1. Large Synoptic Survey Telescope (LSST)
  2. Safety Policy
  3. Chuck Gessner and Victor Krabbendam
  4. LPM-18
  5. Last revision date: November 11, 2014
  6. Change Record
    1. Table of Contents
  7. The LSST Safety Policy
  8. Summary
  9. Acronyms and Definitions of Terms
  10. The LSST Safety Policy
    1. 1 Introduction
    2. 2 Objective
    3. 3 Overview
      1. 3.1 Safety, Health, and Environmental (SHE) Plans
      2. 3.2 Safety Reviews and Hazard Analysis
      3. 3.3 Safety Manager and Safety Council
      4. 3.4 Design for Safe Development and Operation
    4. 4 LSST Safety, Health and Environmental (SHE) Plans
      1. 4.1 Compliance to Regulations, Codes and Standards
      2. 4.2 Safety Health and Environmental Plan Responsibilities
      3. 4.3 SHE Plan Expectations
      4. 4.4 Contractor Safety and Health Plans
      5. 4.5 SHE Plan Availability to Personnel
    5. 5 Safety Reviews and Hazard Analysis
      1. 5.1 Safety Reviews
      2. 5.2 Hazard Analysis and Hazard Register
    6. 6 Safety Policy Management and Responsibilities
      1. 6.1 LSST Safety Manager
      2. 6.2 LSST Director
      3. 6.3 LSST Project Manager
      4. 6.4 LSST Project Safety Council
      5. 6.5 LSST Team Members
    7. 7 Design for Safe Development and Operation

Large Synoptic Survey Telescope (LSST)

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Safety Policy

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Chuck Gessner and Victor Krabbendam

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LPM-18

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Last revision date: November 11, 2014
This LSST document has been approved as a Content-Controlled Document. Its contents are subject to
configuration control and may not be changed, altered, or their provisions waived without prior
approval. If this document is changed or superseded, the new document will retain the Handle
designation shown above. The control is on the preferred version of the digital document with this
Handle in the LSST digital archive and not printed versions.

LSST Safety Policy
LPM-18
11/11/2014
The contents of this document are subject to configuration control and may not be changed, altered, or their provisions
waived without prior approval.
i

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Change Record
Version
Date
Description
Owner name
1
5/9/2009
Initial version
Chuck Gessner and
Victor Krabbendam
2
11/5/2009
Reviewed for consistency
Oliver Wiecha
3
7/30/2009
Final edits and minor changes
Victor Krabbendam,
et. al
4
8/29/2010
Change to “Policy” and other CCB edits
Victor Krabbendam
5
7/28/2011
Clarifications based on June 21, 2011 Safety Council
Meeting
Victor Krabbendam
6
9/30/2013
Inter-document consistency, formatting and typo
corrections; no content changes. Approved via
LCR-154
R. McKercher
10/4/2013
Implementation of LCR-154
R. McKercher
7
11/11/2014
Minor edits based on NSF review
C. Gessner
1/5/2015
Implementation of LCR-276
R. McKercher

