ism workshop april 25, 20061 doe hq ism champions workshop contractor session “doe policy order...
TRANSCRIPT
ISM Workshop April 25, 2006 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