1. ISM Workshop April 25, 20061 DOE HQ ISM Champions Workshop Contractor Session “DOE Policy Order 226.1” Oversight Policy & Implementation

2. ISM Workshop April 25, 20062 Background  Policy Issued 6/10/05  Establishes New Model for DOE Oversight  Establishes Requirement for HQ Approval of Contractor Assurance System Program Descriptions and Annual Updates Can Be Delegated to DOE Field Elements  Establishes Clear Roles and Responsibilities for Federal Organizations and Leaders

3. ISM Workshop April 25, 20063 Background continued  Order issued 9/15/05  Required to be in Contracts NLT 3/06  Establishes Detailed Requirements for: Scope of Assurance Activities Assessments Event Reporting Worker Feedback Issues Management Lessons Learned, and, Performance Measures

4. ISM Workshop April 25, 20064 Contractor Requirements Document  General Requirements Expands Assurance activities beyond ESH to S&S, Cyber, Emer. Mgt., Bus. Ops, etc.  6 Detailed Requirement Areas Requires Contactor Assurance System data to be documented and available to DOE  Part of Contract Performance Evaluation Requires Corporate Audits, 3 rd Party Certifications, External Reviews

5. ISM Workshop April 25, 20065 Contractor Requirements Document  Assessments No Significant Changes  Event Reporting No Significant Changes  Worker Feedback Employee Concerns plus ……….  Issues Management Requires Comprehensive Structured System Extensive Set of Requirements Identified  “… must include provisions for communicating and documenting dissenting opinions.” Requires Process for Dispute Resolution for Findings and Issues

6. ISM Workshop April 25, 20066 Contractor Requirements Document  Lessons Learned Very General New DOE Order for Operating Experience  Issuance Pending  6 Month Period for Contract Incorporation  Performance Measures Requires Structured Approach to Development and Application of Performance Measures Note: EFCOG‘s Performance Metric Manual Available at no cost to all DOE and DOE Contractors

7. ISM Workshop April 25, 20067 Discussion – Q & A’s  Your Thoughts ??  Significant Issues ??  What can we provide to make implementation easier?  Plus……………………………………..

8. ISM Workshop April 25, 20068 DOE HQ ISM Champions Workshop Contractor Session “Measuring And Monitoring ISM Improvements” aka “Safety Performance Objectives, Measures & Commitments”

9. ISM Workshop April 25, 20069 Background  DEAR Clause Requirement  Annually Requires us to submit to DOE, for Approval, Safety Performance Objectives, Performance Measures & Commitments Consistent with DOE Program and Execution Guidance  Being Implemented in Different Ways

10. ISM Workshop April 25, 200610 Background continued  Proposed DOE Direction Focuses on: Performance Objectives (Strategic) Long Term Multi-year Goals Performance Commitments (Tactical) Action for One Year, Support Performance Objectives Performance Measures Annually Established, Track Progress and Monitor Achievement of Objectives and Commitments Ideally Combination of Leading & Lagging Indicators

11. ISM Workshop April 25, 200611 Discussion  How is done at your location? What are the Key Elements of your Submittals to DOE  Should this be Institutionalized by DOE across all Contractor Operations? Plus / Minus Discussion  Should EFCOG provide Contractor Guidance Document?

12. ISM Workshop April 25, 200612 DOE HQ ISM Champions Workshop Contractor Session “Feedback & Improvement”

13. ISM Workshop April 25, 200613 Background  DNFSB Views as Critical Issue De-centralized Safety Oversight Delegation of Oversight Responsibilities Need Improved Program for Managing Operating Experiences from External Low- probability, High-Consequence Events  DNFSB Issued Tech. Reports 35 & 36 Tech. Rpt. 35 Focused on DOE HQ / Fld. Orgs Tech. Rpt. 36 Focused on both DOE and Contractors

14. ISM Workshop April 25, 200614 Background continued  Tech. Report 36 Highlights F/I viewed as Ineffective ISM Core Function Significant Variance from Site to Site Need focus on:  Rewarding Self-reporting of Errors  Improved Categorization of Problem Significance Perception of Under-classification  Better Accountability of Workers/Managers

15. ISM Workshop April 25, 200615 2004-1 F/I Assessment Results  Most Sites Reported Partial but Substantial Compliance to the New DOE Requirements  Some Gaps in Requirements Flowdown Related to New Contracts  Identified Improvements were Related to: Planning, Conducting and Determining Effectiveness of Self-Assessments Corrective Action Identification & Closure Implementation  Categorization of Problem Significance Performance Trending & Analysis Worker Feedback Processes Positive Reinforcement for Self-reporting of Errors

16. ISM Workshop April 25, 200616 F/I Assessment Results cont’d  Typically All Parts of the Contractor Assurance System are being Implemented within Contractor Management Systems but are: Not Holistically tied together Being Managed by Multiple Organizations  New Requirement for CAS Description Stand Alone Document, Part of ISM Description Document, Part of QA Program Document, etc.

17. ISM Workshop April 25, 200617 Discussion  Your view on the subject?  What are the areas needing most improvement?  Are performance barriers being created by the CAS approach?  What are the top 3 to 5 Issues that impact CAS implementation?  What can EFCOG do to help the Contractor Community?