LSST Safety Policy
LPM-18
11/11/2014
The contents of this document are subject to configuration control and may not be changed, altered, or their provisions
waived without prior approval.
ii
Table of Contents
Change
Record
...............................................................................................................................................
i
Summary
......................................................................................................................................................
iii
Acronyms and Definitions of Terms ............................................................................................................. iii
1
Introduction
..........................................................................................................................................
1
2
Objective
...............................................................................................................................................
1
3
Overview
...............................................................................................................................................
2
3.1
Safety, Health, and Environmental (SHE) Plans ............................................................................ 2
3.2
Safety Reviews and Hazard Analysis ............................................................................................. 2
3.3
Safety Manager and Safety Council .............................................................................................. 2
3.4
Design for Safe Development and Operation ............................................................................... 3
4
LSST Safety, Health and Environmental (SHE) Plans ............................................................................. 3
4.1
Compliance to Regulations, Codes and Standards ....................................................................... 3
4.2
Safety Health and Environmental Plan Responsibilities ............................................................... 3
4.3
SHE Plan Expectations ................................................................................................................... 3
4.4
Contractor Safety and Health Plans .............................................................................................. 4
4.5
SHE Plan Availability to Personnel ................................................................................................ 4
5
Safety Reviews and Hazard Analysis ..................................................................................................... 5
5.1
Safety Reviews .............................................................................................................................. 5
5.2
Hazard Analysis and Hazard Register ............................................................................................ 5
6
Safety Policy Management and Responsibilities .................................................................................. 6
6.1
LSST Safety Manager ..................................................................................................................... 6
6.2
LSST Director ................................................................................................................................. 6
6.3
LSST Project Manager ................................................................................................................... 7
6.4
LSST Project Safety Council ........................................................................................................... 7
6.5
LSST Team Members ..................................................................................................................... 7
7
Design for Safe Development and Operation ....................................................................................... 8

LSST Safety Policy
LPM-18
11/11/2014
The contents of this document are subject to configuration control and may not be changed, altered, or their provisions
waived without prior approval.
iii

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The LSST Safety Policy

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Summary
This document provides the description of the LSST Safety Policy. This Policy
focuses on personnel and
equipment safety throughout the design, construction, and operations phases of the project. The Policy
addresses working conditions and procedures, as well as the management structure and design features
that impact safety throughout the LSST Project.

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Acronyms and Definitions of Terms
Glossary of Abbreviations
(
Document-11921
)
Glossary of Definitions
(
Document-14412
)

LSST Safety Policy
LPM-18
11/11/2014
The contents of this document are subject to configuration control and may not be changed, altered, or their provisions
waived without prior approval.
1

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The LSST Safety Policy
1 Introduction
The Large Synoptic Survey Telescope (LSST) Project is committed to achieving the highest performance
in safety, health, and environmental management practices with the aim of creating and maintaining a
safe and healthy working and operating environment. The Safety Policy focuses on personnel and
equipment safety throughout the design, construction, and operations phases of the project. The Policy
addresses working conditions and procedures, as well as the management structure and design features
that impact safety throughout the LSST Project.
The LSST Project is centrally managed but executed by several teams in distributed locations and with
different funding sponsors. This LSST Safety Policy covers all LSST Project efforts while recognizing and
relying on existing Safety, Health and Environmental policies in place at participating institutions.
This document provides the program description and references other project documents for additional
details.
2 Objective
This Policy establishes and defines Safety, Health and Environmental (SHE) procedures and requirements
for the LSST Project consistent with all United States and Chilean laws and regulations. The objective of
the policy is to make safety, health and environmental management an integral part of the effort from
initial planning and design, to construction, commissioning, and finally throughout the operation of
LSST.
In addition to the stated policies and requirements, this policy lays out a foundation for project
development and operations intended to establish a culture where the safety and health of personnel
and equipment is a paramount concern, and that individuals are empowered and management is
structured to encourage and promote safety in all elements of the project. In particular, LSST is
committed to
Promote a work environment based on continuous improvement, employee involvement,
ownership, teamwork, education, and leadership;
Reinforce the need for people to care about the people they work with;
Promote the philosophy that safety is not a priority that can be reordered, it is a value
associated with everything we do;
Recognize, reward, and reinforce our safety, health and environmental achievements,
innovations, and behaviors;
Address all known risks to people, property, and the environment;
Exercise vigilance to ensure compliance with all applicable, laws, regulations, and management
best practices;

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Integrate safety, health, and environmental considerations into project planning, design,
construction, and operations to minimize loss; and
Conduct sustainable programs to minimize pollution to the environment, to protect material
resources, to honor cultural resources, and to minimize our impact to biota.
3 Overview
To realize these commitments, the LSST Project has established this Policy on the basis of clear lines of
communication, clear procedures, critical review, personal responsibility, and accountability for safe
design and conduct. This section provides an overview of the four major elements in the LSST Safety
Policy. Each of these is further described later in this document and specifically addressed in detailed
implementation documents.
3.1 Safety, Health, and Environmental (SHE) Plans
The detailed guidelines for safe working conditions are found in site specific Safety, Health and
Environmental (SHE) Plans. The SHE Plans at each site are a critical element in the Safety Policy, and LSST
expects that each collaborating organization and contractor has established safety programs that will
govern the specific activities at that location. LSST has a minimum expectation for the criteria
established in these plans and expects all staff, whether permanent to the location or visiting, to follow
these local procedures. When LSST specific sites are established, the project will issue specific SHE plans
for those locations.
3.2 Safety Reviews and Hazard Analysis
LSST will conduct periodic design and procedure reviews focused on compliance to safety regulations,
this program, and good practice. The frequency of the reviews will be commensurate with the stage of
the project as defined in the Project management plan. Reviews will be conducted by SHE professionals
and will focus on specific subsystems of the observatory, the observatory as a whole, and this Safety
Policy itself. Each subsystem will conduct periodic Hazard Analyses to be included in the reviews. Hazard
Registers will be maintained in standard forms for cross project review.
3.3 Safety Manager and Safety Council
The LSST Project Management team is responsible and held accountable for incorporating the Safety
Policies, standards, rules, and principles into the project work. To emphasize the commitment to safety,
a single LSST Safety Manager manages, executes, and verifies compliance to the Safety Policy. This
safety professional is part of the project team, reports to the Project Manager and has direct access to
the LSST Director. A Safety Council also has been established with a complement of safety professionals
and other team members from LSST collaborating institutions and outside affiliations. The LSST Safety
Manager chairs this committee and organizes broad or targeted subject matter reviews consistent with
the Project Execution Plan (LPM-54) or as necessary. For appropriate phases of the LSST construction
activity, for example summit construction, Safety Inspectors will be employed to provide front line
review of work in progress. The LSST also maintains a Safety Web Site to communicate with the large
distributed LSST team and facilitate the dissemination of key information.

LSST Safety Policy
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11/11/2014
The contents of this document are subject to configuration control and may not be changed, altered, or their provisions
waived without prior approval.
3
3.4 Design for Safe Development and Operation
The LSST will follow design, construction and operation best practices and comply with US and Chilean
laws and regulations in all aspects of the LSST Observatory system, from the summit in Chile to the
archive and data centers in the US. The Safety Manager and Safety Council work with the Project
Managers and engineers to identify the US, Chilean, International and agency institution codes and
standards that should be applied to the various elements of the LSST.
4 LSST Safety, Health and Environmental (SHE) Plans
All efforts to design, construct, commission, and operate the LSST are to be performed within the
jurisdiction of an institution with established Safety, Health and Environmental (SHE) policies and
procedures. The local SHE Plans provide the detailed definition of compliance standards, responsibilities,
behavior and reporting. All personnel working on the LSST will follow the guidelines established in the
SHE plan for that location. When traveling, personnel shall follow home institution travel policies.
Personnel traveling on behalf of AURA shall refer to the LSST Travel web page for specific instructions
(
https://project.lsst.org/travel
). Plans will be developed for new LSST facilities as they are put into place
and custom plans are necessary. In all cases, the SHE plans cover the details that mandate and inspire
people to incorporate safe designs, to define safe procedures, and to work safely and responsibly
together.
4.1 Compliance to Regulations, Codes and Standards
LSST expects local SHE plans to comply with all applicable safety, health and environmental regulations
and requirements in Title 29 of the U.S. Code of Federal Regulations (CFR) including part 1910, "OSHA
Safety and Health Standards for General Industry", and Part 1926, "Safety and Health Regulations for
Construction", 49 CFR Federal Motor Carrier Safety Administration, and 40 CFR Protection of
Environment and others that may apply; LSST considers the above CFR’s as minimum standards. Plans
governing work in Chile will comply with the requirements of this document and other Chilean laws such
as Safety Law No 16.744 and other Chilean Standards (
Normas Chilenas
).
4.2 Safety Health and Environmental Plan Responsibilities
Work conducted at participating organizations shall be governed by the local SHE plan. These plans
include identification of the local Safety Manager/Coordinator and lines of authority to which all
personnel working on LSST activities at that location shall adhere. There shall be no ambiguity about
which plans govern activity for visiting staff. Local SHE plans take precedence over home institution
regulations except where the employee is further restricted. Staff members who recognize
inconsistencies in the local plans and their home institution policies shall identify the situation to the
local safety authority, the home institution safety authority, and the LSST Safety Manager to resolve any
conflicts.
4.3 SHE Plan Expectations
LSST has a set of guidelines expected from the local SHE plans. The LSST Safety Manager and project
management will work with the collaborating institutions to insure that the local plans meet Project
expectations. The LSST Safety Manager is charged with the review of the local plans to see that LSST
expectations are met, that all elements (documentation) are available to the staff, and that issues of

