Provide Feedback and Continuous Improvement

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: