Beryllium

DOE-HDBK-1139/1-2000

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

effectiveness.