1 / 13

ESH & Q

ESH & Q. DOE-NP Annual S&T Review of Radionuclide Research & Production (RR&P) J. Bullis November 19-20, 2009. Summary of RR&P Facility Characteristics. 2 Buildings 1 Accelerator Facility (BLIP) Not normally occupied An accelerator facility covered by SAD/ASE ( November 2009)

suchi
Télécharger la présentation

ESH & Q

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript


  1. ESH & Q DOE-NP Annual S&T Review of Radionuclide Research & Production (RR&P) J. Bullis November 19-20, 2009

  2. Summary of RR&P Facility Characteristics • 2 Buildings • 1 Accelerator Facility (BLIP) • Not normally occupied • An accelerator facility covered by SAD/ASE ( November 2009) • 1 Radiological Facility (per BNL Facility Hazard Categorization SBMS subject area), the Radionuclide Research & Production laboratory (Bldg 801) - • Target Processing Laboratory (1 hot cell, 8 hot boxes) • 7 additional Labs (R&D and production support) • Machine shop • Offices

  3. Summary of Environmental AspectsNote: The BLIP was among the first facilities at BNL to receive ISO 14001 certification – August 2000 • Industrial Waste • Hazardous Waste • Mixed Waste • Regulated Medical Waste • Radioactive Waste/R-RMW • Atmospheric discharges • Liquid discharges • Storage/use of chemicals/radioactive material (D-Waste tanks/BLIP tanks) • Soil activation • Nanomaterials

  4. Summary of Radiological Hazards • Low- and High-level Contamination • Radioactive Waste • Radioactive Atmospheric Discharges • Radioactive Liquid Effluents • Storage / Use Of Radioactive Material • Soil Activation • Residual-radiation From Activated Materials

  5. Summary of OSH Hazards • Radiation (ionizing) • Chemicals • Compressed Gases • Cryogenic Liquids • Electrical • Noise • Oxygen Deficiency • Power Tools • Material Handling (cranes/forklifts) • Machine Shops • Nanomaterials • Animals (Bite/Scratch/Allergies) • Falls • Confined Spaces

  6. Applicable Requirements • DOE Orders and Federal Regulations • DOE Order 420.2B, Accelerator Safety • DOE Order 420.1A, Facility Safety, §§ 4.2 and 4.4 • DOE Order 414.1C, Quality Assurance • 10CFR835, Radiation Worker Protection • 10CFR851, Occupational Worker Protection • BNL SBMS Subject Areas • Scores of Subject Areas Contain ESH Requirements That Apply • Accelerator Safety • Work Planning And Control • Voluntary Management Systems • OSH Management System, OHSAS 18001 • Environmental Management System, ISO 14001 • Human Performance Initiative, INPO • Good Manufacturing Practice Regulations • International Conference on Harmonization (ICH), Q7

  7. ESH Systems • As part of the Life Sciences Directorate, Medical Department, the following are managed at the Directorate or Department levels; • Integrated Safety Management • Work Planning & Control • Experiment Safety Reviews • Work Permits/Work Control Coordinators • ALARA Committee • Environmental Management System • Training • Self Assessment Program • Routine Safety Inspections (“Tier 1”) • The RR&P Group ESH Coordinator participates in all of these functions or serves as the point-of-contact for each

  8. Safety Performance • Injury Cases – none in the last 10 years • Lost work days – none in nearly 12 years • Occurrences (see table) • Radiological Awareness Reports (RAR) • Occurrence Reporting and Processing System (ORPS) • Collective Annual Average Equivalent-Dose, 1995-present – 0.74 person-rem

  9. RAR/ORPS TABLE

  10. Quality Assurance • Some radioisotope products are used in manufacture of radiopharmaceuticals, therefore subject to Good Manufacturing Practice (GMP) requirements. • Formerly the driver requirements were in 21 CFR 211, now International Conference On Harmonization Of Technical Requirement For Registration Of Pharmaceuticals For Human Use - ICH Harmonized Tripartite Guideline - Good Manufacturing Practice Guide For Active Pharmaceutical Ingredients Q7 (“ICH Q7”) • These requirements are numerous and time-consuming. Compliance is difficult, given the small size of the RR&P group. • Production program is audited by customers, now international customers. The number of non-US customers and the number of products coming under these requirements is expected to increase. • A recent audit by a new customer resulted in 4 major and 4 minor observations.

  11. Draximage Audit Findings10/20/09 Visit • Observation 1 (Minor) – Modifications to the Master Production Record (TPL 604) are required regarding reagent preparation. • Observation 2 (Major) – Routine QC on balances is required. IQ/OQ on balances required. • Observation 3 (Minor) – Certificates of calibration from provided by contractors must be signed by QAU. • Observation 4 (Major) – Modifications to the Master Production Record (TPL 604) are required regarding critical process parameters and in-process controls. • Observation 5 (Minor) – Batch Certificates of Analysis must be signed by QAU. • Observation 6 (Minor) – Training procedure BLIP-TPL 801 must be modified to exempt procedure authors and reviewers from briefings/training on those documents. • Observation 7 (Major) – A Master Validation Plan and appropriate Validation documentation packages must be prepared. • Observation 8 (Major) – Self-inspection and Product Quality review are required. IN DISPUTE – both of these requirements are currently met but were not discussed during the audit. • Observation 9 (Major) – A product recall program must be established.

  12. Quality Assurance – cont. Additional anticipated QA effort: • Sr-82 process requires retrospective validation investigation and documentation and preparation of revised Drug Master File (DMF) • Ge-68 production must be made GMP-compliant to support a clinical Ge-68/Ga-68 generator. This will require; • Process development/modification • Preparation, implementation, and documentation of Prospective Process Validation • Preparation of a Drug Master File for new process and submission to FDA

  13. Summary • The safety program is satisfactory regarding compliance. • Safety oriented events (injuries, lost work days, RAR & ORPS) are not a significant issue. • GMP compliance will require a significantly increased effort.

More Related