Industrial Macromolecular Crystallography Association
Collaborative Access Team
Environmental, Safety, and Health Plan

February 1999


TABLE OF CONTENTS

ABBREVIATIONS AND DEFINITIONS

  1. INTRODUCTION
    1. Safety Program Overview
    2. General Policies
    3. Organization of Document
  2. PROGRAM ADMINISTRATION
    1. Organizational Structure and Responsibilities
    2. Hazard Evaluations
    3. Orientation and Training
    4. Compliance with Regulations
    5. APS Guidance Documents and Reviews
    6. Organizational Communications
    7. Employee Involvement
    8. Managing Configuration Changes
    9. Chemical Hygiene Plan
    10. Hazard Communication Program
    11. Program Evaluations
    12. Accidents and Incidents
  3. HAZARD EVALUATION AND CONTROL
    1. Chemical Hazards
    2. Electrical Hazards
    3. Ionizing Radiation
    4. Installation and Maintenance Activities
    5. Commissioning Activities
    6. Experiment Safety
    7. USER LOM Shop Operations
    8. Office Safety
  4. SAFETY GUIDANCE, PRACTICES, & PROCEDURES
    1. Listing of Assignments for Key IMCA-CAT Safety Personnel
    2. IMCA-CAT Guidelines for Hand Tool and Portable Power Tool Usage
    3. IMCA-CAT Guidelines for Personal Protective Equipment
    4. IMCA-CAT Guidelines for Work Area Demarcation, Warnings, and Controls
    5. IMCA-CAT Guidelines for Electrical Safety Work Practices
    6. IMCA-CAT Guidelines for the Management of Chemicals
    7. IMCA-CAT Guidelines for Transport of Small Quantities of Chemicals
    8. IMCA-CAT Guideline for the Management of Hazardous Waste
    9. IMCA-CAT Guidelines for the Management of Sealed Radioactive Calibration Sources
    10. IMCA-CAT Guidelines for Hoisting and Rigging Operations
    11. IMCA-CAT Guidelines for the IMCA-CAT Sector Orientation
    12. IMCA-CAT Guidelines for LOM Laboratory Information Binders
    13. IMCA-CAT Guidelines for Inspections
    14. IMCA-CAT Guidelines for Accident Investigations
    15. IMCA-CAT Guidelines for Sample Handling




ABBREVIATIONS AND DEFINITIONS


ALARA As low as reasonably achievable
ANL Argonne National Laboratory
ANL ESH Manual The ANL-East Environment, Safety and Health Manual
APS Advanced Photon Source
ASME American Society of Mechanical Engineers
CAT Collaborative Access Team
CDC-NIH Centers for Disease Control and Prevention, National Institutes of Health
CFR Code of Federal Regulations
DOE U.S. Department of Energy
DOT U.S. Department of Transportation
EPA U.S. Environmental Protection Agency
ESH Argonne National Laboratory's Environment, Safety and Health Division
ESH-IH The Industrial Hygiene Section of Argonne National Laboratory's Environment, Safety and Health Division
ES&H Abbreviates `environment, safety and health'
HazCom Hazard Communication, particularly the OSHA Hazard Communication Standard, 29 CFR 1910.1200
HazMat Hazardous material
IMCA Industrial Macromolecular Crystallography Association
IMCA-CAT Industrial Macromolecular Crystallography Association Collaborative Access Team
LOM Laboratory/Office Module
MAD Multiple-wavelength Anomalous Dispersion
MSDS Material Safety Data Sheet: A synopsis of safety-related product information required under OSHA's HazCom rule
NFPA National Fire Protection Association
OSHA Occupational Safety and Health Administration, a bureau of the U. S. Department of Labor
PPE Personal protective equipment
RCRA Resource Conservation and Recovery Act, a law administered by the EPA and various states, including Illinois
SAA Satellite Accumulation Area
XFD The Experimental Facilities Division of the Advanced Photon Source
Principal Investigator Any IMCA-CAT member, Independent Investigator, or other IMCA-CAT-authorized individual who is designing, building, or performing an experiment at an IMCA-CAT beamline.
IMCA-CAT Personnel IMCA-CAT staff, employees of IMCA member companies, and all other individuals who work at IMCA-CAT's Facilities at the APS under IMCA-CAT auspices.
Visitor A person who has been invited by IMCA-CAT personnel to spend time at IMCA-CAT facilities, but who is not a Principal Investigator.





