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Work Smart Standards (WSS) Users Handbook - index
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Frequently Asked Questions cont'd - hdbk114820020099


DOE-HDBK-1148-2002
sets of standards. Similarity is often a more meaningful basis in the comparison of
safety performance outcomes.
Q14
If the Work Smart Standards set incorporates external standards, who interprets those
requirements?
A14
Existing contracts (and Orders) contain or reference external standards, such as laws,
regulations and consensus standards, that may require interpretation. The incorporation
of external standards into WSS sets does not require a change from the existing policies
or practices regarding interpretation. In general, the chain of authority for the
interpretation of standards used by contractors is: contractor line management,
Department line management, the sources of the standard (regulatory or consensus
organization), and the courts. Under the practices established by the ISM DEAR clause,
the contract, that includes explicit DOE approved provisions for safety management,
becomes both the operational and regulatory basis for interpretation of the integrated set
of requirements for safe work. Thus, the contract agreement processes established by
the DEAR clause address all the various interpretive situations that might be
encountered during the life of the contract. Of course, where requirements are grounded
in law or regulation the contract defers its interpretive authority to the source agency.
Q15
Is there a preference for applying the N&S Closure Process at the site level or the
activity level?
A15
Application of the Process at the site level and the activity level are not mutually
exclusive. The Process can be applied at any level where the Department and the
contractor must agree on the standards to be applied. This clearly includes the contract
requirements, and may include any site level and activity level work controls that require
Department approval prior to the authorization of work
Q16
Who is going to make sure that the standards are used appropriately?
A16
The contractor must plan work in keeping with the DOE-approved ISM system to meet
all applicable contractual requirements and subordinate commitments. Department line
A-10


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