STARBURST/SUMMER 2000 9 formally integrates radiation safety into the DOE-VPP program requirements. Requiring Integrated Safety Management:  The Department of Energy has established a requirement for all operations to implement Integrated Safety Management (ISM).  DOE-VPP program policy now requires that VPP applicants demonstrate verification of Phases I and II of their ISM systems before being recommended for recognition as a DOE-VPP work site. However, applications for the DOE-VPP may be submitted at any time. Emphasizing Injury and Illness Rates and Other Performance Indicators:  In the past, applicants were required to maintain injury rates below the average rate of the industry most comparable to their operations. However, the Standard Industrial Classifications (SIC) used in the commercial sector, often have little in common with DOE operations.  Likewise, DOE experience has shown that differences in DOE sites make it difficult to meaningfully select a SIC for comparison.  While DOE applicants will continue to be compared to current Bureau of Labor Statistics rates for comparable SIC codes (and expected to compare favorably), within DOE the guidance now no longer considers these comparisons on a strict “pass or fail” basis.  Rather, emphasis will be placed on the quality of recording; the adequacy of trending, analysis, and response to noted trends and lessons learned.  Equally important, and consistent with OSHA requirements, DOE will focus on illness data as well as on injury data. Expanding Enforcement Actions Provisions:  DOE requires that no VPP action is taken or decision is made if there are pending enforcement actions.  Specifically, DOE requires that safety and health deficiencies and/or non-conformance with DOE Orders be adequately addressed by the Operations Office before recommending DOE-VPP approval.  DOE now will also emphasize the importance of Price-Anderson Act (PAA) enforcement.  DOE VPP guidance will clarify that DOE- VPP recognition will not be granted if a level I or II violation of that Act remains under enforcement.  It further provides for the option of termination of DOE-VPP recognition after approval should PAA level I or II violations occur. Improving the DOE-VPP Program Guidance The Department of Energy Voluntary Protection Program (DOE-VPP) has been very successful since its inception in 1994 in encouraging and recognizing excellence in occupational safety and health protection.  During this five-year operating period, the program guidance has been adjusted as a consequence of its application within the Department of Energy and a number of changes are being made to capture this learning experience and improve program implementation.  Key improvements include: Adding DOE Federal Facilities:  The Occupational Safety and Health Administration (OSHA) has now extended the commercial sector version of their VPP to apply to Federal agencies.  DOE has added clarifying language to its VPP guidance that encourages federal workers and managers to participate in OSHA’s Voluntary Protection Programs for Federal agencies.  DOE operations, such as government-owned, government- operated (GOGO) facilities, are encouraged to build and maintain excellent safety and health programs and to apply for recognition in OSHA’s VPP for Federal Agencies. Adding Hazardous Waste and Deactivation and Decommissioning (D&D) Sites:  Experience in evaluating D&D and hazardous waste operations at DOE sites confirms that they do not require different approaches from traditional DOE operations.  However, hazardous waste and D&D operations have transient workforces and rapidly changing environments that are similar to construction sites.  Recognizing these conditions, additional guidance has been provided to aid these D&D activities in the application of the VPP principles to their work sites. Providing Operable Units Provision:  The DOE complex has many large work sites with collections of tenant operating contractors, many of whom operate autonomously.    DOE VPP guidance now recognizes that these operable tenant units have a potential to qualify for DOE-VPP even though their host activity may not. Integrating Radiation Safety: When the DOE-VPP was first developed, radiation safety was an integral part of the overall program.  Accordingly, the guidance now | Front Page | Go Back | Go To Page 10 |