Outage PPE Exemptions

[retired nuke]

OK, this one should be simple -

During outages, does Safety exempt certain places / jobs from some of the PPE requirements? Examples would be RP Checkpoints, Refuel floor, Drywell, Containment, etc.
PPE exemptions would be Hardhats, fall protection, etc.

Are hardhats required for satellite checkpoints on the RFF, Turbine bay, etc?

Are hardhats worn in the DW, Ctmt, RFF?

Fall protection under vessel on carousel (BWR)?

Safety glasses on refuel bridge?

Hardhats in CRD Rebuild Rm, or other really contaminated areas?

What factors are used in deciding - contamination level? Risk of injury / overhead work? FME concerns?

Thanks in advance for any replies. If you can, please provide a contact person for followup (use personal message if you prefer)

Peace,

John

[Rennhack]

At the Exelon Outages I worked last fall, the RP check points had Hard Hat Exemptions, but only after some scaffolding was built over them to protect them from any falling hazards. - These check points were in hallways, where no overhead hazard exhisted before the special bunkers were built.

I worked as Both ALARA and Safety for Shaw/Stone & Webster at 3 Excelon plants.  So I had to write a few exemptions myself. 
One example of an exemption we wrote was an exemption for hearing protection in a fan room that seved as a break room.  The sound was close to the 8 hr day db restriction, but the workers were not in the location for 8 hrs, only for breaks.

Most often, they don't give exemptions at Excelon.  Troy is in Safety for GE, he shuold be able to help more than I can.

[UncaBuffalo]

Are hardhats required for satellite checkpoints on the RFF, Turbine bay, etc?

Are hardhats worn in the DW, Ctmt, RFF?

Safety glasses on refuel bridge?

Cooper - No Hardhats on RFF from control point on.  No safety glasses if heat/steam was causing you to fog up.

Diablo - Hardhats/Glasses at all times on RFF.  (Yes, we wore the funny little straps to keep them from falling in the pool.)

[Cathy]

I have worked a few drywells over the years and I have never seen fall protection and rarely hardhats undervessel. Most work undervessel is done overhead and hard hats aren't condusive to that. If the workers are suited up in bubblehoods or delta suits you don't normally see safety glasses either.
The CRD rebuild rooms I have dealt with normally have a hard hat exemption.
I can't remember the last time I wore a hard hat at a check point/ control point. You would not normally put these where there is an overhead hazard anyway.
On the refuel floor and around the SFP I am used to seeing a hardhat exemption. As an RP/HP I don't care for chin straps, they are simply another way to contaminate your face (like the fall protection body harness that goes on over your head). About 50/50 on safety glasses on the refuel bridge. It is an FME issue and common sense, not many overhead hazards over the cavity and SFP. If you have stuff falling out of the overhead over an open core or your SFP I would say you got problems 
As far as fall protection in a drywell, none that I have worked required it unless you were accessing a scaffold that required it.

[Already Gone]

The term "exemption" is misleading.
There is no way to legally "exempt" a worker from the required protective measures.  Not for his/her comfort or convenience and not for the company's.

However, nothing prevents an employer from relaxing the use of PPE if it isn't really required.  Mike gave a couple of good examples of that.

Most nuke plants have a comprehensive rule that you wear Hardhats, Safety Glasses, Work Shoes, Gloves, and Hearing Protection any time you are in the power block - even if no hazards exist.  Then they write you up a form which "exempts" you from this rule as long as you are in an area with no hazards and your work doesn't create any hazards.

I like to make the analogy to entering the RCA.  Imagine that every time you signed into an RWP you had to wear double cloth PC's, a plastic coverall, a tyvek coverall, double gloves, double shoe covers, an air-line respirator and an ice vest.  Then when you get to your work area, the HP tells you what you can take off.

Sounds stupid, huh?  Well, PPE isn't as drastic.  Wearing a hardhat and safety glasses and carrying gloves and ear plugs is not nearly as burdensome as all that.  So, they just make it a blanket requirement.

This all works well until it gets abused.  It gets abused a LOT.  Many times, the supervisor bypasses the Job Safety Analysis, which is required for every job - especially one with a PPE exemption, and goes right to signing an exemption just because the workers asked him to.

In order to establish the PPE requirements for any area, whether it is to add or remove them, you must analyze the work area for hazards.  First, you check the environment, then you analyze the actual work process.  You must provide some approved protective measures against all hazards.  If you want to substitute another protection, it must meet the ANSI standard or it must remove the hazard entirely.

I have heard every excuse.  Most of them are stupid.

