Drivers

DOE-HDBK-1139/2-2006

substances regulated under the OSHA Standard on Process Safety Management of Highly

Hazardous Chemicals (29 CFR 1910.119) and the EPA Risk Management Program (40 CFR

68),

hazardous substances regulated under the Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA) (40 CFR 302),

extremely hazardous substances regulated under the Emergency Planning and Community

Right-to-Know Act (EPCRA) (40 CFR 355),

toxic chemicals regulated under Section 313 of Title III of the Superfund Amendments and

Reauthorization Act (SARA) (40 CFR 372),

hazardous materials regulated under the DOT Hazardous Materials Regulations (49 CFR

172),

wastes regulated under the Resource Conservation and Recovery Act (RCRA) (40 CFR 260-

282), and

substances regulated under the Toxic Substances Control Act (TSCA) (40 CFR 700-799).

3.0

Drivers

The primary objective of a CSLM program is the assurance of worker protection, facility safety,

and protection of the environment as mandated by 10 CFR 851, DOE O 420.1B and 450.1; and

DOE P 450.4, which require the contractor to implement a DOE-approved safety management

system, under the DEAR 48 CFR 970.5204-2(c) clause entitled "Integration of Environment,

Safety, and Health into Work Planning and Execution. " Worker protection, facility safety, and

environmental p rotection issues at DOE facilities are largely governed by Federal laws and

regulations, DOE Orders, conse nsus standards mandated by DOE Orders, and local laws and

regulations such as locally enforced building and fire codes. Volume 3 of the Chemical

Management Handbook contains a comprehensive listing of DOE and Federally mandated laws

and regulations that are required to be followed by DOE sites engaged in chemical-related

activities. Other practical drivers for CSLM programs include prudent financial management

(i.e., keeping chemical lifecycle costs down) and sustaining quality (i.e., ensuring sufficient

quantities of chemical products of required purity are on hand to perform the task).

4.0

Management Approach

4.1

Traditional Approaches

Traditional approaches to CSLM have mirrored organizational requirements found in the

regulatory literature. For example, chemical-related requirements found in National Fire

Protection Association (NFPA) codes and standards (required per 10 CFR 851, Worker Safety

and Health Program) typically fall under the purview of a site's fire protection organization.

Likewise, a site's industrial safety program typically oversees adherence to applicable

regulations for compressed gas cylinders, its industrial hygiene program oversees adherence to

regulations for Hazard Communication (29 CFR 1910.1200) and the Laboratory Standard (29

CFR 1910.1450), and its procurement organization oversees adherence to federal and DOE

acquisition regulations (FAR and DEAR). This "stovepipe" or disconnected approach, however,

does not support a robust CSLM program.