DOE O 251.1D, Departmental Directives Program
Functional areas: DOE Directives, Requires Crosswalk When Revised
The Order establishes directives as the primary means to set, communicate, and institutionalize policies, requirements, responsibilities, and procedures for Departmental elements and contractors. Supersedes DOE O 251.1C.
Supersedes:
DOE O 251.1C, Departmental Directives Program on Jan 17, 2017
Superseded By:
DOE O 251.1D Chg 1 (Admin Chg), Departmental Directives Program on Nov 08, 2019
Version history and related documents
Superseded by
A newer version replaces this document.
Supersedes
Earlier documents this one replaced.
- DOE O 251.1CDepartmental Directives Program (Jan 17, 2017)
Document text
Text extracted from the attached file. Refer to the original document for the authoritative version.
Section 1
AVAILABLE ONLINE AT: INITIATED BY:
www.directives.doe.gov Office of Management
U.S. Department of Energy ORDER
Washington, D.C.
Approved: 1-17-2017
SUBJECT: DEPARTMENTAL DIRECTIVES PROGRAM
1. PURPOSE. To establish directives as the primary means to set, communicate, and
institutionalize policies, requirements, responsibilities, and procedures for Departmental
elements and contractors.
a. Directives facilitate achievement of the Department of Energy’s (DOE’s)
strategic and operational goals. They also help to ensure safe, secure, efficient,
cost-effective operations and compliance with applicable legal requirements.
b. Directives promote operational consistency throughout the DOE complex and
foster sound management.
2. CANCELS/SUPERSEDES. DOE O 251.1C, Departmental Directives Program, dated
1-15-09. Cancellation of a directive does not, by itself, modify or otherwise affect any
contractual or regulatory obligation to comply with the directive.
3. DEPARTMENTAL APPLICABILITY.
a. Departmental Elements.
(1) With the exception of the equivalencies/exemptions listed in paragraph
3.c., this Order applies to all Departmental elements.
(2) The Administrator of the National Nuclear Security Administration
(NNSA) must ensure that NNSA employees comply with their
responsibilities under this directive. Nothing in this directive will be
construed to interfere with the NNSA Administrator’s authority under
section 3212(d) of Public Law (P.L.) 106-65 to establish
Administration-specific policies, unless disapproved by the Secretary.
b. Contractors. This Order does not apply to contractors.
c. Equivalencies/Exemptions for DOE O 251.1D.
(1) Requests for Equivalencies and Exemptions to this Order must be sent in
memorandum form to the Director, Office of Management, for advice.
(a) The memorandum must briefly justify the reasons for the
equivalency or exemption.
(b) The memorandum must reference the offices, or localities, and
requirements for which the equivalency or exemption is sought.
DOE O 251.1D
http://www.directives.doe.gov/
2 DOE O 251.1D
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(2) Equivalency. In accordance with the responsibilities and authorities
assigned by Executive Order 12344, codified at 50 U.S.C. sections 2406
and 2511 and to ensure consistency through the joint Navy/DOE Naval
Nuclear Propulsion Program, the Deputy Administrator for Naval
Reactors (Director) will implement and oversee requirements and
practices pertaining to this Directive for activities under the Director's
cognizance, as deemed appropriate.
(3) Exemption. The Procurement Management System is exempt from this
Order when not in conflict with a Departmental Directive. DOE heads of
contracting activities (HCAs) will have an opportunity to review and
comment on draft Acquisition Letters (AL) that would significantly
affect the contract terms and conditions of management and operating
contracts or other site and facility management contracts, or would
materially affect contractor performance.
(4) Exemption. The Office of the Chief Financial Officer (CFO) is exempt
from this Order when developing and issuing the CFO’s Financial
Management Handbook. However, DOE Field CFOs will be afforded a
reasonable opportunity to review and comment on draft handbook
chapters that provide guidance, instruction or direction to Field CFOs.
(5) Exemption. CFO budget calls, which provide guidance, instruction and
direction to Headquarters Departmental elements and the field on the
preparation of budgets.
Section 2
(6) Exemption. Guidance, direction and instruction issued by the
Department’s Designated Agency Ethics Official (DAEO) in carrying out
the DAEO’s responsibilities required by law or by the Office of
Government Ethics, or as determined necessary by the DAEO in carrying
out the Department’s ethics and standards of conduct program.
(7) Exemption. Guidance, direction, legal interpretation and instruction issued
by the Department’s General Counsel (or NNSA’s or any Power
Marketing Administration’s General Counsel) to, or concerning the
management of, the Department’s (or NNSA’s or any Power Marketing
Administration’s) attorneys and the legal services and advice they render.
Legal guidance, direction, interpretation or instruction issued by an
attorney of the Office of the General Counsel, NNSA General Counsel or
any Power Marketing Administration Office of General Counsel is within
this exemption.
(8) Exemption. Guidance, direction and instruction issued by the Office of the
Chief Human Capital Officer (CHCO) (when not in conflict with a
Departmental Directive) related to the proper execution of human
resources authorities and processes within the Department.
DOE O 251.1D 3
1-17-2017
(9) Exemption. Instructions regarding Appendix E for human resources
related Orders. For non-NNSA organizations, an exemption or
equivalency must be approved by the CHCO. For NNSA, an exemption or
equivalency must be sent to the CHCO for review and comment. If the
CHCO has any comments that are not resolved to the satisfaction of the
CHCO and NNSA, the CHCO and the NNSA Administrator shall jointly
submit the dispute to the Deputy Secretary or the Secretary for resolution.
4. REQUIREMENTS.
a. General.
(1) Principles for Directives Development. Directives must adhere to the
Principles for Directives Development listed in Appendix D.
(2) Department of Energy (DOE) Operations Committee. The DOE
Operations Committee must be maintained to provide strategic oversight
and senior-level direction in the evaluation of the need for new or updated
directives and other Departmental requirements, and the prioritization of
those requirements. In particular, the DOE Operations Committee will
review the justification and need for requirements, and provide direction
to ensure that the promulgation of requirements is evaluated with respect
to mission relevance and impact. Further, it will appropriately prioritize
next steps to promote mission achievement. The Secretary or the Deputy
Secretary will determine the membership of the DOE Operations
Committee.
(3) The Directives Review Board (DRB). The DRB ensures that the
Departmental Directives Program contains directives that enhance DOE’s
ability to achieve its mission goals in a safe, secure, and cost-effectives
manner. The DRB is chaired by the Director, Office of Management,
Membership is comprised of two senior representatives from each of the
three Under Secretarial offices; the Office of the General Counsel (GC);
and the Office of Environment, Health, Safety and Security (AU). Senior
representatives from the National Laboratories Directors Council and
Field Managers Council serve as non-voting advisory members on the
Board and attend meetings and other proceedings, as required. A list of
DRB members and the organizations they represent is available on the
DOE Directives website.
Section 3
(4) The Departmental Directives Program. The Departmental Directives
Program must provide and maintain a methodology for creating and
promulgating DOE-wide requirements for Federal staff. The Departmental
Directives Program must also be used to extend related requirements to
applicable contracts.
4 DOE O 251.1D
1-17-2017
(5) Integrated Project Team(s) (IPTs). Each IPT must be charged with
developing a consensus product in support of the desired end state for a
directive’s development or revision as determined by the DRB and the
DOE Operations Committee (see Appendix B).
b. Directives Development.
(1) New directives and revisions to existing directives must be processed
using an IPT or a Fast Track revision process as outlined in Appendices A
through C. Documents not developed and processed as outlined in these
appendices are unauthorized and must not be considered directives.
Acceptable alternative programs or processes must have an approved and
current Order outlining the methodology for promulgating unique
requirements.
(2) Unauthorized directives must be reported to the Departmental Directives
Program and implementation held until a DRB determination.
(3) Unauthorized directives must be, either:
(a) withdrawn;
(b) modified (e.g., restrict its applicability to one Departmental
element) so that it no longer fits the description of an unauthorized
directive; or
(c) converted to a directive following the processes described in this
Order.
(4) Headquarters and field elements are authorized to publish supplemental
directives for use by those organizations and their contractors, provided
the supplemental directives do not contradict, delete, or duplicate
provisions in any applicable Policy, regulation, or Order.
(5) Requirements in this Order for directives development, revision,
cancellation, and approval must take precedence over all other directives.
Where conflicts exist between directives, the Departmental element that
identifies the conflict must notify the DRB in writing. If the DRB
confirms that a conflict exists, the conflict must be resolved by revising
one or more of the subject directives or by other means approved by the
DRB.
(6) Directives must be written to clearly and concisely specify the goals and
requirements that must be met while refraining from mandating how to
fulfill them to the highest extent possible. Directives that cover high risk
functions, such as safety and security, or areas that require consistency,
such as financial reporting and information technology, may, when
necessary, specify how the requirements must be met.
DOE O 251.1D 5
1-17-2017
(7) Directives must be written following a standardized format and include the
content required by this Order (Templates will be maintained on the DOE
Directives website).
(8) Offices of Primary Interest (OPIs) must propose directives actions, when
requested, for inclusion on the Directives Prioritization list. The DRB may
request that OPIs review and/or revise a specific directive if the DRB is
notified that the directive is ineffective. OPIs may also propose directives
actions for inclusion on the Directives Prioritization list on an ad hoc basis
(see Appendix A).
