10 CFR 851 Health Safety Final Approved

Department of Energy
Oak Ridge Operations

P.O. Box 2001
Oak Ridge, Tennessee 37831—
May 2 2, 20 0 7
Dr. Ronald D. Townsend, Director

Oak Ridge Institute for Science
and Education
Mai! Stop 22
Post Office Box I 17
Oak Ridge, Tennessee 37831-0117
Dear Dr. Townsend:
CONTRACT NO. DEAC05-06OR23100, OAK RIDGE INSTITUTE FOR SCIENCE AND

EDUCATION (ORISE) 10 CFR 851 WORKER SAFETY AND HEALTH PROGRAM (WSHP)
DESCRIPTION DOCUMENT
The ORISE WSHP submitted to us on February 26, 2007, was evaluated to provide reasonable assurance
that the ORISE WSHP accurately describes the methods by which the requirements of 10 CFR 851,
Subpart C, will be satisfied. It is recognized that there are several issues pending which may result in
changes to the WSHP. These issues are:
The jurisdictional status of Methodist Medical Center for worker safety and health that continues
to be explored through communications with the Tennessee Occupational Safety and Health
Administration
The permanent variance from the Occupational Medicine requirements for ORISE subcontractors
contained in Appendix A to 10 CFR 851 - Worker Safety and Health Functional Areas
Pursuant to 10 CFR 851.1 l(b), the ORISE WSHP dated May 8, 2007, is approved. The evaluation
resulted in the conclusion that the established WSHP reasonably describes the methods by which Oak
Ridge Associated Universities will comply with the applicable rule requirements, provides for a safe and
healthful workplace and is implemented through integration with other ORISE management systems
elements. This approval does not validate each functional element of referenced compliance method
contained in the WSHP.
The time and effort applied to the development of the WSHP and the responsive and open process in
working with Assistant Manager for Science staff and review team are appreciated.
If there are any questions or additional information is required, please contact me at 576-4444 or
Johnny Moore of my staff at 576-3536.
Sincerely,
Gerald G. Boyd
Manager
Dr. Ronald D. Townsend -2- May 22, 2007
cc:
Robert J. Brown, M-2, ORO

Roger L Casteel, SE-30, ORO
George C. Manthey, SC-12, ORO
Johnny O Moore, SC-10, ORO
Robert J. Kapolka, SC-1-03, ORAU
Oak Ridge
Associated Universities
Oak Ridge Institute

for Science and Education
10 CFR 851
Worker Safety and Health
Protection Program
Oak Ridge Institute for Science and Education
ORALJ
OAK RlDCE ASSOCIATED UNIVERSITIES
TABLE OF CONTENTS
Signature Page 1
1. Executive Summary 2
2. Scope/Exclusions 3
3. Integrated Safety Management System 4
4. Flowdown of Worker Safety Health Requirements 4
5. Implementing Processes 8
6. Program Assessments 16
7. Variance Process 16
8. Appendices 18
Appendix A, Crosswalk of 10 CFR 851 Requirements
to ORISE Implementing Documents 19
Appendix B, Applicable Worker Safety and Health Requirements 50
Appendix C, Functional Area Descriptions 51
Appendix D, ORISE CFR 851 Facilities 58
Appendix E, ORISE Acronyms and Abbreviations 60
SIGNATURE PAGE
~ (a ~
Robert J.KapolKa date
Director, Environment, Safety & Health
Ronald D. Townsend date

Director
%n
JoMinyjjOAMoore date
AssJstarrtivIanager for Science
Gerald G. Boyd <iat

Manager
May 2007 (Rev. 1)

OAK RIDGE ASSOCIATED UNIVERSITES
OAK RIDGE INSTITUTE FOR SCIENCE AND EDUCATION
10CFR851
WORKER SAFETY AND HEALTH PROTECTION PROGRAM
Office of Science Program Elements & Review Criteria

Executive Summary
This Worker Safety and Health Program Description discusses how Oak Ridge Associated
Universities (ORAU) approaches the development, management, and implementation of the
worker safety and health program (W5HP) at the Oak Ridge Institute for Science and
Education (ORISE). This program description documents the ORISE processes for
compliance with worker safety and health regulatory requirements, including 10 CFR 851,
Worker Safety and Health Program (10 CFR 851), and provides cross-references to
implementing systems, programs, and subject areas. It also describes how ORAU integrates
worker safety and health requirements with other related worker protection activities and the
ORISE Integrated Safety Management System (ISMS). This program description also
illustrates the ORISE framework for effective worker protection and the integration of safety-
and health-related functional areas, including construction safety, fire protection, pressure
safety, industrial hygiene, occupational medicine, motor vehicle safety, and electrical safety.
The information in this program description is intended to provide an understanding of the

overall approach to worker safety and health and to show how worker safety and health
requirements flow down to workers. This document is not an implementing procedure that
drives performance relative to specific requirements, or establishes requirements, but rather
serves as a description of the W5HP and its interfaces. Appendix A contains a crosswalk of
requirements from 10 CFR 851 and the respective implementing documents at ORISE.
Workers use the implementing documents referenced in Appendix A for specific
requirements.
ORISE is designated as a non-nuclear, radiological low-hazard faciKty. Its focus is on scientific

initiatives to research health risks from occupational hazards, assess environmental cleanup,
respond to radiation medical emergencies, support national security and emergency
preparedness, and educate the next generation of scientists.
As part of its commitment to maintaining the highest standards of worker safety and health,
ORISE has pursued and received two key honors for its safety and environmental
management programs. First, in August 2003, ORISE submitted an application to the
Department of Energy (DOE) for inclusion in the Voluntary Protection Program (VPP).
Following a site visit in December of that year, DOE awarded ORISE with VPP Star Site
status on August 9,2004, as just the twenty-first organization within the DOE complex to
receive this designation.
Then in March 2005, ORISE applied for and began the process of registration for ISO
14001:2004. After a lengthy review of the organization's Environmental Management System,
followed by a site visit, ORISE earned ISO 14001 registration in April 2005.
May 2007 (Rev. 1)

In order to establish and implement appropriate standards for environment, safety and health
(ES&H), ORAU uses the DOE-authorized Work Smart Standard (WSS) process for all work
performed under the ORISE contract. This process identifies a set of standards that, when
successfully implemented, provides reasonable assurance that the safety and health of workers,
the public, and the environment are protected.
ORAU initiated the WSS process in 1999, starting with a comprehensive analysis of the work
that it performs in fulfillment of the ORISE contract. This analysis was conducted by a team
consisting of program representatives, ES&H support staff, and DOE subject matter experts
(SMEs). The team identified potential work hazards and the operational and administrative
controls required to conduct work safely. On that basis, a set of ES&H requirements was
identified and documented The set included all applicable statutory and regulatory
requirements, plus those DOE orders and other consensus standards that were determined to
be appropriate for incorporation as contractual requirements to ensure adequate protection of
workers, the public, and the environment.
The WSS set is published as the ORISE Work Smart Standards Setfor Environment, Safety, and
Health and is available on the ORAU intranet as well as the ORISE site on the World Wide
Web at http://orise.orau.gov/safety/wss-current.htm. Changes in the approved WSS set are
governed by change controls specified by DOE. The ORISE WSS set is updated annually or
as new directives, regulations, and industry standards are released.
Scope/Exclusions
This program description applies to ORISE-managed, DOE-owned or -leased facilities,
operations, and activities, and to ORISE employees and subcontractor personnel at ORISE-
managed, DOE-owned or -leased facilities. This program description also demonstrates the
methodology used by ORISE employees and its subcontractors at DOE facilities not managed
by ORISE when the host facility does not have a DOE-approved WSHP. This program
description applies to contractor and subcontractor employees at ORISE-managed, DOE-
owned or -leased facilities as referenced in Appendix D. All of these facilities are located in
Oak Ridge, Tennessee.
This description explains how worker safety and health requirements are implemented and
managed including 10 CFR 851 and its referenced standards. Not all activities managed by
ORAU are subject to 10 CFR 851. The DOE Office of General Counsel clarified the
applicability of 10 CFR 851 to activities under the management and oversight of ORAU that
are performed in facilities owned or leased by ORAU. Per the DOE legal opinion, activities
managed by ORAU, including those that are in furtherance of the DOE mission, are not
subject to 10 CFR 851 unless DOE "controls" the site. The opinion further states that DOE
control requires that DOE either holds the lease or sets requirements for the lease.
Based on this ruling, some ORISE activities and locations are not under the scope of 10 CFR
851. In addition, the provisions of 10 CFR 851 do not apply to the following:
• Work at a DOE site that is regulated by the Occupational Safety and Health
Administration (OSHA).
• Radiological hazards regulated by 10 CFR Parts 20, 820, 830 or 835.
May 2007 (Rev. 1)

• Transportation to or from a DOE site.
• Work at a DOE site that is not in furtherance of a DOE mission.
• Work that is not performed at a DOE-owned or -leased site.
• Activities by DOE personnel.
• Visitors, students, visiting scientists, research partners, and others who may be stipend
recipients.
• Activities by foodservice or other similar vendors.
• Activities by suppliers of commercial items.
• Activities by subcontractors that are providing operation and maintenance services for
commercial items (e.g., equipment technicians, fax/copier technicians, repair services
for equipment under warranty, training activities for equipment operation).
• ORAU personnel at non-DOE controlled facilities, including, but not limited to, the
following facilities:
o 701 Scarboro Road
o ORAU Main Campus
Integrated Safety Management System

A major concept of ISMS is the integration of safety awareness and good practices into all
aspects of work For ORISE, safety is an integral part of every job, not a stand-alone program.
In fulfilling the ORISE contract, ORAU has adopted DOE's Guiding Principles and Core
Functions of ISMS on a corporate level and in all the individual program/department ISMS
plans. This is outlined in ORAU Policy and Procedure ESH-100, Integrated Safety Management
(ESH-100) and fully detailed in the Integrated Safety Management System Program Description.
ORISE flows down requirements through a network of tailored ISMS plans for each program
and department consistent with the practices established in the corporate documents. Each
plan follows a standard format for describing how the unit manager and employees
incorporate the Guiding Principles and Core Functions of ISMS into their day-to-day
activities. All employees have access to ISMS documents electronically and in hard copy.
Flowdown of Worker Safety and Health Requirements

^•1 Overview
ORAUs safety requirements apply to all employees and subcontractors in ORISE-
controlled facilities. As stated above, this is outlined in ESH-100 and fully detailed in
the Integrated Safety Management System Program Description. Planning and performing
work in accordance with these established controls developed from requirements
stated in the WSS set protects our workforce, the public, and the environment.
The Integrated Safety Management System Program Description, together with the ORAU
Health and Safety Manual, ORA U Radiation Protection Manual, ORA U Emergency
Preparedness Manual, and the ORAU Environmental Management System provide the
global framework for integrating safety requirements into planning and performing
work They provide form and substance for the detailed, unit-level ISMS plans and
procedures. Most ORAU employees work in low-hazard environments. However,
May 2007 (Rev. 1)

where hazards increase in severity or number, the formality, intensity, and level of
controls and assurance measures also increase. For example, laboratories, shops, and
field operations require redundancy in hazard controls.
The 10 GFR 851 requirements are conveyed through this mechanism. All work is
performed in a manner consistent with these established mechanisms.
4-2 Technical Staff and ES&H Responsibilities

In the operation of ORISE, ORAU seeks to recruit, develop and retain the most
qualified worker protection professionals to assist line management and
organizational components in meeting worker safety and health goals and objectives.
This is stated in ORAU Policy and Procedure HR-400, Staffing. The hiring of certified
professionals and management support of the attainment of certifications by current
staff is one way that ORAU ensures the quality of the WSHP. Presently, ORAU
employs professionals certified in safety, industrial hygiene, health physics, and
occupational nursing.
Other staff that have credentials in hazardous material management, training,

transportation, and other disciplines are also available to support the WSHP. Under
the ORAU Policy and Procedure HR-810, Human Resources Development Plan (HR-810),
Attachment 1, ORAU provides for attainment and maintenance of professional
certifications in order to maintain a quality ES&H staff.
4*3 Procurement Interface

ORAUs Procurement Services group includes in all of its subcontracts involving the
performance of work on an ORAU site provisions requiring subcontractors to
comply with ORAlFs ES&H standards when such standards are mandated bylaw,
regulation, the ORISE contract, or as necessary to ensure safe work practices.
ES&H considerations are addressed in the ORAU Procurement Services and Guidelines
Manual and are essential elements of all contractual activities conducted at ORAU. It
is ORAU policy to follow ES&H laws, regulations, and ORAU-adopted practices as
described in ESH-100. No activity can be considered so urgent or so important that
safety may be compromised Within the ESH-100 responsibilities, all staff members
are responsible for maintaining a complete understanding of the safety requirements
of their workplace and assignments. Furthermore, important operational safety
information for Procurement Services is contained in the Financial Operations
Department ISMS Plan, which is available on ORALPs Safety 1st intranet site.
In the event that ORAU must procure the services of a subcontractor, specific
guidelines as stated in the ORAU Procurement Services Guidelines and Procedures Manualare
to be followed. All ORAU and ORISE subcontractor personnel have a right to a safe
workplace and a right to inform line management if they consider a condition unsafe.
ESH-100 also explains the responsibilities of ORAU for on-site work performed by
subcontractor personnel.
ORAU is accountable for the ES&H performance of its subcontractors. Each
May 2007 (Rev. 1)

contract specialist/buyer in Procurement Services will work with all parties to prevent
and resolve potential hazardous work issues arising in the performance of each
subcontract. The contract specialist/buyer in consultation with ES&H support staff
will consider the appropriate procedures, clauses or handbooks to include in
solicitations and subcontracts involving on-site work including the ORAU Health &
Safety Manual, Facilities and Transportation Department (FTD) policies and
procedures, Safeguards and Security policies, and environmental management
procedures. This is stated in the ORAU Procurement Services Guidelines and Procedures
Manual. Refer to Section 8, paragraph 4 of this manual for more detailed information
on ES&H provisions for on-site work.
ORAU contract specialists/buyers use the Subcontract Safety Clause Matrix when
acquiring materials, services and construction with ES&H implications to ensure the
appropriate ES&H provisions and clauses are included in the subcontract. As an
additional measure, the Visitor and Subcontractor Handbook is also distributed to
subcontractors for general compliance issues.
Types of Flowdown
Within the ORAU and ORISE boundaries, there is only one type of flowdown of
ES&H guidelines. All employees or subcontractors are ultimately bound byESH-100
and the ORAU WSHP where applicable. This is the overarching guideline for all of
our missions. In the case of subcontract employees, guidelines for safety performance
are the same as for regular full-time ORAU employees.
Subcontractor Safety and Review

Construction subcontractors build new facilities or modify existing facilities under
construction contracts using their own supervisory personnel. ORAU maintains a
comprehensive construction safety program, which is documented in procedure FMS-
7, Safe Subcontractor Work (FMS-7). This procedure requires major subcontractors to
comply with applicable ES&H requirements as stated in ESH-100. As determined by
the ES&H director, plans must be approved before work can start. Per FMS-7, both
ES&H SMEs and FTD construction and maintenance managers who understand the
scope and nature of the work being contracted analyze the hazards involved and agree
upon the set of applicable ES&H requirements prior to the arrival of the
subcontractors on site. FTD project managers and other construction managers
enforce compliance with these safety plans. Additionally, ES&H staff perform
unannounced inspections of construction sites on a regular basis. Finally, before any
new or modified work is initiated, an ISM Pre-Job Hazard Analysis Checklist and an ISM
Plan for New or Modified Work must be completed and approved by both program
management and ES&H SMEs.
For construction or other business contracts through the procurement process,

ORAU uses a Performance Based Safety Target Construction Subcontract in all
construction-related contracts as stated in the ORAUProcurement Services Guidelines and
Procedures Manual including the Subcontract Safety Clause Matrix:
1. The successful subcontractor must "qualify" to be a viable candidate for safe
May 2007 (Rev. 1)

work on an ORAU or ORISE site by meeting a stipulated minimum Experience
Modification Rate (EMR) rating.
2. During the life of the contract, ORAU will make payments aggregating up to 90
percent of the contract amount and hold back amounts on each invoice
aggregating to 10 percent of the face amount of the subcontract.
3. The only condition under which the subcontractor can collect the full 10 percent
retainage at the end of the contract is if the job is completed safely with no
recordable-as defined by OSHA— accidents. The rate of permanent reduction of
payments under the subcontract for each official recorded and OSHA-reported
accident shall be five percent of the then current balance of ten percent retainer.
For each officially-recorded accident, the subcontractor agrees in advance to a
reduction of a portion of the 10 percent retainage, which computes to one-half of one
percent of the face value of the contract. The subcontractor may experience a
reduction in final payment aggregating up to five percent of the face amount of the
subcontract should multiple recordable and OSHA-recordable accidents occur under
this subcontract. The contract specialist will approve final payment. The contract
specialist may, depending on circumstances, choose to use his/her sole discretion to
mitigate any individual reduction levied by the above formula by further reducing the
assessment by up to 50 percent, resulting in an actual reduction equal to one-fourth of
one percent of the face amount of the subcontract award. The process for reviewing
subcontractor safety and health programs is described in FMS-7.
To summarize the procedure, once the engineering designs and scope of the project is
finalized, the designs are reviewed byFTD engineering and architecture personnel.
After their review, the plans are reviewed by ES&H personnel to determine if
applicable safety issues are addressed. After this approval, a Request For Proposal
(RFP) solicitation package is submitted for subcontractor bids. In addition,
throughout the project, inspections byFTD and ES&H personnel are performed to
ensure that safety and health procedures are being followed.
Lower Tier Subcontractors