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waived without prior approval.
4
nomenclature and document titles are reconciled where differences are identified. The following topics
are expected to be addressed in local SHE plans:
Local Safety Manager/Coordinator
Staff Responsibilities
Visitor and Access Policy
Behavioral Policies
Personal Protection Equipment
Hazardous Material Management
Emergency Contacts and Procedures
Special Equipment Procedures (Laser etc.)
Utility Use and Servicing (Cryogens, gasses, power etc.)
Lock-out processes
Inspections
Housekeeping
Reporting and Records
4.4 Contractor Safety and Health Plans
All LSST institutions and contractors that perform LSST work are required to develop, submit, and
implement a project and site-specific safety and health management plan. The plan must extend to its
own employees, project employees, other workers, and members of the public. The contractor is also
required to ensure compliance with the plan. The details of the contractor requirements are subject to
specific policies from the specific LSST organization contracting the work but are expected to address
the same information as described in Section 4.3 above.
For work contracted at LSST specific locations,
the contractor’s safety record and ongoing safety
program will be an important element in the selection criteria. All contractors are required to complete
the
“Safety and Health Questionnaire for Contractors”
(as maintained by AURA procurement) that will
be used to evaluate potential contract employers. All general contractors shall require subcontractors to
comply with the Contractor’s Safety and Health Specification.
The Safety and Health Questionnaire for
contractors will be provided to potential contractors during the proposal process and shall be completed
and submitted with the contractor proposal documents. The questionnaire will be used by LSST to
assess
contractors’ safety performance and programs and will be used during the selection process.
4.5 SHE Plan Availability to Personnel
The LSST project maintains a Safety Program Website
(
https://project.lsst.org/safety/home
) that
includes links to all applicable local SHE plans and policies to facilitate convenient access to the
information to everyone working on LSST tasks. This is particularly important for staff who visit and work
at other institutions where access to the information is not routine. The LSST Safety Manager is charged
with establishing the links to the appropriate and applicable information for each participating

