DOE EFCOG Laser Safety Task Group Benchmark Study of ANSI Z136.1 (2014) Controls Requirements 12 th DOE Laser Safety Officer Workshop May 8, 2018 Tekla A. Staley, CIH, CSP, CLSO INL LSO
Purpose Working Group commissioned by EFCOG LSTG Mike Woods (SLAC) Chair Joanna Casson (LANL) Tedi Criscuolo (PNNL) Jamie King (LLNL) Igor Makasyuk (SLAC) Mathew Quinn (FNAL) Jamie Santucci (FNAL) Tekla Staley (INL) Harmonization of best laser safety policies and practices across the DOE Complex Follow-up benchmark controls requirements of ANSI Z136.1, 2014 Motivation A lack of specificity for certain controls requirements A lack of clarity for certain controls requirements Changes in controls requirements between the 2000, 2007, and 2014 versions.
Basis for Report Definitions, requirements, rationale for requirements and explanation of deviations. Assumes a DOE Facility with a laser program as follows: Multiple Class 3B or Class 4 LCAs, and multiple Class 3B or Class 4 lasers in the LCAs. A typical laser lab has: A contained indoor LCA (enclosed within a room) A single entrance A safety interlock system with an access control panel at the entrance All laser located within the LCA
Topics of Focus Laser Supervisors Laser Workers Approval Requirements Annual Inspections/Audits by LSO Risk Assessment* Enclosures Unsupervised and Unattended Operations Alternate Controls Alignment Procedures Fiber Lasers and High Power/High Pulse Energy Lasers* *Included in survey questions not policy requirements. Policy requirements may be addressed at a later date. Topics were selected by the LSTG study group.
Approach Definitions Where available/applicable ANSI definitions were used. Many definitions provided in the report are not included in ANSI Z136.1 A limited few were modified for clarity. In cases where requirements are flexible for Class 3B lasers, the LSTG group chose to list all requirements as mandatory, using the word shall for both Class 3B and Class 4 lasers. This report is NOT an attempt to set policy. Policy requirements are the responsibility of each GOCO facility and their respective DOE oversight group. Rationale statements reflect the LSTG study group consensus regarding policy statements. A follow-up survey was conducted to determine agreement with the controls requirement statements.
Data Out of the twenty (20) possible LSTG member laboratories, 17 responses were received from 16 laboratories. In general, there was at least an 80% agreement with the recommended policy requirement statements. No controls requirements had unanimous agreement from all 16 laboratories. 2 controls requirements had 15 laboratories agreeing and 1 disagreeing*. 8 controls requirements had 14 laboratories agreeing and 2 disagreeing*. 4 controls requirements had 13 laboratories agreeing and 3 disagreeing*. 2 controls requirements had 12 laboratories agreeing and 3 disagreeing*. * Many dissenting answers reflected concern with adding requirements, where flexibility would otherwise be permitted, without the opportunity of a cost-benefit analysis.
Demographics Laser Use by Environment Research Laser Labs (with associated Principle Investigators or Program Managers) 94.44% User Facility (provided for non-employee research and investigations) 55.56% Industrial Lasers (primarily operated as a Class 1 laser system) 33.33% All Laser Types in Use Fiber Lasers in Use Pulsed Lasers in Use 12 14 10 12 8 6 4 2 0 All Lasers >100 W >1 kw >10 kw Unknown >100 W >1 kw >10 kw Unknown 10 8 12 6 8 4 2 5 2 0 >1 J >10 J >100 J Unknown
Laser Supervisors SHALL: Be assigned by their line management. Have the authority to carry out the responsibilities of the job. Rationale: No one size fits all; management must have authority. Deviations: Assignment and authorization are not addressed. Ensure work is carried out in a safe and compliant manner. Rationale: Supervisors must ensure safe laser operations. Deviations: Minimal responsibilities in A3.1 are listed as should. Work planning is not addressed. Complete NTC ESH-518, DOE Laser Worker Training or equivalent. Rationale: Supervisors must have adequate knowledge about the lasers, hazards and controls. Deviations: Laser supervisor training is not specifically addressed.