ORAU applies ES&H requirements to activities involving service providers, guest
workers, and visitors, on a case-by-case basis. Subcontracts for services are governed
by the Visitor and Subcontractor Handbook. These requirements are inserted into all
service subcontract documents and specify that all subcontractors will follow
applicable ES&H requirements and protect the interests of ORAU and DOE.
However, these visitors are not governed by the compliance standards of 10 CFR 851.
Guest workers and students on occasion work at ORISE on a temporary basis in

close collaboration with a program manager or specialist, sometimes without
remuneration. As with all regular employees, they are required to follow all ES&H
requirements covered under ESH-100> and the ORAU host is responsible for
ensuring that they meet these requirements, or that they are escorted or supervised by
fully-qualified individuals.
The Visitor and Subcontractor Handbook provides pertinent ES&H information to
May 2007 (Rev. 1)

accommodate this work. Visitors and subcontractors are also provided a safety and
security brochure on their first visit to ORAU facilities in order to orient these
persons to the safety culture expected throughout their stay.
5. Implementing Processes
5*1 Overview
ORAU will provide a workplace that is free from recognized hazards that are causing
or have the potential to cause death or serious physical harm to workers This includes
exposures to hazardous substances or conditions. This provision is addressed through
this program description and the health and safety policies and procedures for
ORISE. Included in these policies and procedures are the following broad-based
principles:
• Provide a safe and healthy workplace by developing and implementing work
processes and equipment that abate hazards.
• Maintain a culture where individuals performing work understand and
support the concept that all injuries are preventable.
• Comply with applicable requirements for performing work and work-related
activities on and off site, including requirements in the ORISE WSS set.
• Comply with the applicable requirements of the Rule by ensuring that all
work performed by subcontractors in a 10 CFR 851 covered workplace
complies with established requirements.
ORAU intends to provide continual improvement and remain in compliance with the
rule when new or modified orders are issued. This is performed through the ORAU
General Counsel's office. Listings of the directives that are applicable to ORAU are
cited on the ORISE contract on Attachment D, Baseline List of Required Compliance
Documents. Additions, deletions, and updates to Attachment D are made quarterly by
the General Counsel's office in coordination with the DOE/Oak Ridge Operations
(ORO), Directives Management Group. Any new or modified directives are then sent
to the ES&H office to determine applicability for modification of existing policies or
procedures. If a compliance order is issued pursuant to 851.4, ORAU senior
management shall direct that an investigation commence as to the conditions
applicable to the compliance order and that, if needed, corrections be implemented as
soon as is feasible.
5-2 WSH Program - General Requirements (10 CFR 851.10)

Management Responsibilities
ORAU subscribes to the philosophy that line management is responsible for safety.
This is outlined in ESH-100 and fully expressed in the ORISE Integrated Safety
Management System Description. However, it is clear that management needs support
when implementing the WSHP. ORAU holds management, staff, and subcontractors
accountable for worker safety and health, and each has a significant role in
implementing this program. It is ORALTs expectation that employees and
subcontractors will follow the requirements set forth in the WSS set and use specified
work controls to prevent occupational injury and illness. ORAU holds both managers
May 2007 (Rev. 1)

and employees accountable for adherence to worker safety and health requirements.
Management communicates expectations of individual roles and responsibilities
through assignment of workers in their Individual Performance Plans. ORAU has a
comprehensive employee performance assessment program in place for all employees,
consisting of a midyear progress report and a year-end formal assessment. This
process is described fully in ORAlJs Performance Management Program.
Accountability of personal performance is also addressed in ORAU Policy and Procedure

HR-900, Employee Corrective Action. This policy provides a framework, process, and
guidelines for employees and managers to improve and correct work performance
and behavior, identify areas for professional growth, increase productivity, and
enhance the overall work environment. When needed, it also provides for progressive
disciplinary action.
Similarly, worker protection performance goals and objectives for subcontractors are
established and contained in contract documents. Subcontractors are held accountable
for worker protection performance through contract provisions that include the
option to remove subcontractors' employees or termination of the subcontract. This
is stated in the ORAU Procurement Services Guidelines and Procedures Manual.
Several health and safety codes and standards, including National Fire Protection
Association (NFPA) standards, allow for the designation of an Authority Having
Jurisdiction (AHJ). For example, NFPA 70 defines the AHJ as "the organization,
office, or individual responsible for approving equipment, materials, and installation,
or a procedure." NFPA 1 more globally defines the AHJ as "... an organization,
office, or individual responsible for enforcing the requirements of a code or standard,
or for approving equipment, materials, an installation, or a procedure." In general,
NFPA codes and standards contain several provisions that allow the AHf to approve
alternatives that provide equivalent levels of protection, Le., "equivalencies" to the
levels provided by the standard.
The ORISE WSHP recognizes the responsibility of the designated ORISE AHf to
resolve implementation issues and approve equivalencies related to fire protection and
electrical safety/design as allowed by codes and standards. The ORISE ES&H
director is the designated AHf for this purpose. The ORISE AHf may delegate to
other qualified individuals such powers as necessary for the proper administration and
enforcement of the ORISE fire protection and electrical safety programs. As
appropriate, the ORISE AHf consults with the AHf for the City of Oak Ridge and
DOE/ORO as appropriate.
"Worker Involvement
The ORAU Values Statement declares that "employees are our most valuable
resource." This value is demonstrated in many ways, one of the strongest being the
"Safety 1st" approach to work completed at ORISE. Employees are required to be
involved in the health and safety process and encouraged to be as involved as they are
willing to be.
May 2007 (Rev. 1)

Authority to suspend and/or stop work is extended to all ORAU employees, guest
workers, students, and subcontractor employees as described in the responsibilities
section of ESH-100. Without fear of reprisal, employees are encouraged to approach
all work with caution and to satisfy themselves that it is safe to proceed. Management
empowers all employees to request and receive results of all inspections and accident
investigations as described in the responsibilities section of ESH-100, and to
understand the right to refuse to perform work that is unsafe, even if directed to do
so by supervisors or other persons.
Many opportunities are provided to employees to become involved in ORISE safety

activities, including the following:
Being involved with their natural work teams.
Attending and participating in staff meetings.
Initiating informal communications with their immediate manager.
Contacting SME support staff.
Developing Job Hazard Analyses (fHAs).
Participating in accident investigations and near-miss critiques.
Participating in safety committees.
ORISE maintains processes for encouraging and acting on employee suggestions and
for improving worker safety and health. The Safety 1st Web site provides tools to
enable workers to easily report safety concerns or questions, anonymously if desired.
The Web site also provides the employee with access to the WSHP, all standards,
policies, procedures, or controls that are applicable to operations, and other pertinent
information or links to applicable DOE safety and health resources. Posters and other
informational devices, along with the annual posting of the OSHA 300 and the Form
301 log can be found throughout the ORAU workplace on public bulletin boards.
The ORAU President's Line allows employees to submit questions or comments on
any work-related topic directly to the president of ORAU. Mechanisms are provided
for feedback as appropriate as determined by the president of ORAU with the
counsel of the ES&H director. Also, suggestions for the improvement of the ORAU
WSHP or to submit a safety question can be found on the ORAU intranet site under
"How To Raise an Issue." Issues may also be presented through the employee's
supervisor. All issues, concerns or recommendations presented by employees of
ORAU are free from reprisal as stated in ESH-100.
5.3
Development and Approval of the WHS (10 CFR 850.11)
5.3.1 Preparation, Evaluation and Approval
This program description was developed with the active participation of
ORISE management, ORAU Safety Council, legal counsel, procurement
specialists, health and safety SMEs, and the ORAU Site Safety
Representatives. Close coordination of the local DOE site office and the
DOE Office of Science was maintained during the entire process.
Procedures, program descriptions, management system descriptions, subject

areas, and other implementing documents listed in this program description
are not incorporated by reference, or made a part of this document.
May 2007 (Rev. 1) 10

5.3.2 Coordination with Other Contractors and Labor Organizations
ORAU is the prime contractor for work performed at ORISE. As such,
ORAU is responsible for all work that is performed at ORISE. ORISE
management staff meets regularly with other DOE prime contractors to
discuss issues of common concern and ES&H issues. Employees at ORISE
are not represented by collective bargaining units.
Through memoranda of understanding and other agreements with other

DOE site contractors, ORAU provides postgraduates, students, and
employees that work at other DOE sites. Pursuant to specific requirements
of the ORISE contract, these individuals must follow the work practices and
WSHPs established by these other sites and are under the control of the
respective contractor at those sites. See Contract DE-AO05-06OR23100,
Clause H.3. Also, if contractor employees from other sites are used at
ORISE, these employees will be required to follow ORAUs WSHP as noted
in the Visitor and Subcontractor Handbook.
5.3.3 Program Updates
ORAU will submit an update to the appropriate DOE field element for
approval whenever a significant change or addition to the program is made.
A change will be submitted to DOE if a hazard associated with a change in
the worksite or processes, or any newly recognized hazards, are not
effectively controlled by the measures in the currently approved WSHP.
Changes will not be implemented until approved. ORAU will submit annually
either an updated WSHP for approval or a letter stating that no changes are
necessary in the current program in advance of the anniversary of the
previous approval.
5.4 Implementation (10 CFR 851.12)

In its implementation of 10 CFR 851, ORAU will take all necessary protective actions
that may be necessary consistent with both the letter and the spirit of the regulation to
ensure the adequate protection of its workers. This will include the implementation
and maintenance of a written worker protection program that provides a place of
employment free from recognized hazards that are causing or are likely to cause death
or serious physical harm to employees. This is stated in ESH-100.
5.5 Compliance (10 CFR 851.13)

ORAU will achieve compliance with the provisions of 10 CFR 851 by no later than
May 25,2007, or earlier as determined by DOE. This is stated in ESH-100.
5.6 Worker Protection Goals and Objectives, Management Responsibilities,

Worker Rights and Responsibilities, and System to Ensure Compliance with
Established Work Practices (10 CFR 851.20)
May 2007 (Rev. 1) H

