Management Support

DOE-HDBK-1139/2-2006

The following four programmatic/administrative elements are required for the successful

implement ation of the CSLM program: (1) management support; (2) regulatory interpretation;

(3) po licies and procedures; and (4) verification.

5.3.1

Management Support

Management support at all levels is critica l to the success of the CSLM program. Management

is responsible for establishing the CSLM program and ensuring adequate staffing and support.

Furthermore, management is responsible for clearly communicating to site personnel that the

CSLM Manager is the single point of contact for all chemical issues onsite. The CSLM Manager

is responsible for providing policies, procedures, and tools (such as the MSDS System and

inventory tracking s ystem) to meet all regulatory and site requirements. Line management is

responsible and accountable for implementing site policies and procedures related to the CSLM

program.

5.3.2

Regulatory Interpretation

5.3.2.1 Regulatory Compliance

The CSLM Manager should implement a fully documented process that complies with all

appropriate statutes, DOE Orders, Federal, State and local regulations, and site policies and

procedures.

5.3.2.2 Data Collection for Reporting

The CSLM Manager should implement a fully documented process that complies with all

aspects of data collectio n for regulatory reporting.

If the CSLM program does not perform the reporting function, it should, at a minimum, provide

oversight for the reporting function.

5.3.3

Verification

Self-assessment and independent assessment are two mechanisms used to collect data for

analysis and feedback. A comprehensive evaluation of the CSLM program allows the contractor

to analyze feedback information to measure performance against expectations and identify

improvement opportunities. The CSLM Manager should be responsible for performing a full

evaluation of the CSLM program for the site at a frequency commensurate with the prevailing

level of chemical activities occurring at the site. An annual evaluation is suggested for sites not

undergoing a significant change in missions. Comparing feedback information in subsequent

evaluation reports against the baseline report allows one to identify the areas of the CSLM

program that need additional attention or resources for further improvement. This corresponds to

the final ISMS core function, Provide Feedback and Continuous Improvement.