NIST S 7101-20_Work and Worker Authorization Based on Hazard Reviews_12172020.pdf
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About this file
This document is a NIST suborder that defines the requirements and associated roles and responsibilities for authorizing both hazardous activities ("work") and workers based on a systematic level of work planning and control commensurate to the hazards, job complexities, and physical location.
The key details are:
- The suborder establishes a graded approach to managing the safety of a wide range of hazardous activities, from those that are relatively simple and routine to those that are highly complex one-time projects.
- It defines the risk-assessment methodology, hazard-review process, authorization of work and workers, re-review and re-approval of hazard reviews and re-authorization of work and workers, retraining and re-authorization of workers, and records management requirements.
- The suborder applies to all activities conducted by NIST employees and associates, except for common everyday tasks and inherently low-risk activities.
- Hazard reviews must be approved by line management based on the Relative Hazard Index (RHI) level, with activities having an RHI of 4 prohibited at NIST.
- The suborder also addresses requirements for activities involving workers from multiple organizational units.
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Text version
NIST S 7101.20 (Uncontrolled Copy in Print) Page 1
WORK AND WORKER AUTHORIZATION 3
BASED ON HAZARD REVIEWS 4
(“HAZARD REVIEW”) 5
NIST S 7101.20 7
Approval Date: 12/23/2020 8 Effective Date: 06/05/2020 9
1. PURPOSE 12
The purpose of this suborder is to define the requirements and associated roles and 13 responsibilities for authorizing both hazardous activities (“work”) and workers based on a 14 systematic level of work planning and control commensurate to the hazards, job 15 complexities, and physical location, i.e., based on hazard reviews. 16
2. BACKGROUND 19
a. This suborder describes NIST’s graded approach to managing the safety of a wide range of 20 hazardous activities, from those that are relatively simple and routine to those that are highly 21 complex one-time projects. The graded approach is based on the severity of the consequences 22 of hazardous events or exposures to hazards and the likelihood of such events or exposures. 23
b. While this suborder primarily focuses on hazardous activities performed under normal and 25 off-normal operating conditions, there are provisions for authorizing work and workers under 26 abnormal operating conditions in which external factors may alter the risk assessment or 27 present additional hazards to those directly associated with performance of the activity. 28
c. This suborder supersedes NIST Administrative Manual Subchapter 12.06, Hazard Analysis 30 and Control. 31
3. APPLICABILITY 34
a. The requirements of this suborder apply to all activities conducted by NIST employees and 35 associates as part of their assigned duties under normal operating conditions except for the 36 following: 37
NIST S 7101.20 (Uncontrolled Copy in Print) Page 2
(1) Common Everyday Tasks Performed Routinely by Members of the General Public at 38 Work and Home and that Do Not Involve Extraordinary Hazards. This exception 39 recognizes that NIST staff members possess the knowledge, skills, and abilities to 40 perform a wide variety of common everyday tasks safely without written hazard reviews. 41 Examples of such common everyday tasks include working at a computer, reviewing 42 documents, walking, climbing stairs, picking up objects, and using scissors or short step 43 stools. 44
(2) Inherently Low-Risk Activities. This exception applies to activities that are considered to 46 present low safety risks without NIST personnel having to implement any safety controls 47 to mitigate those risks.1,2 The following activities are considered to present low safety 48 risks: 49
(a) Activities that could result in injuries requiring first aid but only infrequently; and 51
(b) Activities that could result in injuries requiring medical treatment beyond first aid but 53 are very unlikely to do so. 54
Examples of inherently low-risk activities include calibrating a balance, preparing non-56 hazardous solutions, and using an optical microscope to examine non-hazardous samples. 57
b. The requirements of this suborder apply to any activity, regardless of the hazardous nature of 59 the activity itself, when performed under abnormal operating conditions (see Section 2.b) 60 where external factors may present hazards or pose additional risk beyond those associated 61 with performance of the activity, except when: 62
(1) Following the general requirements and/or guidance associated with the abnormal 64 condition provides sufficient protection from the hazards associated with the abnormal 65 condition; 66
(2) No activity-specific instructions are needed to implement the general requirements and/or 68 guidance associated with the abnormal operating conditions; and 69
(3) The activity-specific risks do not change as a result of the abnormal conditions. 71
1 This presumes that if such an activity involves the use of equipment with built-in safety features, these features do not require written safe work practices, are not easily defeated, and will not be intentionally defeated or separated from the equipment.
2 The requirements of this suborder apply to any activity for which PPE is required to mitigate the activity’s safety risks. They do not apply to the following uses of PPE: PPE required solely for entry into the space in which the inherently low-risk activity is conducted, not for protection from the hazards associated with the activity; PPE used voluntarily as an additional layer of protection; and PPE worn solely to protect equipment or materials.