The ORAU Safety Council annually prepares an emphasis plan for the following year.
This plan is published as the ES&H Thrust document and is used as an institutional
planning guide for ISMS implementation. Each item included in the Thrust
documents has been expanded with itemized expectations. These expectations serve
as a plan of action and a guide for assessing program and department performance.
The assessments are shared with all employees on ORAUs Safety 1st intranet site.
Management responsibilities, worker rights and responsibilities, and systems to ensure

compliance with established work practices are addressed in ESH-100. Individual
WSHP responsibilities within the ES&H office are assigned by the ES&H director
according to the individual's knowledge and area of expertise. The ES&H director
assesses the individual's performance every six months. This method of individual
performance is documented through the ORAU Individual Performance Plan as
stated in policy ORAU Policy and Procedure HR-925, Performance Management.
As required by 10 CFR 851, required program posters have been physically placed on
official bulletin boards and on electronic Web sites accessible to all workers.
57 Hazard Identification and Assessment (10 CFR 851.21)

Hazard identification and assessment begins with ESH-100, which directs the use of
ISMS in all daily operations. ORAU managers ensure that hazards are addressed at all
stages of work planning and performance. At the institutional level, all known hazards
with a potential to impact ORISE operations have been assessed and analyzed. The
results are listed in the ORAU/ORISE Hazards Survey. This comprehensive
assessment is used as a building-specific tool for the evaluation, design and control of
potential hazards that could adversely impact workers, the public, or the environment
with a prioritization given to risk as determined by the ORISE SMEs.
The Hazards Survey serves a two-fold purpose. It is an inventory of potential sources

of occupational exposure and environmental damage. It also serves as a planning
guide for emergency preparedness and response actions. The Hazards Survey provides
a basis for the individual procedures and plans in the ORAU Health <& Safety Manual
Additionally, the Industrial Hygiene Monitoring Procedure uses a risk-based, quantitative
method to obtain baseline information on workers who are potentially exposed to
chemical or physical worlq>lace hazards. Potential exposure situations are assessed,
monitored if necessary, documented, and recorded. Employees have the right to
observe any monitoring or measuring of operations, be provided with the results and
explanation of their own results, and promptly receive notification of overexposure as
described in ORAUs Health & Safety Manual, Industrial Hygiene Monitoring Procedure.
Operations are then evaluated to establish procedures or make adjustments to current
ones. When modifications are made to existing facilities and/or equipment, or in the
design of new facilities, the ES&H office along with FID work with Procurement
Services under the Subcontract Safety Clause Matrix to identify potential problems and
hazards associated with the modifications.
At the program and department level, the primary method used to identify hazards is
contained within each work unit's ISMS plan; presently, there are 20 unit plans.
May 2007 (Rev. 1) 12

These plans are tailored to the facilities and circumstances of the work that is
performed, and each program/department lists its own potential hazards. In areas
where hazardous materials are stored or used, inventories are maintained to ensure
that Material Safety Data Sheet (MSDS) collections are complete, current, and readily
accessible to all employees. Postings are required for all areas where radiological
substances and hazardous materials are stored or used. Additionally, ES&H SMEs
must approve the purchase of all chemical and radiological materials, as stated in the
Procurement Services and Guidelines Manual. Whenever there is a need to coordinate safety
and radiological interests, the ES&H department employs the Hazardous Work
Authorisation Procedure (HWA) as outlined in the ORAU Health & Safety Manual. The
intent of the HWA is to provide a comprehensive permit to cover all types of
hazardous work at ORAU in accomplishing the goals of ESH-100. The HWA
combines and includes the following permits: Radiation Work Permit (RWP),
Industrial Hygiene Work Permit (IHWP), Confined Space Entry Permit (CSEP), and
Burn Permit.
At the activity level, workers use JHAs extensively. Presently, there are 140 JHAs
covering work performed at ORISE. JHAs are prepared, reviewed and validated in
accordance with provisions contained within the Job Hazard Analysis Procedure located
in the ORAU Health <& Safety Manual. Copies of JHAs are available to all employees
electronically, and hard copies are maintained where deemed appropriate.
Facilities that will be permanently closed, demolished, or subject to title transfer are a
rare occurrence at ORISE, yet represent special circumstances. In the event that
ORISE has a facility that comes under this categorization, ORAU will implement
appropriate abatement controls under the ORAU Health & Safety Manual and through
the appropriate channels within the scope of the ORAU Procurement Services and
Guidelines Manual. ORAU will submit to the appropriate DOE field element a list of
closure facility hazards and the established controls within 90 days after identifying
such hazards.
Finally, the ES&H office performs monthly statistical analyses of accident and near-
miss reporting data and compares this information with specific DOE targets used
across the DOE complex. This information is used to predict potentially hazardous
trends in order to prevent recurrence.
Hazard Prevention and Abatement (10 CFR 85122)

Hazard prevention and abatement is an integral component of the ORAU WSHP in
order to protect workers from potential and/or current hazards. This program
incorporates the core functions of the ISMS program as established under ESH-100.
After hazards have been identified and prioritized according to risk using the
ORAU/ORISE Hazards Survey, the IH Monitoring Procedure, and the HWA, they are
assessed for all stages of work to be completed.
As much as is possible, hazards are eliminated from the workplace. When this is not
possible, hazards are mitigated to the greatest degree possible through the use of the
OSHA-endorsed hierarchy of engineering and administrative controls. These include
the substitution with less hazardous materials, specialized ventilation, engineered
May 2007 (Rev. 1) 13

systems, and procedural controls. Personal protective equipment (PPE) is used
appropriately as directed in the ORAU Health <& Safety Manual, but not as a primary or
exclusive control for hazard mitigation.
As mentioned previously in the Hazard Identification and Assessment section, JHAs

are used extensively both to identify hazards and to implement controls for ongoing
work for potentially hazardous activities. Work permits are used to analyze all work
performed by Facilities Management Services (FMS), which is a sub-unit of FTD;
subcontractors; and others to document required safety controls. Additionally, more
rigorous project-specific health and safety plans are developed for the same purpose
on the larger FMS projects. All employees are required to adhere to established safety
policies, procedures and JHAs. As determined by SMEs, other safety controls are
sometimes used. These include the use of radiation monitors/dosimeters, continuous
air monitoring devices, fire watches, elevated work watches, and the requirement for
conducting some work activities during off-normal business hours. Finally, all
operations are conducted with long-term consideration and job-specific planning for
environmental protection and preservation.
In addition to the above, FMS management, in conjunction with affected employees,

has developed a number of departmental safety procedures aimed at addressing
unique or particularly hazardous work activities. Examples are procedures FMS-1, Safe
Electrical Work Practices and FMS-2, Lockout ITagout. Also, FMS ensures that all
employees and subcontractors are trained, experienced, skilled, and have the proper
tools available to conduct their assigned work in a safe and efficient manner. To this
end, resources for employee training, new and replacement tool purchases, and
employee PPE are all factored into departmental operating budgets. Prospective
subcontractors are required to provide for these items as part of their contract bids or
bid proposals. All employees are encouraged to take an active role in the budgeting
process by forwarding recommendations for improved tools and other safety
suggestions to their respective team leaders or to FMS management.
"When new work is planned or when work that is presently being performed is
modified, managers are required to complete and submit an ISM Pre-Job Hazard
Checklist form. This form identifies the basic expected hazards that would be found
when the work is being performed. This must be completed before beginning any
work that is not addressed in the program or department's ISMS plan. The function
of the ISM Pre-Job Hazard Checklist form is to serve as a hazards inventory only and
not as a plan or a work process control document. If a plan is required due to the
potential hazards involved, the ISM Plan for New or Modified Work or a formal health
and safety plan is also required. These plans are used to describe individual work
process controls and to prioritize and implement abatement actions according to the
potential risks. Also, if an individual health and safety plan or ISM Plan for New or
Modified Work is required, individual procedures in the ORAU Health & Safety Manual
are used to provide procedural instruction for hazard prevention.
As an integral and parallel function of the hazard abatement process, Procurement

Services uses, as a part of the Subcontract Safety Clause Matrix, administrative controls
that address hazards when the needs for equipment, products or services are
presented.
May 2007 (Rev. 1) 14

5.9 Safety and Health Standards, including additional standards determined to be
needed beyond those specified (10 CFR 851.23)
Gty of Oak Ridge Code of Ordinances, Title 7, Fire Protection
5.10 Applicable Functional Areas (10 CFR 851.24)
5.10.1 Construction Safety (Appendix Q
5.10.2 Fire Protection (Appendix Q
5.10.3 Explosive Safety (Appendix Q
5.10.4 Pressure Safety (Appendix Q
5.10.5 Fire Arms Safety (Appendix Q
5.10.6 Industrial Hygiene (Appendix Q
5.10.7 Biological Safety (Appendix Q
5.10.8 Occupational Medicine (Appendix Q
5.10.9 Motor Vehicle Safety (Appendix Q
5.10.10 Electrical Safety (Appendix Q
5.10.11 Other Functional Areas Needed to Address Workplace Hazards
5.10.12 Chronic Beryllium Disease Prevention Program (CBDPP) 10 CFR 850
5.11 Training and Information (10 CFR 851.25)