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waived without prior approval.
5
institution.
5 Safety Reviews and Hazard Analysis
Formal safety reviews and hazard analyses will be the principal elements of the LSST system safety
engineering and analysis methodology.
5.1 Safety Reviews
LSST will conduct periodic design and procedure reviews focused on compliance to the Safety Policy and
applicable standards. The frequency of the reviews will be commensurate with the stage of the project
as defined in the Project management plan. Reviews will be led by the LSST Safety Manager with
support from other safety professionals. They will focus on specific subsystems of the observatory,
contracted efforts, the observatory as a whole, and the Safety Policy itself. Each subsystem will conduct
periodic risk assessment and hazard analyses to be included in the reviews. Contractor hazard analysis
will also be reviewed consistent with deliverables established in contract documents. A Project-level
safety review will be conducted at a minimum of yearly, while other reviews and their scope will be
determined by the Project Manager and LSST Safety Manager during the project period.
A key element of the safety review process is the assessment of hardware designs, construction and
operational processes, hazard analysis results and the interaction with the LSST Risk Management Plan
(see LPM-20). There are three types of risk associated with the project: 1) Technical Risk, consisting of
the risk of not meeting performance requirements; 2) Programmatic Risk, which consists of the risk of
project failure due to cost or schedule overruns; and 3) Risk of Harm, personnel and equipment safety.
LSST Risk Management focuses on items 1 and 2 and this Safety Policy focuses on item 3. There are
interdependencies that are managed within system engineering and the safety review process.
5.2 Hazard Analysis and Hazard Register
LSST utilizes a formal hazard analysis process to identify, analyze, and determine the resolution of
hazards throughout the project. This hazard resolution method for LSST consists of the series of analytic
steps summarized below and described fully in the LSST Hazard Analysis Plan (LPM-49).
Define the physical and functional characteristics of the proposed telescope, camera, and
facilities by employing the information available (design documents, operating procedures, etc.),
and relating the interaction between people, procedures, equipment, and the environment.
Identify known hazards related to all aspects of the LSST project and determine their causes.
Assess the hazards to determine severity and probability, and to recommend means for their
elimination or control.
Implement corrective measures to eliminate or control the individual hazards, or accept the
corresponding risks.
Conduct follow-up analyses to determine the effectiveness of preventive measures, address
new or unexpected hazards, and issue additional recommendations if necessary.

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The contents of this document are subject to configuration control and may not be changed, altered, or their provisions
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6
6 Safety Policy Management and Responsibilities
The LSST safety program requires a clear line of responsibility and authority to ensure proper
implementation and verification. The Project will appoint a single Safety Manager for the project to
manage all aspects of the program. The Safety Manager is assisted by a standing council, comprised of
safety professionals and other team members, to provide the review and assessment required within
the program and to support the Safety Manager as needed during the project. This section provides the
roles and responsibilities for the key LSST staff regarding the safety program.
6.1 LSST Safety Manager
The Safety Manager is responsible for the LSST Safety Policy, its implementation and helping
management to ensure compliance. The Safety Manager reports directly to the LSST Project Manager
and works closely with LSST subsystem managers, systems engineers, and the local safety
managers/coordinators at each participating organization responsible for the implementation of local
Safety, Health, and Environmental Program (SHE) plans. The LSST Safety Manager has the authority and
responsibility to report safety, health, and environmental issues and to make recommendations to the
Project Manager, the Project Safety Council, and other leadership of the LSST Project, reporting directly
to the LSST Director if necessary. The Safety Manager inspires the project team to value safety and
manage all risks in their area of responsibility
The Safety Manager leads the effort to establish, plan, organize, and integrate this Safety Policy into the
LSST Project as well as influence the design when necessary. The Safety Manager, working with the
institutional Safety Managers/Coordinators, will be actively involved in many if not all aspects of the
Project. They are responsible for
Participating in design reviews;
Preparing the Safety Program deliverable documents;
Supporting the program level interface with NSF, DoE, and others;
Developing and establishing safety design criteria and safety design requirements as needed;
Reviewing and approving selected drawings, specifications, and procedures;
Participating in hazardous testing if required;
Evaluating design changes for their impact on safety, health, or the environment;
Coordinating and verifying adequate emergency response systems and procedures that will be
used during construction; and
Coordinating safety, health, and environmental activities needed during the project.
The LSST Safety Manager and local safety managers/coordinators are all obligated to keep current with
all laws, ordinances, statutes, rules, and regulations as they become promulgated.
6.2 LSST Director
The LSST Director has the overall responsibility for ensuring that SHE management practices are
incorporated into the LSST Project. The LSST Director works with the Project Manager and Safety