NIST S 7101.20 (Uncontrolled Copy in Print) Page 3
c. The exemptions provided in Section 3a do not relieve NIST staff members or management 72 from their responsibility to manage the safety risks associated with common everyday tasks 73 and inherently low-risk activities. NIST focuses on these using a variety of mechanisms, 74 including general safety training, safety-related communications, and incident awareness and 75 reduction efforts. In addition, the exemptions do not relieve NIST of its responsibility to 76 evaluate the compatibility of such activities with more hazardous activities in the same 77 spaces. 78
4. REFERENCES 81
a. 29 Code of Federal Regulations 1910.132, Personnel Protective Equipment. 82
5. APPLICABLE OCCUPATIONAL SAFETY AND HEALTH (OSH) SUBORDERS 85
a. NIST S 7101.04: Safety and Health Requirements for Minors; 86
b. NIST S 7101.21: Personal Protective Equipment; 88
c. NIST S 7101.58: Respiratory Protection; 90
d. NIST S 7101.55: Hearing Protection; 92
e. NIST S 7101.22: Hazard Signage; 94
f. Other OSH suborders that contain sections focused on the identification, assessment, and 96 mitigation (i.e., control) of hazards in specific OSH areas, e.g., chemical hazard 97 communication, chemical management, cryogen safety, dispersible engineered 98 nanomaterials, hearing protection, and magnetic-field safety, to name several; and 99
g. NIST S 7101.23: Safety Education and Training. 101
6. REQUIREMENTS 104
Requirements are provided for the risk-assessment methodology to be used in conducting 105 hazard reviews; the content, conduct, and approval of hazard reviews; the authorization of 106 work and workers; the re-review, and re-approval, of hazard reviews and the re-authorization 107 of work that falls outside the scope of current hazard reviews; retraining and reauthorization 108 of workers according to updated hazard reviews; records; activities involving workers from 109 multiple OUs; and Organizational Unit (OU) implementing procedures. Appendix B 110 illustrates the processes for authorizing work and workers and the role of hazard reviews. 111 https://www.ecfr.gov/cgi-bin/text-idx?SID=c50e51395529ffa95af2398d4a4bd540&mc=true&node=se29.5.1910_1132&rgn=div8
NIST S 7101.20 (Uncontrolled Copy in Print) Page 4
a. Risk-Assessment Methodology 112 Procedures for implementing this suborder shall use the risk-assessment matrix in Appendix 113 C as the basis for conducting risk assessments. Once a hazard has been identified, the risk of 114 a hazardous event or exposure associated with that hazard shall be characterized, as indicated 115 in Appendix C and below, by a Relative Hazard Index (RHI) based on the severity of the 116 consequences of a hazardous event or exposure to a hazard and the likelihood of such an 117 event or exposure. 118
(1) Severity of the consequences of a hazardous event or exposure to a hazard (“Severity”) 120
(a) The severity categories in Appendix C provide qualitative measures of the 122 consequences of the worst credible hazardous event (see definition of “Worst 123 Credible Hazardous Event”) or exposure associated with an identified hazard due to 124 design inadequacies; procedural deficiencies; human error; environmental conditions; 125 or system, subsystem, or component failure or malfunction. The severity categories 126 that shall be used are: 127
i. CATASTROPHIC: Death or permanent disability; system or facility loss; 129 major property damage, lasting environmental or public-health impact. 130
ii. SEVERE: Serious injury; temporary total disability (more than 3 months); 132 subsystem loss or significant facility/property damage, temporary 133 environmental or public-health impact. 134
iii. MODERATE: Medical treatment beyond first aid; lost workdays; more than 136 slight facility/property damage; external reporting requirements; more than 137 routine clean-up. 138
iv. MINOR: First aid or minor medical treatment; negligible or slight 140 facility/property damage; no external (outside NIST) reporting requirements, 141 routine cleanup. 142
(2) Likelihood of a hazardous event or exposure (“Likelihood”) 144
(a) The likelihood categories in Appendix C broadly estimate the probability that a 146 hazardous event or exposure involving an identified hazard will occur in carrying out 147 an activity. The likelihood categories that shall be used are: 148
i. FREQUENT: Likely to occur frequently or repeatedly. 150
NIST S 7101.20 (Uncontrolled Copy in Print) Page 5
ii. PROBABLE: Likely to occur multiple but infrequent times. 152
iii. OCCASIONAL: Likely to occur at some time. 154
iv. REMOTE: Possible, but not likely to occur. 156
v. IMPROBABLE: Very unlikely: can reasonably be assumed not to occur. 158
To the extent practical, likelihood should be assigned based on research, analysis, 160 experience, or evaluation of historical safety data from work with similar hazards. 161
(3) RHIs 163
(a) RHIs shall be associated with identified hazards by assigning both severity and 165 likelihood categories as indicated above and by identifying the corresponding RHIs at 166 the intersection of the severity column and likelihood row in the risk-assessment 167 matrix in Appendix C. The RHI levels that shall be used are: 168
i. Critical (RHI = 4) 170
ii. Serious (RHI = 3) 172
iii. Medium (RHI = 2) 174
iv. Low (RHI = 1) 176
v. Minimal (RHI = 0) 178
The RHI for an identified hazard provides a measure of the risk associated with that 180 hazard assuming that some set of controls has been implemented, where that set of 181 controls could range from inherent/built-in controls only to inherent/built-in controls 182 plus additional controls. In this sense, RHIs are based on mitigated hazards.3 183
b. Hazard-Review Process 185 Hazard reviews shall consist of the following primary elements, each of which must be 186 documented: (1) activity description, (2) activity hazard identification, (3) physical-location 187 review, (4) compatibility assessment, (5) initial hazard assessment, (6) hazard mitigation, (7) 188
3 RHIs are sometimes conceptualized as being based on (a) severity taking into account inherent/built-in controls only and (b) likelihood after the implementation of additional controls. This is valid to the extent that additional controls reduce, or are considered to reduce, only likelihood, not severity.