Laser Supervisors (cont.) SHOULD: Complete training required of laser workers. Complete laser beam alignment training. Be competent commensurate with responsibilities. Rationale: Deviations: Supervisors should receive training commensurate with level of hands-on involvement. Laser supervisor training is not specifically addressed. The 2005 DOE Special Operations Report: Laser Safety requires laser training for laser supervisors. Survey Information Laser supervisors may be assigned to oversee laser activities most commonly by LCA, laser or project and in some cases by building, department or laser system. Laser supervisors are typically assigned by line management and approved by either/both line management or LSO. Laser supervisors generally receive the same training as laser workers, and may be required to take additional laser supervisor training.
Laser Workers SHALL: Require approval from their supervisor. Receive documented approval. Rationale: Workers must have documented approval for clarity of direction. Deviations: Approval or its documentation is not described. Not operate a laser unless authorized to do so. Comply with all safety rules and procedures applicable to the laser system/facility. Immediately report all laser accidents/injuries or near misses. Rationale: Workers must have appropriate authorization, follow established safety requirements and promptly report all incidents/accidents to aid in the prevention of future incidents. Deviations: None
Laser Workers (cont.) SHALL: Complete training (OJT/hands-on/proficiency testing/alignment/nbh). SHOULD: Have all training documented. Rationale: a. NTC ESH-518, DOE Laser Worker Training, was developed to address all of the training requirements set forth in Z136.1-2014. This course also states that laser users shall receive site- or task-specific training or orientation. b. The 2005 DOE Special Operations Report: Laser Safety requires hands-on training for performing alignments and a formal documented OJT process. Deviations: Requirements are not specified for OJT, hands-on or alignment training. NOTE: It is recommended in Z136.8 (required in upcoming revision of Z136.8 for personnel exposed above Class 3R MPE).
Laser Workers (cont.) Survey Information In 2/3 rds of cases reported, laser workers may not be authorized to use all lasers within an LCA. Laser worker authorization comes mainly from either the laser or administrative supervisor, in some cases from the LSO or some other authority and that authorization is documented in nearly all cases. The scope of laser worker authorization varies from specific lasers systems to facilities with multiple lasers, and, in limited cases, may be sitewide. Generally, laser workers would not operate a laser without authorization. At most facilities, OJT is required and documented. Various types of NBH training is required, such as for electrical, fire and compressed gas hazards. Hands-on and alignment training tends to be experience level specific, as well as laser-specific, is informal and is typically documented. Formal alignment training is less common.
Approval Requirements SOPs, lasers or LCA operations SHALL: Be approved by an LSO, safety representative (NBH) and supervisor. Be approved for a specified time period. Rationale: To ensure SOPs are in place and accurate, hazards have been identified and controlled, and LCAs/facilities are established for safe laser operation. Deviations: Only requires LSO approval. Laser Workers SHALL: Receive approval from a supervisor for each laser/system/lca. Complete the required training. Rationale: Ensures laser workers have completed training and received approval to work on various systems. Deviations: Supervisory approval is not addressed; the LSO ensures adequate training. Survey Information SOP, work control, laser and/or LCA operations approval is generally obtained from a manager/supervisor, safety (NBH) and an LSO but may also be needed from others, such as security, occupancy space managers, the training department or a Readiness Review panel.
Annual Inspections/Audits by LSO SHALL: Review SOP/work control Verify interlock functionality Review the list of authorized users and verify training is current Ensure laser operations are accurately described in the SOP/work control Ensure LCA entryway postings are accurate Inspect LEP Ensure barriers/beam containment is adequate Ensure housekeeping is adequate Review/status open action items from previous inspection Rationale: This list was determined to be the most important inspection requirements manageable within demanding schedules and LSO job scopes. Deviations: LSO is only required to perform periodic inspections for the presence/functionality of control measures for each Class 3B (4) laser and periodically inspect LEP/ protective equipment.
Annual Inspections/Audits by LSO (cont.) Survey Information The following represents the level of agreement from all responding laboratories that the items listed are included in the annual inspection: Unanimous agreement to verify that eyewear & eyewear storage location and LCA posting requirements are met. >90% agreement that requirements for lasers in use, barriers/beam containment and other laser safety documentation are met. >80% agreement that SOPs are adequate, NBH are adequately controlled, the list of authorized laser workers is accurate and training is current, interlock functionality is verified, lasers/optics are properly secured, housekeeping is adequate, and new comments/controls are implemented. >70% agreement to status action items from last inspection. >60% agreement that operational requirements for UV laser are met. >50% agreement that beam diagnostics are adequate.