ORISE is committed to ensure workers are appropriately trained in safety and health
hazards and worker protection. Responsibilities and accountability for training are
described in ESH-100. Line management is responsible to ensure that staff members
are technically competent to perform their assigned duties. ORISE establishes clear
roles and responsibilities, which are then translated into training and qualification
requirements.
Each ORISE worker has an individualized Required Training Checklist that is

reviewed and revised annually to ensure that job qualifying training is completed.
Training is specifically required in all job development roles and responsibilities as
described in individual performance plans. Specific procedures as outlined in the
ESH-100 and JHAs. Overall responsibility for training of personnel is governed by
HR-810.
Specific training may not be required for all employees. The number and type of
training programs required for an employee depends upon the job/task that the
employee performs. Initial required training for all employees includes ES&H
Orientation, General New Employee Orientation, and Program/Department
Orientation. This training is conducted on the day of sign up. Provisions for periodic
training to ensure adequate knowledge of health and safety issues or when specific
conditions change are provided through individual procedures and in specific parts of
May 2007 (Rev. 1) 15

the ORA U Health and Safety Manual.
Training for those individuals who have worker safety and health responsibilities are
provided in specific job descriptions and individual performance plans as outlined in
HR-810, Attachment 1, Human Resources Development Guidelines.
5.12 Recordkeeping and Reporting (10 OFR 851.26)
ORISE is committed to the accurate and complete reporting of worker safety and
health information in accordance with established guidelines. These processes include
the following:
• DOE Computerized Accident and Incident Reporting System (CAIRS) data

reporting and trending of injury and illness reports consistent with DOE M
231.1 1A.
• Occurrence Reporting Processing System (ORPS) reporting of identifying
occurrences.
• Lessons learned submission of significant events and processes as required

per DOE Order 225.1 A.
• Records management practices as contractually identified.
• Maintenance of hazard inventory information, hazard assessments, MSDSs,
and chemical and radiological exposure measurements.
ORISE staff members who are responsible for these reporting processes are required
to maintain the current knowledge required to conduct these operations.
Recordkeeping and reporting responsibilities are assigned to the ES&H director in
ESH-100. Provisions for ensuring the completion of investigations for all work-
related accidents, illnesses, or injuries are described in ESH-100 and in the ORAU
Health & Safety Manual procedure Reporting On-the-Job Injuries and Near Misses. Specific
retention of these records is governed by ORAU Policy and Procedure FM-800, Records
Management. Information concerning the WSHP and related documentation is
available to all employees and others as applicable as described in ESH-100.
5.13 Reference Sources (10 CFR 851.27)

Within the 10 CFR 851 rule, several materials and standards are incorporated by
reference. These references are included in the ORAU WSS and are used as applicable
intheORAUWSHP.
6» Program Assessments
DOE-VPP/ISMS Self-Assessments are completed annually and forwarded to DOE-
ORO in February of each year, as stated in ESH-100.
?• Variance Process
When 10 CFR 851 was promulgated in February 2006, ORAU formed a working
group to guide and assist management in implementing the rule. The working group
comprises a cross-section of employees. Membership of the working group includes
May 2007 (Rev. 1) 16

ES&HSMEs, members of management, legal counsel, Procurement Services staff
members, and impacted workers. The working group met intermittently from July
2006 until April 2007. At these meetings, the group discussed that ORAU would be
seeking a permanent variance to 10 CFR 851 Appendix A.8. Working group members
had the opportunity to assist in developing this permanent variance request.
The matter was discussed on several occasions at ORAU Safety Council meetings. An
announcement of the permanent variance request was sent by letter to all current
potentially impacted subcontractors.
ORAU is seeking a permanent variance from the Occupational Medicine

requirements for ORISE-affected subcontractors as contained in 10 CFR 851,
Appendix A, Worker Safety and Health Functional Areas. This appendix establishes
the mandatory requirements for implementing the applicable functional areas required
by 10 CFR 851.24. Appendix A, Section 8, Occupational Medicine contains extensive
requirements for establishing and providing comprehensive occupational medicine
services to workers employed at a covered work place who (1) work on a DOE site
for more than 30 days in a 12-month period; or (2) are enrolled for any length of time
in a medical or exposure monitoring program required by this rule and/or any other
applicable federal, state or local regulation or other obligation. In accordance with the
rule's scope and applicability boundaries, the prime contractor is required to provide
or flow down the requirements for comprehensive occupational medical services to
its subcontractors at all levels.
The requirements for a comprehensive occupational medicine program are contained

in Appendix A.8 and represent precisely the requirements that have been in the DOE
Order 440.1A, Contractors Requirements Document (CRD) since March 27,1998.
ORAU has been implementing an effective, comprehensive occupational medicine
program in accordance with the DOE Order 440.1 A requirements for its contractor
employees for many years. ORISE subcontractors have never participated in ORISE's
occupational medicine program. The scope of the ORISE contract does not include
provisions for ORAU to purchase medical malpractice insurance, which would be
necessary if subcontractors were provided occupational medical services. Without
medical malpractice insurance, ORALTs contract medical staff could be exposed to
medical malpractice claims from subcontractor companies and their employees.
After approval of this variance request, ORISE will require through contract terms,
conditions and special requirements that all subcontractors at any tier have an
occupational medicine program under the direction of a licensed physician meeting
the credentials requirements of Appendix A.8(b) and personnel providing health
services meeting the credentials requirements of Appendix A8(c). A written
description of the subcontractor's occupational medicine program, including proof of
staff credentials, will be a required submission under the subcontract. Each
subcontractor's occupational medicine program contents will be determined by their
occupational medicine director and based on the subcontractor's scope of work and
associated hazards.
ORISE is fully implementing the requirements of 10 CFR 851 Appendix A.8,

Occupational Medicine for prime contractor employees and is protective against
May 2007 (Rev. 1) 17

identified hazards. The subject of this variance request is the implementation of the
occupational medicine requirements for ORISE subcontractors, at all sub-tier levels,
for the Appendix A.8(d) through (k) requirements. Once approved, this variance
request will allow each subcontractor's credentialed occupational medicine provider to
determine what is required to provide for a safe and healthful workplace in
accordance with the rule.
Pending the approval of this variance request in order to avoid non-compliance with
10 CFR 851, ORISE will temporarily include the 10 CFR 851 covered subcontractors
under the ORISE Occupational Health program as provided for regular full-time
employees.
8. Appendices
8.1 Acronyms, Abbreviations, and Initialisms

See Appendix E
8.2 List of Memorandum of Understandings & Agreements

None
8.3 Implementation Matrix for 10 CFR Part 851

See Appendix A.
8.4 List of Applicable Workplace Safety and Health Requirements from 10 CFR
851, Section 851.23 and Section 851.27
See Appendix B.
8.5 List of Other Applicable Workplace Safety and Health Requirements

Others as identified in Appendix B.
8.6 Lists of Closure Facility Hazards and Controls (10 CFR 851.21 (b))
None identified.
8.7 Equivalencies Granted Prior to Promulgation of the Rule in accordance with

the Equivalence Provisions of the Codes or Standards (10 CFR 851.23)
None.
May 2007 (Rev. 1) 18

Appendix A
Crosswalk of 10 CFR 851 Requirements to ORISE Implementing
Documents*
May 2007 (Rev. 1) 19

May 2007 (Rev. 1) 20
Nothing in this part shall be construed to limit or otherwise affect contractual obligations of a contractor to comply with contractual
13 NA
requirements that are not inconsistent with the requirements of this part.
(a) Management responsibilities. Contractors are responsible for the safety and health of their workforce and must ensure that contractor
management at a covered workplace:
(a)(l) Establish written policy, goals, and objectives for the worker safety and health program;
WSHPD
(a)(2) Use qualified worker safety and heakh staff (e.g. QH, CSP) to direct and manage the program;
(a)(3) Assign worker safety and health program responsibilities, evaluate personnel performance, and hold personnel accountable for worker
ORAU/ORISE Policy & Procedure ESH-100,
safety and health performance;
Integrated Safety Management
(a)(4) Provide mechanisms to involve workers and their elected representatives in the development of the worker safety and health program
goals, objectives, and performance measures and in the identification and control of hazards in the workplace;
1SMSPD
(a)(5) Provide workers with access to information relevant to the worker safety and health program;
20
(a)(6)£stablish procedures for workers to report without reprisal job-related fatalkies, injuries, illnesses, incidents, and hazards and make
ORAU/ORISE Safety 1* Website
recommendations about appropriate ways to control these hazards;
(a)(7) Provide prompt response to such reports and recommendations;
ORAU/ORISE Health and Safety Manual
(a)(8) Provide for regular communication with workers about workplace safety and health matters;
Employee Health & Safety Concerns
(a)(9) Establish procedures to permit workers to stop work or decline to perform an assigned task because of a reasonable belief that the
Reporting On-the-Joh Injuries and Near misses
task poses an imminent risk of death, serious physical harm, or other serious hazard to workers, in circumstances where the workers believe
Suspend, Stop and Restart Work
that there is insufficient time to utilize normal hazard reporting and abatement procedures; and
(a)(lO) Inform workers of their rights and responsibility by the appropriate means, including posting the DOE-designated Worker
Protection Poster in the workplace where it is accessible to all workers.
May 2007 (Rev, 1) 21