NIST S 7101.20 (Uncontrolled Copy in Print) Page 6 incident-response plan, and (8) risk assessment. Appendix D provides a flowchart 189 illustrating the relationship of these elements. 190
(1) Activity Description 192
Hazard reviews shall: 193
(a) Fully and accurately describe the activity being reviewed, including its intended 195 outcome or expected result, in a way that is detailed enough for someone outside of 196 the division or group to understand it;4 197
(b) Define the activity boundaries by identifying what is included in the activity as well 199 as what is specifically excluded from the activity, e.g., commissioning, normal 200 operations, and maintenance of an instrument could be considered separate activities 201 with their own hazard reviews, depending on how different the hazards and 202 associated controls are in the three phases; 203
(c) Identify distinct subtasks within an activity based on significant differences in the 205 nature of the work and associated hazards (hazards may differ from task to task and 206 must be managed accordingly); 207
(d) Specify the physical location in which the activity is to be conducted; if the activity is 209 to be conducted in multiple locations, describe the general environment in which the 210 activity will be conducted and describe any specific restrictions, if applicable. When 211 the restrictions vary from location to location, subtasks should be assigned by 212 location. 213
(2) Activity Hazard Identification 215
The activity hazard identification shall: 216
(a) Identify the hazards associated with the activity, or, if the activity comprises distinct 218 subtasks, the hazards associated with each of those subtasks; and 219
(b) Note, reference, or include as attachments to the hazard review the results of any 221 exposure assessments or calculations conducted to characterize or quantify identified 222 potential hazards associated with the activity. 223
(3) Physical-Location Review 225 The physical-location review shall determine if the venue in which the activity is to be 226 conducted is appropriate and adequate. Routine laboratory, shop, or mechanical activities 227
4 An activity description similar to a scientific abstract would represent a best management practice.
NIST S 7101.20 (Uncontrolled Copy in Print) Page 7 are typically acceptable in spaces intended for such activities. OSHE should be consulted, 228 however, when unique, atypical, or unusual activities may not be consistent with the 229 proposed venue, and the results of the consultation should be noted in the review. For 230 example, OSHE should be consulted when the activity involves unusual quantities or 231 classes of hazardous materials or requires specialized fire and life-safety systems or 232 emergency-response equipment, and the results should be noted in the review. 233
(4) Compatibility Assessment 235 The compatibility assessment shall examine the hazard reviews associated with the 236 totality of activities conducted in the proposed physical location, both in the actual space 237 itself and, when applicable, neighboring spaces, to identify any potentially negative or 238 antagonistic interactions, taking into account both planned operations and off-normal 239 conditions that could reasonably be expected to occur. 240
(5) Initial Hazard Assessment 242
The initial hazard assessment shall: 243
(a) Identify for each identified hazard the key stages in the activity, or its subtasks, at 245 which a hazardous event or exposure could occur, focusing on those stages essential 246 to safe conduct of the activity or its subtasks; and 247
(b) Assign severity levels to each of the identified hazards, taking into account 249 inherent/built-in controls only, i.e., prior to identifying any other controls (see 250 definition of “Inherent/Built-In Controls”); 251
(c) Consider any synergistic, negative, or antagonistic interactions identified in the 253 compatibility assessment. 254
(6) Hazard Mitigation 256
(a) Hazard mitigation shall employ the following “hierarchy of controls” (i.e., preferred 258 order of implementation of controls) to mitigate each of the identified hazards, with 259 each subsequent control category being less effective and reliable than the previous 260 category: 261
i. Elimination; 263
ii. Substitution; 265
iii. Engineering controls; 267
NIST S 7101.20 (Uncontrolled Copy in Print) Page 8
iv. Administrative controls (including signage, warnings, alarms, and training), 269 and; 270
v. Personal protective equipment (PPE). 271
Hierarchy of controls shall be employed until enough controls have been identified to 273 mitigate the hazards to acceptable levels; in some cases, a combination of controls 274 may be necessary, e.g., engineering controls such as machine guarding and local 275 exhaust ventilation could be used in conjunction with training and PPE to mitigate a 276 hazard. There must be a clear connection between the hazards, the controls, and the 277 mitigation of the hazards. 278
(b) Hazard mitigation shall stipulate the engineering controls required for an activity, 280 e.g., chemical fume hood, gas cabinet, enclosures, interlocks, blast wall, safety 281 interlock. 282
(c) Hazard mitigation shall specify the alarms and other warnings required for an 284 activity, e.g., toxic gas alarms, oxygen sensors, warning lights, hazard signage. 285
(d) When engineering controls and alarms and other warnings must be integrated into the 287 building infrastructure, the hazard review shall confirm that the physical location in 288 which the activity is to be conducted contains, or will contain, such equipment. 289
(e) Hazard mitigation shall specify safe operating guidelines, as applicable (see definition 291 of “Safe Operating Guidelines”), and incorporate these explicitly in the hazard 292 review, either in their entirety or by reference. 293
(f) Hazard mitigation shall specify any restrictions on employees conducting activities 295 alone or out of hours, and if there are such restrictions, the additional safety measures 296 that must be implemented, e.g., buddy system, safe operating guideline. 297
(g) Hazard mitigation shall specify any ongoing direct supervision required for 299 employees to engage in the activity when ongoing direct supervision is deemed a 300 necessary administrative control. 301
(h) Hazard mitigation should specify any restrictions on: 303
i. The number of hours employees spends on the activity during a workday; 305
ii. The time of day employees conduct the activity; and 307
NIST S 7101.20 (Uncontrolled Copy in Print) Page 9
iii. The environmental conditions under which employees conduct the activity. 309