Enclosures An equipment label, providing hazard information for the output laser beam SHALL: Be affixed to a conspicuous place on the PH. Be placed on the control panel, if it is separated from the housing by more than 2 meters. Rationale: Readily accessible laser hazard information is needed. Deviations: None. A warning label identifying the highest class of laser radiation contained within the enclosure SHALL: Be affixed to each removable cover. Include Class 3B (4) Laser Radiation When Open for non-defeatable interlocks. Include Class 3B (4) Laser Radiation When Open and Interlocks Defeated for defeatable interlocks. Rationale: Extends requirements for service access panels to all removable covers on PHs and Class 1 enclosures, adapted from IEC 60825-1. Deviations: Currently only required on service access panels.
Enclosures (cont.) A warning label identifying the highest class of laser radiation contained within the fiber SHALL: Be affixed to each removable fiber connector. Include Hazardous Laser Radiation May Be Accessible When Disconnected. Rationale: Includes additional laser classification information on removable fiber connectors. Deviations: Laser classification information is not required on removable fiber connectors. On long-distance beam conduits and fiber transport, a warning label SHALL: Be placed approximately every 3 meters. Include WARNING or DANGER signal word and Class 3B (4) Laser Radiation Enclosed. Rationale: Readily accessible laser hazard information is needed. Deviations: None.
Enclosures (cont.) Removable covers for PHs, Class 1 enclosures, and beam conduits, if used as part of a Class 1 enclosure, SHALL: Be provided with failsafe/redundant interlocks, if covers may be removed during normal operation. Be interlocked or require a tool to remove, if covers are only removed during service tasks. Prevent replacement with the interlock defeated, if defeatable interlocks are used. Have a warning label identifying when defeatable interlocks are used. Rationale: Extends the requirements for PHs to all Class 1 enclosures and beam conduits associated with Class 1 enclosures. Deviations: Currently only applicable to PHs. NOTE: Z136.8-2012 considers the need for a tool to secure removable covers as equivalent to an interlock.
Enclosures (cont.) Removable connectors for fiber transport cables SHALL: Have the Class 3B (4) laser source blocked/disabled prior to disconnecting the fiber. 1) be interlocked so the laser source is disabled when in the disconnected state, or 2) require a tool to disconnect the cable, unless the connector is within a secured/interlocked enclosure. Rationale: Deviations: Ensure laser sources are blocked/disabled when connecting/disconnecting fibers. Does not describe blocking the laser source when connecting a fiber or using interlocks as an alternative to securing a fiber connector. Exclusion LCAs and walk-in PHs SHALL: Have fail-safe/redundant access control interlocks which disable Class 3B (4) upon entry. Use an LCA warning device which indicates a NO ACCESS condition. Rationale: This emphasizes engineering controls and recognizes functional similarities between PHs, Class 1 enclosures, beam conduits, fiber transport cables and exclusion LCAs and the need for similar requirements. Deviations: Describes requirements for walk-in PHs, not exclusion LCAs or Class 1 enclosures. NOTE: Z136.8-2012 describes exclusion location (occupancy is possible but denied by the LSO during laser operation), yet no engineering control requirements are provided.
Enclosures (cont.) Survey Information Nearly all responding laboratories (>86%) have incorporated policy requirements for equipment labels and removable enclosure covers. 2/3rds of the responding laboratories have incorporated policy requirements for removable fiber connectors. Remaining laboratories will either follow Z136.1 as stated or will incorporated those requirements in a future program revision. Slightly more than half (53%) of responding laboratories have incorporated policy requirements for exclusion LCAs and/or walk-in PH. Remaining laboratories had one or the other or neither of these situations and would either follow Z136.1 as stated or will incorporated those requirements in a future program revision.
Unattended/Unsupervised Operation Unattended use of Class 3B/4 lasers (systems) SHALL require: The laser supervisor to ensure control measures are adequate and access is restricted. Class 4 LCA entryways to be interlocked, disabling accessible Class 3B and Class 4 laser beams in the event of an unauthorized entry. Unattended use of Class 3B (4) lasers (systems) SHOULD require: Entryways to be locked with restricted access. Class 3B LCA entryways to be interlocked, disabling accessible Class 3B laser beams in the event of an unauthorized entry. Rationale: Only Class 1 lasers are exempt; laser supervisors need to be assigned with authority to approve use only when an LCA and engineering controls are established. Deviations: Responsibility is assigned to the LSO and provides some direction in the standard. Entryway/access controls are not emphasized, nor are controls hierarchy. NOTE: Z136.8-2012 states interlocked entryway should be required for Class 3B (4).
Unattended/Unsupervised Operation (cont.) Unsupervised laser operations SHALL not be permitted (except by manufacturer or Class 1 lasers). Rationale: For the purposes of this study, this is defined to be operation of a Class 3B (4) laser without authorization from a laser supervisor. Deviations: Unsupervised laser operation is permitted but is defines it differently (occurring when no supervising operator maintains visual surveillance of the entire LCA). Survey Information 2/3rds of responding laboratories (>67%) have incorporated policy requirements for unattended and/or unsupervised laser operations.
Alternate Controls Alternate controls may be used to replace control requirements and SHALL: Provide equivalent protection. Be reviewed and approved by the LSO. Be included in training. Rationale: Alternate controls may be appropriate depending on the laser use environment and for a graded approach to controls requirements commensurate with the associated risk. Deviations: LSO is required to recommend or approve alternate controls; this is not a required training element. NOTE: Z136.8-2012 does not require alternate controls to provide equivalent protection. Survey Information 2/3rds of responding laboratories (>67%) have incorporated policy requirements for alternate controls.
Alignment Procedures SOPs SHALL address: Alignment actions that change the wavelength hazard or eyewear requirement. SOPs, training or other instructional methods SHALL address: LEP for accessible Class 3B (4) beams. The availability of good viewing diagnostics. The use of beam blocks. The use of barrier or irises to prevent or block stray beams and the need to check for stray beams at each step in the alignment procedure and prior to high beam operation. Performing safety inspections to ensure proper beam containment and safeguards are in place after alignment. That peeking over/under LEP is not allowed. Avoiding the need to view at beam level.
Alignment Procedures (cont.) SOPs, training or other effective methods SHOULD address: Exclusion of unnecessary personnel during alignment. Using low power alignment lasers. Attenuating high power laser beams to the lowest power practicable. Placing beam blocks/barriers behind optics to terminate beams during alignment. Terminating beams down range of optics being aligned and prior to high power operation. The use of appropriate warning signs/displays during alignment/maintenance activities. Reducing unwanted reflections. Good housekeeping practices that remove unnecessary tools, components or combustibles. Training documentation requirements. Rationale: SOPs need to describe situations that create different wavelength hazards and required changes in control measures, PPE and LEP. Shall requirements are needed to ensure safe alignment practices. Deviations: SOPs must outline alignment methods not more detailed guidance. The guidance in 4.4.3.8 describes actions that should be taken but does not elevate them to shall.
Alignment Procedures (cont.) Survey Information All responding laboratories agreed that LEP requirements for accessible Class 3B/4 laser beams must be addressed in an SOP, and would include this either in general training, OJT or by other means. Better than 50% of responding laboratories agreed that alignment actions which changed hazards or LEP requirements, use of beam blocks and signs must be addressed in the SOP. More than 50% of responding laboratories agreed that SOPs should address using the lowest power possible during alignments. Greater than 50% of responding laboratories agreed that LEP and the use of beam blocks should be addressed in general training. The following list of requirements should be addressed in some manner; however, there was no clear agreement as to how or in what context they should be addressed: Excluding unnecessary personnel Using low power alignment lasers Using good viewing diagnostics Down-range beam termination Blocking stray beams Reducing reflections Peeking above/below LEP Not viewing at beam level Housekeeping Post alignment inspection for beam containment and safeguards Documenting alignment training
Risk Assessment Survey Information Nearly all responding laboratories (>93%) have a risk assessment policy in place. All of those responding laboratories with a risk assessment policy are using an established risk matrix or some other criteria for risk identification and acceptance. Only 1/3 rd of responding laboratories reference a risk assessment policy in the laser safety program. Fewer yet (13%) formally discuss risk assessment, require a risk assessment, or define when a risk assessment would be required for laser operations.
Summary Great participation in the study and survey. Good agreement with the study topics. Improvements are needed in regards to: Formal alignment training Risk assessment practices Exclusion LCA/walk-in protective housing requirements This is a living document we will continue to benchmark additional topics. Full report is published at the EFCOG LSTG website: http://efcog.org/safety/worker-safety-healthsubgroup/laser-safety-taskgroup/?drawer=laser%20safety%20task%20group* Reports