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LIFE SCIENCES OPERATIONS. Management Review October 16, 2007. Introduction. Purpose: Provide Senior Managers with information to answer the following questions regarding the Life Sciences integrated safety management system.. Is the system effective in achieving ESSH policy commitments?

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life sciences operations


Management Review

October 16, 2007

  • Purpose: Provide Senior Managers with information to answer the following questions regarding the Life Sciences integrated safety management system..
  • Is the system effective in achieving ESSH policy commitments?
  • Are the objectives and targets suitable and is the system effective in achieving our objectives, targets and performance measures?
  • Is the system adequate in terms of :
    • identifying significant aspects, hazards and impacts?
    • resource allocation?
    • Communication, information systems?
    • Organizational issues-staff expertise, procedural reqmts?
operations management review agenda
Operations Management Review Agenda
  • ISM Overarching programs -status
    • Work Planning and Control
    • Training and Qualifications
    • Tier I and Work Observation Programs
    • ISM Results
  • Environmental Performance
  • OSH Performance
  • FY08 Goals and Objectives
  • Manager evaluation of ISM program
  • Discussion
life sciences work control program
Status on Goals/Objectives:

Reviewed 2 WPs, Subject Area revised, training in process

Small Science working group revising ESR process (90%)


Increased training reqmts for Work Control Coords (Suspect Parts, Davis Bacon, etc)

Need to incorporate ISM issues. Electronic ESR would help.

Scope creep –keep reminding PIs to communicate changes

Visitors and students are still a challenge--

MO 200 guests, BO 100 guests, ~ 30 OEP students; ~200 NSRL Users









- Imaging (old CO)


Life SciencesWork Control Program

Breakdown of Work Planning for small science








facility safety
Facility Safety


  • Static Magnetic Field Exemption pending DOE Approval
  • Completed- TPL Supplemental Hazard Assessment


  • BLIP SAD still in process of being updated (did not meet goal)
    • Reflects current operations.
    • Does not meet subject area or accelerator safety order format.
    • Staff did a TPL Hazard Assessment and DOE NE Audit
  • Electrical Safety -- 2 FY07, 1 FY06 ORPS
  • 463 removed from Lab Upgrade funding (line item) which will limit the extent of OSHA/851 corrective actions (ie showers)
esh q training and qualification
ESH&Q Training and Qualification
  • FY07 LS Performance Measures (4200 reqmts tracked)
    • Goal >95% Training Completion Employees

MO ~99%; BO ~99%; DJ (Directorate staff) 100%

    • Goal>95% Required Training Completion for Guests

MO ~96% (Improvement +5%); BO ~100%; DJ N/A

    • Goal: JTAs reviewed annually and linked for all new staff Complete
  • Avg. Time spent in training
    • BO Employees: 9 hrs (+3 from 06), Guests: 5 hrs (-1 FY06)
    • MO Employees: 12 hrs (+3 from 06), Guests: 9 hrs (+1 FY06)
    • Site-Wide: Employees- 20hrs, Guests: 4hrs
  • Improvement-Students/collaborators check in at GUV Center—helps ensure training is complete prior to activation of appointment.


    • Supervisory Training –ensure all JTAs are assigned/training completed
    • Intermittent staff—come/go and must maintain training. Rely on host.
tier 1 program
Tier 1 Program
  • Tier 1 program follows Subject Area. Corrective actions dispositioned by next Tier I of that area.
  • Chemical Storage, Labeling, Use (~40% findings)
    • Plan--FY08 Goal to focus on OSHA Particularly Hazardous Substances (highly acute toxins, carcinogens, reproductive toxins, and chemicals easily absorbed through skin)
  • Waste Management (~20% findings plus informal walkthrough findings)
    • Continues to be a problem.
    • FY08—meet with repeat offenders to determine cause and correct.
  • Housekeeping (~5% but not always written up)
    • Marked improvement in this area—constant struggle, manager work observations helping—need to continue.
manager work observations
Manager Work Observations

Life Sciences Implemented in FY07: Total: 60 observations, 52 hrs

    • ALD completed 24 [BES: 12hrs/yr, EENS: 36hrs/yr]
    • Chairs -12 each [ BES: 3hrs/yr, EENS 24hrs/yr]
    • Level 3 Mgrs - 2 each [BES: 3hrs/yr, EENS: 12hrs/yr]
  • Feedback—valuable for ALD and Chairs but not the Level 3s, well-received by staff
  • Do we need to adjust # of observations? Any requirement to drill down further?

