DOE O 5480.17, Site Safety Representatives

U. S. Department of Energy ORDER Washington, D.C. DOE 5480.17 10-5-88 S U B J E C T : S I T E S A F E T Y R E P R E S E N T A T I V E S 1. PURPOSE . To establish the interim functions and procedures for Environment, Safety and Health (EH) organization Site Safety Representatives. 2. SCOPE . The provisions of this Order apply to all Departmental Elements and contractors performing work for the Department as provided by law and/or contract and as implemented by the appropriate contracting officer. 3. APPLICABILITY. This Order applies to DOE management and operating contrac- tors and their appropriate contracting officers excluding those facilities and activities conducted under Executive Order 12344 and Public Law 98-525 section 1634, 98 Stat. 2649. 4. BACKGROUND. The National Academy of Science and Engineering, in its report to he Secretary of Energy of 10-28-87, recommended that the Department's over- sight organization should have a permanent and significant onsite presence with a formal reporting relationship between onsite personnel and Headquarters. In response to this recommendation, EH Site Safety Representatives are being assigned to selected field sites through a multiphased program to be imple- mented over a period of several years. The EH Site Safety Representative presence in the field is to enhance EH’s independent oversight role by providing f irsthand observation of field activities. The objective is to assure that DOE’s safety performance is sound. Effective two-way commnunica- tion is fundamental to achieving this objective. Accordingly, this Notice defines interim functions and procedures for EH Site Safety Representatives for interaction between DOE Headquarters elements, field elements, and the EH Site Safety Representatives. 5. RESPONSIBILITIES. a. Program Secretarial Officers and Heads of Field Organizations (i.e., Operations office Managers and Area offlee Managers) are responsible for assuring that all operations and activities under their jurisdiction are carried out in accordance with Orders and consistent with sound safety practices. DISTRIBUTION: INITIATED BY: All Departmental Elements Office of Environment, Safety and Health 2 DOE 5480.17 10-5-88 b. EH Site Safety Representatives responsibilities are to provide independent onsite oversight through monitoring, inspecting, observing, and reporting on safety activities at a site. Interaction Organizations and EH Site Safety Representat with Attachment 1, “Functions and Procedures Representatives." BY ORDER OF THE SECRETARY OF ENERGY: ~ JOSEPH Deputy between Heads of Field - ve(s) shall be in accordance of EH Site Safety F. SALGADO Secretary DOE 5480.17 10-5-88 Attachment 1 Page 1 FUNCTIONS AND PROCEDURES FOR EH SITE SAFETY REPRESENTATIVES 1. PURPOSE. To define the functions of the EH Site Safety Representative(s) and procedures for interaction between the Operations Office and/or Area Office and the EH Site Safety Representative(s). The intent is to provide a framework which promotes mutual cooperation and interaction between the parties while preserving and protecting both EH’s independent oversight responsibilities and the Headquarters program offices and Operations Offices line environment, safety, and health responsibilities.

