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Standards Management
Work Smart Standards (WSSs)
Standards/Requirements Identification Documents (S/RIDs)
Directives
Implementations Plans (IPs)
Technical Standards

STANDARDS MANAGEMENT

What are Standards?

  • Standards are expressed expectations for the performance of work.
  • Standards may be reference points against which to measure excellence, or they may become enforceable requirements (either under law or under Department contract).
  • An organization’s internal policies and procedures are implementing documents, not standards.
  • Standards include Federal, state, and local laws and regulations; Department Orders, Manuals, and Notices; and voluntary consensus standards that protect the environment and the safety and health of the workers and the public. Standards are also referred to as source documents.
  • Standards must be supportive of work, not barriers or extra burdens.

What is Standards Management?

  • Standards Management is a program or system for making sure that DOE operations are responsive to all laws and regulations applicable to us and that appropriate standards support and aid in the performance of work.
  • Standards management seeks to support cost efficient operations and provide adequate protection of safety and the environment through the implementation of work-tailored standards that fit a specific scope of work and the hazards associated with that work.
  • Standards management provides a framework for coordinating the many standards activities underway and planned and ensuring that these activities are integrated with other management systems.
  • Standards activities include selection of appropriate standards, development of DOE standards where needed, implementation of standards in work performance, assessment of performance against selected standards, and improvement of standards and standards systems to take advantage of improvements in technology and experience.

What is ORO's Philosophy on Standards Management?

ORO strongly supports the concepts of standards management and is a leader within DOE in the development and application of standards management principles and systems.  Our goal is an efficient and integrated system that supports the accomplishment of our mission in a high quality manner, at a reasonable cost to the taxpayer, and with protection of workers, the public, and the environment.

What are the Benefits of ORO's Standards Management Program?

  • It creates a better understanding between ORO and contractors of requirements and expectations.
  • It allows for good judgment in planning work and allocating resources, and permits judgment to be exercised at the appropriate decision level.
  • It creates consistency and stability in expectations and accountability.
  • It maintains protection while establishing a balance between costs and benefits.
  • It increases the effectiveness of work.

What are the Key Components of ORO's Standards Management Program?

  • ORO O 250 describes the ORO Standards Management Program.   Key elements include:

How are Safety Standards Identified for ORO Contractors?

Click the following link for the  "Safety Standards for Oak Ridge Contracts" brochure.

What are the Key Documents on Standards Management?

Click the following link for the Key Standards Management Documents.
WORK SMART STANDARDS (WSSs) WSS Crystal Ball

What are Work Smart Standards Sets?

Work Smart Standards (WSS) sets are sets of environment, safety, and health laws, regulations, and other standards that have been specifically chosen for applicability and appropriateness for a particular scope of work.  They are selected to provide adequate protection (when properly implemented) against the hazards associated with that work. WSS sets were previously known as Necessary and Sufficient Sets of standards prior to the name change directed by the Secretary of Energy in April 1996.

How are Work Smart Standards Developed?

WSS sets are developed using a DOE-authorized closure process.  This process is described in DOE M 450.3-1, THE DEPARTMENT OF ENERGY CLOSURE PROCESS FOR NECESSARY AND SUFFICIENT SETS OF STANDARDS.   Use of the process is authorized in DOE P 450.3, AUTHORIZING USE OF THE NECESSARY AND SUFFICIENT PROCESS FOR STANDARDS-BASED ENVIRONMENT, SAFETY, AND HEALTH MANAGEMENT.  Both of these Directives were issued January 25, 1996.

The primary objective of the closure process is the identification of a set of standards that, when implemented, will provide reasonable assurance that the environment and the safety and health of the workers and the public will be protected during the performance of work.  All applicable requirements of law and regulation are included in the WSS set (even if accidently omitted from the formal list).

The closure process relies on expert judgment of a team of people familiar with the work and with ES&H controls and programs.  DOE and contractor line management, ES&H professionals, and outside stakeholders such as the public and regulators, all have the opportunity to provide input to the process. The process promotes re-examination of missions, activities, work operations, and work controls to ensure that work is carried out efficiently in a safe, responsible, and cost-efficient manner.

What are the Basic Steps of the Closure Process?

The Closure Process consists of six steps that can be grouped into the Plan-Do-Check-Act cycle of quality management:

1.   Planning: Determining that a set of standards is needed

2.  Planning: Creating the team(s)

3.  Planning: Defining and agreeing to protocols and documentation requirements for the teams

4.  Doing: Identifying the hazards and the associated the set of standards

5.  Checking: Confirming the set of standards

6.  Acting: Approving the set of standards and authorizing work to the set

What If I'm on a WSS Team and I Don't Agree with the Other Team Members?

