The Laser-Safety Management Program

INTRODUCTION

The laser-safety management program as presented here is a tool that is designed to demonstrate the current status of one's laser safety and to act as a plan for where you need to be and how you are going to get there. While the format presented here is paper based, there is no reason why all the documents should not be stored electronically. However, most people seem to find the paper version easier to use. In an electronic version certain sections could be linked and updated from larger databases such as a training database. In this way as a user completes a course, it would be entered into the program's training matrix.

___2 BENEFITS OF THE LASER-SAFETY MANAGEMENT PROGRAM

When there are many other things you have to do at work, it’s reasonable to question why you have to put more effort into something that could be seen as even more bureaucracy. The approach presented in this section is based on over a decade's experience of helping organizations identify their laser safety issues, manage those issues, and prove that they have done so.

Whom are you preparing the program for? Primarily your own organization, but there are different groups of people within the organization who could benefit from a clear statement of your laser safety system, what you are trying to achieve, and how you intend to get there. These include the following:

1. Senior management

2. Safety office

3. Laser management

4. Laser users

The laser-safety management program also has benefits because of the presentation to people external to the organization. These include enforcement officers, but perhaps more importantly, anyone wishing to fund your work. You may also find that the program fits in well with any quality-control system your organization uses.

Perhaps the biggest test for laser-safety management programs has been their implementation in research and university environments, where any form of administrative load is seen to get in the way of valuable research time, particularly for postgraduate students working for their doctorates in a fixed time. However, we have been able to demonstrate that the program is just an extension of good project management. The students can take ownership of their laser-safety management program. Pressure from supervisors can be used to ensure that students thought through the work they wanted to do - mainly practically, but with safety issues included. As the students came to write their theses, they found that they had a section on safety management. Think of the impact this has on assessors from industry. It’s not unusual to employ a new doctorate to find that he or she has had no safety training and essentially has an extremely poor safety ethic. The students who had used the laser-safety management program were able to demonstrate that they were, at the minimum, safety aware and recognized the positive benefits of this approach.

___3 FILE STRUCTURE

The approach we have generally used is to use a ring binder file with 13 sections.

Consider the binder as a central point for laser safety documentation. With use it may be found that your laser application needs more or fewer than 13 sections, and they may not have the same titles as those suggested here.

We need to decide on the level of the laser-safety management program.

At the highest level, we could produce a program for the whole organization.

The advantage of this is that a standard could be set across the organization.

We could have a program for the site, department, section, laboratory, or individual laser application. As we get closer to the laser application itself, more detail is likely to be included. We also need to exercise some caution. If we have a laser-safety management program for each laser application, and there are a number of applications in the laboratory, they cannot be treated in isolation.

___4 INSTITUTIONAL BINDER SECTIONS

1. Safety structure

2. Safety committee

3. Standards and regulatory

4. Training program

5. Audits and reports

6. Risk assessments

7. Control measures

8. Incident investigation

9. External liaison

10. Miscellaneous

We suggest starting with the following 13 sections for user binders:

1. Standard operating procedure

2. Training and authorized worker list

3. Interlock checks

4. Alignment procedures

5. Audits and reports

6. Material safety data sheets and URLs

7. Checklists

8. Engineering safety notes

9. Contact list

10. ES&H sections

11. Lessons learned

12. Emergency procedures

13. Miscellaneous

The following sections are optional:

14. Safety structure

15. Specific procedures

16. Safety committee minutes

17. Standards and regulatory items

18. Risk assessments

Some of the sections remain fairly static throughout the life cycle of the laser application; others will need to be updated regularly. Therefore, it’s important that the file represents the current status of laser safety. It could be audited by external organizations, including regulatory officers. The impression they get of your organization could be colored by what they find in the file. Much of real life inspections hinges on perception. Some sections of the binder are for reference and therefore for appearance. A well-kept program binder provides a good impression of laser and safety awareness and concern.

A benefit that comes with time is that the regulatory officers begin to recognize the format of the laser-safety management program files. Even the existence of the file produces a positive impression.

The following presents guidance on what to include in each section. The actual contents will depend on your development of the laser-safety management program and are likely to change with time as you find out what works best for you.

___4.1 STANDARD OPERATION PROCEDURES

The first section of the binder provides an opportunity to describe the laser application, hazards, and control measures. What makes a good standard operating procedure (SOP) is covered in Section 4. The level of detail will depend on the level of the laser-safety management program: corporate, application, or somewhere in between.

