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Exhibit 2.1
DOE-HDBK-1101-96
Management of Change
Procedures exist to manage changes to process chemicals, technology, equipment, procedures, and
process facilities. These procedures provide assurance that the PrHA, PSI, and procedures are
updated, if necessary, to reflect the changes. Essential to the success of MOC system is the active
participation by both site and affected subcontractor employees in the review and evaluation process
to determine the impacts of proposed changes.
Incident Investigation
An incident is an event whose occurrence resulted in, or could reasonably resulted in a catastrophic
release of a highly hazardous chemical in the workplace. It is site policy that all incidents will be
investigated as soon as possible, but be initiated no later than 48 hours after the incident. The team
investigating the incident shall consist of at least one person knowledgeable in the process involved;
a contract employee, if a subcontractor was involved; and other cognizant and informed individuals.
Employees are typically involved in incident investigations since their knowledge and skills in
operations or maintenance are necessary for the conduct of the investigation.
When the investigation is completed, a report, containing the contributing factors to the incident and
recommendations for prevention of future occurrences, will be made by posting in work areas,
circulation of reports, discussion in scheduled safety meetings, or as a subject in ad hoc meetings
with employees. Management then addresses, resolves, and implements the report findings and
recommendations. All site and contractor personnel affected by the changes are informed of any
changes and may be involved in their implementation.
Emergency Planning and Response
A formal review process for site-wide procedures exists for soliciting and obtaining employee input
on site emergency response plans. Employees may critique drills and actual incidents to identify
opportunities for performance improvements, and improve both emergency response planning and
responder performance. Communication to employees and subcontractors to promote understanding
of the actions to take during an emergency.
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