Frequently Asked Questions cont'd

DOE-HDBK-1148-2002

sets of standards. Similarity is often a more meaningful basis in the comparison of

safety performance outcomes.

Q14

If the Work Smart Standards set incorporates external standards, who interprets those

requirements?

A14

Existing contracts (and Orders) contain or reference external standards, such as laws,

regulations and consensus standards, that may require interpretation. The incorporation

of external standards into WSS sets does not require a change from the existing policies

or practices regarding interpretation. In general, the chain of authority for the

interpretation of standards used by contractors is: contractor line management,

Department line management, the sources of the standard (regulatory or consensus

organization), and the courts. Under the practices established by the ISM DEAR clause,

the contract, that includes explicit DOE approved provisions for safety management,

becomes both the operational and regulatory basis for interpretation of the integrated set

of requirements for safe work. Thus, the contract agreement processes established by

the DEAR clause address all the various interpretive situations that might be

encountered during the life of the contract. Of course, where requirements are grounded

in law or regulation the contract defers its interpretive authority to the source agency.

Q15

Is there a preference for applying the N&S Closure Process at the site level or the

activity level?

A15

Application of the Process at the site level and the activity level are not mutually

exclusive. The Process can be applied at any level where the Department and the

contractor must agree on the standards to be applied. This clearly includes the contract

requirements, and may include any site level and activity level work controls that require

Department approval prior to the authorization of work

Q16

Who is going to make sure that the standards are used appropriately?

A16

The contractor must plan work in keeping with the DOE-approved ISM system to meet

all applicable contractual requirements and subordinate commitments. Department line

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