2. ROLE OF THE EH SITE SAFETY REPRESENTATIVE. The overall role of the EH Site Safety Representative(s) is to strengthen the Department’s independent oversight by providing EH with onsite capability for technical monitoring and assessment of field activities. The primary functions of EH Site Safety Representative(s) are to monitor, inspect, observe, and report on safety activities at a site. The specific activities of the EH Site Safety Representative(s) will include: (a) Conducting onsite observations of facilities and operations. These observations may be performed through both scheduled and unscheduled inspections or “walk-throughs” at a site or facility. The resident EH staff will inform the Operations Office and/or Area Office of formal itinerary in advance, but may also make spot visits or unscheduled site observations, as deemed necessary, to verify that site facilities and operations are performed in accordance with established requirements. (b) Monitoring of the status of Operations Office/Area Office appraisal, review, and safety analysis programs. This will include an overview of the status of facilities prior to construction, during construction, preoperational testing, startup, and all phases of operation. (c) Reviewing contractor reports and notifications of incidents, events, or unusual occurrences. (d) providing EH with a firsthand technical safety resource for the DOE site in question and participating in EH assessment teams. (e) Observing the interpretation and application of safety and health requirements and practices at the site to identify problems that the site experiences in implementing safety and health requirements or situations in which requirements have not been fully implemented. The EH representative will provide clarification of the intent of the requirements and observations made and, as appropriate, review the Operations Office or Area Office resolution of the problem with EH Headquarters. 3. REPORTING. EH Site Safety Representative(s) will provide daily, weekly, and monthl y written reports to the Deputy Assistant Secretary for Safety, Health and Quality Assurance (EH-30) on the status of safety assurance at the site, highlighting the results of observations and issues identified. Daily Attachment 1 DOE 5480.17 Page 2 10-5-88 reports should be limited to highlights of daily technical observations; weekly reports should cover activities, administrative information, and highlights of weekly technical observations; monthly reports should cover activities, administrative information, a technical synopsis of issues needing action, an open items summary, identification of trends and root causes, and actions taken by the field organization in response to issues identified. Other reports may be necessary as mutually agreed upon between EH-30 and the site representative(s). Copies of site representative(s) reports to EH-30 will also be distributed to the cognizant Assistant Manager of the Operations Office or Area Office, the field safety organization director, and the cognizant Headquarters program office. The site representative(s) will report daily by telephone to EH-30 on site activities and safety observations. Significant safety problems or issues that require immediate attention will be reported promptly to the appropriate Operations Office or Area Office so that appropriate corrective actions can be taken. (See Section 6 for EH Site Safety Representative/contractor interface.) The EH Site Safety Representative(s) will also advise EH-1 and EH-30, as well as Operations Office/Area Office management, of activities and actions that warrant prompt attention (e.g., corrective action, special reviews, and investigations) with possible follow up action required through the Operations Office or Area Office.

4. MEETINGS. The EH Site Safety Representative(s) will normally be afforded the opportunity to attend technical information exchange meetings which have safety implications conducted between the Operations Office or Area Office and its contractors. Attendance at other internal Operations Office/Area Office/contractor management meetings will be by invitation, with follow-up meetings or information provided to the senior site representative as warranted. Meetings between the senior EH Site Safety Representative and cognizant Operations Office Assistant Manager or Area Office Manager will be held on a routine (e.g., weekly) basis. The Manager or Deputy Manager will meet with the senior site representative as requested by either party. 5. EH SITE SAFETY REPRESENTATIVE/FIELD ORGANIZATION INTERFACE. The EH Site Safety Representative(s) report directly to EH-30. The field organization management interface with the senior EH Site Safety Representative will normally be at the Assistant Manager or Area Office Manager level, as appropriate. Routine day-to-day technical interfaces will be through an Operations Office/Area Office designated point of contact (typically the ES&H Director). Any problems or issues identified by the site representative(s) deemed to be of immediate urgency will be brought to the attention of Operations Office/Area Office management followed by immediate notification to EH-30. The Operations Office/Area Office will also keep the EH Site Safety Representative(s) informed of unusual occurrences, occupational safety or health complaints, emergencies, and other items of safety significance. 6. EH SITE SAFETY REPRESENTATIVE/CONTRACTOR INTERFACE. EH Site Safety Repre- sentatives will be provided unencumbered access to management and operating contractors and their subcontractors so that significant safety issues or DOE 5480.17 Attachment 1 10-5-88 Page 3 concerns can be observed routinely. EH Site Safety Representatives will not provide any direction to the contractor and will not interact in a manner that interferes with operations or the contracting officer/contractor relationship. The Operations Office/Area Office will be apprised in a timely manner of any observations that need to be verbally communicated to the contractor. 7. 8. 9. EH SITE SAFETY REPRESENTATIVE/INTERFACE WITH OTHER AGENCIES AND GROUPS. In the event an Site Safety Representative is contacted by employees or union representatives, Federal, State, or local regulatory agencies, media, etc., concerning inquiries or safety issues related to the site, the representative should refer the matter to the appropriate site or field DOE management for response. If a satisfactory response is not obtained as a result of the referral, then the matter should be brought to the attention of EH-30 by the senior site representative for further action. DOCUMENTATION SUPPORT. A comprehensive list of routine, formal safety- related reports will be provided to the EH Site Safety Representative(s). All requests for program/technical documents from both contractors and DOE field organizations will be provided through the cognizant Operations Office or Area Office point of contact. Correspondence of EH interest, currently provided to Headquarters, will also be provided to the EH Site Representa- tives. All EH Site Safety Representatives will routinely receive Operations Office and Area Office announcements and other information customarily provided to field organization employees.