(i) Hazard mitigation shall specify the PPE required for conduct of the activity or 311 subtasks of the activity. 312
i. All PPE, including employee-owned PPE, shall be of safe design and 314 construction for the work to be performed. 315
ii. PPE shall be selected in accordance with the requirements in the PPE and 317 other OSH suborders (e.g., Biosafety, Cryogen Safety, Hearing Protection, 318 Respiratory Protection, etc.), as applicable. 319
iii. PPE that properly fits each affected employee shall be selected. 321
(j) Hazard mitigation shall, based on the physical-location review, identify any 323 additional controls necessary to conduct the activity safely in the proposed physical 324 location. 325
(k) Hazard mitigation shall, based on the compatibility assessment, identify any 327 additional controls necessary to conduct the proposed activity safely in proximity to 328 other activities in the space and, when applicable, neighboring spaces. 329
(l) Hazard mitigation shall specify the activity-specific training, to be provided by the 331
OU, required for employees to engage in the activity, or distinct subtasks of the 332 activity, in the proposed physical location, and, when applicable, in proximity to other 333 activities in the space and neighboring spaces. 334
i. The Safety Education and Training suborder requires employees to complete 336 the training specified in OSH suborders (e.g., Biosafety, Cryogen Safety, 337 Magnetic Fields, etc.) applicable to the work they are to conduct. This training 338 is documented and recorded in accordance with the requirements of the Safety 339 Education and Training suborder and need not be specified in the hazard 340 review. 341
ii. When activities involve the use of PPE, the activity-specific training must 343 result in employees being able to demonstrate an understanding of the 344 following requirements, and any special activity-specific abilities needed to 345 use the applicable PPE properly, before they are permitted to perform work 346 with that PPE: 347
NIST S 7101.20 (Uncontrolled Copy in Print) Page 10
(i) What PPE is necessary; 348
(ii) When PPE is necessary; 350
(iii) How to properly don, doff, adjust, and wear the PPE; 352
(iv) The limitations of the PPE; and 354
(v) The proper care, maintenance, useful life, and disposal of the PPE. 356
This activity-specific training must address only those activity-specific aspects 358 of the PPE not covered in either (1) the training provided by OSHE on the 359 PPE program, or (2) the training completed previously by affected employees 360 for other activities. This training shall be provided by OU employees, or 361 others, who have demonstrated an understanding of the activity-specific 362 aspects of the applicable PPE and any activity-specific ability to use that PPE 363 properly. 364
(m) Voluntary use of controls should be documented in the hazard mitigation section of 366 the Hazard Review when such use is subject to requirements in other OSH 367 suborders.5 368
(7) Incident-Response Plan (Activity Specific) 370
Planning for incidents, including off-normal conditions6, as applicable, is a critical 371 element of the hazard review process. In addition to providing guidance during an 372 emergency, the development of incident-response plans may result in the identification of 373 hazardous conditions that could aggravate or compound an emergency situation. 374 Additionally, the planning process may bring to light deficiencies, such as the lack of 375 resources (equipment, trained personnel, supplies) or adequate controls that can be 376 rectified before an emergency occurs. Hazard reviews shall include activity-specific 377 incident-response plans that: 378
(a) Stipulate any activity-specific equipment and supplies required for incident response, 380 e.g., emergency shut-off switch, spill containment, special-purpose vacuum cleaner; 381
(b) Include the following when necessary to protect employee safety and health, the 383 physical location, and the environment: 384
5 For example, the voluntary use of respiratory protection is governed by specific requirements in the Respiratory Protection suborder.
6 Examples of off-normal conditions, i.e., conditions outside of expected operating limits, include over or under pressure, over or under temperature, over or under flow rates, and loss of electrical power.
NIST S 7101.20 (Uncontrolled Copy in Print) Page 11
i. Procedures for shutting down or placing systems in a safe configuration; 385
ii. Plans for responding to off-normal conditions resulting from the failure of one 387 or more controls in the activity itself and, when necessary, other activities 388 conducted in the same space or neighboring spaces; 389
iii. Plans for responding to events such as utility losses, e.g., power or water, and 391 building evacuations; and 392
iv. The identification of additional controls deemed necessary to reduce risks to 394 acceptable levels; 395
(c) Ensure that decisions regarding employees working alone or out of hours fully 397 consider the need to respond promptly, if necessary, to incidents that threaten 398 employee safety and health or the environment; and 399
(d) Specify the activity-specific incident-response training, to be provided by the OU, 401 required for employees to engage in the activity or distinct subtasks of the activity. 402
(8) Risk Assessment 404
(a) Hazard Reviews shall include an assessment of the risks by assigning RHIs to each of 406 the identified hazards subsequent to the application of controls. 407
(b) If the risk assessment subsequent to hazard mitigation results in RHIs that feasibly 409 could be lower, additional steps to mitigate the hazards shall be taken to reduce the 410 RHIs to those lower levels. 411
(9) Additional Requirements 413
(a) Hazard reviews shall meet the additional requirements established in other OSH 415 suborders, when applicable;7 416
(b) Hazard reviews shall flag, e.g., using checkboxes, activities requiring the control of 418 hazardous energy (lockout/tagout), confined-space entry, hearing protection, 419
7 For example, hazard reviews of activities involving the use of biohazardous materials must include a Biohazardous Materials Registration and Authorization Form approved by the NIST Biosafety Officer; hazard reviews of activities involving the use of radioactive material at NIST Gaithersburg must include (among other things) a specific hazard assessment and hazard mitigation plan whose safety evaluation by the NIST Gaithersburg Radiation Safety Officer has been approved by the NIST Ionizing Radiation Safety Committee.
