Implementation of the Necessary and Sufficient Closure Process leading to Work Smart Standards was approved by Martha Krebs, Director, Office of Energy Research on April 19, 1996, and was initiated at the Ernest Orlando Lawrence Berkeley National Laboratory with a kick-off meeting on May 31, 1996.
The attached first draft set of Work Smart Standards has been produced by the Identification Team and approved for distribution by the Convened Group on September 13, 1996. It will be provided to the Internal Review Teams and the Confirmation Team, as well as the Stakeholder Reading Rooms, on September 16, 1996.
The set will be modified, as needed, during the review and confirmation process. You are invited to submit comments and suggestions to Ben Feinberg, Process Leader, Lawrence Berkeley National Laboratory, MS 80-101, Berkeley, CA 94720 (e-mail [email protected]).
Several criteria rules were agreed to by the Convened Group, and are presented below.
The Work Smart Standards process develops a set of standards appropriately tailored to the specific work to be performed and the hazards associated with that work. Because of its focus on specific work and associated hazards, the Work Smart Standards process is not designed to assess systems for overall management of environment, safety and health. (These overall ES&H management systems include maintenance management, quality assurance, performance assessment, and control of operations.)
Coincident with application of its Work Smart Standards initiative, however, the Department of Energy is also studying an improved approach to management systems for environment, safety and health. Central to the improved approach to ES&H management is an emphasis on integrating environment, safety and health into all levels of management so that work is planned and missions accomplished while protecting the public, the worker, and the environment. The Berkeley Laboratory fully supports the integrated approach to ES&H management, and is an active participant in the Department's teams that are crafting the guidance for implementation of an Integrated Safety Management System.
The Berkeley Laboratory intends to implement the approved set of Work Smart Standards in a manner which advances an Integrated Safety Management System. Since the first steps in developing an Integrated Safety Management System (Define the Work and Associated Hazards and Develop the Set of Requirements needed to address those risks) are identical, the design of the Laboratory's Integrated Safety Management System to meet current conditions will be completed after the approval of the Work Smart Standards set. The existing systems for implementation of Department directives on ES&H management will remain in force until the Integrated Safety Management System is implemented. The Laboratory and the Department intend to collaborate on the design of the Integrated Safety Management System and appropriately revise the contract upon completion of an Integrated Safety Management Plan for the Laboratory.
The Work Smart Standards set was chosen under the following ground rules.
- In general, federal laws and regulations that are applicable to DOE facilities and require protection of workers, the public, and the environment are included in the set. State laws and regulations and local ordinances are also included if the applicable federal law contains a waiver of federal sovereign immunity, making federal facilities subject to state and local laws to the same extent as nonfederal facilities.
- Other external or internal standards that the Identification Team has determined are required to assure adequate protection of the worker, public, and environment are included in the set. These may include consensus standards (e.g.: ANSI standards); state laws and regulations and local ordinances where there is no sovereign immunity waiver in the applicable federal law; and internal standards (e.g.: Berkeley Lab Health and Safety Manual, PUB-3000). This category may also include standards that are specifically applicable to the Department of Energy but not Berkeley Lab. They are included since the Berkeley Lab provides support and assistance to the Department of Energy in carrying out its obligations.
- External or internal guidance documents are not included in the Work Smart Standards set. These documents typically require substantial professional judgment to apply, and are not intended as a set of regulations with which to determine compliance. Documents of this nature which are deemed important to implementation of the Work Smart Standards set are included in the individual Identification Team documents and in the narrative of the report.