Most WSS teams strive for consensus -- but this doesn't mean perfect agreement. Consensus means that the issues and positions have been fully discussed and that all team members agree that they can live with a particular position.

If the issues have been fully discussed and no consensus is reached, the team member who believes that the team’s recommendation does not provide adequate ES&H protection or imposes standards that are disproportionate to the known hazards should prepare and submit a "Minority Report" that spells out his/her position and reasoning. The team forwards the Minority Report and accompanying recommendation (Final Report) to the next level (e.g., Confirmation Team or Approval Authorities), or the team follows the issue resolution protocol if one was identified by the Convened Group.

Most important is that issues receive full and fair discussion and consideration based on the nature of the work and the hazards, not on unwritten management expectations, emotions, or fears based on how DOE and the contractor have worked internally or interacted in the past.

What if I'm a Subject Matter Expert (SME) Rather Than a Team Member and I Don't Agree with the Team's Recommendation?

During the WSS development process, stakeholders, subject matter experts, and other interested parties who are not members of the ID Team, Confirmation Team, or Convened Group may review the proposed WSS set and have concerns and issues. If one of these reviewers believes that the proposed WSS set does not provide adequate ES&H protection, that person may write up his/her issue as a "Difference of Opinion" and submit it to the process leader for referral to the Confirmation Team or Approval Authorities. If the person is a DOE or contractor employee, he should also notify his management of his concerns and provide them with a copy of the Difference of Opinion write-up.

How are WSS Sets Used?

Approved WSS sets may be used instead of DOE Directives as contractually binding ES&H standards.  When included in the contract, all standards contained in the WSS set are contractually enforceable.

How are WSS Sets Changed?

WSS sets are changed using the process described in ORO O 250, Chapter V, "Development, Approval, and Maintenance of Work Smart Standards."

For information on changes that have been made or are under review, review the ORO WSS Change Log.  For further information, contact Wayne H. Albaugh, DMG, via telephone at (865) 576-0974  or Jennifer G. Hamilton, DMG, via telephone at (865) 576-0681.

Do I have to Use the WSS process?

No.  The use of the process is not required; other existing systems for determining safety standards (S/RIDs or compliance with Orders listed on the contract appendix) may continue to be used instead.  For ORO facilities and activities, contractor and local DOE management determine which work scopes will be included in the WSS process.

Do WSS Sets replace S/RIDs?

A WSS set for a specific scope of work replaces the S/RID for that scope of work. Any exceptions are identified in the WSS set approval or in the contract modification incorporating the WSS set into the contract. Also, in general the WSS program is a refined and improved version of the S/RID program. New sets of standards for ORO contractors developed after April 1996 will be developed using the WSS Closure Process. S/RIDs may be maintained indefinitely, but revisions must be made using the S/RID change process outlined in ORO O 250, Chapter VII, "Maintenance of Standards/Requirements Identification Documents.".

What is the Status of the ORO WSS Projects?

Click the following link for the ORO WSS Projects Status.

STANDARDS/REQUIREMENTS IDENTIFICATION DOCUMENTS (S/RIDs)

What are S/RIDs?

The concept of Standards/Requirements Identification Documents (S/RIDs) was developed by DOE's Offices of Defense Programs (DP) and Environmental Management (EM) in response to the Defense Nuclear Facilities Safety Board's (DNFSB) Recommendation 90-2.  This recommendation, which was accepted by DOE, was that DOE should develop mechanisms for identifying which standards are applicable to the work, determining whether those standards are fully implemented, and determining whether the standards are appropriate and adequate to ensure protection to workers, the public, and the environment.

The original concept of S/RIDs as espoused by DP was a document that included all applicable Order requirements for which an exemption had not been granted, plus additional laws, regulations, and other standards necessary to ensure adequacy.  EM's original concept was somewhat different -- they believed from the beginning that many applicable Order requirements added little safety value for the types of work they did.  In their concept, S/RIDs would result in selection of only those requirements that were important to a sound ES&H program.

By the time the S/RID Development and Approval Instruction was issued in September 1994, the S/RID concept had evolved considerably: An S/RID was defined as containing "the standards/requirements that are necessary and sufficient to provide an adequate level of protection of workers, the public, and the environment."

The determination of selected standards was to be tailored to the work to be performed -- "Judgments related to inclusion of requirements in S/RID will be based on the hazards present at the site, facility, or activity."

There was no longer any requirement to include all applicable DOE Order requirements.

