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DOE-HDBK-1139/1-2006
In general, the role of DOE and its contractors with respect to authorizing work and
work changes at any level are defined in a properly implemented ISM system. This
agreement can become the binding contractual agreement between DOE and the
contractor for predetermined hazardous facilities, tasks, or activities. However,
because all activity- level hazards in general cannot be predetermined, activity- based
hazards and controls will need to be continually modified and modified as needed.
The use of air monitoring data along with the appropriate statistical analysis can be
useful in determining if the work is being performed within controls. For example,
personal air monitoring for beryllium exposures is required by one DOE rule, 10
CFR Part 850, Chronic Beryllium Disease Prevention Program. If 10 CFR 851 is
part of the contract's List B requirements, then application of the Order requires
compliance with Title 29 of the CFR which contains substance-specific standards
that also require air sampling. In addition, 10 CFR 851 requires exposure
monitoring as appropriate for exposure assessments. In any case, good industrial
Beryllium
hygiene practice calls for personal monitoring and/or medical surveillance for any
10 CFR 850
potential exposure. Applying appropriate statistical analysis to chemical sampling
data will allow the industrial hygienist to determine potential employee exposures
and the level of controls needed, as well as determine if the operation is in
compliance with occupational exposure limits.
1.5 Provide Feedback and Continuous Improvement
The expectation for continuous improvement in safety management systems is built
into the ISM requirements. After a mission is translated into work and the set of
requirements to safely accomplish the work is identified, the contractor and DOE
should define the expectation for whether the safety management system is to meet
or exceed requirements. This expectation can influence planning, prioritization of
tasks, and resource allocation.
Sections (d) and (e) of the DEAR Clause, 48 CFR, Chapter 9 require contractors to
develop safety performance objectives, measures, and commitments to measure
ISMS effectiveness. Several tools are available to assist managers and provide
feedback on chemical lifecycle and safety management objectives:
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