Industrial Hygiene:
Occupational Exposure and Health Hazards Management Program

FUNCTIONAL AREA GOAL:  This CRAD is intended to provide guidance for evaluation of the occupational exposure assessment and health hazards management component of the DOE and contractor's Industrial Hygiene (IH) program.  The goal of the criteria is to answer two fundamental questions:

• Is the Operating Contractor implementing, and effectively managing an IH; occupational exposure assessment and hazards management program that meet the intent of DOE Directives?
• Is the DOE Field Element providing effective oversight, program direction, guidance, and requirements to the Operating Contractor?

REQUIREMENTS:

• Worker Protection Management for DOE Federal and Contractor Employees; DOE Order 440.1A
• 10 CFR Part 851, Worker Safety and Health Program Rule (Pending)
• 10CFR Part 850 Chronic Beryllium Disease Prevention Program; Final Rule
• OSHA Regulations Standards - 29 CFR 1910 and 1960.
• DOE ES&H Reporting Order 231.1; and Computerized Accident/Incident Reporting System (CAIRS)
• DOE O 231.1A, Environment, Safety and Health Reporting
• Work Authorization System Order; DOE O 412.1A
• Environment, Safety and Health (ESH) Goals Policy; DOE P 450.7
• Safety Management Functions, Responsibilities, and Authorities Policy; DOE P 411.1
• Quality Assurance Order; DOE O 414.1C
• DOE Notice 450.14, Safe Handling, Transfer, and Receipt of Biological Etiologic Agents at Department of Energy Facilities.
• DOE Policy 456.1, Secretarial Policy Statement on Nanoscale Safety.
• DOE Order 5480.19, Conduct of Operations Requirements for DOE Facilities.
• DOE Order 5480.20A, Personnel Selection, Qualification, and Training. Requirements for DOE Nuclear Facilities.
• DOE Order 225.1A, Accident Investigations.

GUIDANCE:

• DOE G 440.1-3, Implementation Guide: Occupational Exposure Assessment.
• A Strategy for Managing and Assessing Occupational Exposures, Second Edition, American Industrial Hygiene Association: 1998. (Or Current Edition).
• NIOSH 77-173, Occupational Exposure Sampling Strategy Manual: 1977.

Performance Objective 1: Contractor Program Documentation

DOE expects under its Integrated Safety Management System (ISMS) philosophy that; line management has documented a formalized, and effective organization for managing the IH; occupational exposure and health hazards program.

Criteria:

1. The Operating Contractor's Safety and Health Organization has a documented IH; occupational exposure and health hazards management program in place based on DOE Directives and recognized consensus standards, i.e. the American Industrial Hygiene Association (AIHA), and the National Institute of Occupational Safety and Health (NIOSH). The program defines the technical areas and the frequency at which each technical area is assessed. For each technical area there is a procedure for performing the health hazard assessment which defines the purpose, scope, responsibilities, assessment criteria, and references. The assessment documentation includes; the occupational exposure assessment and sampling methodology, laboratory analysis method used, report findings, corrective actions, review, and distribution of reports.
    
2. The Operating Contractor has documented clear definition of responsibility for decisions by senior management, provision for escalation of worker health matters involving significant occupational exposures and hazards to DOE in an appropriate time frame.
    
3. The Operating Contractor has a documented site wide planning and budgeting process include priorities for managing occupational exposures and health hazards.
    
4. The Operating Contractor's Safety and Health Organization has documented implementation plans for the occupational exposure and health hazards management program.
    
5. The Operating Contractor has established formal documentation defining clear lines of authority and responsibility for management of the occupational exposure and health hazards program. Responsibilities of each staff position are defined for worker health activities. Internal and external interfaces within and between the DOE Field Element, the Operating Contractor, and with outside groups (i.e., State, local, and regional health officials and other government agencies) are clearly and formally defined for each position.
    
6. The Head of the Operating Contractor's Safety and Health Organization ensures that they develop and maintain a written occupational exposure and health hazards management program in conformance to DOE Order 440.1A, 10 CFR 850, and 10 CFR 851.