(9) Directives may cite a section or requirement in an existing directive, law,
regulation, or standard but must not re-promulgate the same requirement.
To the extent possible, directives should be written so that they are
consistent with, or incorporate, voluntary consensus standards.
Section 4
(10) Directives must use attachment(s) when providing more detailed
information, direction, or requirements that are applicable to Federal
and/or contractor employees. Where applicable, a CRD must be
Attachment 1 to an Order.
(11) Directives must use an appendix when providing more detailed
information, direction, or requirements that are applicable only to Federal
employees.
(12) Changes to directives that affect nuclear safety as defined in the current
version of DOE O 410.1, Central Technical Authority Responsibilities
Regarding Nuclear Safety Requirements, and therefore require Central
Technical Authority (CTA) review, must be placed into the Review and
Comment system for a concurrence review.
(13) If any part of a directive applies to the NNSA, the following language
must be added to the Departmental Applicability paragraph:
The Administrator of NNSA will assure that NNSA
employees and contractors comply with their respective
responsibilities under this directive. Nothing in this
Order/Notice will be construed to interfere with the NNSA
Administrator’s authority under section 3212(d) of Public
Law (P.L.) 106-65 to establish Administration-specific
policies, unless disapproved by the Secretary.
(14) If any part of a directive applies to the Naval Nuclear Propulsion Program,
the following language must be added to the Departmental Applicability
paragraph:
6 DOE O 251.1D
1-17-2017
In accordance with the responsibilities and authorities
assigned by Executive Order 12344, codified at 50 USC
sections 2406 and 2511 and to ensure consistency through
the joint Navy/DOE Naval Nuclear Propulsion Program,
the Deputy Administrator for Naval Reactors (Director)
will implement and oversee requirements and practices
pertaining to this Directive for activities under the
Director's cognizance, as deemed appropriate.
c. Contractor Requirements in Directives. A concise set of all contractor
requirements must be provided in Attachment 1, the contractor requirements
document (CRD). Where appropriate, the CRD's requirements and responsibilities
for contractors must be consistent with requirements and responsibilities for DOE
personnel as defined in the directive. The CRD must be a stand-alone document,
not simply direct a contractor to follow requirements in an Order.
d. Secretarial Memoranda.
(1) Secretarial and Deputy Secretarial policy memoranda that contain
requirements that affect more than one Departmental element must
identify the OPI, must be converted or incorporated into the Departmental
Directives Program, and must include a timeline for the conversion and
incorporation of the memoranda requirements (see process in
Appendix H).
(2) Secretarial and Deputy Secretarial policy memoranda that contain
requirements that affect more than one Departmental element and are not
identified for cancellation or conversion or incorporation into the
Departmental Directives Program must be reviewed upon departure of the
Secretary/Deputy Secretary for possible integration into DOE’s business
practices (see process in Appendix H).
e. Implementation of DOE Directives.
(1) Requirements for Federal employees in new or revised directives must be
fully implemented within twelve months of issuance, unless otherwise
stated in the directive.
(2) Directives with CRDs must denote, for existing contracts, the
implementation timeline established by the Head of the Departmental
Element if it is prior to the next contract award, renewal, or extension.
Section 5
(3) The Head of the Departmental Element, or his or her designee, shall notify
the Contracting Officer (CO) and other appropriate subject matter experts
in the organization that the directive applies to an existing contract or to a
solicitation for a future contract. For existing contracts, the Head of
Departmental Element shall designate appropriate representatives to work
DOE O 251.1D 7
1-17-2017
with the CO to develop an appropriately tailored set of standards, practice,
and controls.
(a) For existing M&O contracts, after being notified by the Head of
the Departmental Element or his or her designee, the CO shall
provide the contractor the opportunity to assess the effect of
incorporating the CRD on contract cost, funding, schedule, and
technical performance, and to provide input on the appropriately
tailored set of requirements for the contract. All associated
activities will be accomplished in a timely manner and, if
applicable, in accordance with the timelines established in DEAR
970.5204-2. The Contracting Officer will incorporate the CRD
without alteration unless the directive permits alteration and the
appropriate process is followed.
(b) For existing non-M&O contracts, after being notified by the Head
of the Departmental Element or his or her designee, the CO shall
provide the contractor the opportunity to assess the effect of
incorporating the CRD on contract cost, funding, schedule, and
technical performance, and to provide input on the appropriately
tailored set of requirements for the contract. Non-M&O contracts
do not give the CO the unilateral right to modify them. Therefore,
the CO shall attempt to incorporate the CRD bilaterally. If attempts
to negotiate the requirement into the contract bilaterally are not
successful, the CO shall consult with the Head of Contracting
Activity (HCA), Headquarters program office, and General
Counsel. The CO shall incorporate the CRD without alteration
unless the CRD or directive permits alteration and the appropriate
process is followed.
(4) The DRB will seek feedback on the implementation of new or revised
directives after the directive is fully implemented but no later than 18
months following issuance. The DRB will determine if the directive needs
to be placed back on the prioritization list for update and revision. The
DRB will help determine the magnitude and scope of further revision.
(5) IPT Co-Chairs may be called upon by the DRB to help determine the
magnitude and scope of further revision.
(6) Equivalencies must be obtained when substituting another method for
accomplishing the goal of a requirement (see Appendix E).
(7) Exemptions must be obtained when not implementing one or more
requirements (see Appendix E).
(8) For contracts containing DEAR 970.5204-2, Laws, Regulations and DOE
Directives, requirements for contractors seeking equivalencies/exemptions
8 DOE O 251.1D
1-17-2017
must be stated in the contractor requirements document. For contracts not
containing DEAR 970.5204-2, requirements for contractors seeking
equivalencies/exemptions must include instructions to the Head of the
Departmental Element.
5. RESPONSIBILITIES.
a. Secretary of Energy.
(1) Issues, approves or cancels Directives or delegates approval authority.
(2) Establishes the policy expectations for Department (sometimes referred to
as the “Commander’s Intent”). This includes the purpose and desired end
state for all Directives.
Section 6
(3) Approves an expedited directive development process other than that
described in Appendices A through C, when necessary, or delegates
approval authority to the Deputy Secretary.
(4) Approves cancellation of policy memoranda or conversion into the
Departmental Directives Program or delegates approval authority to the
Deputy Secretary.
(5) Adjudicates any remaining impasse on proposed directives when they
occur between the office of primary interest (OPI) and/or other
Departmental elements, organizations, or offices, or delegates resolution
to the Deputy Secretary, as appropriate.
(6) Determine the membership of the DOE Operations Committee.
b. Deputy Secretary. As the Secretary's delegate:
(1) Approves and cancels Directives.
(2) Approves an expedited directive development process other than that
described in Appendices A through C for a directive, when necessary.
(3) Approves the cancellation of policy memoranda or conversion into the
Departmental Directives Program.
(4) Adjudicates any remaining impasse on proposed directives when they
occur between the office of primary interest (OPI) and/or other
Departmental elements, organizations, or offices.
(5) Designate a cognizant Head of a Departmental Element to serve as OPI for
the development of each Secretarial Memoranda.
(6) Determine the membership of the DOE Operations Committee.
DOE O 251.1D 9
1-17-2017
c. Under Secretaries. Designate two senior-level representatives to represent their
interests and perform the roles and responsibilities of DRB members.
d. Administrator, National Nuclear Security Administration.
For comments on NNSA exemptions or equivalencies to CHCO directives that
are not resolved to the satisfaction of NNSA and the CHCO, submit the dispute,
in coordination with the CHCO, to the Deputy Secretary for resolution.
e. DOE Operations Committee.
(1) Reviews and approves a prioritized schedule for directives development.
(2) Reviews and approves justification for new or revised requirements.
(3) Establishes the desired end-state for the development or revision of a
directive, based on established law and the Secretary’s policy expectations
for the Department.
(4) Seeks to resolves impasse on Directives issues, if the DRB is unable to
reach resolution
(5) Provides guidance to the DRB and IPT Co-Chairs as needed.
f. Associate Under Secretary for the Office of Environment, Health, Safety and
Security.
(1) Ensures transmission of draft directives, invoked standards, and other
relevant, approved documents through the DOE Departmental
Representative to the Defense Nuclear Facilities Safety Board (DNFSB),
for directives of interest to the DNFSB.
(2) Ensures the Technical Standards Program (TSP) provides the DRB and the
DOE Operations Committee with an annual prioritized list of Technical
Standards proposed for revision.
(3) Ensures the TSP coordinates with the DRB and the Departmental
Directives Program regarding the development of any invoked Technical
Standards.
g. Chief Human Capital Officer (CHCO).
For comments on NNSA exemptions or equivalencies to CHCO directives that
are not resolved to the satisfaction of the CHCO and NNSA, submit the dispute,
in coordination with the NNSA Administrator, to the Deputy Secretary for
resolution.
10 DOE O 251.1D
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h. Heads of Departmental Elements. As appropriate may, or may delegate to a direct
report to:
(1) Initiate development or revision of proposed directives in accordance with
the requirements defined in Appendices A through C.
Section 7
(2) Participate in or designate a participant for the IPT process for the
development or revision of directives, as appropriate.
(3) Assign an IPT Co-Chair for directives for which he/she is the OPI
undergoing the IPT development process.
(4) Ensure sufficient support and engagement in efforts to process draft
directives within the prescribed timetables.
(5) Review and concur on the organization’s position when impasses occur.
(6) Ensure that the organization implements new or revised directives in a
timely manner.
(7) Ensure that contracting officers, in conjunction with Heads of Field
Elements, work with contractors to incorporate CRDs into contracts, as
appropriate.
(a) For non-NNSA elements, work with the Office of the General
Counsel and the Office of Management (Office of Acquisition and
Project Management) in developing requirements for contractors.
(b) For NNSA elements, work with the NNSA Office of the General
Counsel and the NNSA Office of Acquisition and Project
Management in developing requirements for contractors.
(8) Assign a Senior Authorizing Official (SAO) and alternate who possess
sufficient knowledge and capabilities to be liaisons between their
organization and the Departmental Directives Program. Provide the names
and contact information to the Departmental Directives Program.
(9) Establish a documented process for evaluating requests for exemptions
and equivalencies. Obtain the advice of the applicable OPI before
approving an exemption or equivalency. All exemptions and equivalencies
to Directives must be submitted to the Departmental Directives Program
for appropriate posting.
(10) Submit recommendations for the directives prioritization process (See
Appendix A).
DOE O 251.1D 11
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(11) Consult with the Director, Office of Management on Secretarial or Deputy
Secretarial policy memoranda to recommend cancellation or conversion
into the Departmental Directives Program.
i. Director, Office of Management.
(1) Administers the Departmental Directives Program.
(2) Serves as Chair of the DRB, and makes the final determination on
directives process matters, unless otherwise specified.
(3) Serves as the representative for Departmental staff/support offices not
already represented on the DRB. For organizations that are represented,
reviews submitted comments, and reconciles differences in coordination
with DRB members.
(4) Facilitates discussion between DRB members and Heads of Departmental
Elements, or designees, for unresolved issues.
(5) Coordinates and facilitates discussions with the DRB and the DOE
Operations Committee.
(6) Recommends to the DRB that a directive be removed from the Directive
Prioritization List for inactivity.
(7) Coordinates with the Executive Secretariat and relevant organizations to
ensure that requirements established in Secretarial Memoranda are
included in relevant directives.
(9) Provides Headquarters Contracting Authorities and Field Managers with a
regular list of canceled or approved directives. Approves and cancels
Guides.
j. Directives Review Board Members.
(1) Participate in DRB meetings, provide advice to the DRB Chair and other
members, and vote (with the exception of advisory members) on proposed
directives.
(2) Solicit, reconcile, and consolidate comments on documents on behalf of
represented organizations, and submit the comments to the Departmental
Directives Program, when requested.
Section 8
(3) Recommend to the DRB Chair, whether the annual Directives
Prioritization List be approved and sent to the DOE Operations Committee
for final approval.
12 DOE O 251.1D
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(4) Recommend (with the exception of advisory members) that the DRB
Chair concur on directives for approval or for forwarding to the Secretary
or Deputy Secretary, through the DOE Operations Committee.
(5) Recommend to the DRB Chair, whether to approve the membership of an
IPT, to include IPT Co-Chairs.
(6) Recommend to the DRB Chair, whether an IPT’s decision memorandum
presenting a new Order or recommended revisions to an existing Order be
approved and sent to the DOE Operations Committee for final approval.
(7) Communicate with IPT members during all phases of the IPT process.
(8) Educate and communicate with the organizations they represent regarding
the results of DRB meetings and Departmental Directives Program
changes.
(9) Consult with Heads of Departmental Elements on policy memoranda
before recommending to the DRB Chair that the Deputy Secretary either
cancel or convert of Secretarial or Deputy Secretarial policy memoranda
into appropriate Departmental directives, as appropriate.
(10) When at impasse, prepare position paper for DOE Operations Committee
review.
k. Central Technical Authorities (CTAs). Provide, to the applicable Senior
Authorizing Officials and the applicable Head of the Departmental Element,
their concurrence or non-concurrence on all directives that affect nuclear safety
as defined in the current version of DOE O 410.1, Central Technical Authority
Responsibilities Regarding Nuclear Safety Requirements.
l. Departmental Directives Program Manager, Office of Management.
(1) Manages the Departmental Directives Program processes.
(2) Serves as Executive Secretariat to the DRB.
(3) Ensures that documents submitted to the DRB by program offices meet
established criteria prior to submission to the DRB for review.
(4) Manages the Departmental Directives Program website and the Review
and Comment system.
(5) Approves administrative changes to existing directives.
(6) Notifies the Office of Acquisition and Project Management when
directives with CRDs are issued.
DOE O 251.1D 13
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(7) Provides Department-wide education regarding the Departmental
Directives Program and its processes.
m. Offices of Primary Interest (OPI).
(1) Follow the process outlined in Appendices A through C for developing or
revising directives.
(2) Provide an IPT Co-Chair as well as IPT member, as directed, for
directives proposed for development under the IPT process (See Appendix
B).
(3) For non-NNSA elements, work with the Office of the General Counsel
and the Office of Management (Office of Acquisition and Project
Management) in developing a CRD.
(4) For NNSA elements, work with the NNSA Office of the General Counsel
and the NNSA Office of Acquisition Management in developing a CRD.
(5) Adhere to the prescribed formats when developing or revising directives,
maintained on the DOE Directives website
(6) Support efforts to engage organizations in resolving differences over
comments.
(7) Coordinate with the DOE Departmental Representative to the DNFSB, for
all directives of interest to the DNFSB.
(8) Provide advice to offices seeking Equivalencies or Exemptions.
(9) Provide a progress report to the DRB, as requested, on implementation of
a directive's requirements.
(10) Support the Secretary, as directed, in the development and issuance of
Secretarial Memoranda.
Section 9
n. Senior Authorizing Official (SAO).
(1) In consultation with the Head of their Departmental Element, determines
his/her organization’s official policy position on directives.
(2) Ensures timely organizational input on decision memoranda, draft
directives, and cancellation of directives from subject matter experts
(SMEs), as requested by the OPI, DRB, IPT, or IPT Member.
(3) Develops a process by which to solicit, review, and adjudicate comments
from within his/her organization, to be used when a review does not take
place using the Review and Comment system.
14 DOE O 251.1D
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(4) Assigns subordinate Authorizing Officials (AO) as needed to execute
SAO duties at lower/localized levels, to include SME comment
resolution/adjudication.
(5) Assigns SMEs within his/her organization, as needed, for each draft
directive issued for review and comment through the Departmental
Directives Program.
(6) Obtains extensions on comment due dates from initiator (OPI, IPT, or
IPT Member), in conjunction with the Departmental Directives Program.
(7) Consolidates and adjudicates SME comments, eliminating editorial,
pejorative, conflicting, redundant, or non-value added comments, and
provides a specific cohesive set of recommendations for document
improvement. Assures SMEs are informed when their comments are not
forwarded with consolidated submission package.
(8) Coordinates with the DOE Departmental Representative to the DNFSB,
for all directives of interest to the DNFSB.
(9) Acts as the liaison between the organization and the Departmental
Directives Program as appropriate.
(10) Ensures organization awareness of significant concerns and issues.
(11) Appoints an Authorization Coordinator (AC) from within his/her
organization, as needed.
o. Integrated Project Team (IPT) Co-Chairs.
(1) Manage the IPT throughout the directive development and revision
process (See Appendix B).
(2) Serve as the IPT’s direct interface to the DRB, providing updates and
facilitating required approvals.
p. IPT Members.
(1) Represent the equities and interests of their Programmatic chain.
(2) Solicit SME input and buy-in from within their organization, as
appropriate.
(3) Coordinate and consolidate input and/or comments from across their
organization.
(4) Solicit their management chain buy-in throughout the development
process.
DOE O 251.1D 15
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(5) Develop, maintain, and track communication with project stakeholder
groups they are assigned to represent.
(6) Develop a consensus draft in support of the desired end state for the
directive’s revision, as determined by the DRB and the DOE Operations
Committee (see Appendix B).
q. DOE Departmental Representative to the DNFSB.
(1) Coordinates with the AU DRB member.
(2) Coordinates relevant directives reviews with the DNFSB.
(3) Provides the OPI/IPT/DRB with DNFSB comments through the process
used by the Department.
(4) Facilitates communication between the OPI/IPT and DNFSB regarding
DNFSB comments prior to a directive’s approval.
(5) Provides the DNFSB with approved copy of directives and related
documents, for directives of interest to the DNFSB.
(6) Ensures that the DNFSB has access to the most recently approved versions
of directives and other relevant documents.
(7) Informs the Departmental Directives Program when the DNFSB has
questions, concerns or comments on directives or other relevant
documents.
(8) Informs the DNFSB when a directive is considered for cancellation.
Section 10
(9) Informs the OPI/IPT and DRB on relevant DOE implementation plan
provisions and Secretarial commitments to the DNFSB that impact
directives of interest to the DNFSB.
r. Heads of Field Elements.
(1) Ensures comments, implementation perspectives and impacts are provided
into the Directives development process through assigned SMEs.
(2) Serve as the AO when designated by the SAO (i.e. performing SAO duties
at a lower organizational level).
(3) Appoints local ACs, when needed, in support of an AO.
(4) Provides oversight of the directives implementation process as applicable
to their organizational element (to include efforts required of Contracting
Officers (CO)).
16 DOE O 251.1D
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s. Contracting Officers (CO).