There is NEVER a reason to exempt safety glasses.  All the reasons for doing so go right out the window as soon as somebody walks on the refuel bridge wearing his own prescription glasses.  If those are OK on the bridge, then all glasses are OK.  If they are new and clean, they will not impair vision.  If they are an FME concern - use a lanyard.  If they fog up - use ventilation.  etc. etc. etc.  You would never tell someone to take off his prescription glasses because of these things, so you have no justification for telling him to remove his protective glasses either.

A face-shield is never a substitute for safety glasses.  Any job that requires a face shield also requires either safety glasses or goggles as well.  The flimsy contamination barrier that HP supplies to keep zoomie dust off your face has ZERO impact protection and is not ANSI approved.  Bubble hoods are not approved eye protection.

Hardhats are not an FME problem.  They float.  They are too big to fit into most piping systems or get lost in the fuel.  they are easy to see and easy to retrieve.  If they get contaminated, they can be wiped clean.  If they can't be wiped clean, they can be replaced.  You can buy a new one for under ten dollars.  If they fall off, you can put on a chin strap.  (In over twenty-five years of wearing a hardhat at work - even inside a submarine - I have NEVER had one fall off unless it was knocked off, in which case it was good that I was wearing it to protect me from the thing that knocked it off.)

Earphones and face shields are available that fit onto hardhats.  The fact that the wrong ones were bought does not give a license to exempt hardhats just because these are in use.

So, I'll tell you straight.  You can never "exempt" PPE.  If you are sure that you have no hazards, or if you can remove them, or if you can establish an approved alternative method to protect against them, then you can show that PPE is not necessary.  But if you cut the tiniest of corners, and exempt something that could protect someone, and someone gets hurt, you have done that person a grave disservice as well as exposed your employer to the liability that comes with failing to protect a worker against injury.

I know the babies will cry.  A lot of times they will argue that PPE or fall protection or a safe work practice is more dangerous than not using it.  they are wrong.  They mix up things that are uncomfortable, time-consuming, difficult, or expensive with unsafe.  Nukes get things twisted even further.  You need to protect the PEOPLE first, then the fuel - period.  Being contaminated is not dangerous.  You have to decon people with contaminated chins.  You have to fill out forms, and maybe calculate a skin dose or do a WBC.  You get a head laceration in a contaminated area, and you have to do all that PLUS it gets on the evening news, PLUS the NRC starts asking questions, ...  Ask yourself which is worse to deal with - a contaminated chin, or a contaminated bleeding head.  There is NO (zero, zip, nada) job in this world other than lifesaving itself that justifies exposing human beings to injury.  Melted metal that ejects neutrons can be a problem (a HUGE problem) but it doesn't measure up to blinding or paralyzing a single person.  I spend a lot of my time defending my decision to deny waivers and exemptions, and it makes the workers angry.  There is no financial penalty to me for making someone angry that he has to do his job safely.  I used to sign these things all the time.  Now, I know a lot more than I did then.

Of course, it seems as though I am at odds with my dear friend Cathy.  Actually, she makes the best point of all.  Remove the hazard.  If contamination is the hazard - decon.  If falling is a hazard - build scaffold with rails.  If falling objects are the hazard - do the work elsewhere or  construct a barrier.  Remove as many hazards as you can FIRST.  Then you can start looking at PPE requirements.

I know this homily is a little long.  But I really believe in my work.  The "short" answer (as always) is: it depends.  Now, you know what it depends on.  No two situations are identical, so no single answer can be correct.  You have to take each situation as you find it.  No hardhats at a control point might sound like an easy one.  But, then the carpenters show up and start building a scaffold next to it.  No glasses on the fuel bridge?  Until a cable snaps and flings little pieces of wire into an eye.  Get the picture?  You can write these things all day long, but something will eventually bite you in the ass.

"OK, this one should be simple - "  Yeah, you might have thought so, huh?

[stownsend]

I worked as Both ALARA and Safety for Shaw/Stone & Webster at 3 Excelon plants.  So I had to write a few exemptions myself. 
One example of an exemption we wrote was an exemption for hearing protection in a fan room that seved as a break room.  The sound was close to the 8 hr day db restriction, but the workers were not in the location for 8 hrs, only for breaks.

We don't allow for TWA due to the unknown locations that people may or may not work after they exit the known noise hazard area.. We do use personnel noise dosimetry and calculate percentage of dose by the noise standard.

