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10 CFR 851.11(b) requires DOE Field Elements to evaluate
and approve contractor Worker Safety and Health Programs
(WSH Program). In evaluating the WSH Program the approving
authority should request documentation of a 'gap analysis'
that identifies any short comings (gaps) in the existing
safety and health program. In addition, corrective
actions for these 'gaps' should clearly explain how
and when the contractor will come into compliance.
A crosswalk matrix of all the requirements in 10 CFR
851 Subpart C is the most important part of the WSH
Program. The matrix should clearly show how the existing
and/or revised contractor SH program meets each of
the rules requirements.
The WSH Program is intended to be a high level program
and should be between 15 and 30 pages in length. Details
of each program element should be made available upon
request, however, detailed programs should not be
a part of the Approved Program Plan.
NNSA has developed a "Standardized Review Plan"
and has agreed to have the document made available
on the 10 CFR 851 web site (see below). This document
is only one approach that can be used to assure consistency
of WSH Programs across a field office or secretarial
office. Each Program Office should be aware of any
unique situations they must deal with in approving
WSH Programs, however, as a minimum every WSH Program
should have the gap analysis and cross walked mentioned
above.
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