*#!i^^
(b) Worker rights and responsibilities Workers must comply with the requirements of this part, including the worker safety and heakh
program, which are applicable to their own actions and conduct. Workers at a covered workplace have the right, without reprisal, to:
(b)(l) Participate in activities described in this section on official time;
(b)(2) Have access to: WSHPD
(b)(2)(i) DOE safety and health publications;
(b)(2)(ii) The worker safety and heakh program for the covered workplace; ORAU/ORISE Safety 1« Website
(b)(2)(iii) The standards, controls, and procedures applicable to the covered workplace;
(b)(2)(iv)Tbe safety and health poster that informs the worker of relevant rights and responsibilities; ORAV/ORISE Policy & Procedure ESH-100,
(b)(2)(v) Limited information on any recordkeeping log (OSHA Form 300). Access is subject to Freedom of Information Act requirements Integrated Safety Management
and restrictions; and
(b)(2)(vi) The DOE Form 5484.3 (the DOE equivalent to OSHA Form 301) that contains the employee's name as the injured or ill worker, ORA U/O1USE Industrial I lygene Monitoring
(b)(3) Be notified when monitoring results indicate the worker was overexposed to hazardous materials; Procedure
20
(b)(4) Observe monitoring or measuring of hazardous agents and have the results of their own exposure monitoring;
(b)(5) Have a representative authorized by employees accompany the Director or his authorized personnel during the physical inspection of ORAU/ORISE Health and Safety Manual
the workplace for the purpose of aiding the inspection. When no authorized employee representative is available, the Director or his Employee Health & Safety Concerns
authorized representative must consult, as appropriate, with employees on matters of worker safety and health; Reporting On-the-Job Injuries and Near misses
(b)(6) Request and receive results of inspections and accident investigations; Suspend, Stop and Restart Work Procedure
(b)(7) Express concerns related to worker safety and heakh; Occurrence Reporting Procedure
(b)(8) Decline to perform an assigned task because of a reasonable belief that, under the circumstances, the task poses an imminent risk of
death or serious physical harm to the worker coupled with a reasonable belief that there is insufficient time to seek effective redress through
normal hazard reporting and abatement procedures; and
(b)(9) Stop work when the worker discovers employee exposures to imminently dangerous conditions or other serious hazards; provided
that any stop work authority must be exercised in a justifiable and responsible manner in accordance with procedures established in the
approved worker safety and heakh program.
21 Hazard identification and assessment
(a) Contractors must establish procedures to identify existing and potential workplace hazards and assess the risk of associated workers
WSHPD
injury and illness. Procedures must include methods to:
(a)(l) Assess worker exposure to chemical, physical, biological, or safety workplace hazards through appropriate workplace monitoring;
(a)(2) Document assessment for chemical, physical, biological, and safety workplace hazards using recognized exposure assessment and
testing methodologies and using of accredited and certified laboratories;
21 (a)(3) Record observations, testing and monitoring results;
ISMSPD
a)(4 Analyze designs of new facilities and modifications to existing facilities and equipment for potential workplace hazards;
a)(5 Evaluate operations, procedures, and facilities to identify workplace hazards;
ORAU/ORISE Industrial Hygiene Monitoring
a)(6 Perform routine job hazard analyses;
Procedure
a)(7) Review site safety and heakh experience information; and
a)(8) Consider interaction between workplace hazards and other hazards such as radiological hazards
May 2007 (Rev. 1) 22

May 2007 (Rev. 1) 23
May 2007 (Rev. 1) 24
lmftlei
Procurement Services and Guidelines Manual
FMA-5 - New Equipment Identification and

M
23 a (a) Contraaors must comply with the following safety and heakh standards that are applicable to the hazards at their covered workplace: NA
23 a (a)(l) 10 CFR 850, "Chronic Beryllium Disease Prevention Program.'
WSHPD

(a)(2) Title 29 CFR, Parts 1904.4 through 1904.11,1904.29 through 1904.33; 1904.44, and 1904.46, "Recording and Reporting Occupational
23 a
Injuries and Illnesses." ORAU/ORISE Health and Safety Manual
Reporting On-the-Job Injuries and Near misses
Procedure
Workers Compensation Procedure
WSHPD

23 a (a)(3) Title 29 CFR, Part 1910, "Occupational Safety and Iieakh Standards," excluding 29 CFR 1910.1096, "Ionizing Radiation." Integrated Safety Management
ISMSPD
23 a (a)(4) 29 CFR 1915, Shipyard Employment NA
23 a (a)(5) 29 CFR 1917, Marine Terminals NA
23 a (a)(6) 29 CFR 1918, Safety and Health Regulations for Longshoring. NA
May 2007 (Rev. 1) 25

May 2007 (Rev. 1) 26
May 2007 (Rev. 1) 27
Section
General Requirements
ORAU/ORTSE Health and Safety Manual

Electrical Safety Procedures
Facilities Maintenance Procedures
23 a (a)(13) National Fire Protection Association (NFPA) 70, "National Electrical Code," (2005) (incorporated by reference, see § 851.27). FMS Documents
FMS-1 - Safe Electrical Work Practices
FMS-2 - Lockout f Tasput
FMS-5 - New Equipment Identification and
Information Requirements
ORAU/OKISE Health and Safety Manual

FMS Documents
23 a (a)(14) NFPA 70E, "Standard for Electrical Safety in the Workplace," (2004) (incorporated by reference, see § 851.27).
FMS-2 ■ Lockout I Tagout
ORAU/ORISE Visitor and Subcontractor Safety

Handbook
May 2007 (Rev. 1) 28

May 2007 (Rev. 1) 29
385; j;i
WSHPD

(a) Recordkeeping. Contractors must:
(a)(l) Establish and maintain complete and accurate records of all hazard inventory information, hazard assessments, exposure
measurements, and exposure controls.
ISMSPD
(a)(2) Ensure that the work-related injuries and illnesses of its workers and subcontrartor workers are recorded and reported accurately and
26 consistent with DOE Manual 231.1-1 A, Environment, Safety and Health Reporting Manual, September 9,2004 (incorporated by reference,
see § 851.27).
Procedure
(a)(3) Comply with the injury and illness recordkeeping and reporting sections of the health standards in 851.23 unless otherwise directed in
DOE Manual 231.1-1A.
(a)(4) Not conceal nor destroy any information concerning non-compliance or potential noncompliance with the requirements of this part.
Employee Health & Safety Concerns
Reporting On-tbe-Job Injuries and Near misses
Workers Compensation Procedure
ISMSPD
ORAU/ORISE Policy & Procedure ESII-100,


(b) Reporting and investigation. Contractors must:
Lessons Learned
26 (b)(l) Report and investigate accidents, injuries & illnesses; and
(b)(2) Analyze related data for trends and lessons learned (reference DOE Order 225.1 A, Accident Investigations, November 26,1997).
ORAU Policy & Procedure GP-1100, Occupational
Medicine

Reporting On-the-Job Injuries and Near misses
May 2007 (Rev. 1) 30

(a) Materials incorporated by reference.
(a)(l) General. The following standards which are not otherwise set forth in part 851 are incorporated by reference and made a part of part
851. The standards listed in this section have been approved for incorporation by reference by the Director of the Federal
Register in accordance with 5 US.G 552(a) and 1 CFRpart 51.
(a)(2) Availability of standards. The standards incorporated by reference are available for inspection at:
(a)(2)(i) National Archives and Records Administration (NARA). For more information on the availability of this material at NARA, call
202-741-6030, or go to: http://www.archives.gov/ federalregister/ codeof fedendregulations/ ibr_locations.html
(a)(2)(ii) US. Department of Energy, Office of Environment, Safety and Health, Forrestal Building, 1000 Independence Ave., SW.,
27 Washington, DC 20585. NA
(a)(2)(iii) American National Standards Institute Headquarters, 25 West 43rd Street, New York, NY 10036. Telephone number: 12-642-
4980, or go to: http://www.ansLorg.
(a)(2)(iv) National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169. Telephone: 617 770-3000, or go to:
http://www.nfpa.org.
(a)(2)(v) American Conference of Governmental Industrial Hygienist (ACGIH), 1330 Kemper Meadow Drive, Cincinnati, OH 45240.
Telephone number 513-742-2020, or go to: http://www.acgih.org.
(a)(2)(vi) American Society of Mechanical Engineers (ASME), P.O. Box 2300 Fairfield, Nf 07007. Telephone: 800-843-2763, or got to:
http://www.asme.org.
27 (b) Ust of standards incorporated by reference NA

Respiratory Protection Program
27 b (b)(l) ANSI Z88.2, American National Standard Practices for Respiratory Protection, 2004.
Procedure
27 b (b)(2) ANSI Z136.1, Safe Use of Lasers, 2000. NA

27 b Respiratory Protection Program
(b)(3) ANSI Z49.1, Safety in Welding, Cutting and Allied Processes, 1999.
Hazardous Work Authorisation
PPB Procedure
May 2007 (Rev. 1) 31

May 2007 (Rev. 1) 32
May 2007 (Rev. 1) 33
May 2007 (Rev. 1) 34
May 2007 (Rev. 1) 35
OMSE Implementing Documenfe^
Section
WSHPD
(d) The construction contractor must prepare a written construction project safety and health plan to implement the requirements of this
0RAU/0R1SE Policy & Pwcedun ESI1-100,
section and obtain approval of the plan by the construction manager prior to commencement of any work covered by the plan. In the
App plan, the contractor must designate the individual(s)responsible for on-site implementation of the plan, specify qualifications for those
A.1 individuals, and provide a list of those project activities for which subsequent hazard analyses are to be performed. The level of detail
ISMSPD
within the construction project safety and health plan should be commensurate with the size, complexity and risk level of the construction
project. The content of this plan need not duplicate those provisions that were previously submitted and approved as required by § 851.11.
Procurement Services and Guidelines Manual -
Subcontract Safely Clause Matrix
May 2007 (Rev. 1) 36