Performance Objective 2: Operating Contractor's Program Implementation

DOE expects under DOE Directives that the Operating Contractor manage, implement, and verify a technically sound IH; occupational exposure and health hazards management program.

Criteria:

1. The Operating Contractor has fully integrated its IH; occupational exposure and health hazards management program into the Contractor's work planning and execution process.
    
2. The Operating Contractor's Safety and Health Organization prepares an annual schedule showing the occupational exposure and health hazards assessments planned.
    
3. The Operating Contractor's Safety and Health Organization submits to the DOE Field Element, a list of the dates on which occupational exposure and health hazards technical assessments were preformed.
    
4. The Operating Contractor's audit tools include; procedures for performing occupational exposure and health hazards assessments, worksheets, periodic standard report formats, reference material, training material, which are provided to staff performing assessments.
    
5. The Operating Contractor's Safety and Health Organization has a system in place to control, maintain occupational exposures, health hazards management procedures and hazard control guides current. This system includes a mechanism for updating and distributing procedures, and internal guides on a specified schedule.
    
6. The Operating Contractor's Safety and Health Organization performs analyses on significant occupational exposures and health hazards assessment findings. The Operating Contractor has identified people responsible for correcting a health hazard deficiency. The actions necessary to correct that deficiency are addressed and a schedule for implementing corrective actions established.
    
7. The Operating Contractor's Safety and Health Organization performs trend analysis of findings from the occupational exposures and health hazards programs. Identifiable trends are communicated to the DOE Field Element. Corrective actions are identified and mutually agreed on.
    
8. The Operating Contractor's Safety and Health Organization has a tracking system that includes all occupational exposures and health hazards findings. The system identifies corrective actions, schedules, and progress made on corrective actions. Other information such as results of root cause analyses is also included in the tracking system. A method to flag or highlight significant events or actions is included in the tracking system.
    
9. The Operating Contractor's Safety and Health Organization ensures that management processes, activity hazards identification and analysis, and functional technical appraisals in specific occupational exposure and health hazards assessment subject areas are included in the contractor's program and are integrated into the Contractor's safety management, work planning and execution system. This might include: activity hazards analysis, exposure assessments, hazard controls and, the specific technical program elements (e.g., noise and hearing conservation, ventilation, respiratory protection, asbestos, non-ionizing radiation (radio-frequency radiation, lasers, magnetic fields), ergonomics, carcinogens, DOE Beryllium program, OSHA substance specific health standards i.e. Benzene, Asbestos, etc; occupant emergency and critical event planning, sanitation, vibration, extreme temperature, biohazards, confined spaces, laboratory hygiene program, Indoor Air Quality (IAQ), office environments, recordkeeping, employee training and certification, and labeling and posting).
    
10. The Operating Contractor line management tracks the effectiveness of its implementation of the occupational exposure and health hazards program by reviewing the findings of its internal assessments of the program. Problem areas identified are addressed promptly.
     
11. The Operating Contractor has an effective corrective action program and organizational structure for resolving related action items. Contractor performance with respect to completing corrective actions is documented, reported, and tracked.
     
12. The Operating Contractor's Safety and Health Organization has adequate staff with a level of professional training, experience commensurate with the requirements for implementation of the IH; occupational exposures and health hazards management program.
     
13. The Head of the Operating Contractor's Safety and Health Organization ensures that internal self-assessments of occupational exposure and health hazards are conducted.
     
14. The Head of the Operating Contractor's Safety and Health Organization ensure compliance with mandatory standards for assessing and managing occupational exposures and health hazards.
     
15. The Operating Contractor's occupational exposure and health hazards assessment staff is adequately trained in occupational exposure assessment, such as through an AIHA, or other academic based program. The training addresses familiarization with all mandatory standards, AIHA or NIOSH criteria, guidance documents, and other references that are pertinent to the technical area; use of procedures for conducting the assessment and, instructions on preparing reports and related documentation.
     
16. The Operating Contractor's Safety and Health Organization prepares performance indicator reports, utilizes performance indicators involving occupational exposures, health hazards data, and other operations information. This includes; medical monitoring, epidemiological surveillances, CAIRS, OSHA 300 log data, ORPS reportable occurrences, for performing trending and analysis to provide early identification of potential exposure and health hazards and/or deteriorating/improving worker health conditions.
     
17. The Operating Contractor provides management periodic summaries of performance on the assessment and management of occupational exposures and health hazards.
     
18. The Operating Contractor has developed program management goals related to occupational exposures and health hazards. The goals are measurable and include short-term (annual) and long-term goals (several year period) to assess and manage occupational exposures and health hazards. Progress towards goals is monitored regularly and goals adjusted as necessary. Line managers have performance elements in their personnel appraisal relating to successful attainment of program management goals.

Performance Objective IH-3. DOE Oversight

DOE expects under its ISMS philosophy and the Department of Energy Acquisition Regulations (DEAR) that, DOE program elements conduct formal oversight and contractual control of the IH; occupational exposure and health hazards management program.

Criteria:

1. The DOE as provided the Operating Contractor with adequate program direction guidance, standards, orders, clear priorities, and goals to facilitate meeting DOE contractual expectations.
    
2. The DOE Field Element Safety and Health Organization review the follow up of corrective actions involving occupational exposures and health hazards and ensure that root causes are documented. The DOE Field Element Safety and Health Organization independently tracks the findings from the contractor's audits.
    
3. The DOE Field Element Safety and Health Organization verify that the contractor has assigned qualified staff to perform internal audits of the IH; occupational exposures and health hazards program.
    
4. The DOE Field Element Safety and Health Organization verify that contractor audit personnel are adequately trained to perform their duties related to occupational exposures and health hazards. Training includes conduct of audits and overview of procedures as well as training to ensure technical expertise.
    
5. The DOE Field Element review of corrective action plans related to occupational exposures and health hazards program deficiencies address all findings, issues, and root causes.
    
6. The DOE Field Element Safety and Health Organization has verified that the Contractor has ensured that management processes, activity hazards identification and analysis, functional technical appraisals in specific subject areas are included in the contractor's program and are integrated into the Contractor's safety management, work planning and execution system. This might include conducting independent review or sampling of the Contractor's: management concerns (e.g., policy, directives, organization, communication, operating procedures, worker health standards, coordination, staffing and professional development, facilities, equipment, and support, budget review, accident/incident investigation, performance analysis, quality assurance); activity hazards analysis, exposure assessments, hazard controls and, the specific technical program elements (e.g., noise and hearing conservation, ventilation, respiratory protection, asbestos, non-ionizing radiation (radio-frequency radiation, lasers, magnetic fields), ergonomics, carcinogens, DOE Beryllium program, OSHA substance specific health standards i.e. Benzene, Asbestos, etc; emergency and critical event planning, sanitation, vibration, extreme temperature, biohazards, confined spaces, laboratory hygiene program, Indoor Air Quality (IAQ), office environments, recordkeeping, employee training and certification, and labeling and posting).
    
7. The DOE Safety and Health Organization conducts technical appraisals of Operating Contractors occupational exposure and health hazards management program at least once every 3 years.
    
8. The DOE Field Element provides effective oversight and implementation of the contractor award fee evaluation. The DOE also ensures that appropriate percentages are applied to the evaluation of program performance against agreed objectives and requirements. The DOE Field Organization award fee determinations are consistent with audit reports and self-assessments. The DOE award fee determinations are integrated with performance indicator reports, occurrence reports, accident, illness, injury data, corrective action plans, and closeout of findings.
    
9. The DOE Field Element has an adequate number of staff with technical skills assigned to carry out oversight of the IH; occupational exposure and health hazards management program.
    
10. The DOE Safety and Health Organization prepares an annual schedule showing the oversight of the Contractor's IH; occupational exposure and health hazards management program planned for the following year.

Suggested Lines of Inquiry and Review Approach
 

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