INTRODUCTION

    Safety Program Overview

    The member institutions of IMCA-CAT;

    wish to create and maintain a safe and ecologically sound research environment at the Advanced Photon Source (APS). However, IMCA as a consortium of competing pharmaceutical companies is required to maintain a certain level of confidentiality concerning the nature of the materials being analyzed by the member companies. Furthermore, the organization of IMCA-CAT, with a small staff of beamline specialists permanently stationed at the APS and a large user base of macromolecular x-ray crystallographers from the member companies, will be reflected in the way safety reporting relationships are structured. This document describes IMCA-CAT's policies for achieving these objectives by controlling hazards and reducing risks to acceptable levels. Specifically, IMCA and the IMCA-CAT will:

    To preserve the effectiveness of the engineered and procedural hazard controls IMCA-CAT provides, all individuals using IMCA-CAT's facilities will:

    IMCA-CAT reserves the right to suspend the activities or revoke the research privileges of any person within its purview who disregards or attempts to circumvent these requirements.

    General Policies

    IMCA-CAT shall give highest priority to protecting the health and safety of its members, other users of the APS, visitors, ANL personnel, and the general public, and shall take all reasonable measures to prevent accidental damage to property and the environment.

    It is IMCA-CAT's policy that no shielding or personnel safety system installed by the APS or included in an APS-approved configuration shall be modified, removed, or disabled and that no equipment, system, or apparatus shall be operated outside of its designed safety parameters without a formal review by the applicable XFD safety committees and the written approval of the XFD Associate Division Director for Operations.

    It is IMCA-CAT's policy that no person shall be inside an IMCA-CAT first optics enclosure or experiment station when all the doors to that enclosure/station are closed. Samples which require biological containment facilities greater than those found in a standard biochemistry laboratory will not be entertained at the IMCA-CAT facility. The only radioactive materials expected to be present in the IMCA-CAT facilities will be small quantities of unenriched uranium salts, organouranium compounds, and thorium compounds used as heavy-atom derivative reagents.

    IMCA-CAT will provide all IMCA-CAT personnel (i.e., IMCA-CAT members and all other individuals who work at IMCA-CAT's facilities at the APS under IMCA-CAT auspices) with an introductory safety orientation that will describe this safety program and stress the importance of complying with the environmental, safety, and health policies and practices described in this document and the ES&H documents of the respective IMCA-CAT member institutions, the XFD and ANL ESH Manuals, and the APS Conduct of Operations Manual. This plan is intended to supplement those documents; however, wherever policies or practices differ among the various documents, IMCA-CAT will observe the most protective requirements. IMCA-CAT expects its personnel to inform the IMCA-CAT Safety Coordinator of hazards not covered by any of the above-mentioned documents.

    IMCA-CAT expects that its members and guests will:

    Organization of Document

    The rest of this document has been divided into the following parts:





PROGRAM ADMINISTRATION

Organizational Structure and Responsibilities

    IMCA-CAT has identified and evaluated the hazards its personnel are likely to encounter during operations in its spaces at the APS. This analysis and the practices mandated by the APS have led to the following assignments of IMCA-CAT responsibilities.
    (Key personnel assignments are listed in Chapter 4 of this document.)

 

Hazard Evaluations


IMCA-CAT will take a graded approach in evaluating the hazards associated with all of the activities to be performed in the spaces it occupies. That is, evaluations will become more comprehensive as the likely severity of a mishap increases or the complexity of the process increases.

Orientation and Training


IMCA-CAT will require its personnel to complete the APS User Orientation provided by the APS and the complementary IMCA-CAT-administered Sector Orientation. (See IMCA-CAT Guidelines on the IMCA-CAT Sector Orientation.) IMCA-CAT and the APS will jointly establish additional training requirements for individuals as necessary.

Compliance with Regulations


IMCA-CAT will comply with all applicable regulations of:

APS Guidance Documents and Reviews


IMCA-CAT will adhere to all APS safety-related specifications for the design of IMCA-CAT's facilities and equipment--for example, those found in ANL/APS/TB-14, APS Beamline Design and Construction Requirements. The CAT will follow a graded approach in documenting its efforts to characterize hazards and select hazard controls. In accordance with APS design review procedures, IMCA-CAT will:

IMCA-CAT understands that the APS will continually issue and revise procedures relevant to IMCA-CAT's management of environmental, safety, and health concerns. IMCA-CAT will incorporate such procedures into its safety program as they become available.