ORAU/ORISE Emergency Preparedness Manual

Fire Safety Procedures
Installation & Maintenance ofElectric Space
Heatersfor Personal Use
Storage Practicesfor Flammable/Combustible
Liquids
Facilities Maintenance Procedure
(a) Contractors must implement a comprehensive fire safety and emergency response program to protect workers commensurate with the General Storage Practices
nature of the work that is performed. TTiis includes appropriate facility and site-wide fire protection, fire alarm notification and egress
A.2 features, and access to a fully staffed, trained, and equipped emergency response organization ORA U/ORISE Visitor and Subcontractor Safety
that is capable of responding in a timely and effective manner to site emergencies. Handbook
ORAU/ORISE Spill Prevention, Control and

Countermeasures Plan
FMS Documents
FMS-4 - Compensatory Actionsfor Fire System
FMS-5 - Hazardous Work Permitting,
ORAU/ORISE Emergency Preparedness Manual
ORA U/ORISE Health and Safety Manual

Fire Safety Procedures
Installation & Maintenance of Electric Space
(b) An acceptable fire protection program must include those fire protection criteria and procedures, analyses, hardware and systems, Heatersfor Personal Use
App
apparatus and equipment, and personnel that would comprehensively ensure that the objective in paragraph 2(a) of this section is met. Storage Practicesfor Flammable/ Combustible
A-2
This includes meeting applicable building codes and National Fire Protection Association codes and standards. Liquids
General Storage Practices

Handbook
May 2007 (Rev. 1) 37

0RAU/0R1SE Spill Prevention, Control and
Countermeasures Plan
FMS Documents
FMS-t - Safe Electrical Work Practices
FMSA - Compensatory Actionsfor Fire System
FMS-5 - Hazardous Work Permitting
AppA
App
(a) Contractors responsible for the use of explosive materials must establish and implement a comprehensive explosives safety program. NA
A3
(b) Contractors must comply with the policy and requirements specified in the DOE Manual 440.1-1 A, DOE Explosives Safety
App
Manual, Contractor Requirements Document (Attachment 2), January 9,2006 (incorporated by reference, see § 851.27). A Contractor may NA
A3
choose a successor version, if approved by DOE.
App (c) Contractors must determine the applicability of the explosives safety directive requirements to research and development laboratory
NA
A3 type operations consistent with the DOE level of protection criteria described in the explosives safety directive.
AppA Pressure Safety
FTD Preventative Maintenance Schedule Procedures

(a) Contractors must establish safety policies and procedures to ensure that pressure systems are designed, fabricated, tested, inspected,
maintained, repaired, and operated by trained and qualified personnel in accordance with applicable and sound (ORAU bos no boilers operating at or above 15psi,
A4
engineering principles. which makes most identified codes and standards
N/A)
(b) Contractors must ensure that all pressure vessels, boilers, air receivers, and supporting piping systems conform to:
(b)( 1) The applicable American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (2004); sections I through
section XTI including applicable Code Cases (incorporated by reference, see § 85127).
(b)(2) The applicable ASME B31 (Code for Pressure Piping) standards as indicated below; and or as indicated in paragraph (b)(3) of this FTD Preventative Maintenance Schedule Procedures
section:
(b)(2)(i) B31.1— 2001-Power Piping, and B31.1a- 2002- Addenda to ASME B31.1- 2001 (incorporated by reference, see § 851.27);
A.4
(b)(2)(ii) B31.2—1968—Fuel Gas Piping (incorporated by reference, see § 851.27); (ORAU has no boilers operating at or above 15psi,
(b)(2)(iii) B31.3- 2002- Process Piping (incorporated by reference, see § 851.27); which makes most identified codes and standards
(b)(2)(iv) B31.4— 2002— Pipeline Transportation Systems for Liquid Hydrocarbons and Other liquids (incorporated by reference, see § N/A)
85U7);
(b)(2)(v) B31.5- 2001- Refrigeration Piping and Heat Transfer Components, and B31.5a- 2004, Addenda to ASME B31.5- 2001
May 2007 (Rev. 1) 38

May 2007 (Rev. 1) 39
May 2007 (Rev. 1) 40
e) Contractors must implement procedures related to firearms training, live fire range safety, qualification, and evaluation activities,
including procedures requiring that:
(e)(l) Personnel must successfully complete initial firearms safety training before being issued any firearms. Authorization to remain in
armed status will continue only if the employee demonstrates the technical and practical knowledge of firearms safety semiannually;
(e)(2) Authorized armed personnel must demonstrate through documented limited scope performance tests both technical and practical
knowledge of firearms handling and safety on a semi-annual basis;
(e)(3) All firearms training lesson plans must incorporate safety for all aspects of firearms training task performance standards. The lesson
plans must follow the standards set forth by the Safeguards and Security Central Training Academy's standard training programs;
App
(e)(4) Firearms safety briefings must immediately precede training, qualifications, and evaluation activities involving live fire and/or NA
A.5
engagement simulation systems;
(e)(5) A safety analysis approved by the Head of DOE Field Element must be developed for the facilities
and operation of each live fire range prior to implementation of any new training, qualification, or evaluation activity.
Results of these analyses must be incorporated into procedures, lesson plans, exercise plans, and limited
scope performance tests;
(e)(6) Firing range safety procedures must be conspicuously posted at all range facilities; and
(e)(7) live fire ranges, approved by the Head of DOE Field Element, must be properly sited to
protect personnel on the range, as well as personnel and property not associated with the range.
(f) Contractors must ensure that the transportation, handling, placarding, and storage of munitions conform to the applicable DOE
A.5 requirements.
Industrial Hygiene
WSHPD
ORA U/0R1SB Policy & Procedure ESH- WO,

ISMSPD
Contractors must implement a comprehensive industrial hygiene program that includes at least the following elements:
A.6
0RAU/01USH Industrial Hygiene Monitoring
Procedure
ORAU/ORJSE Health and Safety Manual

PPE Procedure
Respiratory Protection Program Procedure
May 2007 (Rev. 1) 41

Iia^ard Q^otntnuntcation I rografft
ORAU/ORISE Health and Safely Manual

App (a) Initial or baseline surveys and periodic resurveys and/or exposure monitoring as appropriate of all work areas or operations to identify
A6 and evaluate potential worker health risks; ORAU/ORISB Industrial Hygiene Monitoring
Procedure
WSHPD

(b) Gooidination with planning and design personnel to anticipate and control health hazards that proposed facilities and operations ISMSPD
A.6 would introduce;
Procedure

WSHPD
ORAU/ORISE Policy & Prvcedurv ESI1-100,

ISMSPD
(c) Coordination with cognizant occupational medical, environmental, health physics, and work planning professionals;
A6
Procedure
May 2007 (Rev. 1) 42

ORAU/ORISE Industrial Hy&ene Monitoring
Procedure

(d) Policies and procedures to mitigate the risk from identified and potential occupational carcinogens;
A6 Asbestos Management
Chemical Hygiene Plan
WSHPD

ISMSPD
ORA U/ORISE Industrial Hygiene Monitoring

Procedure
(e) Professionally and technically qualified industrial hygienists to manage and implement the industrial hygiene program; and
A.6

ORAU/ORISE Policy & Procedure IJR-400,

Staging
ORAU/ORISE Policy & Procedure HR-810,

Human Resources Development
May 2007 (Rev. 1) 43

(f) Use of respiratory protection equipment tested under the DOE Respirator Acceptance Program for Supplied-air Suits (DOE Technical
Standard-1167-2003) when National Institute for Occupational Safety and Heakh- approved respiratory protection does not exist for
App
DOE tasks that require such equipment. For security operations conducted in accordance with Presidential Decision Directive 39, U.S. NA
A6
POLICY ON OOUNTER TERRORISM, use of Department of Defense military type masks for respiratory protection by security
personnel is acceptable.
Biological Safety
(a) Contractors must establish and implement a biological safety program that:
(a)(l) Establishes an Institutional Biosafety Committee (IBQ or equivalent. The IBC must:
(a)(l)(i) Review any work with biological etiologic agents for compliance with applicable Centers for Disease Control and Prevention
(CDQ, National Institutes of Health (NIH), World Health Organization (WHO), and other International, Federal, State, and local
guidelines and assess the containment level, facilities, procedures, practices, and training and expertise of personnel; and (a)(l)(ii) Review
the site's security, safeguards, and emergency management plans and procedures to ensure they adequately consider work involving
biological etiologic agents.
(a)(2) Maintains an inventory and status of biological etiologic agents, and provide to the responsible field and area office, through the
laboratory IBC (or ixs equivalent), an annual status report describing the status and inventory of biological etiologic agents and the
biological safety program.
(a)(3) Provides for submission to the appropriate Head of DOE Field Element, for review and concurrence before
App
transmittal to the Centers for Disease Control and Prevention (CDQ, each Laboratory Registration/Select Agent Program registration NA
application package requesting registration of a laboratory facility for the purpose of transferring, receiving, or handling biological select
agents.
(a)(4) Provides for submission to the appropriate Head of DOE Field Element, a copy of each CDC Form EA-101,
Transfer of Select Agents, upon initial submission of the Form EA-101 to a vendor or other supplier requesting or ordering a biological
select agent for transfer, receipt, and handling in the registered facility. Submit to the appropriate Head of DOE Field Element the
completed copy of the Form EA-101, documenting final disposition and/or destruction of the select agent, within 10 days of completion
of the Form EA-101.
(a)(5) Confirms that the site safeguards and security plans and emergency management programs address biological etiologic agents, with
particular emphasis on biological select agents.
(a)(6) Establishes an immunization policy for personnel working with biological etiologic agents based on the evaluation of risk and
benefit of immunization.
May 2007 (Rev. 1) 44

