Change Notice No. 1
that result from a disciplined safety analysis. However, this standard does not
address common industrial hazards that make up a large portion of basic OSHA
regulatory compliance (DOE-STD-3009-94, Sections 188.8.131.52 and 184.108.40.206.3). Line
managers need to ensure that this interface between the SAR hazard level and
activity level is addressed. DOE O 440.1A and its associated guides can be used to
DOE O 440.1A
assist in addressing activity level hazard analysis and controls.
For hazards not identified at a higher level analysis, unique activity-specific
controls may be required. The Enhanced Work Planning (EWP) process relies on a
work planning team to specify and tailor the controls for this level. At each level
(site, facility, activity), these multi-disciplinary teams can address all relevant
functional areas or disciplines of concern (e.g., quality assurance, fire protection,
chemical safety, industrial safety, radiological protection, emergency preparedness,
criticality safety, maintenance). Controls at the activity level may be developed
from higher-level analysis or by using the results of activity hazard analysis.
Emphasis, however, should be on designing the work and/or controls to reduce or
eliminate the hazards and to prevent accidents, unplanned releases, and exposures
1.4 Perform Work within Controls
In addition to a discussion on authorization agreements, guidance for startup and
restart of nuclear facilities is provided in the ISM guide, Chapter II, Section 5.
While this process and guidance focus on Category 1 and 2 nuclear facilities, some
concepts can be applied directly to chemical hazards at the activity level.
A process to confirm adequate preparation and application of controls prior to
authorizing work at the activity level should be carried out by a qualified multi-
disciplinary team. First line supervisors should team with employees and safety and
health professionals to ensure the activity-level hazards and controls needed to
establish a safe working environment. The hazard and complexity of work should
determine the formality and rigor of the review process, documentation, and level of
authority for agreement.
In general, the role of DOE and its contractors with respect to authorizing work and
work changes at any level are defined in a properly implemented ISM system. This