___4.2 TRAINING AND AUTHORIZED WORKER LIST

This section should contain a list of all training courses required by this SOP.

The courses can be listed in a spreadsheet matrix. All staff working under the SOP are required to sign the matrix. This shows they have read the SOP and have completed the training requirements. The principal investigator (PI) may add or delete names and course requirements for individuals as needed. This is a simple way for the responsible individual to keep track of training and demonstrate that all staff have read the SOP.

___4.3 INTERLOCK CHECKS

The laser use area may require access controls such as door interlocks. There may also be other safety devices that require periodic inspection or verification of operation. This section of the binder is the place for documentation related to such inspections to be kept. More than just the log showing a history of dates needs to be recorded; so do any procedures that need to be followed to perform the inspection. A copy of the periodic (set within the SOP) interlock checklist is found here. Make entries on this form and continue on the same page until the form is filled (see example at end of section).

___4.4 ALIGNMENT PROCEDURES

When one considers that over 60% of laser accidents that occur in the research setting occur during the alignment process, it’s easy to see why a section in this binder should be dedicated to alignment. In this section either generic alignment guidance (see example in Section 4) or specific alignment procedures for the laser operation should be found. While specifics are desired, the general alignment is adequate (if followed).

___4.5 AUDITS AND SELF-ASSESSMENT REPORTS

The auditing of the laser use area is critical to good laser safety and is a required task of the LSO or designee. This section contains a copy of such audits. If management or users perform any self-assessments or other audits, those records should be here (this does not include regulatory inspections). Program management or self-inspection should be encouraged. Specific status or required corrective actions may be found here. Auditing is a very powerful tool to demonstrate that you are doing what you say you are doing. This section should include some kind of audit plan. You may decide to dedicate a specific time to audit the complete laser-safety management program or you may break the audit down into a number of smaller tasks that are carried out on a regular basis throughout the year.

There will be results from the audits. They may indicate that everything is still completely up to date and the operational use of the laser-safety management program correlates with what actually happens. If so, this is still a valuable result that needs to be recorded. If there are non-compliances or something needs to be improved, then this needs to be recorded and an action plan developed.

The frequency of auditing specific aspects of the laser-safety management program will depend on the risk if a given part of the program fails. For example, a safety-critical control measure may need to be audited frequently - some even each time the laser is used.

Should you be visited by an enforcement officer who is assessing your laser safety, then this part of the file can be extremely useful. If, For example, you have an interlocked enclosure and someone manages to get exposed to the laser beam because the interlock did not work, can you demonstrate that the interlock had only recently failed? If the interlock checks were part of a weekly safety audit, then you may be able to demonstrate that it was working at the last check. This will generally only convince the enforcing officer if there is a written record of the test, signed and dated. If you have not been carrying out the safety audit, then it’s possible that the interlock failed shortly after installation.

___4.6 MATERIAL SAFETY DATA SHEETS AND URL--Material safety data sheets (MSDSs) are for chemicals. The most current MSDSs are accessible on the Web, and it’s recommended that a Web address be listed here. For some research labs, it would be easy to fill a binder just with MSDSs.

Workers may wish to keep hard copies here for particular chemicals used under this SOP.

___4.7 CHECKLISTS

This section is available for additional checklists that maybe needed under the SOP.

___4.8 ENGINEERING SAFETY NOTES If specialized equipment such as vacuum vessels is used for the project, this section allows one to keep a copy or reference where any engineering or safety documentation exists to verify the manufacturer of the equipment.

___4.9 CONTACT LIST

This section contains useful contacts for various EH&S concerns. It should be updated annually or the information may not be accurate, for instance, if safety personnel change. The PI may add extra names applicable to the SOP or facility.

Names and contact details should be included for everyone involved in laser safety, appropriate to the level of the laser-safety management program.

___4.10 ES&H SECTIONS

Most institutions have a health and safety manual. Such a manual lists the hazards and requirements for working with such. Examples would be lasers, electrical systems, toxic gas, and radioactive materials. This section contains hard copies of the most relevant sections of the health and safety manual. One could only list Web address, but having a hard copy for staff to reference generally makes it more likely to be used.