NIST S 7101.20 (Uncontrolled Copy in Print) Page 12 respiratory protection, fall protection, and assessments of exposure to carcinogenic 420 chemicals; 421
(c) Hazard reviews shall be readily available in hard-copy or electronic form in or near 423 the space in which the associated activities are to be conducted; and 424
(d) Hazard reviews shall identify hazardous wastes generated in the conduct of the 426 activity and include management of those wastes, as applicable. Arrangements for 427 disposal shall be coordinated with OSHE. 428
c. Conduct of Hazard Reviews 430
Hazard reviews shall be conducted by, or in consultation with, individuals with the 431 knowledge, skills, and abilities to identify, assess, and mitigate the hazards associated with 432 the activity under review, to conduct the physical-location review and compatibility 433 assessment, and to develop plans for incident response. 434
(1) Hazard reviews shall be conducted by individuals who collectively8 have taken the 436 training provided by OSHE on the Hazard Review program and on all OSH programs 437 pertinent to the activity under review. 438
(2) Hazard reviews should include subject matter experts from OSHE, the Office of Facilities 440 and Property Management (OFPM), and other OUs when the OU conducting the hazard 441 review requires additional safety or facilities expertise. 442
(3) Hazard reviews shall include consultation with the relevant groups in OSHE, ESO, and 444
OFPM (e.g., Fire and Facilities Safety Group, Police Services Group, Fire Protection 445 Group, Facilities Maintenance Division) when activity-specific alarms must be tied into 446 building or facility alarm systems. 447
d. Approval of Hazard Reviews9, 10 449
Completed hazard reviews shall be approved by line management, with the approval 450 signifying that the RHIs associated with the activity represent an acceptable level of safety 451 risk.11 452
8 At least one member of the team must have taken the required training.
9 Sections 6d-i focus on activities that involve workers from a single OU. Section 6j indicates how Sections 6d-i apply to activities that involve workers from multiple OUs.
10 OUs may approve hazard reviews and authorize work at one time provided that the requirements in this section and Section 6e, respectively, are met.
11 The approved hazard review serves as the Certification of Hazard Assessment required by 29 CFR 1910.132, Personal Protective Equipment.
NIST S 7101.20 (Uncontrolled Copy in Print) Page 13
(1) Hazard reviews shall be approved by line managers who have taken the training provided 454 by OSHE on the Hazard Review program. 455
(2) Activities with any RHI = 4 shall not be conducted at NIST. 457
(3) Hazard reviews of activities involving minors (individuals under age 18) that could result 459 in their being exposed to hazards with RHI = 2 shall be approved by OU Directors.12, 13 460
(4) With the exceptions noted in items (5) and (6) below, all other hazard reviews shall be 462 approved at the following or higher levels of the line management of the OU responsible 463 for the activity (see NIST 7101.00):14 464
(a) Group Leaders: 466
i. Activities with all RHIs ≤ 1. 468
(b) Division Chiefs: 470
i. Activities with some RHIs = 2 but no RHIs = 3. 472
(c) OU Directors:15 474
i. Activities with at least one RHI = 3. 476
(5) Activities for which the highest hazards have RHI = 2 and these are fully controlled to 478 industry standards (see definition of “Fully Controlled to Industry Standards”), as 479 determined by OSHE, may be approved by Group Leaders. 480
(6) Activities for which the highest hazards have RHI = 3 and these are fully-controlled to 482 industry standards (see definition of “Fully Controlled to Industry Standards”), as 483 determined by OSHE in consultation with experts in the OUs, may be approved by 484 Division Chiefs. 485
12 As indicated in Section 10. AUTHORITIES, OU Directors may delegate the authority to approve such hazard reviews to OU Deputy Directors or Division Chiefs.
13 Activities with RHIs > 2 and a list of other specific activities are prohibited for minors; see the Safety and Health Requirements for Minors suborder.
14 OUs may require lower levels of line management (and others, e.g., chairs of hazard review committees, OU/division safety personnel, and project leaders) to sign off on hazard reviews prior to those hazard reviews being approved at the levels of line management indicated.
15 OU Directors may wish to establish (standing or ad hoc) Hazard Review Committees to conduct (or review) hazard reviews for such activities and recommend their approval or disapproval.
https://oshe.nist.gov/apps/docs/programs/Documents/NIST%20O%207101-00%20-%20Occupational%20Safety%20and%20Health%20Order_080216.docx
NIST S 7101.20 (Uncontrolled Copy in Print) Page 14
e. Authorization of Work16 487 Activities covered by approved hazard reviews shall be authorized to commence by line 488 management, with the authorization signifying that controls other than training17 have been 489 verified to have been implemented and that the controls will continue to be implemented as a 490 condition for the ongoing conduct of the work.18 491
(1) Activities shall be authorized by line managers who have taken the training provided by 493
OSHE on the Hazard Review program. 494
(2) Activities with any RHI =4 shall not be authorized by NIST. 496
(3) With the exceptions noted in item (4) below, activities covered by all other hazard 498 reviews shall be authorized at the following or higher levels of line management:19 499
(a) Group Leaders: 501
i. Activities with all RHIs ≤ 2. 503
(b) Division Chiefs: 505
i. Activities with at least one RHI = 3. 507
(4) Activities for which the highest hazards have RHI = 3 and these are fully-controlled to 509 industry standards (see definition of “Fully Controlled to Industry Standards”), as 510 determined by OSHE, may be authorized by Group Leaders. 511
(5) If an activity of one OU is to be conducted in space assigned to another OU, access to 513 that space must be authorized by the line management of the second OU subject to any 514 conditions established by that OU to protect other employees working in the space from 515 the hazards associated with the activity. These conditions must be included as part of the 516 formal authorization of work (see NIST 7101.00). 517
16 OUs may approve hazard reviews and authorize work at one time provided that the requirements in this section and Section 6e, respectively, are met.
