How can we be assured of adequate safety if some alternative standards to the DOE
ES&H Orders are identified for the WSS set?
Proper application of the N&S Closure Process establishes a WSS set that provides
reasonable assurance of adequate protection whether or not particular standards,
including DOE Orders, are identified within the WSS set. It is the collective control of the
WSS set, developed according to the N&S Closure Process, that provides adequate
protection when appropriately implemented through Integrated Safety Management.
The DOE ES&H Orders represent an effective way of achieving safety for certain work
done by the Department, particularly for work which is essentially unique to the
Department. The DOE Order system has provided a consistent approach across the
Department for control of the hazards considered in the Order development. The Orders
are by necessity somewhat broad in scope. The focus of the N&S Closure Process is on
understanding the particular work to be performed, hazards associated with that work
and identification of a proper experienced-based set of standards for control of those
Fidelity to the N&S Closure Process leads to identification of the proper WSS set. The
Process does not specify sources of standards. The principal issue is adequate
protection not the source(s) of the standards selected.
Consideration of the DOE Orders developed for particular hazards within the scope of a
specific N&S Closure Process application is appropriate where selection of a particular
DOE Order may be advantageous because of:
Familiarity and experience of the work force with the DOE Orders
Existing implementation processes for the Orders
Ease of explaining to DOE and order-experienced personnel the coverage of the