(1) For M&O contracts, after being notified by the Head of the Departmental
Element or his or her designee, the CO must incorporate the CRD into the
contract by the due date established by the Head of the Departmental
Element. The Contracting Officer must incorporate the CRD without
alteration unless the CRD permits alteration and the appropriate process is
followed, or unless requirements are tailored per DEAR 970.5204-2.
(2) For non-M&O contracts, after being notified by the Head of the
Departmental Element or his or her designee, the CO must attempt to
incorporate the CRD into the contract by the due date established by the
Head of the Departmental Element. Non-M&O contracts do not give the
CO the unilateral right to modify the contract. Therefore, the CO must
attempt to incorporate the CRD bilaterally. If unsuccessful, the CO must
consult with Head of the Departmental Element or appropriate program
official. The CO must incorporate the CRD without alteration unless the
appropriate process for exemption/equivalency is followed.
t. Senior Authorization Coordinator (SAC).
(1) Provide administrative support to the Senior Authorizing Official (and any
assigned AOs) for directive activities.
(2) Develop functional area/SME workflows for the Senior Authorizing
Official (and any assigned AOs) to use during directive activities.
(3) Serve as the primary means of dissemination and engagement of comment
and input processes (working in conjunction with ACs, if utilized within
the organization).
(4) Facilitate the review and comment process for draft directives (working
with AOs and ACs as appropriate) to assure the expected set of SMEs are
involved in each effort, as appropriate.
6. REFERENCES.
a. Title 41, Code of Federal Regulations (CFR), Parts 102-193.25(c), which
provides agency managers with the means to convey written instructions to users
and document agency policies and procedures through effective directives
management.
b. Public Law (P.L.) 106-65, Title XXXII National Nuclear Security
Administration Act, as amended, which established a separately organized
agency within the Department of Energy.
DOE O 251.1D 17 (and 18)
1-17-2017
c. National Defense Authorization Act for FY 2013, Section 3120. Improvement
and Streamlining of the Missions and Operations of the Department of Energy
and National Nuclear Security Administration.
d. DOE O 252.1, Technical Standards Program, current version.
e. DOE O 410.1, Central Technical Authority Responsibilities Regarding Nuclear
Safety Requirement, current version.
f. DOE O 471.6, Information Security, current version.
7. DEFINITIONS. See Appendix J.
8. CONTACT. Questions concerning this Order should be addressed to the Departmental
Directives Program at 202-287-5641.
Section 11
BY ORDER OF THE SECRETARY OF ENERGY
ELIZABETH SHERWOOD-RANDALL
Deputy Secretary
DOE O 251.1D Appendix A
1-17-2017 A-1
DIRECTIVES PRIORITIZATION PROCESS
This Appendix describes the process for the prioritization of directives actions. The DRB and the
Departmental Directives Program will prioritize and schedule directives actions. The DOE
Operations Committee will review and approve the proposed Directives Prioritization list. This
review and approval will serve as the justification for scheduled directives actions. No
development of a draft directive should begin until the DOE Operations Committee approves the
Directives Prioritization list.
1. REQUEST FOR DIRECTIVES ACTIONS. The DRB and the Departmental Directives
Program will compile a list of proposed directives.
a. OPIs must review their directives and propose revisions to existing directives or
the development of new directives, as needed.
b. OPIs must review directives in which they are stakeholders and provide the DRB
with recommendations for directives revision.
c. OPIs must provide a justification for the revision to or development of a new
directive. Justifications may include, but are not limited to:
(1) Presidential or White House direction;
(2) Congressional or legislative direction;
(3) Secretarial or Deputy Secretarial direction;
(4) Government Accountability Office (GAO) or Office of Management and
Budget (OMB) report responses;
(5) Changes needed to improve implementation efficiency, reduce
implementation burden, or reduce mission risk; and
(6) Program or field requests for updates.
d. OPIs must propose a revision path as follows:
(1) Integrated Project Team (IPT) Development or Revision. IPT revisions
may include, but are not limited to, major, substantive, or complex
revisions where disputes in changing requirements are anticipated. The
OPI must recommend Co-Chairs to head the IPT. (See process in
Appendix B.)
(2) Fast Track Development or Revision. Fast Track revisions are limited to
minor changes, undisputed reductions in requirements, changes directed
by S1/S2, verbatim codification of Secretarial Memoranda into directives,
or a combination of the above. (See process in Appendix C.)
Appendix A DOE O 251.1D
A-2 1-17-2017
e. The DRB and the Departmental Directives Program will meet with OPIs, as
necessary, to determine the final proposed Directives Prioritization list and
schedule. Priorities will be set as follows:
(1) Priority 1.
(a) Changes directed by the White House, the Congress, the Office of
Management and Budget (OMB), the Secretary (S1), the Deputy
Secretary (S2), or the DOE Operations Committee.
(b) Critical national security updates.
(c) Critical nuclear safety and security updates.
(d) Critical safety and security issues.
(2) Priority 2.
(a) Revisions to correspond with changes in law or regulations.
(b) Commitments to the Inspector General (IG) or the Government
Accountability Office (GAO).
(c) Revisions to benefit the Department.
(3) Priority 3.
(a) Minor changes or reduced requirements.
(b) Revisions to align with external standards and practices.
(c) Clarifications of requirements.
(d) Cancellations.
f. The DRB-approved Directives Prioritization list and schedule will be presented to
the DOE Operations Committee for approval.
2. AD HOC DIRECTIVES ACTIONS.
a. OPIs must notify the DRB and the Departmental Directives Program of the need
to revise or develop a directive that is not on the approved Directives
Prioritization list as soon as possible.
Section 12
b. OPIs must provide a justification for the revision to or development of a new
directive. Possible justifications are outlined in paragraph 1.c. of this Appendix.
OPIs must propose a revision path as outlined in paragraph 1.d. of this Appendix.
DOE O 251.1D Appendix A
1-17-2017 A-3 (and A-4)
c. The DRB and the Departmental Directives Program will meet with OPIs, as
necessary, to determine whether unscheduled directives actions should be placed
on the Directives Prioritization list and schedule. DRB approved actions will be
presented to the DOE Operations Committee for approval.
DOE O 251.1D Appendix B
1-17-2017 B-1
INTEGRATED PROJECT TEAM (IPT) DIRECTIVES PROCESS
This Appendix describes the process for developing, revising, and approving directives using the
IPT process. The processing time for Directives will be determined by the DRB and approved by
the DOE Operations Committee. The Secretary, Deputy Secretary, DOE Operations Committee,
or DRB Chair may approve an expedited process for processing directives.
IPT revisions may include, but are not limited to, major, substantive, or complex revisions where
disputes in changing requirements may be anticipated.
1. STAGE 1. DEVELOPMENT APPROVAL AND SCHEDULING. The OPI must follow
the Directives Prioritization process outlined in Appendix A. Once the Directives
Prioritization list is approved, the OPI may establish the IPT according to the schedule.
2. STAGE 2. IPT CREATION.
a. The OPI must propose two IPT Co-Chairs for the directive revision. One
Co-Chair must represent the OPI, and the other Co-Chair must represent a field
element from a different program office. The DRB will approve the IPT
Co-Chairs.
b. The IPT Co-Chairs, in coordination with program offices, must submit a list of
proposed IPT Members to the DRB for approval. The IPT must consist of
membership from all affected groups (to include the OPI; HQ program and staff
organizations; field/site offices; and laboratories), and may include a member of
the Departmental Directives Program, as appropriate. IPTs will have 10-12
members.
c. Once the DRB approves the IPT membership, the IPT will hold a kick-off
meeting with senior leaders in the stakeholder organizations to discuss the
purpose of the revision. This meeting will also cover the formation of the IPT and
the anticipated directive revision process.
d. The IPT’s first charge is to confirm that the directive is necessary. If the IPT
decides the directive is needed, members will use the directive principles to
review and revise the directive. If the IPT decides the directive is not needed, the
OPI will begin the directives cancellation process.
3. STAGE 3. DEVELOPMENT OF THE DECISION MEMORANDUM. The IPT must
develop a decision memorandum to be approved by the DRB and the DOE Operations
Committee, following the timeline established through the Directives Prioritization effort.
The approved decision memorandum must:
a. Recommend the desired end-state for the revision of the directive.
b. Confirm why the directive is necessary.
Appendix B DOE O 251.1D
B-2 1-17-2017
c. Describe qualitatively and, where practical, quantitatively anticipated costs and
beneficial impacts, such as improved safety, associated with the revised
directive’s implementation.
d. Identify any major issues arising from the recommended revisions. For issues that
the IPT is unable to resolve, the decision memo must include options for DOE
Operations Committee decision. The recommended options must weigh the pros
and cons for each decision.
Section 13
e. Identify all conflicts with existing directives, and any potential impacts to other
directives, or to Departmental functions or operations; include options for DOE
Operations Committee decision if such conflicts exist.
f. If IPT members cannot agree on an issue, the IPT will provide options for
decision by the DRB and the DOE Operations Committee.
4. STAGE 4. FIRST DIRECTIVES REVIEW BOARD MEETING.
a. The DRB must review and provide comments, if applicable, on the decision
memorandum. As appropriate, any comments received during the review will be
forwarded to the IPT Co-Chairs.
b. The IPT Co-Chairs must meet with the DRB to discuss the IPT-developed
decision memo.
c. The DRB will provide the decision memorandum, along with its
recommendations to the DOE Operations Committee for approval.