Senior Manager Work Observation at uMRI (Aronson/McNair)

  • Several findings tracked in ATS (training, posting)
  • Not well-received. Scope was not well defined (issues found with time reporting, property, etc).
  • Many hours spent in follow up for little improvement.
  • Recommend less formality in these assessments and a better defined scope.
  • Biology is on the list for FY08
doe ism audit how will findings affect life sciences
DOE ISM AuditHow will findings affect Life Sciences?

CF#1 – Define Scope

of Work

CF#2 – Analyze Hazards

CF#3 – Develop and Implement Controls

CF#4 – Perform Work Within Controls

Core Functions of ISM

Should force clarity in subject areas and lessen confusion.

Will drive more details in Experimental Safety Reviews, Work Permits and other documents.

More rigorous line self-assessments

Could end up tracking “everything” at an Institutional level (findings from all audits/assessments including Tier Is, Suggestions, Ideas) –resource problems

Still implementing the ISM Improvement Plan


Small Science



Effective Performance

Effective Performance

Effective Performance

Needs Improvement

Effective Performance

Needs Improvement

Needs Improvement

Needs Improvement

Needs Improvement

Needs Improvement

Effective Performance

Needs Improvement

Effective Performance

Needs Improvement

Needs Improvement

Effective Performance

changing circumstances
Changing Circumstances

Institutional Requirements:

  • 10CFR851gaps
  • Human Performance –in process
  • Manager Work Observations
  • PPE Requirements
  • Many Subject Areas Revised
  • Nuclear Safety Program evaluation may impact CERF

Directorate Changes:

  • Organization and staffing fairly static in FY07
  • General sense of urgency causes staff to work faster.
  • FY08—Change in ECR, RMW support

Challenge—many requirements and programs are not well integrated. Still has the flavor of the week feel to staff.

follow up from 06 management review
Follow up from ’06 Management Review
  • Last year’s meeting:
  • New ESS&H policy just signed off on
  • Electronic ESR’s requested
  • SAD for BLIP
  • MO’s training goal for Guests not met
  • PI’s supplementary lab-specific OJT not documented
  • Continual Tier 1 findings for wastes (CBT T/B modified)
  • Sr. Mgr. Work Observations need to focus on ‘housekeeping’
  • DOE 851 order concerns
  • Hg-contaminated, legacy D-pipes (801)
  • Methylene chloride usage
  • Tier 1 tracking
  • UMC Program rollout (490 basement & 901 cyclotron)
  • EP fees for hauling animal bedding to compost pile-addressed.
ls ems significant aspects
LS EMS Significant Aspects

Identified as part of

Work Control Process

  • Industrial Waste
  • Hazardous Waste
  • Mixed Waste
  • Regulated Medical Waste
  • Radioactive Waste/R-RMW
  • Atmospheric discharges (BLIP, TPL)
  • Liquid discharges
  • Storage/use of chems/rad (D-tanks/BLIP tanks)
  • Historical contamination

Greenhouse soils

  • Soil contamination


  • Other

Nanomaterials (NEW)

how did we do in 07 fy07 environmental goals objectives
How did we do in 07?FY07 Environmental Goals/Objectives


  • Completed FY06 goal to desludge 801 F & D tanks and remove from Article 12 (Health Dept.)
    • F tanks were completed in FY06, legacy D-tanks desludged/mercury piping removed. Pending removal from Article 12 list
    • ADS still in place to remove all legacy tanks (contaminated tank shells).
  • Communicate RCRA requirements to generators twice in FY07
    • Completed—still have RCRA issues.
  • Install room damper at BLIP and measure potential air emission reductions
    • Damper was tested— 18.4% reduction however additional testing needed
  • Continue to Review Environmental Monitoring Data
    • Ongoing – no issues.
    • BLIP Cap inspections/maintenance conducted by MO.
how did we do in 07 fy07 environmental goals objectives1
How did we do in 07?FY07 Environmental Goals/Objectives

Pollution Prevention/Waste Minimization

  • Participate in Pollution Prevention Program by submitting 1 P2 proposal
    • Completed – 4 proposals submitted/1 funded by P2 and 1 funded by Program, 2 successes


