Change Notice No. 1
agreement can become the binding contractual agreement between DOE and the
contractor for predetermined hazardous facilities, tasks, or activities. However,
because all activity-level hazards in general cannot be predetermined, activity-based
hazards and controls (i.e., chemical hazards) will need to be continually identified.
The use of air monitoring data along with the appropriate statistical analysis can be
useful in determining if the work is being performed within controls. Personal air
monitoring for non-radiological chemical exposures is required by one DOE rule,
10 CFR Part 850, Chronic Beryllium Disease Prevention Program. If
DOE O 440.1A is part of the contract's List B requirements, then application of the
Order requires compliance with Title 29 of the CFR which contains substance-
specific standards that also require air sampling. In addition, DOE O 440.1A
requires exposure monitoring as appropriate for exposure assessments. In any case,
good industrial hygiene practice calls for personal monitoring and/or medical
surveillance for any unknown exposure. Applying appropriate statistical analysis to
chemical sampling data will allow the industrial hygienist to determine potential
employee exposures and the level of controls needed, as well as determine if the
operation is in compliance with occupational exposure limits.
Chemical exposure data as part of the hazard analysis and air sampling should be
communicated to the occupational medical organization. These data and
information on hazards experienced may be used by the first line supervisor to
improve the safety of future activities with the same type of exposures.
1.5 Provide Feedback and Continuous Improvement
The expectation for continuous improvement in safety management systems is built
into the ISM requirements. After a mission is translated into work and the set of
requirements to safely accomplish the work is identified, the contractor and DOE
should define the expectation for whether the safety management system is to meet
or exceed requirements. This expectation can affect planning, prioritization of
tasks, and resource allocation.
Sections (d) and (e) of DEAR, 48 CFR 970.5204.2, require contractors to develop
safety performance objectives and measures, and commitments and measure ISMS