ISM Workshop April 25, 20061 DOE HQ ISM Champions Workshop Contractor Session “DOE Policy Order...

ISM Workshop April 25, 2006 1

DOE HQ ISM Champions WorkshopContractor Session

“DOE Policy Order 226.1”Oversight Policy & Implementation


Background

Policy Issued 6/10/05 Establishes New Model for DOE Oversight Establishes Requirement for HQ Approval

of Contractor Assurance System Program Descriptions and Annual Updates Can Be Delegated to DOE Field Elements

Establishes Clear Roles and Responsibilities for Federal Organizations and Leaders


Background continued

Order issued 9/15/05 Required to be in Contracts NLT 3/06 Establishes Detailed Requirements for:

Scope of Assurance Activities Assessments Event Reporting Worker Feedback Issues Management Lessons Learned, and, Performance Measures


Contractor Requirements Document

General Requirements Expands Assurance activities beyond ESH

to S&S, Cyber, Emer. Mgt., Bus. Ops, etc. 6 Detailed Requirement Areas

Requires Contactor Assurance System data to be documented and available to DOE

Part of Contract Performance Evaluation

Requires Corporate Audits, 3rd Party Certifications, External Reviews



Assessments No Significant Changes

Event Reporting No Significant Changes

Worker Feedback Employee Concerns plus ……….

Issues Management Requires Comprehensive Structured System Extensive Set of Requirements Identified

“… must include provisions for communicating and documenting dissenting opinions.”

Requires Process for Dispute Resolution for Findings and Issues



Lessons Learned Very General New DOE Order for Operating Experience

Issuance Pending 6 Month Period for Contract Incorporation

Performance Measures Requires Structured Approach to Development and

Application of Performance Measures Note: EFCOG‘s Performance Metric Manual Available

at no cost to all DOE and DOE Contractors


Discussion – Q & A’s

Your Thoughts ?? Significant Issues ?? What can we provide to make

implementation easier? Plus……………………………………

..



“Measuring And Monitoring ISM Improvements”

aka“Safety Performance Objectives,

Measures & Commitments”


Background

DEAR Clause Requirement Annually Requires us to submit to DOE,

for Approval, Safety Performance Objectives, Performance Measures & Commitments Consistent with DOE Program and Execution

Guidance

Being Implemented in Different Ways



Proposed DOE Direction Focuses on:• Performance Objectives (Strategic)

• Long Term Multi-year Goals

• Performance Commitments (Tactical)

• Action for One Year, Support Performance Objectives

• Performance Measures

• Annually Established, Track Progress and Monitor Achievement of Objectives and Commitments

• Ideally Combination of Leading & Lagging Indicators


Discussion

How is done at your location? What are the Key Elements of your

Submittals to DOE Should this be Institutionalized by

DOE across all Contractor Operations? Plus / Minus Discussion

Should EFCOG provide Contractor Guidance Document?



“Feedback & Improvement”


Background

DNFSB Views as Critical Issue De-centralized Safety Oversight

Delegation of Oversight Responsibilities

Need Improved Program for Managing Operating Experiences from External Low-probability, High-Consequence Events

DNFSB Issued Tech. Reports 35 & 36 Tech. Rpt. 35 Focused on DOE HQ / Fld. Orgs

Tech. Rpt. 36 Focused on both DOE and Contractors



Tech. Report 36 Highlights F/I viewed as Ineffective ISM Core Function Significant Variance from Site to Site Need focus on:

Rewarding Self-reporting of Errors Improved Categorization of Problem

Significance Perception of Under-classification

Better Accountability of Workers/Managers


2004-1 F/I Assessment Results

Most Sites Reported Partial but Substantial Compliance to the New DOE Requirements

Some Gaps in Requirements Flowdown Related to New Contracts

Identified Improvements were Related to: Planning, Conducting and Determining Effectiveness of

Self-Assessments Corrective Action Identification & Closure Implementation

Categorization of Problem Significance Performance Trending & Analysis Worker Feedback Processes Positive Reinforcement for Self-reporting of Errors


F/I Assessment Results cont’d

Typically All Parts of the Contractor Assurance System are being Implemented within Contractor Management Systems but are: Not Holistically tied together Being Managed by Multiple Organizations

New Requirement for CAS Description Stand Alone Document, Part of ISM Description

Document, Part of QA Program Document, etc.


Discussion

Your view on the subject? What are the areas needing most

improvement? Are performance barriers being created

by the CAS approach? What are the top 3 to 5 Issues that

impact CAS implementation? What can EFCOG do to help the

Contractor Community?



