Management of Requirements

DOE-HDBK-1139/2-2006

Stovepiping creates inefficiencies. For example, chemical regulations are largely organized by

chemical type while chemical work is largely performed according to work function. When

chemical management is stovepiped, it forces work managers to spend additional time and

resources to determine which procedures, processes, or requirements apply to their particular

operations. As a result, managers or individual workers may not be aware of certain

requirements or procedures that could impact their chemical activities, potentially resulting in a

deficient process. Stovepiped safety requirements also create inefficiencies when a variety of

applicable procedures and requirements must be woven into a compliant process. Developing

chemical storage requirements can become a daunting task, for example, when numerous

organizations that "own" a multitude of unique requirements and procedures are involved.

Stovepiping also leads to inconsistencies (and potential conflict) with safety requirements. One

example is the area of requirement ownership. Confusion often results when multiple

organizations "own" overlapping requirements. Inconsistency can lead to problems when

different organizations owning overlapping requirements write conflicting procedures. One

organization may interpret a requirement in a manner that makes it easier for it to do business

without recognizing that it conflicts with a similar requirement from another organization with

overlapping responsibilities.

Clearly, stovepiping chemical management undermines some of the basic principles of an

effective safety program. Sites should rigorously pursue a centralized approach embodied in a

CSLM program to ensure consistency in the interpretation and implementation of these

requirements.

4.2

Management of Requirements

4.2.1

Complexity of Requirements

There are several factors that complicate chemical lifecycle and safety management, primarily

the large number of requirements and their complexity. Volume 3 of the DOE Chemical

Management Handbook , "Consolidated Chemical User Safety and Health Requirements," lists

approximately 1,500 requirements from approximately 130 sources; this is only a partial listing.

State and local requirements, such as those found in locally-enforced building and fire codes, are

not included, nor are requirements for waste, transportation of chemicals over public roads, and

This complexity is exacerbated by the fact that requirements have been promulgated by different

agencies for varying purposes. One agency might write a requirement to protect workers, while

another may write a similar requirement to protect emergency responders, with a third writing

yet another requirement to protect the building, its occupants, and contents. An understanding of

the intent behind a set of requirements is often needed to prevent them from appearing

contradictory, or worse, simply confusing. In some cases, these requirements are contradictory

even when the intent is understood.

The technical nature of chemistry and chemical safety adds another layer of complexity to

understanding and enforcing these regulations. Most chemicals have more than one hazard