March 27, 2006
MEMORANDUM FOR ALL DEPARTMENTAL ELEMENTS
FROM: CLAY SELL
SUBJECT: Correspondence to the Defense Nuclear Facilities Safety Board
Two important principles in the Secretary’s drive to improve management of the Department are line accountability and clear roles and responsibilities. It is incumbent on all of us to review ongoing practices and policies to ensure they comply with those principles.
In that light, I have reviewed the guidance promulgated by my predecessor on August 6, 2003, mandating coordination with the Defense Nuclear Facilities Safety Board staff prior to signing any correspondence to the Board (copy attached). The policy set forth in that memorandum inadvertently blurs the distinction between line responsibility and accountability and the role of external reviewers such as the Defense Nuclear Facilities Safety Board. By implication (and by the practice of some) this notice could suggest a Board veto over line actions. Such blurring of responsibilities weakens the independence and effectiveness of the Defense Nuclear Facilities Safety Board and weakens line responsibility. To avoid perpetuating possible confusion, the requirement to coordinate with the Board staff prior to submission of correspondence is rescinded.
Departmental elements will continue to cooperate closely with the Defense Nuclear Facilities Safety Board. In preparing correspondence and responses to Board requests, it is entirely appropriate to consult with the Board where there are questions about the meaning of the request. But departmental elements should not “pre-clear’’ responses with the Board nor allow Board staff to become enmeshed in the internal drafting and review process. This guidance does not alter the Department’s policy of providing the Board an opportunity to comment on formal directives within the Board’s area of competence.