[justatech]

During outages, does Safety exempt certain places / jobs from some of the PPE requirements? Examples would be RP Checkpoints, Refuel floor, Drywell, Containment, etc.
PPE exemptions would be Hardhats, fall protection, etc. Answer: RP Checkpoints outside of CTMT (if it has "office" overhead tiles) or on specified walkways marked in yellow spray paint
Are hardhats required for satellite checkpoints on the RFF, Turbine bay, etc? Answer: depends on where you are at - general walkways in turbine that are marked with yellow paint - doors are posted
Are hardhats worn in the DW, Ctmt, RFF? Answer: always worn in CTMT - NO exceptions - unless you are undressing at the SOP outside of CTMT
Safety glasses on refuel bridge? Answer: Yes - all the time - SFP and CTMT - must use lanyards
Hardhats in CRD Rebuild Rm, or other really contaminated areas? Answer: all areas except refuel bridges
What factors are used in deciding - contamination level? Risk of injury / overhead work? FME concerns? Answer: FME concerns - and less risk of injury
Thanks in advance for any replies. If you can, please provide a contact person for followup (use personal message if you prefer) Answer: sent IM for clarification
Peace,

John
[/quote]

[vikingfan]

while working at exelon sites and other sites using the BWR inspection platform, or otherwise called a 360 platform, crock pot,ring of fire, etc generally sites will allow us the workers not to have to wear safety glasses while performing inspections or reactor core maintenance. also on the refuel bridge while moving fuel, removing and replacing control rod blades and Lprm's safety glasses generally are not worn during these operations.

[Already Gone]

while working at exelon sites and other sites using the BWR inspection platform, or otherwise called a 360 platform, crock pot,ring of fire, etc generally sites will allow us the workers not to have to wear safety glasses while performing inspections or reactor core maintenance. also on the refuel bridge while moving fuel, removing and replacing control rod blades and Lprm's safety glasses generally are not worn during these operations.

This is true -- although the reason for it is a crock.  If you can't see through your glasses, you can't see much better without them, or you should get better ones.  In your line of work, vision is critical to your performance.  Which is why I can't understand why they continually let you put it at risk by working with unprotected eyes.

Even for people who do not need prescription glasses, I recommend using your insurance benefit for getting a pair of prescription safety glasses.  They are optically better for your vision even with a null prescription.  And you can get them with anti-glare coatings, scratch resistant lenses and  they are much more comfortable and durable than those $3.50 disposables that you get at work.  For an RST, like Vikingfan, I would even recommend the racquetball goggles.  They won't fall off, won't slip down your nose, and won't fog up too much.  If you can get them with polarized lenses, they will eliminate the glare off the surface of the water.

[retired nuke]

Cooper - No Hardhats on RFF from control point on.  No safety glasses if heat/steam was causing you to fog up.

Diablo - Hardhats/Glasses at all times on RFF.  (Yes, we wore the funny little straps to keep them from falling in the pool.)

Any problems with contamination from the chinstraps?

[illegalsmile]

PPE should be the last line of defense against occupational hazards. Like radioactive contamination, occupational hazards should be dealt with by eliminating the hazard before you revert to PPE. This is, of course, subject to the "practical"....a term that usually gets translated as "profitable."  The knee-jerk reaction of requireing PPE (usually hard hats, safety glasses, gloves and safety shoes) where no hazard actually exists is most beneficial to the people who are tasked with identifying areas where the conditions actually warrant the use of these items. Who among us hasn't been required to wear a hard hat in a room where only our crew was in there and the work was all at waist level or below?
PPE 'exemptions' are usually just the determination that the items weren't appropriate for those areas to begin with.

[Already Gone]

PPE should be the last line of defense against occupational hazards. Like radioactive contamination, occupational hazards should be dealt with by eliminating the hazard before you revert to PPE. This is, of course, subject to the "practical"....a term that usually gets translated as "profitable."  The knee-jerk reaction of requireing PPE (usually hard hats, safety glasses, gloves and safety shoes) where no hazard actually exists is most beneficial to the people who are tasked with identifying areas where the conditions actually warrant the use of these items. Who among us hasn't been required to wear a hard hat in a room where only our crew was in there and the work was all at waist level or below?
PPE 'exemptions' are usually just the determination that the items weren't appropriate for those areas to begin with.

You managed to say in six lines what it took me a whole page to say.  Thanks for the clarity.

[UncaBuffalo]

Any problems with contamination from the chinstraps?

No, but that was at Diablo Unit 2 and it was hard to find a hot smear anywhere outside of the cavity.  I'm betting we will have to revise the plan on Unit 1.