Organizational Communications

Employee Involvement


IMCA-CAT encourages responsible input from its members and other users regarding safety concerns that have yet to be effectively addressed. IMCA CAT personnel at every level will be represented on the IMCA-CAT Safety Committee. Anyone who feels a safety concern has not been dealt with appropriately should inform the IMCA-CAT Director, IMCA-CAT Safety Coordinator, XFD ES&H Coordinator, or XFD Director.

Managing Configuration Changes


Before making any change that could affect the performance of an existing engineered hazard control, IMCA-CAT will review and approve the planned change. The purpose of this review is to determine whether additional engineered controls, procedures, training, or information needs to be provided. IMCA CAT will then record the changes and, as appropriate, post warnings to alert personnel who could be affected. Similar requirements apply to changes in the distribution of utilities (electricity, pipes, fluids, and ventilation), the installation of temporary experimental facilities and equipment, and the startup of previously unreviewed systems and activities that could introduce new hazards. Changes will be described in electronic mail messages from a CAT staff member to all affected CAT staff and to at least one representative from each of the IMCA member companies. IMCA-CAT will discuss these changes at staff meetings and will consult our own records in formulating such changes. It is IMCA-CAT's policy that no shielding or personnel safety system installed by the APS or included in an APS-approved configuration shall be modified, removed, or disabled and that no equipment, system, or apparatus shall be operated outside of its designed safety parameters without a formal review by the applicable XFD safety committees and the written approval of the XFD Associate Division Director for Operations.

Chemical Hygiene Plan


IMCA-CAT has developed a Chemical Hygiene Plan (see IMCA-CAT Guidelines for Laboratory Information Binders) to satisfy APS and OSHA requirements, in accordance with the guidelines established by Chapter 4-2 of the ANL ESH Manual. (A copy of Chapter 4-2 is available from the IMCA-CAT Safety Coordinator and is available on the World Wide Web.)

Hazard Communication Program


IMCA-CAT has woven elements of its hazard communication program throughout this ES&H plan. IMCA-CAT believes that these elements address all OSHA and APS requirements.

Program Evaluations

Accidents and Incidents


If an unplanned event occurs which has adverse or potentially adverse effects, IMCA-CAT will investigate it as described in the IMCA-CAT Guidelines for Accident Investigations, and will implement the corrective actions needed to ensure that similar accidents or incidents do not occur in the future. IMCA-CAT recognizes that the APS requires prompt notification of some types of incidents. The IMCA-CAT Manager will be responsible for this notification.




HAZARD EVALUATION AND CONTROL

    Chemical Hazards

    Electrical Hazards

    Ionizing Radiation

    Installation and Maintenance Activities

    The IMCA-CAT hazard evaluation and control effort with respect to installation and maintenance activities is based on the following concepts:

    Commissioning Activities

    IMCA-CAT will comply with all APS policies and procedures related to the preparation for and verification of beamline commissioning readiness. IMCA CAT has reviewed the APS document covering commissioning readiness (Advanced Photon Source Experimental Beamline Commissioning Readiness Process) and understands its own role in planning some commissioning activities. IMCA CAT believes that it will be able to effectively control anticipated commissioning hazards using the processes set forth in the APS document. If IMCA-CAT becomes aware of any hazard not covered by the APS plans, it will immediately inform the XFD Associate Director for Operations and the XFD ES&H Coordinator.

    Experiment Safety

    Most hazards associated with the preparation and conduct of IMCA-CAT experiments at the APS have been addressed under the topical hazard evaluations listed above. IMCA-CAT will follow the experiment safety review guidance issued by the APS to ensure that sufficient controls are in place before experimental work begins. No beamline experiment will begin until the Experimental Safety Approval Form (ESAF) has been signed by the responsible CAT staff member and the form has been posted by an APS Floor Coordinator in the locked cabinet provided for the purpose. Ordinarily the CAT Safety Coordinator and the CAT Director will evaluate ESAFs, but for routine crystallographic studies the CAT professional staff members responsible for user support will be permitted to evaluate the ESAFs. In general the staff should receive the ESAF at least four working days prior to the beginning of the experiment, to provide them with time to analyze the details of the experiment and, if necessary, seek help from outside sources in the evaluation. In the special case of experiments involving crystals pre-soaked in volatile heavy-atom reagents, the minimum evaluation time should be four weeks (see IMCA-CAT Guidelines for Sample Handling).