5. STAGE 5. FIRST DOE OPERATIONS COMMITTEE MEETING. The IPT Co-Chairs
will present the IPT’s decision memorandum at a DOE Operations Committee meeting,
with the DRB Chair in attendance.
a. The DOE Operations Committee will review the decision memorandum and, if
necessary, choose from any recommended options for final approval.
b. The IPT Co-Chairs must receive approval from the DOE Operations Committee
to start writing or revising the directive.
6. STAGE 6. DEVELOPMENT OF THE FIRST DRAFT. Once the decision memorandum
is approved by the DOE Operations Committee, the IPT may begin draft development.
a. The IPT must adhere to the Directives Prioritization schedule established by the
DRB and the DOE Operations Committee, and collaborate with the Departmental
Directives Program when developing or revising the draft directive.
b. The IPT Co-Chairs must provide the DRB with a plan that outlines the IPT’s
communication strategy with stakeholders as well as DRB Members. A template
can be found on the DOE Directives website.
DOE O 251.1D Appendix B
1-17-2017 B-3
c. If the IPT determines more time is needed for development than is allotted on the
Directives Prioritization schedule, the IPT Co-Chairs must present their rationale
and a recommended time frame to the DRB for approval.
d. IPT members must engage stakeholders throughout the IPT process and provide
IPT documents to stakeholders, when appropriate. IPT members must document
these communications, and provide the tracking sheet to the DRB, the IPT
Co-Chairs, and/or the Departmental Directives Program when requested. These
stakeholders must include, but are not limited to:
(1) affected program and site offices;
(2) Field Management Council representatives, as requested;
(3) National Laboratory Directors Council representatives, upon DRB request;
(4) the appropriate DOE or NNSA counsel;
(5) the Office of Primary Interest responsible for any DOE Technical
Standard being invoked in the directive;
(6) the Office of Policy, Office of Acquisition Management (MA-61);
(7) Field Contracting Officers;
(8) CTAs, when appropriate; and
(9) the DOE Departmental Representative to the DNFSB, for all directives of
interest to the DNFSB.
e. The Review and Comment system may be used throughout the IPT draft
development process to collect comments from key stakeholders across the
complex, as appropriate.
f. The IPT Co-Chairs will meet with the DRB at various milestones determined by
the DRB and the Departmental Directives Program.
g. After the draft directive has been developed, the IPT Co-Chairs must submit an
electronic copy of the draft directive to the Departmental Directives Program.
Section 14
h. For a revised directive, a crosswalk of requirements must accompany the draft
directive when requested by the DRB.
7. STAGE 7. DIRECTIVE REVIEW AND COMMENT.
a. The draft directive must be coordinated with key stakeholders across the
department, as determined by the DRB and IPT, following the timeline
established through the Directives Prioritization effort. The DRB, in coordination
Appendix B DOE O 251.1D
B-4 1-17-2017
with the IPT, will determine if the draft directive warrants further review using
the Review and Comment system.
b. If the Review and Comment system is used, IPT members must respond to all
comments provided, stating whether the comment was accepted or rejected by the
IPT. IPT members will not directly address editorial comments. Editorial
comments will be used by the IPT and the Departmental Directives Program for
final draft edits.
c. If the draft is an Order invoking a draft Technical Standard, the draft Order and
the draft Technical Standard must be coordinated concurrently to ensure that all
reviewers have access to both documents. The process for development of
invoked DOE Technical Standards for contractors is found in the current version
of DOE O 252.1, Technical Standards Program.
d. Classified information in DOE Directives must be protected according to
requirements in the current version of DOE O 471.6, Information Security.
Unclassified descriptions of classified directives can be posted on the Review and
Comment system prior to transmission.
8. STAGE 8. COMMENT RESOLUTION/DEVELOPMENT OF THE FINAL DRAFT.
The IPT, following the timeline established through the Directives Prioritization effort,
must:
a. Respond to all non-editorial comments, work with commenters to resolve issues,
and submit the comment resolution package on the Review and Comment system,
if the system is used.
b. Provide the electronic files of the clean, updated draft directives, the updated
development synopsis, and a communications plan to the Departmental Directives
Program for presentation to the DRB.
9. STAGE 9. FINAL REVIEW AND CONCURRENCE.
a. The final draft directive will be posted to the Review and Comment system for
department-wide concurrence, as appropriate.
b. The final draft directive and any relevant documents must be reviewed by the
DRB. Technical Standards approved through the Technical Standards
development process and invoked by Orders must be reviewed by the DRB along
with the revision to the applicable Order. Comments received during the review
will be forwarded to the IPT Co-Chairs, as appropriate.
c. For issues that cannot be resolved at the IPT level, Heads of Departmental
Elements or their designee(s), must meet with the DRB to address concerns
regarding the final draft directive and the implementation strategy.
DOE O 251.1D Appendix B
1-17-2017 B-5 (and B-6)
d. If consensus is reached, the DRB will validate that the final directive reflects the
approved DRB decisions.
e. If consensus cannot be reached between the DRB members, the DRB Chair
facilitates the discussion of unresolved issues between the DRB members and the
Heads of Departmental Elements or their designees who cannot reach agreement.
f. If the issues cannot be resolved, an impasse occurs. The OPI must include the
impasse issue(s), its position, the position of the dissenting organization(s), the
decision memo as approved by the DOE Operations Committee, and the DRB’s
recommendation in a summary paper. The organization that does not agree with
the OPI’s position must provide a summary paper with its position to the OPI for
inclusion in the approval package.
Section 15
10. STAGE 10. FINAL APPROVAL.
a. Once the DRB reaches consensus on the final draft directive or agrees to send an
impasse issue forward, the OPI must prepare an approval package. Templates for
approval package content can be found on the DOE Directives website.
b. The approval package will be forwarded by the Departmental Directives Program
through the DOE Operations Committee Chair to the Secretary or Deputy
Secretary to render a decision on any impasse issues and issue the directive.
11. STAGE 11. IMPLEMENTATION.
a. The IPT must develop an implementation strategy throughout the IPT process.
The strategy must include specific actions for effectively communicating and
implementing the revised directive. This document will include key milestones
and the organizations responsible for each action as established in the directive.
b. The DRB will provide guidance on proposed implementation strategies.
c. The IPT Co-Chairs will return to the DRB, when requested, to provide an update
on implementation. DRB members may also provide perspectives on
implementation.
d. If the DRB is presented with implementation issues that require an update to the
directive, it will recommend the directive as an ad hoc addition to the
prioritization schedule for DOE Operations Committee approval.
e. Upon DOE Operations Committee approval, the ad hoc update to the directive
will be added to the Directives Prioritization list and schedule.
DOE O 251.1D Appendix C
1-17-2017 C-1
FAST TRACK DIRECTIVES PROCESS
This Appendix describes the process for developing, revising, and approving directives using the
Fast Track process. The processing time for Directives will be determined by the DRB and
approved by the DOE Operations Committee. The Secretary, Deputy Secretary, or DRB Chair
may approve a Fast Track process for processing directives.
Fast Track revisions are limited to minor changes proposed by the OPI, undisputed reductions in
requirements as agreed to by the DRB and DOE Operations Committee, changes directed by
S1/S2, verbatim codification of Secretarial Memoranda into directives, or a combination of the
above. The goal of the Fast Track process is for the directive to be issued within 60 days.
Directives will only be scheduled for Fast Track development with the unanimous approval of all
DRB members.
1. STAGE 1. DEVELOPMENT APPROVAL AND SCHEDULING. The OPI must follow
the Directives Prioritization process outlined in Appendix A. Once the directive action is
approved for the Fast Track process, the OPI may begin draft development according to
the established schedule.
2. STAGE 2. DEVELOPMENT OF THE FIRST DRAFT.
a. The OPI must adhere to the Directives Prioritization schedule established by the
DRB and the DOE Operations Committee.
b. The OPI must collaborate with the Departmental Directives Program when
developing or revising the draft directive.
c. As needed, the OPIs must engage stakeholders throughout the Fast Track
process and provide IPT documents to stakeholders, when appropriate. The OPI
must document these communications, and provide the tracking sheet to the
DRB and/or the Departmental Directives Program when requested. These
stakeholders must include, but are not limited to:
(1) affected program and site offices;
(2) Field Management Council representatives, as requested;
(3) National Laboratory Directors Council representatives, upon DRB request;
(4) the appropriate DOE or NNSA counsel;
Section 16
(5) the Office of Primary Interest responsible for any DOE Technical
Standard being invoked in the directive;
(6) the Office of Policy, Office of Acquisition Management (MA-61);
(7) Field Contracting Officers;
Appendix C DOE O 251.1D
C-2 1-17-2017
(8) CTAs, when appropriate; and
(9) the DOE Departmental Representative to the DNFSB, for all directives of
interest to the DNFSB.
d. After the draft directive has been developed, an electronic copy must be sent to
the Departmental Directives Program.
(1) If revising a directive, a crosswalk of requirements must accompany the
draft directive when requested by the DRB.
(2) The OPI must provide the DRB and the Departmental Directives Program
a development synopsis detailing points of contact consulted, comments
submitted during draft development, and remaining comment resolution
disputes (collaboration tracking system).
(3) The OPI must provide the DRB and the Departmental Directives Program
with any relevant background documentation, applicable to the proposed
directives revision or development (e.g., S1/S2 Memoranda, GAO Report,
etc).
