General Recommendations cont'd

DOE-HDBK-3027-99

approaches (facility or activity reviews) while not restricted by policy, may be more

difficult to administer and evaluate.

b. When tasked to conduct a two-phase review, it is important to ensure that issues

affecting implementation are appropriately relegated to Phase II. It is appropriate to

provide implementation issues to the contractor informally; however, these issues should

not be made part of Phase I. At Rocky Flats, a Phase II verification at two facilities (B371

and B664) was simultaneously conducted. During the Phase I Review, implementation

issues were routinely developed and required some rethinking to categorize them

correctly. Some of the Phase I concerns affected the approach to verifying ISMS

implementation at the two facilities. While these issues were not terribly significant in the

Rocky Flats case, if there does appear to be significant issues in the Phase I verification,

then the decision to simultaneously conduct the Phase II review should be reconsidered.

c. In a combined Phase I and II ISMS verification it is incumbent on the contractor to

provide some assurance to the team that the ISMS process has been effectively established

and implemented. One method to demonstrate this accomplishment is by conducting

comprehensive ISMS independent self assessments at both the corporate and divisional

levels. The contractor can then present the documented results of these self assessments

to the ISMS verification team during the orientation discussions and later in written form

during the review.

d. In combined Phase I and Phase II ISMS verifications, the ISMS verification team

members should begin with detailed record reviews prior to proceeding to any interviews

or evolution observations. This allows the ISMS verification team member to establish a

baseline understanding for the structuring of interviews and evolution observation. For

example the development of questions related to identified lines of inquiry, the

identification of additional lines of inquiry, and the tailoring of questions to the individual

being interviewed will be more substantive. The record review provides the basis for the

Phase II evaluation. To proceed with other Phase II activities without first reviewing the

records establishing the ISMS processes is counterproductive.

A-5-24