DOE/OAK ES&H Policy Committee Comments
Date	Issue	Disposition*	Remarks	I D Dbase Ref
9/16/96	Aboveground Storage Tanks	W	Already addressed.	233
9/16/96	Repetitive motion	W	Internal standard to be developed.	188
9/16/96	Drinking water	P	Standards identified and ANSI added to implementation.	142
9/18/96	10 CFR 20 & CCR 17 not needed in set	P	Removed except specific sections.	164
9/18/96	ACGIH TLVs in set	P	Added for chemicals.	5
9/18/96	property protection from fire	W	Covered by environmental team, potential contamination control.	234
9/23/96	Accelerator Air Activation	W	Standards modified.	2
9/23/96	Accel. Release of Volume Activated Mat.	W	Standards modified.	183
10/7/96	Standard Revisions	N	Implementation issue.	260
10/7/96	Lack of ES&H management standards	N	Outside of WSS scope, implementation issue.	261
10/7/96	Future changes to standards	N	Implementation issue.	262
10/7/96	Document dissent	W	Convened Group included in charter as decision authority.	263
10/7/96	Validation and length of set	P	Length is greater, since no consolidation of many standards in a few DOE orders. Set is initially validated by the confirmation team.	264
*W = Wholly incorporated P = Partially incorporated N = Not incorporated

Berkeley Lab Safety Review Committee Comments
Date	Issue	Disposition*	Remarks	I D Dbase Ref
9/25/96	Removal of PUB-3000 from Worker Prot.	P	Removed except specific sections.	77
9/25/96	Is 6430.1A applic. to Bldg. & Fac. Safety?	W	Removed from set.	41
9/25/96	PUB-3000 Ch. 23 re seismic safety	W	Moved to Implementation.	201
9/25/96	ANSI for Rotating Equip.	W	Moved to Implementation.	192
9/25/96	Order 440.1 for fire	W	Moved to Implementation.	69
9/25/96	6430.1A for Industrial Hygiene	W	Moved to Implementation.	187
9/25/96	Health Hzd Gas re PUB-3000	P	Moved to Implementation.	90
9/25/96	Pyrophoric Gas re DOE Handbook	W	Moved to Implementation.	159
9/25/96	Remove DOE Pressure Safety Manual, PUB-3000 Ch. 7 ARI Stds, APIS 620, CGA V-7	P	Moved to Implementation, along with ASME standards.	156
9/25/96	Laser Systems - remove PUB-3000 and NFPA 115	W	Moved to Implementation.	108
9/25/96	Remove Lab procedure for calibrating instruments	W	Removed from set.	177
9/25/96	Fixed Sources - X-ray/ Gamma, remove PUB-3000 Ch. 21	P	Moved to Implementation for Irradiators.	161
*W = Wholly incorporated P = Partially incorporated N = Not incorporated

Confirmation Team Comments
Date	Issue	Disposition*	Remarks	I D Dbase Ref
9/25/96	Recombinant DNA guidelines needed	W	Added to set as external regulation.	17
9/25/96	Contract employee liability	W	Already addressed in set.	110
9/25/96	ANSI (or CAL OSHA draft) in repetitive motion std?	P	Internal standard to be developed.	186
9/25/96	10 CFR 21 defects in products	N	Not applicable to Berkeley Lab.	180
10/8/96	Facility Design-consider DOE O 420	W	Added to set.	61
10/8/96	Construction-CCR Title 8	W	Wording added to set.	25
10/8/96	Fire-treat like electrical (AHJ)	W	Wording added to ID form.	66
10/8/96	Human Subjects	W	Already addressed in set.	100
10/8/96	Electrical Safety	W	ID form modified.	46
10/8/96	Pressure Compressed Gases	W	Already addressed in set.	157
10/8/96	Aviation	W	Already addressed in set.	11
10/8/96	Hzd. & Non-Rad. Waste - add site acceptance criteria	W	Added to set.	80
10/8/96	Emergency Preparedness	W	Already addressed in set.	53
10/8/96	Rad. Safety Training	W	Wording added to ID form.	167
10/8/96	Ctrl. of Radioactive Sealed Sources - DOE Nuc. Mat. Mgmnt. Order	W	Already included in contract as Safeguards and Securities order.	29
10/8/96	Rad. Inst.- Add ANSI to implementation	W	ANSI standard added to implementation.	176
10/8/96	Cryogenic Mat. & Use	N	No effect on set.	33
10/8/96	Peroxidizable Chemicals	W	Already addressed in set.	149
10/8/96	Material Handling	W	Already addressed in set.	125
10/8/96	Traffic Hzds	W	Controlled substances added as issue.	216
10/8/96	Controlled Substances	W	Controlled substances added as issue.	30
10/8/96	Air Emissions (NESHAPS) in Implementation	W	Moved to implementation.	9
`10/8/96	Hzd Mat. Inventory in Implementation	W	Moved to implementation.	86
10/8/96	Sanitary Sewer	W	Already addressed in set.	196
10/8/96	Reptng. Nuc. Mat. Trans & Inventory (NMMSS)	W	Already included in contract as Safeguards and Securities order.	140
10/8/96	Radiography of welds/ construction	W	Added to set.	173
10/8/96	Repetitive Motion	W	Already addressed in set.	185
*W = Wholly incorporated P = Partially incorporated N = Not incorporated