3. STAGE 3. FAST TRACK REVIEW AND COMMENT.
a. The review of the draft directive must be coordinated through the DRB.
b. The draft directive and any relevant documents must be reviewed by the DRB.
Any comments requiring resolution received during the DRB review will be
forwarded to the OPI.
c. Classified information in DOE Directives must be protected according to
requirements in the current version of DOE O 471.6, Information Security.
Unclassified descriptions of classified directives can be provided prior to
transmission.
4. STAGE 4. COMMENT RESOLUTION/DEVELOPMENT OF THE FINAL DRAFT.
The OPI must respond to comments and work with DRB members and commenters to
resolve issues, as necessary;
5. STAGE 5. FINAL REVIEW.
a. The final draft directive and any relevant documents must be reviewed by the
DRB. As appropriate, any comments received during the review will be
forwarded to the OPI.
b. If consensus cannot be reached between the DRB members, the directive will be
removed from the Fast Track development process.
DOE O 251.1D Appendix C
1-17-2017 C-3 (and C-4)
c. Classified information in DOE Directives must be protected according to
requirements in the current version of DOE O 471.6, Information Security.
Unclassified descriptions of classified directives can be provided prior to
transmission.
6. STAGE 6. FINAL APPROVAL.
a. Once the DRB reaches consensus on the final draft directive, the OPI must
prepare an approval package. Templates for approval package content can be
found on the DOE Directives website.
b. The approval package will be forwarded by the Departmental Directives Program
through the DOE Operations Committee Chair to the Secretary or Deputy
Secretary to render a decision.
DOE O 251.1D Appendix D
1-17-2017 D-1 (and D-2)
PRINCIPLES FOR DIRECTIVES DEVELOPMENT
New directives and revisions to existing directives must be developed following the
Department’s Principles for Directives Development.
1. ESTABLISH LINE ORGANIZATION NEED. The need for a new Directive must be
affirmed by the responsible line organization(s). This may done through the DOE
Operations Committee.
2. EMPOWER FIELD OFFICES. Any new or modified Federal requirements should assign
decision authorities and responsibilities at the lowest, appropriate level.
Section 17
3. PROMOTE INCLUSIVENESS. Although the development of new or modified
requirements is led by an office of primary interest, the Integrated Project Team (IPT)
responsible for development must include participation by impacted entities.
4. AVOID UNNECESSARY DUPLICATION. Directives shall not duplicate or be
inconsistent with laws or regulations and should be consistent with or incorporate widely
accepted national standards.
5. REFLECT IMPROVED PLANNING AND COORDINATION. Directives should be
written and developed by IPTs that consists of subject matter experts (SMEs), responsible
line organization personnel, and impacted DOE, plant, and laboratory personnel.
6. CONTAIN PERFORMANCE-BASED CONTRACT REQUIREMENTS. Contract
requirements contained in directives should specify only performance goals and
outcome-based requirements when possible. Model contract requirements should avoid
mandating process or approach for meeting those goals or requirements when possible.
Directives should allow the use of a contract “H” clause in lieu of placing the directive
itself into the contract as a requirements document. For higher risk areas where detailed
process or technical requirements are needed, consideration should be given to the
development of a DOE technical standard in lieu of directives-based contract
requirements.
7. BE TAILORABLE. IPTs developing a directive will determine which organizations need
to be covered by the requirements rather than using a one-size–fits-all approach. Where
possible, directives will reflect a tailored approach based on risk or will provide
flexibility to Under Secretaries to determine the extent to which requirements are
implemented in their organizations.
8. INCORPORATE A RISK MANAGEMENT STRATEGY. IPTs will assess risk in
determining the degree of required prescription for both Federal and contract
requirements. For Federal requirements, the IPT may also consider the need for
consistency and integration within DOE. The IPT will factor implementation costs and
impacts, as well as the effectiveness of the overall risk mitigation strategy, into the
development process for each requirement. Proposed Federal and contract requirements
should be necessary for mission accomplishment or should reflect a strategy for risk
Appendix D DOE O 251.1D
D-2 1-17-2017
management that is integrated with other related laws, regulations, Directives, etc.
DOE O 251.1D Appendix E
1-17-2017 E-1
EQUIVALENCY AND EXEMPTION PROCESS
When an organization seeks an equivalency or exemption, the responsible Head of the
Departmental Element or designee may grant an equivalency or exemption to the requirements in
a DOE directive after seeking advice from the OPI. Organizations should make full use of
exemptions and equivalencies, as appropriate, to avoid unnecessary burden. CTA concurrence,
through their relevant DRB member, is required prior to the granting of equivalencies or
exemptions for nuclear safety directives identified in the current version of
DOE O 410.1, Central Technical Authority Responsibilities Regarding Nuclear Safety
Requirements.
Unless specified otherwise in the directive, the following process must be used to obtain
equivalencies and exemptions.
1. The organization seeking the equivalency or exemption must include the following
information in the exemption/equivalency request and obtain advice from the OPI and
their relevant GC office before submitting the request to the Head of the Departmental
Element for approval. The content of the memorandum must:
Section 18
a. identify the requirement(s) for which the equivalency/exemption is being sought;
b. explain the equivalency/exemption;
c. justify the reasons for the equivalency/exemption;
d. identify the offices or sites for which the equivalency/exemption is being sought;
e. confirm that the application of the exemption or equivalency does not conflict
with applicable federal law or regulations;
f. indicate when compliance will be achieved in cases of an equivalency;
g. describe any alternative or mitigating actions, to include associated risks, that
have been or will be taken to ensure adequate protection of the public, workers,
and the environment for the period during which the exemption will be effective,
when applicable; and
h. describe conclusions and recommendations from the OPI review of the
exemption/equivalency and resolution of recommendations.
2. The Head of the Departmental Element or designee may grant an exemption only if the
exemption:
a. is not contrary to law or regulations;
b. ensures adequate protection of the public, workers, and the environment; and
c. remains consistent with the primary goal and purpose of the directive.
Appendix E DOE O 251.1D
E-2 1-17-2017
3. Heads of Departmental Elements who grant equivalencies and exemptions to directives,
including CRDs, must have a documented process for performing evaluation of proposed
equivalencies and exemptions in place and disseminated to their organization, and be able
to provide that process and its results upon request.
4. The OPI has 15 working days to respond to a request for advice.
5. Directives involving high-risk activities (e.g. nuclear safety) specify that a proposed
exemption or equivalency be concurred on by the responsible organization. These
directives will be revised to include a timeframe (e.g., 45 days) for the responsible
organization to provide concurrence.
DOE O 251.1D Appendix F
1-17-2017 F-1 (and F-2)
DIRECTIVES TYPES
1. POLICIES.
a. Establish high level expectations in the conduct of the Department’s mission and
impact two or more Departmental elements.
b. May be issued through memoranda by the Secretary or Deputy Secretary.
c. Provide the Secretary's direction for Orders, Guides, and Technical Standards.
d. Remain in effect until canceled by the Secretary or Deputy Secretary.
2. ORDERS.
a. Requirements documents developed and processed in the Departmental Directives
Program, and approved by the Secretary or the Deputy Secretary.
b. Establish management objectives, requirements, and assignment of
responsibilities for DOE Federal employees consistent with the law, policy, and
regulations applicable to DOE.
c. If requirements for contractors are necessary, they are included in Attachment 1,
known as the contractor requirements document (CRD).
3. MANUALS.
a. Dictate how Federal and contractor employees are to implement requirements.
b. Are being phased out and canceled or are converted to or incorporated into
Orders, as appropriate. Manuals will not be revised and no new Manuals will be
created.
4. GUIDES.
a. Provide acceptable, but not mandatory, means for complying with requirements
included in Orders and Manuals that have not yet been phased out. Guides must
be associated with a directive or a rule.
b. Do not impose requirements, but may quote requirements if the sources are
adequately cited.
Appendix G DOE O 251.1D
1-17-2017 G-1 (and G-2)
DIRECTIVES CANCELLATION PROCESS
Section 19
The requirements of this section apply only if a given directive is canceled and not replaced by a
successor directive or incorporated into another directive. If the cancellation of a directive is
found to be necessary, the OPI must submit the directive to the Departmental Directives Program
and the DRB for inclusion on the Directives Prioritization list and schedule.
1. Once the DRB reaches consensus on the cancellation, the DRB will determine the course
of further cancellation review.
2. If no objections are received on the cancellation of the directive, the OPI will be
instructed by the DRB to provide the Departmental Directives Program with an approval
package.
3. If a Policy, Order, or Manual is being canceled, the Departmental Directives Program
transmits the approval package to the Deputy Secretary. If a Guide is being canceled, the
Departmental Directives Program transmits the approval package to the Director, Office
of Management.
Appendix H DOE O 251.1D
1-17-2017 H-1 (and H-2)
POLICY MEMORANDA CONVERSION PROCESS
Memoranda issued by the Secretary or Deputy Secretary that contain requirements must state
how those requirements will be integrated into DOE’s business processes (e.g., directive, budget
guidance, regulation), as applicable. These and other memoranda must be reviewed for
consideration for incorporation into the Departmental Directive Program if they establish
requirements for more than one Departmental element. The Director, Office of Management, in
consultation with the OPI, must review memoranda and provide recommendations to the
Secretary or Deputy Secretary, through the DOE Operations Committee. Recommendations may
include retirement, retention, or conversion into a directive in the Departmental Directives
Program.
