARENESS • Operations staff meetings to keep mgmt informed • EMS Rep appointed to keep management informed • Web pages with ESH info, emails, ESR discussions

  11. LS EMSFY01 Objectives & Targets • OBJECTIVES • Maintain compliance • Integrate pollution prevention / waste minimization into all planning & decision making • Implement pollution prevention/waste minimization practices that eliminate, minimize or mitigate environmental impacts. • Correct and Clean Up Existing Environmental Concerns • TARGETS • Maintain compliance through regular Tier I inspections • Implement all Process Evaluation Project (PEP) corrective actions • Evaluate & disposition remaining “assessment, prevention & control” measures in PEP reviews • Disposition all Pollution Prevention (P2) opportunities identified in PEP reviews • Disposition 100% of Facility Review Issues • Maintain Legacy materials in compliant state, disposition as funds allow

  12. LS EMS FY01 Objectives and Targets Operate in Compliance • Maintain and Improve Tier I Inspection Program Status: Ongoing • Implement Remaining FY00 PEP Corrective Actions (MO 22, BO 9) Status: Completed? Issue: 801 Legacy waste tank not empty, no $$ left (ESD Project) Closed: Verified proper disposition of many chemicals. Analyzed photographic rinse water

  13. LS EMS FY01 Objectives and Targets Achieve integration of ESH into all facets of work • Evaluate & disposition 100% of “assessment, prevention & control” measures in FY00 PEP reviews Status: 95% overall Biology: 100% (9 total) Medical: 93% (2 remain) (34 total) • Open: • BLIP Air Monitoring • 801 Air Monitoring • Closed: • Removal of Chromerge from bldgs.

  14. LS EMS FY01 Objectives and TargetsAchieve integration of ESH into all facets of work • Disposition remaining P2 opportunities identified during FY00 PEP as appropriate Status: Complete MO: 19 total BO: 14 total Good Chance to identify Pollution Prevention Proposal opportunities! Life Sciences had 4 funded P2 proposals totaling $64K over 2 FY.

  15. LS EMS FY01 Objectives and TargetsFY01 Funded P2 Proposals: 32P Reduction Cost: $25k P2 (+ Dept Capital) Annual Savings: $5k + Benefits: • Reduce mixed waste • Decrease safety hazards • Decrease training Status: Purchased. ETA: 10/01

  16. LS EMS FY01 Objectives and TargetsP2 Funded FY01: Heavy Metals in crystallography • Cost: $3500 • Annual Savings: $20k • Benefits: • Eliminate heavy metal use • Decrease safety hazards • Decrease training • Status: Purchased. ETA: 10/01

  17. The grinder is wonderful!!!! It does what it says it does and I have already canceled our PO for picking up animal waste. I had to pay extra dump fees- so we have already saved money and time I might add. We don't have to haul all the garbage outside. LS EMS FY00 Objectives and TargetsFY00 Funded P2 Opportunity: BLAF Cost: $5550 Annual Savings: $4880 Benefits: • Increase BODs in sanitary • Decrease solid waste in trash • Reduce labor • Decrease safety hazards • Cost savings • Vector control Status: Operational

  18. LS EMS Objectives and TargetsFY00 FundedP2: Ethidium Bromide Reduction • Cost: $29k • Annual Savings: $50k • Benefits: • Reduce hazardous waste • Decrease safety hazards • Status: 1 undergrad student/1 • post-doc p/t. Eqpt in place, • Need to develop sample handling • techniques

  19. Status: Initial Levels higher than old, still some months. Benefits: Experimental technology Reduce potential for groundwater contamination LS EMS Objectives and TargetsFY00 P2: BLIP Viscous Liquid Barrier

  20. LS EMS FY01 Objectives and TargetsDisposition Excess Materials • Proposed the disposition 100% of Facility Review Issues Status: Ongoing • BO: 5 remain (44 total); MO: 30 remain (95 total) Lower priority issues have been deferred Remaining do not have compliance issues identified Examples of remaining: • Bldg. 801 Tank removal/upgrade • Decontamination of 490 sanitary lines • Remove abandoned tanks behind 490A Need ~$25K to complete

  21. LS EMS FY01 Objectives and TargetsDisposition Excess Materials • Clean up legacy waste issues in Life Sciences Status: Ongoing $88k Funding was used to • Support a Waste Mgmt Rep for ~6mos/ part-time • Support a Facility Support Tech for ~2mos • Sampling and analysis • Hired contractor to clean 3 “legacy rooms” in 490 • Cleaned out remaining 9-802 materials Note: WMD picked up disposal costs!

