Organization of Requirements

DOE-HDBK-1139/2-2006

associated with them, yet most of the regulations are written to protect against a single chemical

hazard. For example, one regulation requires water-reactive chemicals to be stored where there

is no water-based fire suppression system while another regulation states that flammable liquids

must be stored where a water-based fire suppression system exists. What does one do with a

chemical that is both a flammable liquid and water reactive? Chemical hazards may also be

dependent upon chemical concentrations, chemical form, or the environment within which the

chemical is placed. For example, many metals are benign when in the form of an ingot, shot, or

turning, but become water-reactive, flammable, or pyrophoric when present in the form of a

powder. As a part of the hazard identification and analysis function under ISMS, one must

determine the point at which, as the particle size decreases, a metal ceases being benign and

becomes more hazardous, requiring additional controls.

4.2.2 Organization of Requirements

Because of the complexity of requirements and the multitude of regulatory sources, a

coordinated, site wide effort is needed to consolidate and interpret those requirements related to

chemical activities. This effort should focus on grouping requirements by work activity instead

of chemical hazard class, and should result in a process for providing and communicating the

definitive interpretation for chemical req uirements onsite. Although regulations typically

address requirements by chemical type or hazard class, activities such as transport ing, storing, or

working with chemicals almost always involve chemicals that have multiple hazards or are from

multiple hazard classifications. If requirements are organized by hazard class to mirror

regulatory literature, it makes performing chemical work confusing and can lead to increased risk

and regulatory noncompliance. If, instead, regulations are grouped by work activity (e.g.,

storage, in- house transportation, laboratory experimentation), they are more easily

understandable. An additional benefit is that they will reside in one location, eliminating the

need to search for additional regulations.

4.2.3

Interpreting Chemical Requirements

Chemical requirements must be organized in order to make clear a company's determination

regarding the interpretation of individual and overlapping requirement s. If an inconsistency

appears to be present between two sets of requirements in the regulatory literature, management

needs to determine how these conflicting requirements will be interpreted from a corporate

perspective. Once these determinations are made, they must be published so that a record of the

decision exists. If the company does not interpret and publish them for the workforce,

individuals with varying levels of expertise throughout the co mpany will arrive at their own

interpretations through "answer shopping" leading to inconsistent applicat ion of requirements

and a less effective CSLM program.

4.2.4

Requirements Ownership

In accordance with the second ISMS guiding principle, which describes the need for clear roles

and responsibilities, management must identify the owners of CSLM requirements. Without

clear ownership, consistency will be lost as individuals make changes to the company

interpretations of requirements based upon immediate needs.