1. Recommendation to Retire Memorandum. The Departmental Directives Program, in
consultation with the OPI, prepares an approval package consisting of an action
memorandum and the rationale for each recommendation for submission to the Secretary
or Deputy Secretary, through the DOE Operations Committee, for approval.
2. Recommendation to Convert or Incorporate Memorandum Requirements into a Directive.
a. The OPI must place the memo in the appropriate directive template verbatim and
submit an electronic file to the Departmental Directives Program.
b. The draft directive must be reviewed by the DRB.
c. As appropriate, comments must be forwarded to the OPI.
d. The draft directive must be discussed at a DRB meeting.
e. If the DRB approves the draft directive, the OPI must prepare and submit to the
Departmental Directives Program an approval memorandum containing the
former Secretarial memorandum and the proposed conversion to a directive for
the Deputy Secretary’s signature.
Appendix I DOE O 251.1D
1-17-2017 I-1 (and I-2)
ADMINISTRATIVE CHANGE PROCESS
Administrative changes are those that do not alter the applicability of, or requirements or
responsibilities in, the affected directive. Examples of such changes are typographical errors;
nomenclature changes, such as changes to organization names or title of officials; clarifications
that do not alter requirements or responsibilities; or changes to legal citations. All directives
requiring an administrative change have the same review process as delineated in this Appendix.
To request an administrative change, the OPI must:
1. Create redline/strikeout and clean copies of the proposed changes to the directive.
Section 20
2. Incorporate the proposed changes to the directive into a Chart of Changes document.
3. Create an approval memo justifying the need for an administrative change for the
approval of the Head of the Departmental Element or designee. Templates are located on
the DOE Directives website.
4. Submit the signed approval memo with hard and electronic copies of the files listed
above to the Departmental Directives Program for approval by the Program Manager,
Departmental Directives Program.
5. The Departmental Directives Program will notify the OPI whether the administrative
change has been granted. If the administrative change is not granted, the OPI may pursue
the change subject to the process delineated in Appendices A through C.
DOE O 251.1D Appendix J
1-17-2017 J-1
DEFINITIONS
1. Administrative Changes. Changes that do not alter requirements or responsibilities in the
affected directive. Examples of such changes are:
a. typographical errors;
b. nomenclature changes such as changes to organization names or titles of officials;
c. clarifications that do not alter requirements or responsibilities; or
d. changes to legal citations or references.
2. Authorization Coordinators (ACs). Support Senior Authorizing Officials and Authorizing
Officials in their duties. Develop and maintain SME and functional area workflows for
use in the review of directives actions and related documents. Submit the organization’s
consolidated comments on directives and related documents, as approved by the AO, at
the AO’s direction.
3. Authorizing Officials (AOs). Senior-level managers designated to assist the Senior
Authorizing Official by assigning local SMEs to review directives actions; soliciting and
consolidating comments on directives actions; ensuring management concurrence with
comments; authorizing the AC to submit the organization’s consolidated comments on
directives and related documents to the Senior Authorizing Official; facilitating comment
and issue resolution; and acting as liaison between their organizations and Senior
Authorizing Official.
4. Commander’s Intent. Describes what constitutes success for a directive. Includes a
directive’s purpose and the desired end state for a directive or a revision to one.
5. Comment Resolution. Process in which the OPI responds to comments received during
the review of draft directives. All comments submitted on behalf of a Head of a
Departmental Element by the Senior Authorizing Official must be addressed and resolved
before the directive is approved, when possible. Comments not resolved will go through
the impasse process.
6. Communication Plan. A document included with a directive's final draft that identifies
and describes how training and/or any other roll-out activities performed by the OPI will
be accomplished to support effective implementation of the directive.
7. Consensus. The highest level of agreement reached by a group as a whole.
8. Contractors. For purposes of the Directives Program, organizations under contract with
DOE to perform services with the clause at DEAR 970.5204-2, Laws, Regulations and
DOE Directives, in their contracts or requiring incorporation of a CRD in their contracts
to implement an Order. (Note: This definition of contractor does not include all of the
procurement contracts entered into by DOE.)
Appendix J DOE O 251.1D
J-2 1-17-2017
Section 21
9. Contractor Requirements Document (CRD). An attachment to a directive that states the
parts of the directive that apply to contractors. Where required, a CRD is included as
Attachment 1 to a directive. CRDs can be unilaterally inserted into contracts
that include DEAR 970.5204-2, Laws, regulations and DOE Directives, in accordance
with that clause. The clause requires the Government to give the contractor time to
identify the effect on the contract, including any increased costs or need for revision to
the contract’s incentives. For contracts not subject to DEAR 970.5204-2, the
CRD may be bilaterally (that is, with the contractor’s agreement) incorporated into the
contract.
10. Coordination. The process through which all stakeholders, including contractors, have the
opportunity to review and comment on draft directives.
11. Counsel. General Counsel, Procurement Counsel, Program Counsel, etc., all refer to
attorneys assigned to various parties for the purpose of providing legal advice and
guidance.
12. Crosswalk. A table for a directive revision which identifies changes in requirements and
the bases for these changes.
13. Departmental Elements. Headquarters elements and first-tier organizations as listed in the
Correspondence Style Guide, Office of the Executive Secretariat.
14. Directives. Documents in which DOE sets, communicates, and institutionalizes policies,
requirements, responsibilities and procedures for Departmental elements and contractors.
Directives include Policies, Orders, Notices, Manuals, and Guides. Manuals are currently
being phased out.
15. Directives Program Notification. A notification created by the Departmental Directives
Program that is used to communicate the approved issuance, revision, or cancellation of a
directive or other administrative action regarding directives.
16. Directives Review Board (DRB). Chaired by the Director, Office of Management, the
Board advises, as well as concurs, on individual directives before their approval by the
DOE Operations Committee for release for DOE-wide comment and final issuance.
Board membership is comprised of two senior representatives from each of the three
Under Secretarial offices, the Office of the General Counsel, and the Office of
Environment, Health, Safety and Security. Non-voting, advisory members include senior
representatives from the National Laboratory Directors Council and the Field
Management Council.
17. DOE Operations Committee. Chaired by the Deputy Under Secretary for Management
and Performance and advised by the DRB, the Committee provides strategic oversight
and senior-level direction on the need for new or updated directives and other
Departmental requirements. The DOE Operations Committee reviews the justification
and needs for requirements, with respect to mission relevance and impact. The DOE
http://energy.gov/management/downloads/correspondence-style-guide
DOE O 251.1D Appendix J
1-17-2017 J-3
Operations Committee appropriately prioritizes a directives schedule that establishes next
steps to promote mission achievement.
18. Equivalencies. Alternatives to how a requirement in a directive is met in cases where the
“how” is specified. These represent acceptable, alternative approaches to achieving the
goal of a directive’s requirement.
19. Exemptions. A release from compliance with one or more requirements in a directive, as
granted by the exempting organization’s Head of the Departmental Element.
Section 22
20. Fast Track Development. A course of directives development reserved minor changes
proposed by the OPI, undisputed reductions in requirements as agreed to by the DRB and
DOE Operations Committee, changes directed by S1/S2, verbatim codification of
Secretarial Memoranda into directives, or a combination of the above.
21. Financial Impact Analysis. A document that details potential significant budgetary or
other resource impacts of a directive’s implementation on the Department, shared with
DRB members upon request.
22. H Clause. A clause inserted into section H (Special Contract Requirements) of a contract,
used to specify and tailor requirements.
23. Heads of Departmental Elements. For the purposes of this Order, Heads of Departmental
Elements include the Assistant Secretaries and Program Office Directors reporting to the
Secretary either directly or through the Deputy Secretary or Under Secretaries. The
NNSA Administrator is the only NNSA Head of the Departmental Element. For the
purposes of this Order, Power Marketing Administrators are Heads of their Departmental
Elements. Heads of Departmental Elements implement the requirements and
responsibilities assigned to them in this Order. The Secretary, Deputy Secretary, and
Under Secretaries may also perform these roles at their discretion.
24. Impasse. When a resolution of directives issue(s) cannot be agreed on between one or
more Heads of Departmental Elements.
25. Integrated Project Team (IPT). A group of DOE Federal and contractor employees –
including, but not limited to, OPI representatives; senior-level program and National
Laboratory executives; SMEs; and DOE general oversight representatives, as applicable
– convened to work on the revision or development of a specific directive.
26. Invoked Technical Standard. A DOE Technical Standard that is called upon, in part or in
whole, as a required method in a DOE Directive based on a clear requirement statement.
The following is an example of an invoking requirement statement: “DOE Headquarters
line management must oversee DOE field processes for verifying readiness to startup and
restart nuclear facilities in accordance with . . . DOE-STD-3006, Planning and
Conducting Readiness Reviews. (DOE Order 425.1D)”
27. Minor Change. When a directive modification is restricted to a limited portion of the
requirements and/or responsibilities established in the directive. The review process for a
Appendix J DOE O 251.1D
J-4 1-17-2017
minor change is limited to only the changed portions of the draft directive. Previously
known as the Page Change.
28. Office of Primary Interest (OPI). The office responsible for originating a directive and
maintaining its accuracy and currency.
