[DS
LETTERHEAD]
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is rescinded.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.