  • Reduce Unwanted Materials and Chemicals Inventory (UMC)

Community Outreach:

  • Summer Sunday-ECR, FS, ESH participation

Continual Improvement

  • Participate in EWMSD Topical Assessments
    • Completed
ls ems fy07 objectives and targets compliance cleanup p2
LS EMS FY07 Objectives and Targets Compliance/Cleanup – P2
  • Four P2 proposals submitted
  • Lab and unwanted materials cleanups -- FUNDED
  • Microarray hybridization – Funded by research program
  • Infrared Imaging System
  • Motion Detectors (GHG)
  • 2 Success Stories
  • Fluorescently labeled DNA (B. Sutherland/B. Paap) – published paper
  • Formaldetox
ls ems fy07 objectives and targets clean up existing disposition excess materials
LS EMS FY07 Objectives and TargetsClean Up Existing: Disposition Excess Materials

Cleanups in FY07:

  • General Chemical Cleanout
    • 278 items of Unwanted chemicals/rad materials disposed of
      • ~250 lab chemicals
  • Biology
    • Removed trailer behind 463
    • Cleaned out 421’s machine shop chemicals
    • Decommissioned TEM room (Hg, asbestos, industrial wastes)
  • Medical – 490
    • Bin CC
    • Legacy clinical samples
    • 9-901:John Glass’ lab in progress
    • Bin F removed D20 and borated H20
    • Rad Asbestos tiles in 490 (400lbs)
  • Imaging-901
    • High Bay (bulk oil drums)
    • Reduced Sealed Source Inventory
    • Started area around cyclotron
waste trending
Waste Trending
  • 901 Cleanout
  • Haz/Ind: 865 lbs
  • Rad Lq: 62 gal
  • Rad S: 3.0 cuft
ls ems fy07 objectives and targets continual improvement assessments
LS EMS FY07 Objectives and Targets Continual Improvement: Assessments

Have we adequately addressed internal audits and evaluations of compliance?

Do you have any comments on internal audits and evaluation of compliance?

Does this meet our needs?

Any other comments/suggestions?

life sciences osh hazards
Life Sciences OSH Hazards
  • Chemicals (all classes including pesticides)
  • Biologicals
  • Radiation (ionizing, non-ionizing, UV)
  • Lasers
  • Compressed Gases
  • Cryogenic Liquids
  • Electrical
  • Noise
  • Oxygen Deficiency
  • Animals (Bite/Scratch/Allergies)
  • Clinical/Needlesticks/Bloodborne
  • Power Tools
  • Thermal (Steam and Cold)
  • Material Handling
  • Machine Shops
ohsas status
OHSAS Status
  • Implementation completed in FY07
    • Internal Audit went well – no Life Sciences findings
    • NSF Registration and surveillance had no findings.
  • Feedback during implementation
    • Some improvements were identified in process.
    • Staff has not found value in participating in JRAs/FRAs.
  • Status
    • Continue to conduct JRAs as required and maintain system. Will need to revisit 50% this year (3yr cycle)


    • Attempting to embed into Work Planning
    • Is OHSAS here to stay?
fy07 progress on osh targets objectives compliance
FY07 Progress on OSH Targets/ObjectivesCompliance


  • Electrical Safety
    • Implement the NRTL program- continue inventory of non UL listed equipment
      • 901 still not completed.
    • Did complete the inspection of BNL built equipment in 490, 463, 801, 931.
    • Conducted Tier I on exposed wires
  • Biological Safety
    • Implemented Emergency Plan for select agents and EPHA for biologicals (DOE)
    • CDC Select Agent Audit completed—minor findings all corrected.
  • IH Monitoring
    • Biological monitoring program in place
    • Rodent allergen methodology not completed. OMC conducted a review of issue. Recommended monitoring. In IH scheduler. Need response before AALAC beginning CY08.
fy07 progress on osh targets objectives osh management
FY07 Progress on OSH Targets/ObjectivesOSH Management
  • Submit two S2 proposals and/or success stories
    • 7 submitted, 3 funded.
  • Encourage zero traffic violations by communicating reqmts to staff
    • Complete—at staff meeting, in new employee/guest handout, in student orientation.
    • Traffic violations increased
  • Complete/Submit 851 Gap analysis
    • Small science submitted.
    • Identified gaps site wide and needed institutional action first.
  • Zero lost work day cases/zero OSHA Recordable
  • Participate in Document Control causal analysis
    • Causal analysis complete. Subject Area revision in process.
fy07 progress on osh targets objectives osh management1
FY07 Progress on OSH Targets/ObjectivesOSH Management
  • Goal: Submit 2 Safety Solutions (S2) Proposals—7 submitted/4 Completed
    • Gate OPEN/CLOSED Closer to Wm Floyd –Installed FY07
    • Propane Isolation Valves for labs in 490 –Funded/Completed
    • Joint P2/S2 for chemical assessment/cleanout—Funded/Complete
    • Exhaust Ventilation for Waste Anesthesia Gas in micro-MRI Facility (FUNDED by program)
    • Web Based Database for Tier 1 ESH&Q Inspections
    • BNL Uniform Hazard Identification Placards
    • Offset (Staggered) Stop Lines on Main Gate Outbound Lanes