29. Procurement Management System. The Procurement Management System encompasses
the integration of the procurement process (acquisition of supplies, services, and
property), the professional development of procurement personnel, development of DOE
procurement regulations and policies, and the management structure for carrying out the
procurement function. The procurement programs managed by DOE and NNSA Senior
Procurement Executives that ensure the development and implementation of
Department-wide policies, procedures, programs, and management systems pertaining to
procurement and financial assistance.
30. Requirements. Activities that must be performed pursuant to a directive to fulfill the
Department’s mission.
Section 23
31. Responsibilities. Duties and authorities assigned to a position or office to implement,
manage and/or oversee.
32. Review and Comment system. A web-based workflow system used by the DOE for
coordination of draft directives.
33. Revision. When a proposed modification to a directive will affect a large portion of its
requirements and/or responsibilities, as determined by the Departmental Directives
Program.
34. Senior Authorizing Officials (SAOs). Senior-level Headquarters managers designated to
lead efforts to solicit, review, and adjudicate comments from within their organizations.
Duties include assigning local SMEs to review directives actions; soliciting and
consolidating comments on directives actions; ensuring management concurrence with
comments; authorizing the AC to submit the organization’s final, consolidated comments
on directives and related documents; facilitating comment and issue resolution; informing
SMEs of comment resolution and disposition; and acting as liaison between their
organizations and the DRB.
35. Stakeholder. A person or organization affected by or with an interest or concern in a
directive, and therefore an interest or concern in changes made to that directive. DOE
stakeholders may include, but are not limited to:
a. affected program and site offices;
b. Field Management Council representatives, as appropriate;
c. National Laboratory Directors Council representatives, upon DRB request;
DOE O 251.1D Appendix J
1-17-2017 J-5 (and J-6)
d. the appropriate DOE or NNSA counsel;
e. the Office of Primary Interest (Preparing Activity) responsible for any DOE
Technical Standard being invoked in the directive;
f. the Office of Policy, Office of Acquisition Management (MA-61);
g. Field Contracting Officers;
h. CTAs, when appropriate; and
i. the DOE Departmental Representative to the DNFSB, for all directives of interest
to the DNFSB.
36. Technical Standard. DOE standards, handbooks, and specifications established,
approved, and maintained in accordance with the DOE Technical Standards Program (see
the current version of DOE O 252.1, Technical Standards Program). DOE standards, the
only type of DOE technical standard that may be invoked in a DOE Directive, provide
specific standardized approaches, methodologies, technical criteria, or other information
on accomplishing a task, developing a plan, and/or performing a calculation or
assessment to implement a DOE requirement. DOE standards provide a common shared
approach or methodology for implementing a DOE requirement such that its
implementation is consistent across DOE programs and operations.
37. Unauthorized Directives. Unauthorized directives are documents that purport to apply
on-going requirements (other than legal requirements) to more than one Departmental
element outside the OPI’s chain of command, and that have not been reviewed and
promulgated through the processes described in this Order. Exceptions are allowed for
unique requirements promulgated through acceptable alternative programs or processes
covered by an Order, if addressed in paragraph 3.c. of this Order, or as otherwise directed
in writing by the Secretary or Deputy Secretary.
38. Voluntary Consensus Standards. Standards are developed through a process that is open
to participation by representatives of all interested parties, transparent, consensus-based,
and subject to due process. These might be developed by governmental organization or
private sector groups such as the American Society for Testing and Materials (ASTM) or
the International Organization for Standardization (ISO).
Section 24
1. PURPOSE
2. CANCELS/SUPERSEDES.
3. DEPARTMENTAL APPLICABILITY.
a. Departmental Elements.
b. Contractors.
c. Equivalencies/Exemptions for DOE O 251.1D.
4. REQUIREMENTS.
a. General.
b. Directives Development.
c. Contractor Requirements in Directives
d. Secretarial Memoranda.
e. Implementation of DOE Directives.
5. RESPONSIBILITIES.
a. Secretary of Energy.
b. Deputy Secretary
c. Under Secretaries. Designate two senior-level representatives to represent their interests and perform the roles and responsibilities of DRB members.
d. Administrator, National Nuclear Security Administration.
e. DOE Operations Committee.
f. Associate Under Secretary for the Office of Environment, Health, Safety and Security.
g. Chief Human Capital Officer (CHCO).
h. Heads of Departmental Elements. As appropriate may, or may delegate to a direct report to:
i. Director, Office of Management.
j. Directives Review Board Members.
k. Central Technical Authorities (CTAs). Provide, to the applicable Senior Authorizing Officials and the applicable Head of the Departmental Element, their concurrence or non-concurrence on all directives that affect nuclear safety as defined in the c...
l. Departmental Directives Program Manager, Office of Management.
m. Offices of Primary Interest (OPI).
n. Senior Authorizing Official (SAO).
o. Integrated Project Team (IPT) Co-Chairs.
p. IPT Members.
q. DOE Departmental Representative to the DNFSB.
r. Heads of Field Elements.
s. Contracting Officers (CO).
t. Senior Authorization Coordinator (SAC).
6. REFERENCES.
7. DEFINITIONS
8. CONTACT
APPENDIX A. DIRECTIVES PRIORITIZATION PROCESS
1. REQUEST FOR DIRECTIVES ACTIONS. The DRB and the Departmental Directives Program will compile a list of proposed directives.
2. AD HOC DIRECTIVES ACTIONS.
APPENDIX B. INTEGRATED PROJECT TEAM (IPT) DIRECTIVES PROCESS
1. STAGE 1. DEVELOPMENT APPROVAL AND SCHEDULING
2. STAGE 2. IPT CREATION.
3. STAGE 3. DEVELOPMENT OF THE DECISION MEMORANDUM
4. STAGE 4. FIRST DIRECTIVES REVIEW BOARD MEETING.
5. STAGE 5. FIRST DOE OPERATIONS COMMITTEE MEETING. The IPT Co-Chairs will present the IPT’s decision memorandum at a DOE Operations Committee meeting, with the DRB Chair in attendance.
6. STAGE 6. DEVELOPMENT OF THE FIRST DRAFT. Once the decision memorandum is approved by the DOE Operations Committee, the IPT may begin draft development.
7. STAGE 7. DIRECTIVE REVIEW AND COMMENT.
8. STAGE 8. COMMENT RESOLUTION/DEVELOPMENT OF THE FINAL DRAFT. The IPT, following the timeline established through the Directives Prioritization effort, must:
9. STAGE 9. FINAL REVIEW AND CONCURRENCE.
10. STAGE 10. FINAL APPROVAL.
11. STAGE 11. IMPLEMENTATION.
APPENDIX C. FAST TRACK DIRECTIVES PROCESS
1. STAGE 1. DEVELOPMENT APPROVAL AND SCHEDULING. The OPI must follow the Directives Prioritization process outlined in Appendix A. Once the directive action is approved for the Fast Track process, the OPI may begin draft development according to the e...
2. STAGE 2. DEVELOPMENT OF THE FIRST DRAFT.
3. STAGE 3. FAST TRACK REVIEW AND COMMENT.
4. STAGE 4. COMMENT RESOLUTION/DEVELOPMENT OF THE FINAL DRAFT. The OPI must respond to comments and work with DRB members and commenters to resolve issues, as necessary;
5. STAGE 5. FINAL REVIEW.
6. STAGE 6. FINAL APPROVAL.
APPENDIX D. PRINCIPLES FOR DIRECTIVES DEVELOPMENT
1. ESTABLISH LINE ORGANIZATION
2. EMPOWER FIELD OFFICES.
3. PROMOTE INCLUSIVENESS.
4. AVOID UNNECESSARY DUPLICATION.
5. REFLECT IMPROVED PLANNING AND COORDINATION.
6. CONTAIN PERFORMANCE-BASED CONTRACT REQUIREMENTS
7. BE TAILORABLE.
8. INCORPORATE A RISK MANAGEMENT STRATEGY.
Section 25
APPENDIX E. EQUIVALENCY AND EXEMPTION PROCESS
APPENDIX F. DIRECTIVES TYPES
1. POLICIES.
2. ORDERS.
3. MANUALS.
4. GUIDES.
APPENDIX G. DIRECTIVES CANCELLATION PROCESS
APPENDIX H. POLICY MEMORANDA CONVERSION PROCESS
APPENDIX I. ADMINISTRATIVE CHANGE PROCESS
APPENDIX J. DEFINITIONS
1. Administrative Changes
2. Authorization Coordinators (ACs)
3. Authorizing Officials (AOs)
4. Commander’s Intent
5. Comment Resolution
6. Communication Pla
7. Consensus
8. Contractor
9. Contractor Requirements Document (CRD)y inserted into contract...
10. Coordination
11. Counsel
12. Crosswalk
13. Departmental Elements
14. Directives
15. Directives Program Notification
16. Directives Review Board (DRB)
17. DOE Operations Committee
18. Equivalencies
19. Exemptions
20. Fast Track Development
21. Financial Impact Analysis
22. H Clause
23. Heads of Departmental Elements.
24. Impasse
25. Integrated Project Team (IPT)
26. Invoked Technical Standard
27. Minor Change
28. Office of Primary Interest (OPI)
29. Procurement Management System
30. Requirements
31. Responsibilities
32. Review and Comment system
33. Revision
34. Senior Authorizing Officials (SAOs)
35. Stakeholder
36. Technical Standard
37. Unauthorized Directives
38. Voluntary Consensus Standards