Justification for standards/requirements not chosen for inclusion was not required, although the instruction recommended that records of the rationale for not including Order requirements should be maintained until DP, EH, and EM could agree on a process for permitting them to be dropped without formal exemptions.

It is important to note that many of the S/RIDs prepared in the DOE complex were prepared before the final instruction was issued and followed earlier ground rules.  In many cases, the completed S/RIDs included excessive requirements.  Also, since the process was not specified in the instruction, some of the groups preparing S/RIDs used a formal and rigorous process, while others did not.

How do S/RIDs Differ from WSS Sets?

S/RIDs and WSS sets are intended to achieve the same goals: to arrive at a mutually agreed-upon set of ES&H and related standards that a contractor is contractually obligated to implement. The two concepts are really a single concept that represent maturating ideas and increased experience in standards management.

Similarities between S/RIDs and WSS sets:

  • They include standards that are "necessary and sufficient" to adequately protect the environment and the health and safety of workers and the public.
  • They specifically address hazards of the work to be performed.

Differences between S/RIDs and WSS sets:

  • S/RIDs are generally limited to activities conducted under DP and EM, while WSS are intended to apply to all Departmental ES&H activities. However, Headquarters has stated that the WSS process cannot be applied to Emergency Management or Occurrence Reporting at this time.
  • The S/RID instruction describes an end product, with little information on how to create that product.  DOE M 450.3-1, which provides instructions for the development of WSS sets, does not describe the end product in any detail. Instead, it provides assurance through a defined process that the set of standards is adequate for its intended use and has broad buy-in by the various groups involved in performing, managing, overseeing, or otherwise involved in the work.

Do WSS Sets Replace S/RIDs?

A WSS set for a specific scope of work scope replaces the S/RID for that scope of work. Any exceptions are identified in the WSS approval or in the contract modification incorporating the WSS set into the contract.  Also, in general the WSS program is a refined and improved version of the S/RID program.  New sets of standards for ORO contractors developed after April 1996 will be developed using the WSS Closure Process. S/RIDs may be maintained indefinitely, but changes will be made using the S/RID change process outlined in ORO O 250, Chapter VII, "Maintenance of Standards/Requirements/Identification Documents.".

What was ORO's Involvement in S/RIDs?

ORO was required by the DP and EM to develop S/RIDs covering activities under their cognizance.

ORO and its principal contractor proposed modifications to the original S/RID program that would better suit the needs of local management.  Proposed changes included the following:

  • Inclusion of all activities at the sites, including those under the DOE Offices of Nuclear Energy (NE) and Energy Research (ER), in site-wide S/RIDs.  While there would be differences at each site based on the type of work being done, a single coordinated effort would identify the requirements and their applicability at each site.  At that time, Martin Marietta Energy Systems (MMES) was the prime contractor for work at ORO's five major sites:  the Portsmouth and Paducah Gaseous Diffusion Plants, the Y-12 Plant, the K-25 Site (now the East Tennessee Technology Park [ETTP]) and the Oak Ridge National Laboratory (ORNL).  Work was performed under a single contract, ES&H work was strongly centralized, and all five plants performed work for multiple DOE Headquarters program offices.  Both ORO and the contractor believed this would be a more efficient and value-added approach to the development of an S/RID than preparing multiple documents for many different facilities.
  • Exclusion of DOE Order requirements that added little or no value for the work performed or which duplicated laws and regulations.

While all four Headquarters program offices agreed to the site-wide approach, DP disagreed with the proposed exclusion of DOE Order requirements without formal exemptions.  ORO's Manager agreed to include all requirements from the 51 DOE Orders of interest to the DNFSB in the initial S/RID.

MMES personnel prepared the S/RID to cover activities at all five sites, and after rigorous review by a multidisciplinary team of Headquarters, DOE and contractor personnel, the S/RID was approved during the period June through December 1994 and became the contractual ES&H basis for the covered work.

In the meantime, ORO and contractor personnel continued working with the DOE-wide 90-2 Steering Committee and were successful in getting further changes to the S/RID program before the issuance of the formal instruction document in September 1994.

What is the Current Status of S/RIDs for ORO Contractors?

S/RIDs for Emergency Management and Occurrence Reporting are included in the contract for UT-Battelle, LLC, which operates ORNL. 

Do Any Other ORO Contractors have S/RIDs?

An S/RID was developed for the Formerly Utilized Sites Remedial Action Program (FUSRAP) in 1995/1996.  However, FUSRAP was transferred to the Corps of Engineers in October 1997.

An S/RID was developed for the Oak Ridge Water Treatment Plant in the spring of 1996. Even though this set was called an S/RID, it also fully meet the requirements of the WSS process and demonstrates how a single standards set can meet the requirements of both the S/RID and WSS programs.