17 Training is addressed not in the authorization of work, but in the authorization of workers; see Section 6f.
18 So, for example, if a chemical fume hood is a required control, and the chemical fume hood is out of service or suspected to be functioning improperly, the work must stop until the fume hood is fully operational or an equivalent control is identified and implemented. Similarly, PPE must be in good working condition; defective or damaged PPE shall not be used.
19 OUs may require lower levels of line management (and others, such as chairs of hazard review committees, OU/division safety personnel, and project leaders) to sign off on authorizations of work prior to work being authorized at the level of line management indicated.
https://oshe.nist.gov/apps/docs/programs/Documents/NIST%20O%207101-00%20-%20Occupational%20Safety%20and%20Health%20Order_080216.docx
NIST S 7101.20 (Uncontrolled Copy in Print) Page 15
f. Authorization of Workers 519 To engage in activities that have been authorized by line management, workers must 520 themselves be authorized to perform that work by line management. This authorization 521 signifies that: 522
• The workers have taken the training specified in the OSH suborders applicable to the 524 work they are to conduct and the activity-specific training identified in Sections 525 6b(6)(i) (Hazard Mitigation) and 6b(7)(c) (Incident-Response Plan); 526
• Line-management has an appropriate degree of confidence, based on personal 528 knowledge, observation, or reliable input from others, that the workers to be 529 authorized: 530 o Have the knowledge, skills, and abilities to perform the work safely and 532 correctly; and 533 o Fully understand the boundaries/conditions imposed on the activity by the 535 activity hazard review, the need to work within those boundaries/conditions, 536 and the process for requesting work that falls outside of those 537 boundaries/conditions. 538
(1) Workers shall be authorized by line managers who have taken the training provided by 540
OSHE on the Hazard Review program and, in the case of official first-level supervisors, 541 on all OSH programs applicable to the work to be conducted;20 and 542
(2) Workers shall be authorized by their official first-level supervisors, or at that level and 544 higher.21, 22 545
g. Re-Review and Re-Approval of Hazard Reviews and Re-Authorization of Work and 547
Workers 548
20 The Safety Education and Training suborder requires official first-level supervisors to complete training on the OSH suborders applicable to the work to be conducted by employees they supervise. This training is documented and recorded in accordance with the requirements of the Safety Education and Training suborder and need not be specified in the hazard review.
21 If a worker is to be authorized to carry out only a specified set of subtasks of a larger activity, that worker need only take the training applicable to that specified set of subtasks.
22 If an activity involves workers from one or more groups or divisions within a single OU, the OU may wish to establish additional requirements for authorizing workers across organizational lines. For example, if an activity owned by one group involves workers from a second group and the two Group Leaders are the official first-level supervisors, the OU may wish to have the workers from the second group authorized first by their Group Leader and then by the Group Leader of the group that owns the activity.
NIST S 7101.20 (Uncontrolled Copy in Print) Page 16
(1) Hazard reviews shall be re-reviewed whenever: 550
(a) Changes in existing activity parameters would introduce new hazards or increase 552 existing hazards; 23 553
(b) Changes in engineering controls, administrative controls, or PPE would increase 555 safety risks; or 556
(c) Previously unrecognized safety issues are identified, e.g., through direct observation 558 or discussion, relating to an incident or audit that indicates inadequate controls, or 559 abnormal operating conditions which affect availability or efficacy of documented, 560 planned controls. 561
(2) Hazard reviews shall be re-reviewed on a predetermined basis to verify that the hazards 563 have not changed substantially since the hazard review was last approved or reviewed, 564 and that existing controls are adequate. Predetermined review periods: 565
(a) Shall be established when hazard reviews are initially reviewed and approved and 567 when they are re-reviewed; 568
(b) Shall not exceed three years; 570
(c) Shall be included in the hazard review documentation; 572
(d) Shall be based on risk and the potential for change, with higher-risk, more potentially 574 variable activities being reviewed more frequently; and 575
(e) May be more frequent based on the likelihood for change within an activity. 576
(3) When re-reviews indicate that hazards have not changed and that existing controls are 578 adequate, the re-reviewed hazard reviews shall include the date of the re-review, the 579 signature(s) of the individual(s) conducting the re-review, and the signature of the 580 responsible line manager. 581
(4) When re-reviews indicate that hazards have changed or that existing controls are 583 inadequate: 584
23 For example, changes in equipment, equipment operation, materials, maximum quantities of materials, concentrations, operating temperatures and pressures, power levels, or process rates, or changes in permit conditions for permit-required activities, that would introduce new hazards or increase existing hazards.