  22. LS EMS FY01 Objectives and TargetsDisposition Excess Materials • Biology • 1200 barcoded legacy chemicals plus ~1000 additional non-barcoded were disposed of in 463 (~2300lbs) • 7 Rad areas cleaned out, surveyed and deposted. • 70 Chemicals transferred to new owners • Medical • 1200 lbs of legacy waste disposed of. • 400 Lbs Rad Animal Carcasses. • 5 Rad areas cleaned out, surveyed and deposted. • In progress: Outside contractor to clean dilution and carcinogen rooms including hoods and Bin CC in basement ETA mid-Oct, 01.

  23. LS EMS FY01 Objectives and TargetsDisposition Excess Materials

  24. LS EMS FY02 Objectives and TargetsDisposition Excess Materials • Finish Remaining FY01 Work • Outside Contractor to clean out “Dilution” and “Carcinogen” Rooms in 490. • FY02 Plans (need funding) • Medical Incinerator (~$25K) • Excess 3 CERF Sources (on DOE Exchange) • Dispose of more FRDP items on list (~$25K) • 801 3 ADSs in system for legacy issues (abandoned sys) • 801 Legacy Rad material (no path disposal) • A p/t Waste Mgmt Rep would be a good addition to alleviate some of the RCRA compliance and legacy problems and for waste disposal issues!

  25. Medical Incinerator Complaints from BNL workers Chemicals/Rad not an issue Asbestos Abatement Issue Removal ~$25K • Carcinogens such as: • Dimethylbenzanthracene (DMBA) • Nitrosemethyl Urea (NMU) • Benzo(a)Pyrene • Procarbazine • 3-Methylcholanthrene

  26. LS EMSStakeholder Concerns • Genetic modification of crop plants • Considered to be a possible concern • Participated in public debate at SUNY Stony Brook • Little interest • Concluded that this is not an issue at this time but will continue with ongoing outreach efforts • Discussed during Summer Sundays and CAC meetings • BLIP Soil Activation • Working with CIGPA & ESD on community outreach • No reportable spills

  27. Self-Assessment ProgramIO Audit • 6/01 IO Audit (Usher) of LS Self Assessment Program • Strengths: Overall Rating: Outstanding • Clear linkage of science goals and objectives • Inclusion of science deliverables in process • Integration of Environmental Mgmt Program • Responsiveness to BLIP/TPL regulatory/production demands • Responsiveness to IG Select Agent Concerns • Thoughtful analysis, recognition of resource limitations • Improvement opportunities: • MO Mission needs to updated and consistent

  28. LS EMS Internal Assessment • Purpose: • Identify EMS strengths and weaknesses • Assess conformance of EMS to the ISO 14001 Standard • Assess EMS effectiveness in achieving the commitments in the BNL Environmental Stewardship policy • Conducted 4/01 by S. Stein, S. Ferrone, K. Corbett • Conducted desk audit and interviews

  29. LS EMS Internal Assessment • No Findings • Observations: • “The Definition of EMS is very strong in LS Directorate”. • Management Commitment appears high. • Improve employee awareness of environmental commitments, aspects and operational controls applicable to their work. • Minor Improvements to LS EMS System Description.

  30. LS EMS External AuditRegistrar Surveillance Audit • 6/01 Directorate surveillance audit successful!! • No non-conformances or observations!! • LS had one auditor for 1.25 days • Note: Surveillance audits annually for 3yrs, re-registration on fourth year.

  31. Environmental Compliance AuditsLS: Regulated Medical Waste Mgmt Medical Dept manages RMW for site • Limited Resources, limited expertise (long-time RMW packager left) • New Group approach, could lead to gaps, compliance issues • Other Issues: • New DOT Training Element • Movement of RMW on-site • Document control, records mgmt

  32. Environmental Compliance AuditsDEC – RCRA Inspection 6/01 • Audited ALL Satellite Areas (~50 Directorate) • Medical Department had 1 issue in 90 day area with a mixed waste, no finding reported as it was corrected immediately. • Note: Waste Management Rep reviewed all SAA and 90-Day Areas just prior to auditor, corrected all deficiencies (~20!). • Still many Tier I RCRA findings (19 violations which would equate to $137k in fines one month!)

