Program Ownership and Consolidation

DOE-HDBK-1139/2-2006

4.3

Program Ownership and Consolidation

A CSLM program must be appropriately organized and supported in order to be effective. The

owner(s) of the CSLM program should be designated by the site prime contractor, and the CSLM

program should consolidate the number of program owners to the greatest extent possible. The

CSLM program must include clearly-defined roles and responsibilities for all organizations with

chemical management responsibilities. The active involvement of a Program Steering

Committee can also help to strengthen the CSLM program.

4.3.1

Program Ownership

The single most important issue to clarify in CSLM is program ownership. Clear program

ownership is essential to defining each organization's responsibilities and to ensuring effective

coordination between the various organizations involved in the CSLM program.

Failure to clearly establish program ownership can defeat the primary objectives of the CSLM

program, which are reduced frequency, severity, and cost of che mical incidents and reduced

chemical usage costs. Likewise, the lack of clear ownership can lead to increased inefficiency

and increased company liabilities. If program owners are not clearly identified, people may not

know where to go for answers, may seek guidance from those who are not qualified to give it or

may come to disagreement over requirement interpretations .

4.3.2

Program Consolidation

Consolidating the number of program owners and clearly defining their hierarc hy, roles, and

responsibilities can improve the efficiency of a CSLM program. Consolidating the program,

usually with the majority placed under one organization, enables better coordination between

program elements. This helps to eliminate potential friction between various program owners

while ensuring more seamless coverage of requirements. Program consolidation improves

accountability by assigning specific responsibilities, defining program element interfaces, and

providing a point of contact that can answer or resolve questions. Program consolidation is an

important tool to help organize and manage the complex tasks involved in CSLM.

4.3.3

Program Steering Committee

Consolidating a CSLM program increases the risk of the program owners losing touch with the

real needs of the actual chemical users on the site. In particular, program owners may fail to

consider the special needs of particular user groups and create unintentional but additional

quagmires. Examples of these special needs include: simplifying the procurement or

inventorying processes, resolving complex storage issues, or providing interpretations for

requirements or procedures that cannot be implemented in a reasonable manner.

To mitigate this risk, a CSLM program should have a Program Steering Committee whose

responsibilities and interfaces are established in site policy and procedure. These policies and

procedures need to address management support for and the independence of the Steering