    User LOM Shop Operations

    Full details of the safety procedures associated with the use of the LOM Shop are found in the Building 435 LOM Shop Safety Plan, which has been submitted jointly by the four CATs in Building 435 and approved by the APS.

    Office Safety




SAFETY GUIDANCE, PRACTICES, & PROCEDURES

    Listing of Assignments for Key IMCA-CAT Safety Personnel


    Title Name Phone No. E-mail Address
    IMCA Chairman Bill Stallings 314-737-7236 wcstal@ccmail.monsanto.com
    Director / Manager Andy Howard 630-252-0534 ahoward@metis.imca.aps.anl.gov
    Safety Coordinator John Chrzas 630-252-0522 john@metis.imca.aps.anl.gov
    Administrator Virginia Brown 630-252-0520 vbrown@metis.imca.aps.anl.gov
    Chem. Safety Lisa Keefe 630-252-0544 lkeefe@anl.gov
    Biosafety Lisa Keefe 630-252-0544 lkeefe@anl.gov
    Electrical Safety Bill Lavender 630-252-0523 lavender@metis.imca.aps.anl.gov
    Safety
    Captains
    On-site IMCA Investigators
    Principal
    Investigators
    On-site IMCA Investigators
    Safety Technician (currently vacant)    
    CSRRI Director Tim Morrison 312-567-3381 morrison@iit.edu
    ES&H Committee
    Chair
    Brian McKeever 732-594-6157 mckeever@merck.com
    ES&H Committee
    Member
    J.Ronald Rubin 734-622-3298 rubinj@aa.wl.com
    Safety Committee William Stallings, Brian McKeever, Ron Rubin, Andy Howard, Dean Chapman



    IMCA-CAT Guidelines for Hand Tool and Portable Power Tool Usage

    TABLE 1. Power Tool Inspection/Testing Criteria and Inspection Frequency

    Inspection Frequency
    Criteria for Removing a Tool from Service Before and
    During Use
    Semi-Annual
    Testing and
    Inspection
    Cracking, chafing, wear, or other signs of
    faulty power cord insulation
    X X
    Evidence of faulty grounding conductor X X
    Excessive resistance between tool case
    and ground connector prong
    X
    Cracked plug or receptacle housing X X
    Bent or missing plug or connector prongs X X
    Dead front plug, receptacle, or connector X X
    Missing, bent, or otherwise abused switch X X
    Improperly functioning trigger lock on switch X X
    Out-of-date semi-annual inspection tape (tag) X X
    Signs of overheating or excessive sparking X X
    Insulation resistance
    (get meter from XFD ES&H Coordinator)
    X
    Dull, chipped, or broken blades X X
    Malfunctioning guards X X

    TABLE 2. Color Code Schedule for Portable Power Tools, Indicating Date of Most Recent Inspection and Test

    Months Year Tape Color
    January through June 1997 Black
    July through December 1997 Blue
    January through June 1998 Red
    July through December 1998 Green
    January through June 1999 Orange
    July through December 1999 White

    References
    The primary references for this set of guidelines are the 10th Edition of the National Safety Council's Accident Prevention Manual and the ANL ESH Manual.



    IMCA-CAT Guidelines for Personal Protective Equipment



    IMCA-CAT Guidelines for Work Area Demarcation, Warnings, and Controls



    IMCA-CAT Guidelines for Electrical Safety Work Practices



    IMCA-CAT Guidelines for The Management of Chemicals



    IMCA-CAT Guidelines for the Transport of Small Quantities of Chemicals



 

IMCA-CAT Guideline for the Management of Hazardous Waste



 

IMCA-CAT Guidelines for The Management of Sealed Radioactive Calibration Sources



 

IMCA-CAT Guidelines for Hoisting and Rigging Operations



 

IMCA-CAT Guidelines for the IMCA CAT Sector Orientation

Name (first, last) . . . . . . . . . . . . . . . . . . . . . . . . . User Number IMCA-CAT . . . . . . . . . . . . . Sector 17

SECTOR ORIENTATION RECORD

Safety policies and resources. Instructor: ______________ Date: _________

General safety information. Instructor: ______________ Date: _________

Beamline Safety Information. Instructor: ______________ Date: _________

Safety policies and resources:

General Safety Information

Beamline Safety Information:



IMCA-CAT Guidelines for LOM Laboratory Information Binders



IMCA-CAT Guidelines for Inspections



IMCA-CAT Guidelines for Accident Investigations

IMCA-CAT Guidelines for Sample Handling

  • References

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