Perform Work within Controls - DOE-HDBK-1139-1-20060019

DOE-HDBK-1139/1-2006

A multi-disciplinary hazard analysis team comprised of line management, health

and safety professionals , chemical professional , and workers can effectively tailor

the controls applied to the work at the facility and site level.

DOE-STD-3009-94 (CH3) provides guidance for nuclear facilities on establishing

DOE-STD-3009-94

documented safety limits, limiting control settings, and limiting conditions for

(CH3)

operation, surveillance requirements, administrative controls, and design features

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 (CH3)). Line managers need to ensure

that this interface between the DSA hazard level and activity level is addressed. 10

CFR 851 and its associated guides can be used to assist in addressing activity level

10 CFR 851

hazard analysis and controls.

For hazards not identified at a higher level analysis, unique activity-specific

EWP

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

(DEAR 970.5204-2(b)(6)).

1.4 Perform Work within Controls

A process to confirm adequate preparation and application of controls prior to

authorizin g work should be carried out by a qualified multi-disciplinary team. First

ISM Guide

Vol 1

line supervisors should team with employees, chemical lifecycle and safety

Vol 2

management personnel, and other safety and, health professionals to ensure proper

controls are identified and implemented 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.