# Days since Last

Lost Work Day


MO: 3598

Occupational Injury Cases

Life Sciences

occupational injury cases life sciences
Occupational Injury CasesLife Sciences
  • 11 Clinic visits in FY07. No DART or OSHA recordable cases


    • Finger cut on cracked test tube
    • Hypersensitivity to beta mercaptoethanol (BME)


    • 5 Animal bite/scratches
    • 3 finger cuts
    • Minor chemical burn
  • Not tracked--Continued complaints regarding Indoor air quality-related issues (real or perceived) are a problem—mold, temperature, humidity, odors, etc – will request duct cleaning/ regular filter changing.
  • Vet to conduct orientation training on handling if worker is bitten/scratched by animal.
safety health
Safety & Health
  • Chemical assessment done in Life Sciences –

over 100 work hours spent reviewing storage of chemicals, and CMS re-inventory. Many issues resolved during assessment including:

segregated containers in poor condition for disposal.

    • Missing barcodes
    • Flammables moved to flammable cabinets
    • OSHA Particularly Hazardous put in secondary containment (sodium azide, mercury, cadmium)
    • Peroxide formers identified that needed testing or disposal
    • CMS Inventories still not updated
  • Oxygen Deficiency Hazards reviewed for all locations in Life Science where Liquid Nitrogen dewars are used. No locations require ODH posting. Will need to submit to BNL ESH committee.
  • Nanosafety Status
    • Gifford, Schiffer, Gang
    • Issue: Gold work (Hainfeld, Dilmanian)- apply for exemption?
safety and health ih monitoring program
Safety and HealthIH Monitoring Program
  • Status of Monitoring (based on 1 sample only)
  • Issues
    • Difficult to track/validate –two databases tracking data.
    • Researchers aren’t doing the work. It’s in ESR because they may need to use it but in many cases do not.
    • Difficult to get them to remember to notify us before starting work with a chemical we need to monitor.
  • Need methodology for rodent allergen testing before AALAC
traffic violations
Traffic Violations

Represents 8% of site total (290)

Similar in other small science areas with similar staffing levels (CO-5, PO-9, AD-14).


- link to performance appraisal for employees?

- pay for defensive driving course?

biological safety program
Biological Safety Program
  • 851 Gap Analysis status
    • Site Emergency Planning program –updated, includes CDC and DOE reqmts.
    • Clear roles and responsibilities –Worker Safety and Health MSD updated
    • Monitoring for biologicals – in place
    • CDC Site Visit – 3 minor findings, all fixed (recordkeeping)


  • Full DOE Emergency Management Audit to be conducted in June—one area will be biologicals.
  • IBC has AHJ and must report semi-annually to the BNL Director on status of program. Will plan after annual IBC meeting in Nov. to start.
radiological control program
Radiological Control Program


  • No ORPS/contaminations in 490 since consolidated work area.
  • Imaging group meetings cover safety related issues (ie proper frisking)-noteworthy in audit. FS attends
  • FS has been instrumental in cleanouts:
    • Bin CC completely emptied of Rad Material (prevented onset of long term RMA requirements)
    • Sealed source inventory reduced significantly in 901.
site totals all medical dept personnel contaminations
Site Totals –All Medical Dept.Personnel Contaminations
  • Personnel Contamination – 2006
    • 02/23 – Personnel Cont at Building 901
    • 03/22 – Cont Detected on Employee's Shoes at PET
    • 03/28 – Cont of two workers at B-801 during removal of BLIP target filter
  • Personnel Contamination – 2007
    • 04/26 – F-18 finger contamination at PET

MO has 4—total for site! Why?

