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Page Title: Application Guidance for Policy Issues
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extent practical, interdependencies should be minimized by carefully defining activities
subject to prioritization.
Where monetization is not performed for certain elements of the benefits or costs that
are essential to consider, cost-effectiveness analysis should be used to evaluate
alternatives. While not generally yielding an unambiguous choice, such analysis is
useful for determining a " reak-even"value for the unmonetized benefits.
DOE decision maker(s) should retain ultimate authority regarding resolution of policy issues that
arise in the context of risk-based prioritization. Policy issues concerning ES&H activities,
reprioritization, and use of a threshold have traditionally been the most controversial in
prioritization activities. The decision maker(s) should develop a very clear understanding of how
policy issues will be addressed in structuring their prioritization efforts. Some policy issues that
frequently arise in applications of RBP follow.
10.1 Environment, Safety and Health (ES&H) Activities.
Issue. Tradeoffs between safety or environmental protection and cost, schedule, or
mission priorities tend to be very controversial. There are two schools of thought
relating to ES&H activities, namely whether to integrate ES&H activities with activities
not related to ES&H or keep the activities separate by functional area.
Discussion. In some applications of RBP, it is the goal of the prioritization to weigh
ES&H priorities against other priorities such as economic impact. In other
applications, co-mingling ES&H values with other values is unnecessary. However, in
some contexts, it is a choice open to those framing the decision whether to trade off
ES&H values with other values, and it is in these contexts that the policy problem
arises. Integrating ES&H activities with other competing activities can provide a
comprehensive and consistent framework to compare results. The integrated
approach has the advantage that it furnishes a rational basis for an optimum allocation
of resources, but the disadvantage is that it may draw hostile criticism from those who
advocate safety or environmental protection above all else. Separating ES&H
activities by functional area could occur if activities are independent in that the
importance of addressing any one activity does not depend on whether any other
activity is or is not addressed. Although the latter methodology may be easier to
accomplish than a full integration of all activities, the effectiveness of the purpose at
hand should always be strongly considered. It is difficult to capture all of the
motivations for activities and there always exists the possibility that intangible or more
difficult to measure benefits will be underestimated. For this reason, comparisons of
similar activities are generally more reliable than comparisons of dissimilar activities.
Consequently, it may make sense to prioritize ES&H activities separately, so long as
the purpose of the priority system is not to help make decisions about the level of
funding between ES&H and other activities. The guidelines in this standard can be
used by decision makers to help determine whether to fund, by dollars, person/hours
or other measure, either (1) those activities that are the most cost effective overall

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