DIRECTIVES

What are DOE Directives?

Click the following for the DOE Directives System and Oak Ridge Office brochure.

DOE uses documents called Directives to provide formal and organized communications on its policies and directions.  Directives include the following types of documents:

  • Policies are issued by the Secretary. They state philosophy and values for the conduct of DOE work.
     
  • Orders, Manuals, and Notices establish requirements, procedures or responsibilities.  They are mandatory for DOE employees but apply to contractors only to the extent specified in a contract.  Orders are intended to contain broad expectations with substantial flexibility for implementation.  Notices contain temporary or time-sensitive information and may be issued quickly when it is important to issue a Directive without full coordination.  Manuals may be issued when there is a need for more detailed procedural requirements.
  • Guides and Technical Standards contain acceptable methods for implementing requirements contained in other Directives.  They are not mandatory.  Technical standards provide DOE guidance on technical subjects not addressed in existing industry standards. Administrative subjects and procedures are issued as Guides.

What are ORO Directives?

ORO Directives are locally written documents that may supplement information in a DOE Directive, provide procedures for Oak Ridge use, or assign local responsibilities and authorities.  They apply to ORO employees and may be applied to contractors through inclusion in the contract. ORO Directives include the following:
  • ORO Orders, which generally correlate to a broad subject matter category such as 440, Worker Protection, or 250, Standardization.  Orders are typically subdivided into Chapters, which address specific topics within the broad category and frequently correlate to a particular DOE Order.
  • ORO Notices, which typically correlate to a specific and serve the same purpose as an ORO Chapter.  They are used to transmit time-limited information or when immediate issuance without full coordination is required.  They are also used to cancel ORO Directives.  They expire no later than 1 year from issuance.
  • ORO Manuals, which supplement ORO Order Chapters when it is necessary to establish detailed requirements and procedures that exceed 10 pages in length.
  • Oak Ridge Implementation Guidance (ORIG), which is an ORO Directive that was issued between June 1991 and October 1995.  ORIGs are being replaced by ORO Orders and Chapters.

What's New About the DOE Directives System?

New features include more opportunity to participate in the development of a new or revised Directive, and the opportunity to appeal to a higher level of management.  Other new features include the development of a new numbering and classification system, and a periodic Directives review to ensure that Directives are either updated or dropped from the system.

Why Do Some Directives have Four Numbers and Others have Only Three?

Directives developed before October 1995 were numbered using a four-digit numbering/classification system.  New Directives are numbered according to a system that only uses three digits.  As old Directives are revised or reissued, the 4-number system will gradually disappear.

How Does ORO Carry Out Its Directives Program?

The Directives Management Group (DMG) is assigned responsibility to coordinate work related to the DOE and ORO Directives systems.  The ORO Directives Point of Contact is Jennifer G. Hamilton, (865) 576-0681.

The DMG works closely with other ORO offices to make sure that everyone who has an interest in a draft or final DOE or ORO Directive has an opportunity to review the Directive and provide comments.  The ORO Directives system is described in ORO O 250, Chapter II, "ORO Directives System" and ORO O 250, Chapter X "DOE Directives System".  Key features of our program include:

  • Careful scrutiny of the need for local Directives and additional requirements within those Directives;
  • A formal system of review and concurrence on ORO Directives before they are issued;
  • Consolidated ORO comments on draft DOE Directives, to provide a corporate response that considers line, subject matter, and policy issues; and
  • Continuous improvement to systems and local Directives to ensure that the Directives system is supportive of management objectives and mission accomplishment.

Did ORO Participate in DOE's Directives Reduction Effort?

Woman Carrrying A Stack of Papers DOE, along with other government agencies, was directed by the President to reduce internal agency requirements by 50%.  As part of this effort, ORO undertook a complete overhaul of our local Oak Ridge Directives system in 1996.  The total number of local Directives was reduced from 244 to 26 and all were updated, simplified, and streamlined.

Why Don't I Get Paper Copies of Directives Any More?

ORO is participating with DOE Headquarters in efforts to implement a "paperless" Directives system.  This system features on-line availability of draft and final Directives through the Internet, thereby eliminating the need to reproduce large quantities of Directives.  The system for DOE-wide Directives is called DOE Directives, Regulations, Policies, and Standards Portal (formerly DOE Explorer), and it permits easy retrieval and downloading of documents as well as automatic notification of new Directives issued in draft or final.  ORO's Directives are also available on-line, through the ORO Directives portion of the DMG Home Page.  Both systems allow you to register to receive direct E-mail notification about new and revised Directives.