    • There has been improvement over time
    • Activity Levels-- one drop is 10’s of thousands of dpm!
    • Work planning—
        • 2 contams from breakthrough with gloves (ammonia and mineral oil) FS is including glove type on new RWPs.
    • Fast Pace of work--Is the pace causing inattention to detail?
    • Could bring in SME to review PET program in FY08? Funds needed


  • FY07 ATS Status
    • 17 Action Items assigned/ 12 Closed
events issues management life sciences categorized events list
Events/Issues ManagementLife Sciences Categorized Events List
  • 9/28/07 Researcher contaminates himself with Nitrogen-13 (SC-4)
  • 9/24/07 Empty sharps container found in animal bedding compost during disposal
  • 9/13/07 Research assistant suffers mild allergic reaction to chemicals
  • 9/12/07 Exposed Wiring Electrical Hazard in Building 490, SC3
  • 9/05/07 Lab Coat Sleeve burned by contact with bunsen burner flame, SC3
  • 07/05/07  Building 801 D Tank Leak
  • 05/22/07 Worker receives 1st degree chemical burn due to small hole in glove
  • 05/16/07 Employee lacerates arm while cleaning a microtome
  • 05/16/07 Medical Student Passes Out
  • 04/26/07 F-18 finger contamination – Bldg 901
  • 01/03/07 F-18 Contamination at PET, Building 906
  • 11/26/06 Contamination at PET Facility (Building 906), SC3
  • 10/31/06 BLIP Cooling Water leak detection system did not function during testing

13 Events Categorized

fy07 esh financial investments
FY07 ESH Financial Investments
  • OHSAS –Not tabulated, significant internal resources required for system implementation, maintenance and risk assessments.
  • SHSD Support (G&A)
    • ~0.3 FTE SHSD Rep (G&A) – ESRs, Tier Is, Monitoring
    • ~0.3 IH Monitoring, some support for UL inventory
  • RCD Program Costs - $918.4K (FY06: $812.6K)
fy07 esh financial investments1
FY07 ESH Financial Investments
  • EMS - ~$360k
    • ECR ~0.4 FTE
    • Waste Disposal $301K (FY07 $247K) + $20K for RMW
    • Waste Management Rep $38K (P2 funded some work)
      • $3K BO cleanouts
      • $22K MO cleanouts
      • $13K RMW program
ls stakeholder concerns outreach
LS Stakeholder Concerns/Outreach


  • BLIP Soil Activation
    • Working with CAD and EWMS (quarterly monitoring)—CAC meetings
  • 0 Spills caused by MO/BO personnel
  • Concerns about Indoor Air Quality in some areas– case by case.
  • Biosafety across US under close scrutiny from recent incidents


  • Summer Sunday ~800 visitors (not on summer 08 schedule)
  • ~40 summer students
  • Safety review discussions, newsletter, meetings.
  • Do we need a Safety Committee or Ideas Program?

Have we adequately addressed communications?

Do you have any comments on communications?

Does this meet our needs? ESH Committee/Ideas program?

Any other comments/suggestions?

fy07 summary
FY07 Summary
  • What went well
    • Environmental targets/objectives were met
    • OHSAS Registration achieved
    • IH Monitoring –making some progress (biologicals complete)
    • Emergency planning for biologicals- in place
    • ISM Audit—some improvements needed.
    • Chemical Assessment
  • What needs improvement
    • Rad Work practices – improvements in progress but still contaminations.
    • Electrical Safety Program plan – not sure where we stand
    • OHSAS– negative worker feedback on process, not well integrated
    • Chemical Hygiene and RCRA
  • What would help us
    • Roll up of programs to Institutional level where appropriate (EMS, OHSAS)
    • Electronic ESR form for all of small science
    • Assistance with 901 ERE items—waste allocation (currently all MO)?
    • Funding for PET SME to review/train
work ahead goals fy08
Work Ahead (Goals FY08)


  • Chemical Hygiene-focus on OSHA Particularly Hazardous (disposal or proper storage, labeling, use)
  • PPE- keep up with subject areas, better flow down to workers.
  • Complete upgrade of BLIP SAD
  • PET review to reduce contams
  • RCRA- meeting where repeat violations occur
  • 851 Compliance – follow plan once it’s developed
  • Emergency planning – conduct an internal assessment in 2nd qtr and then participate in DOE audit in 3rd qtr.