Stakeholder Comments
Date	Issue	Disposition*	Remarks	I D Dbase Ref
8/29/96	Safety video unnecessary	N	Implementation issue.	235
8/29/96	LOTO procedures	P	Standards will allow more efficient implementation.	236
8/29/96	Strobe lights/fire alarms	N	Implementation issue.	238
8/30/96	Gloves for cryogens	N	Implementation issue.	239
8/30/96	Chemical inventory	P	Standards will allow more efficient implementation.	21
9/2/96	Exempt values for sources	P	Standards will allow more efficient implementation.	171
9/3/96	General issues incl. remove interpretations	P	Standards will allow more efficient implementation.	88
9/4/96	Seismic restraints on equipment	P	Flexibility included in implementation.	237
9/4/96	Disposal of consumer chemicals	N	Implementation issue.	82
9/4/96	Access to rad areas	P	Standards will allow more efficient implementation.	170
9/5/96	Accel. Safety Order	P	Only management sections retained.	240
11/6/96	Notification of SH insufficient	P	Process will continue, with annual report available for stakeholders, allowing input.	241
11/6/96	Why do we choose laws?	W	Covered in report introduction.	242
11/6/96	Regulator inclusion	P	Regulators invited as stakeholders.	243
11/6/96	Don't do only minimum compliance	W	Set includes more than 50 standards above minimum compliance and many more guidance documents under implementation.	244
11/6/96	CA drinking water stds.	P	Already included in implementation.	245
11/6/96	Volume activation std. development	P	Independent experts will be solicited to develop standards.	246
11/6/96	Discussion of accelerator issues not self-evident	W	Narrative has been corrected.	247
11/6/96	Endangered species protection	P	Narrative revised to clarify LBNL responsibilities.	248
11/6/96	Right to Know	P	Narrative revised to clarify LBNL responsibilities.	249
11/6/96	Accidental releases	W	LBNL voluntarily complies with state and local codes, to the extent that reporting thresholds are consistent with those of the state.	250
11/6/96	Pesticide runoff	W	Already included in set under local regulation of surface/storm water.	251
11/6/96	Storm water fees	W	Fees are paid to Berkeley Toxic Management Div. for services including time spent on inspections, meetings, report review and documentation efforts	252
11/6/96	Independent verification of radioactive emissions	P	Emissions are regulated by EBMUD, BAAQMD, and DTSC.	253
11/6/96	Hazardous material inventory	P	Narrative revised to clarify LBNL responsibilities.	249
11/6/96	On-site transportation of hazardous waste	P	Implementation in PUB-3000 provides for packaging to meet DOT standards, with the exception of providing a DOT manifest.	254
11/6/96	DOE 5820.2A Quality Assurance (QA) sections	P	QA is included in the contract between DOE and UC under the ES&H management orders.	255
11/6/96	NEPA	W	DOE will continue to comply with NEPA for Berkeley Lab activities.	256
11/6/96	Site Environmental Report	P	Narrative revised to clarify LBNL activities.	257
11/6/96	Independent Confirmation	W	Confirmation team included 7 of 17 members with no DOE or National Laboratory connection, and no financial interest in the standards selected.	258
11/6/96	Waste minimization	W	Waste minimization is included in the set, waste minimization experts and researchers have been in contact, and these interactions will be expanded during implementation.	259
*W = Wholly incorporated P = Partially incorporated N = Not incorporated