  33. Environmental Compliance AuditsESD: NEPA, Liquid Effluents, Backflow Prevention • NEPA • No issues/problems • Liquid Effluents • No major findings. Postings and sampling • Backflow Prevention • No issues directly in BO/MO • Integrated Pest Management • No issues directly in BO/MO

  34. LS EMSWork Ahead (Goals FY02) • Meet Waste Goals (TPL issues w/targets?) • Seek funding for more legacy cleanups • Continue to identify/disposition P2, APCs, CAs • Work with CMS to improve system • Improve Tier I process • Submit 2 P2 proposals and 2 P2 Successes • Conduct/Participate in Assessments • Maintain ISO Registration • Maintain Training Program • Implement new Transportation Safety SAs

  35. Senior Management EMS Program Evaluation • Is the EMS Program effective in achieving • environmental policy commitments? P2C4 • the objectives & performance measures? • Is the EMS Program adequate in terms of: • Identifying significant environmental aspects & impacts? • Resource allocation? • Information systems? • Staff expertise? • Procedural requirements? • Are the Objectives & Performance Measures or EMS System suitable in terms of: • environmental impacts & current conditions • concerns of stakeholders? • current and future regulatory requirements? • business interests; technological capability? • internal organizational or process changes • should additional measures be established • Recommended revisions to: • environmental policy & commitments? • objectives & performance measures? • elements of EMS?

  36. Industrial Hygiene ProgramAudits • Static Magnetic Field Audit (STEM & MR Groups) • Online Training Course for SMF workers exposure > 5 Gauss • Inclusion on Clinic Protocol (EKG) for >600 Gauss • Noise Audit (LS No Impact: Tractor, sonicators) • Audiometry • Training • Chemical PPE Use and Selection: Gloves • IH Rep on ESR committee. • Lab Standard course will have glove selection module. • Respiratory Protection Audit (BLIP/TPL, Pesticides) • Confined Space Audit

  37. Industrial Hygiene ProgramAudits • Chemical Management System • FY01 Performance measure to audit chemical storage areas. Need>80% barcoded, >80% inventory match • BO ~72% (Good) • MO ~60% (Marginal) • Issues: • Biologicals? • Training for new staff (could incorporate in Haz com/Lab Std training) • Disposition of chemicals for terminating staff • Chemical Web Req

  38. Industrial Hygiene ProgramChemical Hazards Working Group • 37% of CY 2000LS Tier I findings related to improper chemical management (storage, labeling, procurement) • Team in place • Problems • lack of awareness, ineffective training & dissemination, little PI involvement, lack of D&D procedures, lack of good tracking tool • Possible Solutions (need Mgmt Support) • Improve communications between Tier I Team and staff • Develop SBMS Subject area for Tier I and for D&D • Newsletter • Develop better follow up mechanisms

  39. Biological Safety Program • CDC Publication: Biosafety in Molecular Biology and Biomedical Labs • Institutional Biosafety Committee (30 rDNA proposals) • New public representative— local Biology H.S. Teacher • CDC Select Agent Program (Toxin research) • IG Audit results corrected. • Re-registered, pending approval, current approval valid through 12/31/01. • Programs now linked in SBMS Experimental Review Issues: • Need to enhance Biological Safety Program for site? Not exclusive to BO (NSLS, BAF, Medical, DAS…) S&HSD Biological Safety Assessment scheduled in FY02

  40. Radiation Control Program • Radiation Work Permits (LS Total: ~42) • 9 BO; 15 MO-490; 13 MO-TPL; 5 MO-BLIP • Decay-in-Storage program set-up • >12 ft3 of waste in 490 released this FY • BO has program, nothing has reached 10 half-life date yet. • Survey Instrument reduction = $10,000/yr savings • Disposal of scintillation cocktail as industrial waste (previously rad) will save $3000/yr • Timely Termination of TLD service saves $90/mo. • Issues: • Continue to have occurrences • Turn in of TLDs (cost ~$200/occurrence) • Attention to RWP controls

  41. Occurrences ORPS STATUS AS OF 9/26/01 TOTAL FINAL/CLOSED Inherited (Pre-2000) Reports 10 10 CY 2000 Reports 8 8 CY 2001 Reports 7 2 * * 1 Report submitted for Final 2 Reports being re-worked for Final per DOE/BAO Request Medical ORPS Represent 29% of total ORPS for BNL

  42. Building Management • Facility Use Agreements: • Annual upgrades completed by 7/30/01 for 421, 463, 490, 496, 496A, 801, 931 (included legacy issues) • Removal of Bldg. 499 from BO responsibility • FY01 Upgrades: • 490: Thanos-complete • 463: Fu (in progress, funding approved 8/2/01) • Computer network re-wiring in 463 • FY02 Upgrades • 490: Animal MRI and wet lab (Benveniste) • 463: Van der lelie (need to redirect 267 to 298) • Computer network re-wiring in 490

  43. Building Management • System Issues • Need better planning on renovation needs • Retirees occupying space. • D&D Procedures • Infrastructure Issues • 801: Tanks (ADS) • 801: Stack replacement (ADS) • 3 legacy problems 801 (ADS) • Roof leaks (patches are short term fixes) • Old Labs (ADS) • Legacy materials • 463- Library (ADS) • 463-redirect for van der lelie (ADS)

  44. Audit/Assessment FY01/FY02

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