LSST Safety Policy
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waived without prior approval.
7
Manager to implement the LSST Safety Program and SHE objectives by
Ensuring the Safety Policy is established and integrated throughout the LSST Program;
Ensuring that known risks are identified, eliminated, or controlled within established program
risk acceptability parameters; and
Ensuring that LSST operations are performed in accordance with applicable project safety
requirements, and applicable Governmental safety regulations.
6.3 LSST Project Manager
The LSST Project Manager has the day-to-day responsibility for ensuring that SHE management practices
are incorporated into the LSST Project. The LSST Project Manager will implement the LSST Safety Policy
through the appointment of the LSST Safety Manager and will direct all subsystem managers to keep
SHE issues a priority in all aspects of the project. Specifically the Project Manager and subsystem
managers will
Make SHE considerations a part of all planning processes by identifying known hazards,
determining what standards apply, implementing controls, determining the competencies
required to do the work safely, and finally the assurance that each of these elements are in
place before work is authorized to proceed;
Management focuses on safe accomplishments of the mission, understanding assignments, and
carrying out the core safety management functions correctly and efficiently. These principles are
dependent both upon management commitment and employee/individual involvement and
accountability;
Ensure the Safety Program is established and integrated throughout the LSST Project;
Ensure that known hazards are identified, eliminated or controlled within established program
risk acceptability parameters;
Ensure that LSST operations are performed in accordance with applicable project safety
requirements and applicable Governmental safety regulations;
Review and approve safety analysis and safety program documents; and
Ensure that necessary documents are submitted to Agencies that require them.
6.4 LSST Project Safety Council
A Project Safety Council will be established and will consist of LSST Institutional members as well as
independent safety professionals determined by the LSST Director, Project Manager and Safety
Manager. The purpose of this council is to consult on safety, health, and environmental issues, provide
policy advice, evaluate program effectiveness, and make recommendations to the LSST Director. The
Project Safety Council will meet at a minimum yearly, or at appropriate intervals as required and
determined by the Council and Safety Manager.
6.5 LSST Team Members
Each member of the LSST team is responsible for integrating safety into their work and supporting the

LSST Safety Policy
LPM-18
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The contents of this document are subject to configuration control and may not be changed, altered, or their provisions
waived without prior approval.
8
SHE Plan as established for the work location. LSST staff are encouraged and empowered to understand
the work environment and identify designs, procedures and conditions that they consider unsafe,
whether specifically addressed in SHE plans or otherwise occurring. Every team member has the
authority, without fear of reprimand or penalty, to stop work and seek technical assistance from the
Safety Managers for guidance, resolution of safety issues or disputes involving the LSST activity.
7 Design for Safe Development and Operation
The LSST will follow design and construction best practices and comply with the appropriate laws and
standards in all aspects of the LSST Observatory system, from the summit in Chile to the archive and
data centers in the US. The LSST is a technically and geographically diverse observatory that falls under
many categories and jurisdictions of safety standards. This diversity, and the one-of-a-kind nature of the
facilities, requires that the Safety Manager, project managers, and engineers work closely to apply the
correct safety standard to the different design elements. In all cases designs will be consistent with
applicable standards from US, Chilean, International and agency institutions, including
U.S. Occupational Safety and Health Administration (OSHA),
Environmental Protection Agency (EPA),
National Fire Protection Association (NFPA),
International Code Council (ICC),
Chilean Regulations, Codes and Standards,
National Optical Astronomy Observatory Risk Management Policy, and
Department of Energy National Laboratories.
The coordination between the Safety Manager and engineering staff will be driven by system
requirements, the review and Hazard Analysis processes described in this document, and the project
Risk Management process. One objective of these processes is to keep the Safety Manager and Council
involved in the design process. The design for safety will include the intrinsic design, the manufacturing
and construction process, and the resulting operational concepts. As operating procedures are
developed for the observatory, job hazard analysis will be included to protect people, equipment, and
processes from known hazards.

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