18. ISM Workshop April 25, 200618 DOE HQ ISM Champions Workshop Contractor Session “Work Planning & Control”

19. ISM Workshop April 25, 200619 Background  Critical Activity Level ISM Issue  Current Areas Needing Improvement Hazard Identification & Analysis Processes to Ensure “Right” Controls are in Place Increased Recognition of “Scope Creep”  Renewed Emphasis on Stopping, Reanalyzing Hazards and Addressing Controls Written Work Procedures Job Planning Participation Post-job Worker Feedback Open Critiques of Job Errors, and Qualification of Work Control Managers & Planners

20. ISM Workshop April 25, 200620 2004-1 WP&C Assessment Results  Wide Variation in Implementation of WP&C Processes among Contractors  Inadequate Hazard Analysis and Identification of Controls were Widespread Issues Failure to Adequately Cover Hazard Controls in Work Instructions  Some Contractors Identified as only Applying WP&C Principles to Maintenance Activities Needed for Ops, R&D, D&D

21. ISM Workshop April 25, 200621 WP&C Assessment Results cont’d  Training & Qualification Issues for Work Planning Personnel Identified  Clear & Concise Work Instructions Identified as a Broad Issue across the entire complex

22. ISM Workshop April 25, 200622 Discussion  What are the areas needing the most improvement?  What are the top 3 to 5 Issues that impact Effective WP&C implementation?  What Changes would you Recommend to the Customer? Should WP&C Process be Standardized across Complex?  What can EFCOG do to help the Contractor Community?

23. ISM Workshop April 25, 200623 DOE HQ ISM Champions Workshop Contractor Session “10CFR851” Worker Safety & Health Program Regulation

24. ISM Workshop April 25, 200624 Background  National Defense Authorization Act 2003 Maintain “The Level of Protection Currently provided to workers……” Tailor Implementation to Site-specific Hazards Recognize Special Circumstances for “Closure” Facilities Authorizes PAAA Civil Penalties or Fee Reductions for Violations (Not Both)  Final Rule Published 2/’06, Effective 2/’07

25. ISM Workshop April 25, 200625 Background continued  Codifies Existing Worker & Health Requirements (DOE Order 440.1A)  Written Worker Safety & Health Program Plans/Documents to be Submitted to DOE NLT February 26, 2007 DOE Approval NLT May 25, 2007  No Work to be accomplished after Compliance date without an Approved Program

26. ISM Workshop April 25, 200626 Background continued  Customer Perspective at this time reflects that Contractors: Have Verified ISM Systems in place Currently Comply with 440.1A Requirements Currently have written Worker Protection Program,  Therefore, If meeting Contractual Responsibilities…. “Little, if any, additional work will be necessary”

27. ISM Workshop April 25, 200627 Elements of the New Rule  Subpart A – General Provisions  Subpart B – Program Requirements  Subpart C – Specific Program Requirements  Subpart D – Variances  Subpart E – Enforcement Process  Appendix A – Functional Areas  Appendix B – Enforcement Policy

28. ISM Workshop April 25, 200628 Status / Upcoming Activities  Orientation Workshops In Progress  Implementation Workshops Planned for Sept. – Dec. 2006 Locations TBD  Enforcement Program Development In Progress Procedures/Protocols in Development Prototype Inspections June – Aug. 2006 Finalization of WHS NTS Thresholds – Dec. 2006

29. ISM Workshop April 25, 200629 Discussion  Do you consider this Rule to be a Critical Contract Issue?  What areas of the Rule are you most concerned about?  What is the right level for the Enforcement Reporting Thresholds?  From your Perspective are there Unresolved Policy Issues?  Other Concerns ……. ?????????

30. ISM Workshop April 25, 200630 EFCOG 10CFR851 Summary  EFCOG Chair & DOE HQ EH-1 Agreed to Work Together on Implementation  EFCOG Board of Directors Elected to form Separate 10CFR851 Project Team Senior Leadership Team from EFCOG Board  Dave Amerine (Parsons), Pam Horning (BWXT), Bob Pedde (WSRC), and, Mike Schlender (PNL) Board Project Manager – Joe Yanek (WSRC) Project Leads from ISM & PAAA Working Groups  Barb Hargis (LANL) & Bill Luce (WSRC)

31. ISM Workshop April 25, 200631 EFCOG Activity Summary continued  Direct Interface established with DOE HQ Program Manager, Project Manager and Technical/PAAA Leads  Activities to date includes providing input on: Proposed Reporting Thresholds for WHS (PAAA) Noncompliance Tracking System (NTS) Draft Implementation Guide

32. ISM Workshop April 25, 200632 Path Forward  This Afternoon’s PSO Break-outs Provide Opportunity for you to Express your Views and Concerns in each of the Five Topical Areas  Wednesday Panels will provide PSO Cross- cutting Feedback in Each of the Five Areas You may be Asked, or you can Volunteer, to be the PSO Spokesperson on a Panel  Significant Opportunity to Influence the Direction being taken in the Five Topical Areas

33. ISM Workshop April 25, 200633 Closing Remarks  Dave Amerine, EFCOG Chair