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Organization of Requirements


DOE-HDBK-1139/2-2006
Stovepiping creates inefficiencies. For example, chemical regulations are largely organized by
chemical type while chemical work is largely performed according to work function. When
chemical management is stovepiped, it forces work managers to spend additional time and
resources to determine which procedures, processes, or requirements apply to their particular
operations. As a result, managers or individual workers may not be aware of certain
requirements or procedures that could impact their chemical activities, potentially resulting in a
deficient process. Stovepiped safety requirements also create inefficiencies when a variety of
applicable procedures and requirements must be woven into a compliant process. Developing
chemical storage requirements can become a daunting task, for example, when numerous
organizations that "own" a multitude of unique requirements and procedures are involved.
Stovepiping also leads to inconsistencies (and potential conflict) with safety requirements. One
example is the area of requirement ownership. Confusion often results when multiple
organizations "own" overlapping requirements. Inconsistency can lead to problems when
different organizations owning overlapping requirements write conflicting procedures. One
organization may interpret a requirement in a manner that makes it easier for it to do business
without recognizing that it conflicts with a similar requirement from another organization with
overlapping responsibilities.
Clearly, stovepiping chemical management undermines some of the basic principles of an
effective safety program. Sites should rigorously pursue a centralized approach embodied in a
CSLM program to ensure consistency in the interpretation and implementation of these
requirements.
4.2
Management of Requirements
4.2.1
Complexity of Requirements
There are several factors that complicate chemical lifecycle and safety management, primarily
the large number of requirements and their complexity. Volume 3 of the DOE Chemical
Management Handbook , "Consolidated Chemical User Safety and Health Requirements," lists
approximately 1,500 requirements from approximately 130 sources; this is only a partial listing.
State and local requirements, such as those found in locally-enforced building and fire codes, are
not included, nor are requirements for waste, transportation of chemicals over public roads, and
This complexity is exacerbated by the fact that requirements have been promulgated by different
agencies for varying purposes. One agency might write a requirement to protect workers, while
another may write a similar requirement to protect emergency responders, with a third writing
yet another requirement to protect the building, its occupants, and contents. An understanding of
the intent behind a set of requirements is often needed to prevent them from appearing
contradictory, or worse, simply confusing. In some cases, these requirements are contradictory
even when the intent is understood.
The technical nature of chemistry and chemical safety adds another layer of complexity to
understanding and enforcing these regulations. Most chemicals have more than one hazard
4


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