NIST S 7101.20 (Uncontrolled Copy in Print) Page 17
(a) The re-reviewed hazard reviews shall be re-approved in accordance with the 586 requirements in Section 6d; and 587
(b) Work and workers shall be re-authorized in accordance with the requirements in 589 Sections 6e and 6f, respectively. 590
The re-approval of the hazard review and the re-authorization of work shall take place at 592 the levels of line management determined by the hazards that have changed or for which 593 the existing controls are inadequate, or at a higher level of line management. 594
h. Retraining and Re-Authorization of Workers 596
(1) Employees who have been authorized to conduct work shall, as a condition of their 598 authorization, complete retraining identified by the OUs whenever there is reason to 599 believe that employees lack the knowledge, understanding, or skill necessary to conduct 600 their work safely. Individual OSH suborders list specific circumstances under which such 601 retraining is required. General circumstances under which retraining is required include, 602 but are not limited to: 603
(a) An observation or other condition reveals that a worker lacks the necessary 605 knowledge understanding or skill; or 606
(b) An inspection or audit points to a systemic deficiency warranting retraining. 608
i. Records 610
(1) Copies of all current hazard reviews and work and worker authorizations shall be 612 maintained in hard copy or electronic form. 613
(2) Copies of hazard reviews and work and worker authorizations for activities that have 615 ceased shall be maintained in hard copy or electronic form for at least one (1) year unless 616 the hazard assessment involved exposure monitoring, in which case the hazard review 617 and work and worker authorizations shall be submitted to OSHE for retention in 618 accordance with the requirements of the Industrial Hygiene program. 619
(3) Training shall be documented and recorded in accordance with the requirements, roles, 621 and responsibilities in the Safety Education and Training suborder. 622
j. Activities Involving Workers from Multiple OUs 624
NIST S 7101.20 (Uncontrolled Copy in Print) Page 18
(1) The activity shall be owned by the de facto lead OU or, if it is not obvious which OU is 626 the de facto lead OU, by the OU determined to be the lead OU by discussion among the 627 involved OUs. 628
(2) The hazard review shall be approved by the lead OU in accordance with the 630 requirements in Section 6d, Approval of Hazard Reviews. 631
(3) Work shall be authorized by the lead OU in accordance with the requirements in Section 633
6e, Authorization of Work. 634
(4) Workers from the lead OU shall be authorized by the lead OU in accordance with the 636 requirements in Section 6f, Authorization of Workers. 637
(5) Workers from OUs other than the lead OU shall be authorized by their respective OUs 639 in accordance with the requirements in Section 6f and by the lead OU (“final 640 authorization”) in accordance with its own requirements. 641
(a) In authorizing workers from their OUs, OUs other than the lead OU should 643 determine that the hazard review is adequate, that the safety risk to workers from 644 their OUs is acceptable, and that the work has been authorized by the lead OU. 645
(6) Hazard reviews shall be re-reviewed and re-approved and work and workers from the 647 lead OU shall be re-authorized by the lead OU in accordance with the requirements in 648 Section 6g, Re-Review and Re-Approval of Hazard Reviews and Re-Authorization of 649 Work and Workers. 650
(7) Workers from OUs other than the lead OU shall be re-authorized by their respective 652
OUs in accordance with the requirements in Section 6g and by the lead OU (“final re-653 authorization”) in accordance with its own requirements. 654
(8) Workers from the lead OU shall be retrained and re-authorized by the lead OU in 655 accordance with the requirements in Section 6h, Retraining and Re-Authorization of 656 Workers. 657
(9) Workers from other than the lead OU shall be retrained and re-authorized by their 659 respective OUs in accordance with the requirements in Section 6h and by the lead OU in 660 accordance with its own requirements. 661
(10) Records related to hazard-review documentation, the authorization of work, and the 663 authorization of workers from the lead OU shall be maintained by the lead OU in 664 accordance with the requirements in Section 6i, Records. 665
NIST S 7101.20 (Uncontrolled Copy in Print) Page 19
(11) Records of the authorization of workers from OUs other than the lead OU shall be 666 maintained as follows: 667
(a) Records of the authorization of workers from OUs other than the lead OU shall be 669 maintained by the workers’ respective OUs; and 670
(b) Records of the final authorizations of such workers by the lead OU shall be 672 maintained by the lead OU. 673
k. OU Hazard Review and Work and Worker Authorization Procedures 675
Written procedures, which, if followed, would result in the requirements in Sections 6a-j 676 being met, shall be developed and maintained by each OU. 677
7. DEFINITIONS 680
a. Abnormal Conditions – Operational occurrences caused by external factors which are not 681 expected to occur as part of normal and off-normal conditions and may alter the risk 682 assessment or present additional hazards to those directly associated with performance of the 683 activity. Examples include restricted access to campus or need to work in close contact with 684 another staff member during pandemic conditions. 685
b. Activity – An experiment, operation, process, or job, often comprising subtasks, conducted to 687 achieve a specific outcome. 688
c. Direct Supervision – Relative to an employee, a term meaning that a second employee, 690 proficient in the activity being conducted by the first employee, shall be either present in the 691 work area while the activity is being conducted or available for consultation within a 692 reasonable amount of time commensurate with the need for consultation, based on the 693 proficiency of the first employee. 694
d. Fully Controlled to Industry Standards (Used in Reference to Hazards) – Controlled by a 696 device, apparatus, or system being designed in accordance with applicable regulatory and 697 consensus standards and predicated upon that device, apparatus, or system being used in a 698 prescribed manner. The mitigation of hazards that are fully controlled to industry standards 699 relies primarily on built-in/engineering controls or inherent design features but may, in some 700 cases, rely upon best practices. In either case, the control should be traceable to a broad 701 industry, consensus-based set of controls. 702
NIST S 7101.20 (Uncontrolled Copy in Print) Page 20
e. Hazard – Source, situation, or act with a potential for harm in terms of human injury or ill 704 health, adverse impact on the environment, damage or loss of equipment or property, or a 705 combination of these (from NIST 7101.00).24 706
f. Hazard Identification – Process of recognizing that a hazard exists and defining its 708 characteristics (from NIST 7101.00). 709
g. Hazard Review (Document) – A document describing the results of the hazard-review 711 process. 712
h. Hazard Review (Process) – The formal process, aspects of which could be iterative, of 714 describing an activity, identifying the hazards associated with the activity, reviewing the 715 physical-location in which the activity will be carried out, assessing the compatibility of the 716 activity with nearby activities, conducting an initial hazard assessment, identifying controls 717 to mitigate the hazards, developing an incident-response plan, conducting a risk assessment, 718 and developing plans for managing wastes generated during the conduct of the activity. 719
i. Hierarchy of Controls – A range of hazard control methods arranged in order of 721 implementation preference from elimination to substitution, engineering controls, 722 administrative controls, and personal protective equipment. 723
j. Inherent/Built-In Controls – Features of a system's design that prevent or limit the severity of 725 the consequences of system failure. Inherent/built-in controls cannot be defeated or separated 726 from the system without conscious or willful effort. 727
k. Likelihood of a Hazardous Event or Exposure (“Likelihood”) – An estimate of the 729 probability of a hazardous event or exposure. 730
l. Line Management – For the purposes of this suborder, the OU Director, Division Chief, and 732 Group Leader, or equivalent. 733
m. Office-Like Space – A space, such as a conference room, copier room, break room, or 735 ordinary computer room that has the same types of hazards as a typical office or office 736 environment. 737
24 This definition parallels that in Occupational Health and Safety Assessment Series (OHSAS) Standard 18001:2007, Occupational Health and Safety Management Systems – Requirements. For comparison, OSHA 3071, Job Hazard Analysis, 2002 (revised) defines a hazard as “the potential for harm, often associated with a condition or activity that, if left uncontrolled, can result in injury, illness or damage to property or the environment”, and American National Standard for Occupational Safety and Health Management Systems, ANSI/AIHA Z10-2005, defines a hazard as “a condition, set of circumstances, or inherent property that can cause injury, illness or death”.
