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Implementation of DOE’s Worker Safety and Health Rule 10 CFR PART 851 Using DOE’s Integrated Safety Management System to Meet 10 CFR 851 Hazard Identification and Abatement Requirements. Frank Russo Environment, Safety, and Health Advisor National Nuclear Security Administration.

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Implementation of DOE’s WorkerSafety and Health Rule10 CFR PART 851Using DOE’s Integrated Safety Management System to Meet 10 CFR 851 Hazard Identification and Abatement Requirements

Frank Russo

Environment, Safety, and Health Advisor

National Nuclear Security Administration

origin and purpose of the new rule
ORIGIN AND PURPOSE OF THE NEW RULE
  • National Defense Authorization Act of 2003 Added Section 234C to the Atomic Energy Act
  • Congress Required DOE to Promulgate New Worker Safety and Health Regulations That Would:
    • Maintain “The Level of Protection Currently Provided to … Workers”
    • Provide Flexibility to Tailor Implementation to Site-Specific Hazards
    • Recognize Special Circumstances for “Closure” Facilities
    • Authorize Price-Anderson Amendments Act (PAAA) Civil Penalties or Fee Reductions for Violations - Enforcement Inspections Conducted by HSS Organization
doe s response to congress direction
DOE’S RESPONSE TO CONGRESS’ DIRECTION
  • Final Rule Published – February 9, 2006
  • Effective Date – February 9, 2007
  • The Final Rule:
    • Requires Preparation and Submittal of Worker Safety and Health Programs for DOE Approval by February 26, 2007
    • Establishes Specific Safety and Health Requirements
    • Establishes WSH Enforcement/Penalty Regime
subpart a general provisions
SUBPART A – GENERAL PROVISIONS
  • Governs Contractor and Subcontractor Activities at DOE Sites
  • Exclusions from the Rule:
    • Work Regulated by OSHA
    • Naval Nuclear Propulsion Program Activities
  • Contractors Subject to Civil Penalties Up to $70,000 Per Violation or Reduction in Fees
subpart b program requirements
SUBPART B – PROGRAM REQUIREMENTS
  • Contractors Must:
    • By February 26, 2007 Submit Written Worker Safety and Health Program to the Head of the DOE Field Element for Approval
    • Submit One Program for All Covered Workplaces at a DOE Site If the Contractor Is Responsible for More Than One Such Workplace
    • Develop and Maintain Its Own Program, in Coordination with Other Contractors at Multi-Contractor Workplaces
subpart b program requirements6
SUBPART B – PROGRAM REQUIREMENTS
  • A Contractor Must:
    • Provide a Place of Employment Free from Recognized Hazards that are Causing or Have the Potential to Cause Death or Serious Physical Harm
    • Ensure Work is Performed in accordance with the Worker Safety and Health Program for that Workplace
    • Flowdown Requirements to any Subcontractors
subpart b program requirements7
SUBPART B – PROGRAM REQUIREMENTS
  • The Worker Safety and Health Program Must:
    • Describe Methods for Implementing the Specific Rule Requirements of Part 851
    • Integrate the Requirements with the Integrated Safety Management System
  • As of May 25, 2007, Full Compliance Must Be Achieved and “No Work May Be Performed at a Covered Workplace Unless an Approved … Program Is In Place”
subpart c specific program requirements
SUBPART C – SPECIFIC PROGRAM REQUIREMENTS
  • Management Responsibilities and Worker Rights and Responsibilities
  • Hazard Identification and Assessment
  • Hazard Prevention and Abatement
  • Safety and Health Standards/Functional Areas
  • Training and Information
  • Recordkeeping and Reporting
subpart c worker involvement in 10cfr851 safety and health program
SUBPART C – WORKER INVOLVEMENT IN10CFR851 SAFETY AND HEALTH PROGRAM
  • Workers Involved in Program Development
  • Workers Have Access to Relevant Information
  • Workers Can Report Job-Related Injuries and Identify Workplace Hazards Without Reprisal
  • Workers Permitted to Stop Work or Decline to Work When a Hazard is Perceived
  • Workers Informed of Their Rights and Responsibilities by Appropriate Means (Poster)
subpart c work planners are integral to 10cfr851 implementation
SUBPART C – WORK PLANNERS ARE INTEGRALTO 10CFR851 IMPLEMENTATION
  • Section 851.21 - Hazard Identification and Assessment Requires Contractors:
    • Identify and Assess Existing and Potential Hazards: Chemical, Physical, Biological, or Safety
    • Analyze Facility Designs and Modifications for Potential Workplace Hazards
    • Evaluate Operations, Procedures, and Facilities to Identify Workplace Hazards
    • Perform Routine Job Activity-Level Hazard Analysis
subpart c work planners are integral to 10cfr851 implementation cont
SUBPART C – WORK PLANNERS ARE INTEGRALTO 10CFR851 IMPLEMENTATION (Cont.)
  • Section 851.22 - Hazard Prevention and Abatement Requires Contractors:
    • Implement a Hazard Control Process to Ensure All Identified and Potential Hazards are Prevented or Abated
    • Hazards Must be Identified During Facility Design and Procedures Development and Appropriate Controls Incorporated into the Final Design and Procedures
    • For Existing Hazards, Prioritize and Implement Abatement Actions to Protect Workers
    • Select Hazard Controls Based on DOE Hierarchy of Controls
      • Elimination or Substitution
      • Engineered Controls
      • Work Practices or Procedures
      • Personal Protective Equipment
subpart c using ism for hazard identification and abatement

Chemical Exposure

Hazard

Application of ISM

Control Measure(s)

Infrequent Drum Opening

Existing Facility:

Implement Controls Necessary to Protect Worker

Work Instructions Require Adequate Ventilation and Workers to Wear Appropriate Personal Protective Equipment

Modifying Facility: Design Incorporates Controls Necessary to Protect Worker

Routine Opening Drum of Hazardous Chemicals

Engineering Controls established so Work is Performed Within Ventilated Containment Incorporated into Facility Design

SUBPART C – USING ISM FOR HAZARD IDENTIFICATION AND ABATEMENT
upcoming activities
Upcoming Activities
  • DOE 851 Implementation Guide Being Developed
  • DOE Integrated Enforcement Program Guidance Available for Review and Comment
  • Voluntary Noncompliance Reporting in DOE’s Enforcement WHS Noncompliance Tracking System in Progress
  • DOE Mock Inspection Lessons Learned to be Issued
  • DOE Developing “Standard Review Plan” Approach for Contractor Program Plan Reviews
  • DOE Regional Workshops
  • Joint EFCOG/DOE 851 Project Meetings