  • Continue to dispose of excess materials (UMCs)- FY07 Resources?
    • 490 9-901 cleanout, basement hallways, Bin F, Bin T, Bin B, lead-planter (legacy wastes), Hot Waste sampling room, lead lined room
    • 463- high bay cleanout
    • 801 – remove/dispose of out-of-service crane
    • 901 ERE –update project plan and work to meet goals.
work ahead goals fy081
Work Ahead (Goals FY08)

Waste Minimization and P2

  • Two (minimum) P2 proposals and success story reporting
  • Reduce Greenhouse Gas Emissions–Submit P2 for light timers
  • Encourage staff to set energy saver functions on computers, other eqpt.

Accident and Injury Prevention

  • Hands on training with veterinarian after animal bite/scratch
  • Request duct cleaning/filter changing for IAQ issues
  • Review highest risk JRAs (top 50%) or incorporate into Work Planning for revision.
  • Submit two S2 proposals and/or success stories.
  • Work Observations (24/yr ALD and 12/yr Chair, Level 3s 2/yr)


  • Encourage staff to participate in lab level safety initiatives
  • Participate in CAC (as appropriate)
  • Ideas program?

Continual Improvement

  • Combine OSH, EMS, ISM rqmts where appropriate (ie JRAs in ESRs)
work ahead goals fy08 cleanup
Work Ahead (Goals FY08)Cleanup

Are our ‘08 objectives and targets adequate?

Do you have any comments on objectives and targets?

Do they meet our needs?

Any other comments/suggestions?

901 Issues

Oxidized Lead-X-ray Rm

Bin T

Lead Planter

senior management ism program evaluation
Senior Management ISM Program Evaluation
  • Purpose: Identify improvement actions and assign responsibility and resources to implement
senior management ism program evaluation question 1
Senior Management ISM Program Evaluation-Question 1
  • Is the program effective in achieving policy commitments?
    • Compliance
      • Tier Is, Work Planning, Assessments
    • Pollution Prevention
      • Work planning, P2 program success
    • Worker Safety
      • SHSD Field Rep, S2 program
    • Community Outreach
      • CAC, Summer Sundays, tours
    • Clean Up
      • Lab cleanouts, ERE process
    • Continual Improvement
      • Assessments, lessons learned, program improvements
senior management ism program evaluation question 2
Senior Management ISM Program Evaluation-Question 2
  • Is the program effective in achieving objectives and performance measures?
    • Compliance
      • Tier Is, Work Planning, assessments
    • Pollution Prevention
      • Work planning, P2 program success
    • Worker Safety
      • S2 Program, SHSD Field Reps
    • Community Outreach
      • CAC, Summer Sundays, tours
    • Clean Up
      • Lab cleanouts, ERE process
    • Continual Improvement
      • Assessments, incorporating lessons learned
senior management ism program evaluation question 3
Senior Management ISM Program Evaluation-Question 3
  • Are the programs adequate in terms of:
    • Identifying significant aspects, hazards and impacts?
      • Work planning, process assessments
    • Resource Allocation?
      • ESH staff, FS, ECR, funding for cleanouts, safety improvements
    • Communication?
      • Training, work planning, emails, outreach
    • Goals and Objective
      • Do we do enough or too much? Are we missing anything important?
    • Information systems?
    • Staff expertise? ESH, ECR, SHSD, SMEs
    • Procedural requirements?
senior management ism program evaluation question 4
Senior Management ISM Program Evaluation-Question 4
  • Are the Objectives & Performance Measures and System suitable in terms of:
    • impacts & current conditions?
    • concerns of stakeholders?
    • current and future regulatory requirements?
    • business interests; technological capability?
    • internal organizational or process changes
    • should additional measures be established
senior management ism program evaluation question 5
Senior Management ISM Program Evaluation-Question 5
  • Recommended revisions to:
    • ESSH policy & commitments?
    • objectives & performance measures?
    • elements of system?
fy 2007 waste info
FY 2007 Waste info

LEGACY vs Routine