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DOE HQ ISM Champions Workshop Contractor Session

DOE HQ ISM Champions Workshop Contractor Session. “DOE Policy Order 226.1” Oversight Policy & Implementation. Background. Policy Issued 6/10/05 Establishes New Model for DOE Oversight

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DOE HQ ISM Champions Workshop Contractor Session

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  1. DOE HQ ISM Champions WorkshopContractor Session “DOE Policy Order 226.1” Oversight Policy & Implementation ISM Workshop April 25, 2006

  2. 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 ISM Workshop April 25, 2006

  3. 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 ISM Workshop April 25, 2006

  4. 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 ISM Workshop April 25, 2006

  5. Contractor Requirements Document • 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 ISM Workshop April 25, 2006

  6. Contractor Requirements Document • 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 ISM Workshop April 25, 2006

  7. Discussion – Q & A’s • Your Thoughts ?? • Significant Issues ?? • What can we provide to make implementation easier? • Plus…………………………………….. ISM Workshop April 25, 2006

  8. DOE HQ ISM Champions WorkshopContractor Session “Measuring And Monitoring ISM Improvements” aka “Safety Performance Objectives, Measures & Commitments” ISM Workshop April 25, 2006

  9. 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 ISM Workshop April 25, 2006

  10. Background continued • 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 ISM Workshop April 25, 2006

  11. 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? ISM Workshop April 25, 2006

  12. DOE HQ ISM Champions WorkshopContractor Session “Feedback & Improvement” ISM Workshop April 25, 2006

  13. 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 ISM Workshop April 25, 2006

  14. Background continued • 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 ISM Workshop April 25, 2006

  15. 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 ISM Workshop April 25, 2006

  16. 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. ISM Workshop April 25, 2006

  17. 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? ISM Workshop April 25, 2006

  18. DOE HQ ISM Champions WorkshopContractor Session “Work Planning & Control” ISM Workshop April 25, 2006

  19. 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 ISM Workshop April 25, 2006

  20. 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 ISM Workshop April 25, 2006

  21. 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 ISM Workshop April 25, 2006

  22. 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? ISM Workshop April 25, 2006

  23. DOE HQ ISM Champions WorkshopContractor Session “10CFR851” Worker Safety & Health Program Regulation ISM Workshop April 25, 2006

  24. 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 ISM Workshop April 25, 2006

  25. Background continued • 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 ISM Workshop April 25, 2006

  26. Background continued • 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” ISM Workshop April 25, 2006

  27. 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 ISM Workshop April 25, 2006

  28. 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 ISM Workshop April 25, 2006

  29. 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 ……. ????????? ISM Workshop April 25, 2006

  30. 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) ISM Workshop April 25, 2006

  31. 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 ISM Workshop April 25, 2006

  32. 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 ISM Workshop April 25, 2006

  33. Closing Remarks • Dave Amerine, EFCOG Chair ISM Workshop April 25, 2006

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