NIST S 7101.20 (Uncontrolled Copy in Print) Page 21
n. Off-Normal Conditions – Operational occurrences which may be expected to occur that are 738 generally outside routine or planned operations. For example, loss of cooling water would be 739 an “off-normal” condition which could cause a heat-sink to overheat and combust. Other 740 examples include power failure, error at power-up or power-down, loss of cryogen 741 containment, human error, etc. 742
o. Relative Hazard Index (RHI) – A measure of the risk of a hazardous event or exposure based 744 on a combination of the severity of the consequences of the hazardous event or exposure to a 745 hazard and its likelihood. 746
p. Risk – Combination of the likelihood of an occurrence of a hazardous event or exposure and 748 the severity of injury or ill health that can be caused by the event or exposure (from NIST 749 7101.00). 750
q. Risk Assessment – Process of evaluating the risks arising from hazards, taking into account 752 the adequacy of any existing controls, and deciding whether or not the risks are acceptable 753 (from NIST 7101.00). 754
r. Safe Operating Guideline – A written set of requirements or practices developed or designed 756 to enable a task to be carried out safely. Safe operating guidelines can include, but are not 757 limited to, standard operating procedures, job hazard analyses, and instrument/equipment 758 instruction manuals. 759
s. Severity of the Consequences of a Hazardous Event or Exposure to a Hazard (“Severity”) – 761
A qualitative measure of the consequences of the worst credible hazardous event or exposure 762 associated with an identified hazard due to design inadequacies; procedural deficiencies; 763 human error; environmental conditions; or system, subsystem, or component failure or 764 malfunction. 765
t. Standard Operating Procedure – A written step-by-step procedure or operational protocol 767 used to document how a given task must be carried out to ensure safe operation. Standard 768 operating procedures are generally needed when failure to follow a prescribed set of steps 769 results in significant increase in risk. 770
u. Worst Credible Hazardous Event – Most severe or serious event capable of being believed, 772 taking into account all relevant considerations. 773
8. ACRONYMS 776
a. HR – Hazard Review 777
NIST S 7101.20 (Uncontrolled Copy in Print) Page 22
b. OSH – Occupational Safety and Health 778
c. OSHE – Office of Safety, Health, and Environment 780
d. OU – Organizational Unit 782
e. PPE – Personal Protective Equipment 784
f. RHI – Relative Hazard Index 786
9. ROLES AND RESPONSIBILITIES 789
a. NIST Director and Associate Directors: 790
(1) Concur or non-concur on approvals by OU Directors of hazard reviews of activities 792 elevated to the directorship level. 793
b. OU Directors: 795
(1) Ensure that written OU procedures are developed, maintained, and implemented to 797 ensure that the requirements of Sections 6a-j are met within their respective OUs. 798
c. Line Management: 800
(1) Take the training provided by OSHE on the Hazard Review program; 802
(2) Ensure that hazard reviews are conducted for all new activities; 804
(3) Involve employees in the conduct of hazard reviews as appropriate; 806
(4) Ensure that hazard reviews are conducted by individuals who collectively have taken the 808 training provided by OSHE on the Hazard Review program and on all NIST OSH 809 programs pertinent to the activity under review; 810
(5) Approve hazard reviews in accordance with the requirements of Section 6d, with the 812 approval signifying that the RHIs associated with the activity represent an acceptable 813 level of risk; 814
(6) Authorize activities in accordance with the requirements of Section 6e, with the 816 authorization signifying that controls other than training have been verified to have been 817
NIST S 7101.20 (Uncontrolled Copy in Print) Page 23 implemented and that required safety equipment shall be maintained in proper working 818 order in accordance with manufacturers’ specifications and all applicable standards; 819
(7) Authorize workers in accordance with the requirements of Section 6f, with the 821 authorization signifying that (a) the workers have taken the training provided by OSHE 822 on all NIST OSH programs pertinent to the activity to be conducted and the training 823 identified in Sections 6b(6)(l) and 6b(7)(d), (b) line management has an appropriate 824 degree of confidence, based on personal knowledge, observation, or reliable input from 825 others, that the workers to be authorized have the knowledge, skills, and abilities to 826 perform the work safely and correctly, and (c) the workers fully understand the…
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