FACILITY ACCESS a. b. c. Access to all areas of a site will be afforded consistent with DOE safety, emergency preparedness and accountability, safeguards, and security policies. The EH Site Safety Representative(s) need not be escorted onsite unless a special hazard exists or a formal determination is made by the local Director of Safeguards and Security that safeguard and security considerations warrant such provisions. Operations Office/Area Office personnel and contractor personnel will normally be provided the opportunity to accompany the EH Site Safety Representatives on facility inspections or walk-throughs. The Operations Office/Area Office point of contact will notify contractors only for regular scheduled visits. In the event of an emergency condition at a site, the EH Site Safety Representative will be permitted to observe Emergency Operations Center (EOC) onsite activities, as appropriate, related to emergency response. Communication related to the emergency will flow as normal through the EOC . The senior EH Site Safety Representative will not serve as a communication resource to the EOC, but as an observer to independently provide information, as appropriate, directly to EH, but in a manner that does not interfere with the normal emergency operations/communications for the site. Attachment 1 DOE 5480.17 Page 4 10-5-88 10. APPRAISAL AND INSPECTION SCHEDULING. Scheduled appraisals and inspections Will be routinely coordinated between the Operations Office/Area Office and the EH Site Safety Representatives. This coordination effort is designed to minimize redundant and conflicting appraisals and inspections. The EH Site Safety Representative(s) may participate as an observer on Operations Office/ Area Office appraisals, surveys, inspections, investigations, readiness reviews, and audits. 11. TRAINING. EH Site Safety Representatives, prior to conducting any onsite inspections, will receive required facility safety-related training and all essential site training such as safeguards and security training. Training plans will be developed consistent with the responsibility and needs of the individual EH Site Safety Representatives. 12. HANDLING OF COMPLAINTS. a. The procedures for submission and resolution of occupational safety and health complaints contained in DOE 5483.1A, “Occupational Safety and Health Program for DOE Contractor Employees at Government-Owned Contractor-Operated Facilities,” of 6-22-83, Chapter II, shall apply. These procedures require initial submission of complaints by contractor employees to contractor management. In situations where the complainant wishes to remain anonymous or where the complainant believes that unsafe/unhealthful conditions still exist or violations of standards still remain after being brought to the attention of, and addressed by, contractor management, submissions may be made directly to the DOE field organization. DOE 5483.1A procedures also provide for resolution of complaints through EH Headquarters in the event that the complainant is not satisfied with the adequacy or effectiveness of the field organization’s investigation of, or response to, their complaint allegations.

b. In the event that a complaint is submitted directly to an EH Site Safety Representative either by letter, DOE F 5480.4, “Contractor Employee Occupational Safety or Health Complaint,” or orally, the EH Site Representative will refer the matter to the field organization’s health and safety organization for response through the procedures specified in DOE 5483.1A. If judged to be of pertinence to EH, in its independent oversight role, complaints may also be referred directly by the senior site representative to EH Headquarters with copies to the field organization. The EH Site Representative(s), as part of their normal duties, will provide independent oversight of the handling of complaints by the Operations Offices/Area Offices and, if the matter is ultimately referred to EH Headquarters for resolution. may be requested by EH-30 to conduct an investigation of the situation consistent with the - requirements of DOE 5483.1A, Chapter 11, paragraph 5. 13. ADMINISTRATIVE SUPPORT. Office space and normal administrative support will be provided by he Operations Office/Area Office. Clerical support for the EH Site Safety Representatives will be provided by EH if the number of site DOE 5480.17 Attachment 1 10-5-88 Page 5 (and 6) representatives exceeds three. At least half-time clerical support will be provided by EH for smaller site representative groups. Aside from prescribed reporting, a concerted effort must be made to minimize any additional administrative burdens or any other imposed activities which distracts EH Site Safety Representatives from their primary role as safety observers and monitors.