I had just transferred to the Office of Regulatory Affairs (EH-51) when the Office Director decided to train all of the professional staff in conducting evaluation of the Voluntary Protection Program (VPP). My training consisted of an overview of VPP and was very helpful in my first VPP assignment. I was assigned to the VPP re-evaluation of the Protective Technologies Hanford (PTH). Fortunately, the Team Leader had served as the Assistant Team Leader of the pre-evaluation of PTH and served on several VPP evaluation teams.
At the onset I faced two main challenges. First, I had never served as a team member even though I led large assessment teams. Secondly, these assessments were primarily to assess contractors' and field offices' compliance with laws, regulations, DOE orders and contractual clauses. Being a team member requires different skills than a team leader. However, I was confident of my technical competence and was sure that I could get guidance from my highly seasoned team leader. I convince myself to always remember that I VPP is voluntary program and is not compliance-driven.
Armed with satisfactory resolution to myself of the two concerns, I proceeded full speed with the re-evaluation. I reviewed the application and the preliminary VPP evaluation report issued in December 1999. While the report contained many recommendations the VPP Team identified PTH's main weakness lack of documentation. PTH also reported that all of the corrections had been made and that Phase I and Phase II of the Integrated Safety Management (ISMS) were completed successfully in July 2000.
I was also concerned that PTH's Environment, Safety and Health (ES&H) Manager was spread too thin. The management did not seem to have a satisfactory solution to this very serious problem.
During the evaluation I was impressed by the enthusiasm of the workers and management showing excellent management and worker involvement. However, when I asked the management why the Pre-evaluation Team's recommendations were not carried out, the PTH President stated that since these were only recommendations, not concerns, PTH was not required to carry them out. I reminded him that since VPP is a voluntary program the VPP teams only make recommendations but before being admitted to the select group of a DOE VPP site, the site must demonstrate excellence.
We also were faced with an allegation that our weapons expert was from a direct competitor of PTH and was probing in an unusual fashion. However, the Team Leaser and I were able to allay PTH's fears and persuaded the weapons expert to be sensitive to PTH's fears.
Now came the time of team deliberations and both the Team Leader and I were relieved to see a general consensus among the team members, including the employee representatives and the RL staff. The OSHA representative also supported the team's consensus. Every one agreed that PTH has not yet met all of the elements required by DOE VPP Program for designation as a ""Star Site." I am glad to learn that the management likely to award "merit status" to PTH for a re-evaluation in six to nine months.
The size and affiliations of the Team was of great concern to both the Team Leader and I. The normal team size is three or four, including the team leader. Our team consisted of two members of EH-51 staff, one weapons expert from the WSI, a VPP star site, two subject matter experts from the DOE Richland Operations Office (DOE-RL), and three employee representatives from the Hanford Atomic Metal Trades Council (HAMTC). Additionally, RL designated a liaison to work with the team who wanted to be part of all of the team meetings and deliberations. The Team Leader and I were concerned that there may be a conflict of interest since the majority of the team was from the Hanford site, they could make team consensus difficult.
A member of Region X of the Occupational Safety and Health Administration (OSHA) served as an observer. In most of the other VPP Evaluations, the OSHA staff participated as a team member. Being an observer provided him an opportunity to criticize DOE VPP Evaluation without fully participating in it.
When we received the in-briefing by PTH, I got a distinct impression that
PTH management felt that PTH was already a star site and that our
evaluation was just a formality. They did not even provide an update
on the recommendations made by the Pre-evaluation Team. Unlike my
experience in other follow up assessments, the VPP team was not provided
properly organized
documents. These documents were provided to the ISMS the ISMS Team.
My suspicion that PTH had devoted all its efforts to completion of ISMS (which is mandatory) and submitted its VPP application were confirmed in a meeting with PTH management in which PTH management indicated that they had primarily focussed on ISMS and hoped that the documentation required for ISMS would also satisfy the VPP documentation requirements.
RL liaison was able to fully participate in the VPP Team meetings, the PTH meetings and the VPP Team Leader's meetings with PTH. Since we are trying to develop a cadre of field office staff to serve on VPP teams, it is important to share information with DOE staff but we need to ensure that such information does not pass to the contractor.
After the assessment, I came to the following conclusions: