Worker Safety and Health Program Plan Approval

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.

• NNSA Standard Review Plan