___4.11 LESSONS LEARNED

This section contains information and possibly copies of lessons learned applicable to this SOP activity. Because lessons learned is a strong laser safety reinforcement tool, providing lessons learned for users can only help the laser safety program.

___4.12 EMERGENCY PROCEDURES

This section contains general institution emergency response information. In addition, the PI may add SOP-specific emergency instruction and his or her own emergency response contacts here.

___4.13 MISCELLANEOUS

There will invariably be things that don’t belong in any of the other sections.

They could be filed in this section. However, as part of the audit of the file, it may be obvious that some of the items that have accumulated in this section could form a new part of the file. If one of the other sections is not being used, then you could move the information from here to there.

___4.14 OPTIONAL ADDITIONS

___4.14.1 Safety Structure

The safety structure for the organization may be a published document or organizational chart. Therefore, that document could be inserted in this part of the binder or there could be a reference to it. However, more detail is required in this section.

___4.14.2 Specific Procedures

A number of procedures may be involved or related to the work in this laboratory and SOP. Procedures and instructions on how to perform them would be found in this section. In addition, a list of approved or authorized personnel to perform each procedure should be listed.

Many aspects of laser work require written procedures, written systems of work, local rules, or permits to work. In essence, safety rules and instructions may be needed. The detail will depend on the part of the life cycle that you are involved with. It’s suggested that the life cycle be drawn up for the laser application and the parts of the life cycle that need written procedures to be identified. Similar procedures may be required for more than one part of the life cycle and it may be possible to combine these.

If some parts of the cycle involve external organizations, such as service companies, then your procedures may include some sort of handover documentation, both at the start and finish of the work. The actual safety procedures for the intended work, which include how the equipment is confirmed to be back in the normal working condition, should be provided by the external organization.

___4.14.3 Safety Committee Minutes

If a Laser Safety Committee or group meetings exist, safety minutes and issues would go into this section. It’s important that Laser Safety Committee minutes be taken and documentation include corrective actions, not just problems.

___4.14.4 Standards and Regulatory items

If any regulatory activity for the operation is described in the SOP, that documentation would be found here.

___4.14.5 Control Measures

This section of the file is used to state what control measures are in place and, just as importantly, the rationale behind the control measures. For example, in our experience, some establishments have laser safety goggles that were purchased years ago and no one can remember why a particular pair of goggles was bought. The stated optical density bears no relation to what appears to be necessary. Were the goggles the only pair available and been passed for user to user, or did the originator know something that has been forgotten in the mist of time?

___5 INSTITUTIONAL BINDERS

In the preceding sections we discussed a laser-safety program binder and safety binder for the individual SOP. It may be to the institution's advantage to also keep an organizational binder. The LSO would be the logical person to maintain and hold such a document. That binder should contain the following sections:

1. Safety structure

2. Safety committee

3. Standards and regulations

4. Training program

5. Audits and reports

6. Risk assessments

7. Control measures

8. Incident investigation

9. External liaison

10. Miscellaneous

___5.1 SAFETY STRUCTURE

The safety structure for the organization may be a published document or organizational chart. Therefore, either that document could be inserted in this part of the binder or there could be a reference to it. However, more detail is required in this section.

___5.2 SAFETY COMMITTEE

In larger organizations, or organizations with a large number of lasers, it may be beneficial to have a laser safety committee. This allows laser safety staff to share experiences and keep up to date with changes to laser safety standards or regulations.

It’s surprising how often laser safety is treated in complete isolation from the general safety system of an organization. This should not happen. As a minimum, the LSO, or whoever has overall responsibility for laser safety, should have a route to the general safety committee. Depending on the hazards associated with the laser application many general safety issues could be relevant. This section of the file can be used to outline the committee structures, record minutes of meetings (or have a pointer to their location), and provide a record of required actions.

___5.3 STANDARDS AND REGULATIONS

A growing number of standards and legal documents affect our work with lasers.

This section of the file is a reference section in which to record the appropriate standards, regulations, and guidance for your particular laser application. It could be used to pull out sections of those documents that are particularly relevant to you. There may be some cross-referencing to other parts of the laser-safety management program file. This section of the file could be used to store the actual documents; it’s more usual to list references to the location of the documents.

___5.4 TRAINING

This section should contain a list of all required training courses related to laser work, in particular, the course outline of the basic laser safety course and any medical surveillance requirements and polices.

___5.5 AUDIT PROCEDURE AND RECORDS

Auditing is a very powerful tool to demonstrate that you are doing what you say you are doing. This section should include some kind of audit plan. You may decide to dedicate a specific time to audit the complete laser-safety management program, or you may break the audit down into a number of smaller tasks that are carried out on a regular basis throughout the year.

___5.6 RISK ASSESSMENTS

The risk assessments should form the basis for laser-safety management. This section of the file should either contain the actual risk assessments or references to their locations. More importantly, there should be an action plan. This is a document that takes the conclusions from the risk assessments and, where actions are required, logs them, complete with who is responsible and when the actions need to be completed. This can be thought of as identifying the current finish line for our road to successful laser-safety management and the map of how to get there.

___5.7 CONTROL MEASURES

The risk assessment will take into account the control measures that are in place.

Here the institution would list its generic control measures for an area using class 3B or class 4 lasers. The risk assessment may identify additional control measures that need to be implemented.

Interlocks, and interlock override systems, are used in many research facilities. When questioned about the reason for the choice of a particular way of working, sometimes no one can remember. The person who made the decision may have left long ago. This section of the file attempts to overcome this problem by requiring a clear statement of control measure policy and how it’s implemented.

___5.8 INCIDENT INVESTIGATION

All laser incidents should be investigated, and that policy and protocol should be listed here. You may wish to point to where such records might be kept or you can keep them in this section. Should you be visited by a regulatory officer who is assessing your laser safety, then this part of the file can be extremely useful.

If, For example, you have an interlocked enclosure and someone manages to get exposed to the laser beam because the interlock did not work, can you demonstrate that the interlock had only recently failed? If the interlock checks were part of a weekly safety audit, then you may be able to demonstrate that it was working at the last check. This will generally only convince the enforcing officer if there is a written record of the test, signed and dated. If you have not been carrying out the safety audit, then for all you know, the interlock may have failed shortly after installation. This section is also a good location for lessons learned.

___5.8.1 Lessons Learned

Lessons learned are a valuable tool for laser safety. This section would be a copy of any lessons learned that the LSO or institution has distributed to laser users.

___5.9 EXTERNAL LIAISON

This section of the file is a bit like a directory of people and organizations you deal with in relation to the use of the laser. It may include details of suppliers of laser products, the manufacturer if other than the supplier, the suppliers of control measures, and perhaps details of contacts within enforcement authorities and standards bodies.

___5.10 MISCELLANEOUS

Invariably, some items won’t fit into one of the other nine sections. These could be filed here. However, as part of the audit of the file, it may be obvious that some of the items that have accumulated in this section could form a new part of the file. If one of the other sections is not being used, then you could move the information from here to there. Alternatively, you may need to move to a 12 or even a 20-section file.

Repeating this program management binder is essential to laser safety. It acts as the core element to users and regulatory bodies.

___6 SAMPLE FORMS

1. SOP: Section 4

2. Training matrix: Section 7

3. Interlock log: this section

4. Alignment guidance: Section 3

5. New user safety checklist: this section

___6.1 SAMPLE SAFETY CHECK LIST

This checklist must be completed during the first week of employment. The purpose is to ensure that the new staff member or student is aware of the proper use and location of safety items and what actions to take in case of an emergency. Once complete, place the form in the laser management binder.

YES | NA

1. Been instructed to read SOP (any work authorizations) [ ] [ ]

2. Orientation to hazards found in work area [ ] [ ]

3. Location of nearest fire extinguisher [ ] [ ]

4. Location of phone & emergency phone number [ ] [ ]

5. Given handling & waste disposal instructions [ ] [ ]

a. Radioactive [ ] [ ]

b. Chemical [ ] [ ]

c. Instructed on chemical/solvent storage [ ] [ ]

7. Shown building emergency assembly point [ ] [ ]

8. Location of eyewash stand [ ] [ ]

9. Explanation of what eyewear to use and when [ ] [ ]

a. Laser eyewear per wavelength(s) in use [ ] [ ]

b. Safety glasses [ ] [ ]

c. Face shield [ ] [ ]

10. Location of protective eyewear [ ] [ ]

11. Explanation of interlock system (if applicable) [ ] [ ] Signature of employee Print Name Signature of PI (or designee) Date

Above: Fig. 1 Sample safety checklist.