How Do I Find Out if a Directive Exists on a Particular Topic?

Once you know the general area you're interested in, use the DOE Directives Checklist (on DOE Directives, Regulations, Policies, and Standards Portal) or the ORO Directives Checklist to see titles of current Orders in that particular area.

IMPLEMENTATION PLANS (IPs)

What are Implementation Plans?

Implementation plans are written documents addressing requirements that are not fully implemented at a particular site or organization, along with actions and schedules for implementation.   If unfunded costs are an issue, the implementation plan typically addresses which actions are not funded and either recommends reallocation of funds or the development of additional funding requests. Requirements and guidance on ORO's implementation and corrective action program are contained in ORO O 250, Chapter VI, "Directive Implementation Plans and Exemption Requests."

When are Implementation Plans Required?

Plans are required under the following circumstances:
  • For contractors, under a contractual provision.  ORO's prime contracts have a Directives clause that requires preparation of implementation plans for new or revised applicable Directives/requirements that cannot be fully implemented within 6 months of the date the Directive or requirement becomes applicable or if the contractor requires additional funding to implement the Directive/requirement.
  • For ORO organizations, this type of planning is covered under the provisions of the applicable DOE Directive.

Can I Prepare an Exemption Request Instead?

Yes.  If an organization wishes to seek permanent or temporary relief from an applicable requirement, an Exemption Request can be prepared instead of an Implementation Plan.   Exemption Requests may be prepared by a contractor.

Exemption Requests for DOE Order requirements are prepared under the provisions of DOE M 251.1-1B, Chapter X, Exemptions.  Note that Exemption Requests are not prepared for DOE Directive requirements when the subject matter of the requirement is covered in a Work Smart Standards (WSS) set or a Standards/Requirements Identification Document (S/RID).

What is the Effect of Implementation Plans on Compliance?

An approved plan has the effect of modifying the requirement(s) to which it applies.  As long as the approved plan of action is being followed and milestones are being met, an organization cannot be considered as "noncompliant" with the underlying requirements.

TECHNICAL STANDARDS

What are DOE Technical Standards?

DOE Technical Standards are a type of DOE Directive that contain acceptable methods for implementing requirements contained in other Directives.  They are developed for technical subjects not adequately addressed in existing industry standards.  There are three types of documents included in this system:
  • Standards,
  • Handbooks, and
  • Specifications.

Why Does DOE Have Technical Standards?

It is now public law that DOE first seek to find and use non-Government voluntary standards for its activities in lieu of developing internal standards.   However, because of the nature of our work, external standards do not exist for all the things we do.  The DOE Technical Standards Program is designed to ensure that standards are developed only when needed, using a process characterized by openness, balance of interest, and due process as found in private-sector consensus standards bodies.  Within this structured process, technical standards are developed and appropriately reviewed by subject matter experts and given proper administrative validation and approval.

Are Technical Standards Mandatory?

No.  Technical Standards are mandatory only if their use is mandated by a specific requirement contained in a DOE Order, Notice, or Manual.  This is, however, rare.

How are DOE Technical Standards Developed?

Technical Standards are issued under the Technical Standards Program (TSP).  The TSP is managed by the DOE Headquarters Technical Standards Program Office (TSPO) in the Office of Environment, Safety, and Health (EH).  Although part of the Directives system, Technical Standards are issued using a separate but similar process.  Detailed information on this process is contained in the DOE Technical Standards Program Overview and Guidance section of the Technical Standards Home Page.

Technical Standards do not follow a standardized format, nor are they numbered in a related series by topic or subject.  They are numbered sequentially by type of document.  Technical Standards are reviewed much like other DOE Directives, but the review period is usually longer, often 60 days.  There is no formal appeal procedure for the disposition of comments.

How Can I Find out If a Technical Standard Exists on a Particular Topic?

Go to TSP Search as a start.  You can also contact the TSP office directly; it provides services that include conducting searches (upon request) for voluntary standards for use within DOE.

How Can I Be Sure That a Technical Standard Is Authorized for Use?

Some Technical Standards are developed by DOE organizations working either inadvertently or unknowingly outside the TS Program and Directives System in developing unofficial but actual technical standards documents.   Some of these are published under the scientific and technical programs, and some of these publications can be contrary to existing policy and guidance of the DOE office of primary responsibility and lack the approval of the Department's Cognizant Secretarial Officers. These documents are commonly referred to as "Rogue Documents".

Does ORO Develop Technical Standards?

No.  If ORO wished to develop a technical standard on a particular area, it would be published for limited or DOE-wide use through the DOE technical standards program rather than through a local system.

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