“Work Planning & Control”


Background

Critical Activity Level ISM Issue Current Areas Needing Improvement

Hazard Identification & Analysis Processes to Ensure “Right” Controls are in Place Increased Recognition of “Scope Creep”

Renewed Emphasis on Stopping, Reanalyzing Hazards and Addressing Controls

Written Work Procedures Job Planning Participation Post-job Worker Feedback Open Critiques of Job Errors, and Qualification of Work Control Managers & Planners


2004-1 WP&C Assessment Results

Wide Variation in Implementation of WP&C Processes among Contractors

Inadequate Hazard Analysis and Identification of Controls were Widespread Issues Failure to Adequately Cover Hazard Controls in

Work Instructions Some Contractors Identified as only Applying

WP&C Principles to Maintenance Activities Needed for Ops, R&D, D&D


WP&C Assessment Results cont’d

Training & Qualification Issues for Work

Planning Personnel Identified

Clear & Concise Work Instructions Identified

as a Broad Issue across the entire complex


Discussion

What are the areas needing the most improvement?

What are the top 3 to 5 Issues that impact Effective WP&C implementation?

What Changes would you Recommend to the Customer? Should WP&C Process be Standardized

across Complex? What can EFCOG do to help the

Contractor Community?



“10CFR851”Worker Safety & Health Program

Regulation


Background

National Defense Authorization Act 2003 Maintain “The Level of Protection Currently

provided to workers……” Tailor Implementation to Site-specific Hazards Recognize Special Circumstances for “Closure”

Facilities Authorizes PAAA Civil Penalties or Fee Reductions

for Violations (Not Both) Final Rule Published 2/’06, Effective 2/’07



Codifies Existing Worker & Health Requirements (DOE Order 440.1A)

Written Worker Safety & Health Program Plans/Documents to be Submitted to DOE NLT February 26, 2007 DOE Approval NLT May 25, 2007

No Work to be accomplished after Compliance date without an Approved Program



Customer Perspective at this time reflects that Contractors: Have Verified ISM Systems in place Currently Comply with 440.1A

Requirements Currently have written Worker Protection

Program, Therefore, If meeting Contractual

Responsibilities…. “Little, if any, additional work will be necessary”


Elements of the New Rule

Subpart A – General Provisions Subpart B – Program Requirements Subpart C – Specific Program Requirements Subpart D – Variances Subpart E – Enforcement Process Appendix A – Functional Areas Appendix B – Enforcement Policy


Status / Upcoming Activities

Orientation Workshops In Progress Implementation Workshops Planned for

Sept. – Dec. 2006 Locations TBD

Enforcement Program Development In Progress Procedures/Protocols in Development Prototype Inspections June – Aug. 2006 Finalization of WHS NTS Thresholds – Dec. 2006


Discussion

Do you consider this Rule to be a Critical Contract Issue?

What areas of the Rule are you most concerned about?

What is the right level for the Enforcement Reporting Thresholds?

From your Perspective are there Unresolved Policy Issues?

Other Concerns ……. ?????????


EFCOG 10CFR851 Summary

EFCOG Chair & DOE HQ EH-1 Agreed to Work Together on Implementation

EFCOG Board of Directors Elected to form Separate 10CFR851 Project Team Senior Leadership Team from EFCOG Board

Dave Amerine (Parsons), Pam Horning (BWXT), Bob Pedde (WSRC), and, Mike Schlender (PNL)

Board Project Manager – Joe Yanek (WSRC) Project Leads from ISM & PAAA Working Groups

Barb Hargis (LANL) & Bill Luce (WSRC)


EFCOG Activity Summary continued

Direct Interface established with DOE HQ Program Manager, Project Manager and Technical/PAAA Leads

Activities to date includes providing input on: Proposed Reporting Thresholds for WHS

(PAAA) Noncompliance Tracking System (NTS)

Draft Implementation Guide


Path Forward

This Afternoon’s PSO Break-outs Provide Opportunity for you to Express your Views and Concerns in each of the Five Topical Areas

Wednesday Panels will provide PSO Cross-cutting Feedback in Each of the Five Areas You may be Asked, or you can Volunteer, to be

the PSO Spokesperson on a Panel Significant Opportunity to Influence the

Direction being taken in the Five Topical Areas


Closing Remarks

Dave Amerine, EFCOG Chair

ISM Workshop April 25, 20061 DOE HQ ISM Champions Workshop Contractor Session “DOE Policy Order...

Documents

Transcript of ISM Workshop April 25, 20061 DOE HQ ISM Champions Workshop Contractor Session “DOE Policy Order...