May 2007 (Rev. 1) 45
10CTR851
(f) A record, containing any medical, health history, exposure history, and demographic data collected for the occupational medicine
purposes, must be developed and maintained for each employee for whom medical services are provided. All occupational medical records
must be maintained in accordance with Executive
Order 13335, Incentives for the Use of Health Information Technology. 0RAU/OR1SB Policy e* Ptvcedurv GP-1100,
Occupational Medicine
App (f)(l) Employee medical, psychological, and employee assistance program (EAP) records must be kept confidential, protected from
A.8 unauthorized access, and stored under conditions that ensure their long-term preservation. Psychological records must be maintained
ORAU/ORJSE Policy <& Prvcedure HR-100J,
separately from medical records and in the custody the designated psychologist in accordance with 10 CFR
712.38(b)(2). Employee Assistance Program
(f)(2) Access to these records must be provided in accordance with DOE regulations implementing the Privacy Act and the
Energy Employees Occupational Illness Compensation Program Act
(g) The occupational medicine services provider must determine the content of the worker health evaluations, which must be conducted
under the direction of a licensed physician, in accordance with current sound and acceptable medical practices and all pertinent statutory
and regulatory requirements, such as the Americans with Disabilities Act.
(g)(l) Workers must be informed of the purpose and nature of the medical evaluations and tests offered by the
occupational medicine provider.
(g)0)(0 r^ne purpose, nature and results of evaluations and tests must be clearly communicated verbally and in writing to each worker
provided testing;
(g)(l)(ii) The communication must be documented in the worker's medical record; and
(g)(2) The following health evaluations must be conducted when determined necessary by the occupational medicine
provider for the purpose of providing initial and continuing assessment of employee fitness for duty.
App
(g)(2)(i) At the time of employment entrance or transfer to a job with new functions and hazards, a medical placement evaluation of the
ORAU/ORISB Policy & Procedure GP-1 WO,
individual's general health and physical and psychological capacity to perform work will establish a
A.8 Occttpational Medicine
baseline record of physical condition and assure fitness for duty.
(g)(2)(ii) Periodic, hazard-based medical monitoring or qualification-based fitness for duty evaluations required by
regulations and standards, or as recommended by the occupational medicine services provider, will be provided
on the frequency required.
(g)(2)(iii) Diagnostic examinations will evaluate employee's injuries and illnesses to determine work-relatedness, the
applicability of medical restrictions, and referral for definitive care, as appropriate.
(g)(2)(iy) After a work-related injury or illness or an absence due to any injury or illness lasting 5 or more
consecutive workdays (or an equivalent time period for those individuals on an alternative work schedule), a return
to work evaluation will determine the individual's physical and psychological capacity to perform work and return to duty.
(g)(2)(v) At the time of separation from employment, individuals shall be offered a general health evaluation to establish a
record of physical condition.
(h)The occupational medicine provider must monitor ill and injured workers to facilitate their rehabilitation and safe return to work and to
minimize lost time and its associated costs.
OKA U/OR1SE Policy air Procedure GP-1100,
A.8
(h)(l) The occupational medicine provider must place an individual under medical restrictions when health evaluations indicate that the
Occttpational Medicine
worker should not perform certain job tasks. The occupational medicine provider must notify the worker and contractor management
when employee work restrictions are imposed or removed.
May 2007 (Rev. 1) 46

App (i) Occupational medicine provider physician and medical staff must, on a timely basis, communicate results of health evaluations to ORAU/ORISE Policy & Procedure GP-1100,
A8 management and safety and health protection specialists to facilitate the mitigation of worksite hazards. Occupational'Medicine
(j)The occupational medicine provider must include measures to identify and manage the principal preventable causes of premature
morbidity and mortality affecting worker health and productivity.
(j)(l)The contractor must include programs to prevent and manage these causes of morbidity when evaluations demonstrate their cost ORAU/ORISE Policy & Procedure GP-1100,
A.8 effectiveness. Occupational Medicine
(j)(2) Contractors must make available to the occupational medicine provider appropriate access to information from health, disability,
and other insurance plans (de-identified as necessary) in order to facilitate this process.
ORAU/ORISE Policy & Procedure GP-1100,
(k)The occupational medicine services provider must review and approve the medical and behavioral aspects of employee counseling and
ORAU/ORISE Policy & Procedure HR-100S,
health promotional programs, including the following types:
Employee Assistance Program
(k)(l) Contractor-sponsored or contractor supported EAPs;
(k)(2) Contractor-sponsored or contractor supported alcohol and other substance abuse rehabilitation programs; and
App (k)(3)Contractor-sponsored or contractor supported wellness programs.
Exposure Control Plan for Bloodborne Pathogens
A.8 (k)(4)The occupational medicine services provider must review the medical aspects of immunization programs, blood-borne pathogens
programs, and bio-hazardous waste programs to evaluate their conformance to applicable guidelines.
(k)(5) TTie occupational medicine services provider must develop and periodically review medical emergency response procedures
Employee Assistance Program
included in she emergency and disaster preparedness plans. The medical emergency responses must be integrated with nearby community
emergency and disaster plans.
ORAU/ORISE Policy & Procedure HR-10W,
Drug/Alcohol Free Workplace
Iftlotor VehicleSafety

Motor Vehicle Safety Program
(a) Contractors must implement a motor vehicle safety program to protect the safety and health of all drivers and passengers in Powered Industrial Lift Truck (ForkUft) Safety
App
Government-owned or-leased motor vehicles and powered industrial equipment (Le., fork trucks, tractors, platform lift trucks, and other
A.9
similar specialized equipment powered by an electric motor or an internal combustion engine).
Controlled Substances and Alcohol Use and Testing
Commercial Motor Vehicle Drivers
May 2007 (Rev. 1) 47

Motor Vehicle Safety Program
Powered Industrial IJfi Truck (Forklifi) Safety
App (b)The contraaor must tailor the motor vehicle safety program to the individual DOE site or facility, based on an analysis of the needs of
A.9 that particular site or facility.
Controlled Substances and Alcohol Use and Testing
Commercial Motor Vehicle Drivers
(c) The motor vehicle safety program must address, as applicable to the contractor's operations:
(c)(l) Minimum licensing requirements (including appropriate testing and medical qualification) for personnel operating motor vehicles ORAU/ORISE Health and Safely Manual
and powered industrial equipment; Motor Vehicle Safety Program
(c)(2) Requirements for the use of seat belts and provision of other safety devices; Powered Industrial Lift Truck (ForkUft) Safety
(c)(3)Training for specialty vehicle operators;
A.9 (c)(4) Requirements for motor vehicle maintenance and inspection;
(c)(5) Uniform traffic and pedestrian control devices and road signs; ORAU/ORISE Policy & Procedure HR-1020,
(c)(6) On-site speed limits and other traffic rules; Controlled Substances and Alcohol Use and Testing
(c)(7) Awareness campaigns and incentive programs to encourage safe driving; and Commercial Motor Veliicle Drivers
(c)(8) Enforcement provisions.
mmm
FMS Documents
FMS-1 - Stfe Electrical Work Practices
Contractors must implement a comprehensive electrical safety program appropriate for activities at their she. This program must meet the
FMS-2 - Lockout/ Tagout
A.10 applicable electrical safety code and standards referenced in 851.23.

Handbook
Reserved NA
All
May 2007 (Rev. 1) 48

* Procedures, Program Descriptions, Management Systems Descriptions, Subject Areas, and other operating
procedures listed in the Crosswalk are not incorporated by reference or made a part of this document
May 2007 (Rev. 1) 49

Appendix B
Applicable Worker Safety and Health Requirements
A number of worker safety and health standards contained in 10 CFR 851, Worker Safety and Health
Program are applicable to ORISE managed DOE-owned or -leased facilities.
The following health and safety standards contained in 10 CFR 851.23 are applicable to
ORAU/ORISE-managed facilities.
1) 29 CFR 1904, Recordkeeping and Reporting Occupational Injuries and Illnesses

2) 29 CFR 1910, Occupational Safety and Health Standards,
3) 29 CFR 1926, Safety and Health Regulationsfor Construction
4) American Conference of Governmental Industrial Hygienists (AGGIH) Threshold Limit
Valuesfor Chemical Substances and Physical Agents and Biological Exposure Indices (2005) when
TLVs are lower than permissible exposure limits in 29 CFR 1910
5) American National Standards Institute (ANSI) Z88.2, American National Standardfor
Respiratory Protection (1992)
6) ANSI Z49.1, Safety in Welding, Cutting and Allied Processes section 4.3 and E4.3 (1999;.
7) National Fire Protection Association (NFPA) 70, National Electrical Code (2005)
8) NFPA 70E, Standardfor Electrical Safety in the Workplace (2004)
9) ANSI ZU6.U Safe Use of Lasers (2000)
10) ANSI Z49.1, Safety in Welding, Cutting and Allied Processes section 4.3 and E4.3 (1999;
11) DOE Manual 231.1 - 1A, Environment, Safety and Health Reporting Manual, September 9,2004
Note: The following listing of the generally applicable codes and standards for worker safety and
health in the area of fire safety is provided in the Fire Protection Area. It should be noted that the
applicability of NFPA codes and standards is determined based on specific facility conditions and
operations. Therefore, the list of generally applicable codes and standards does not apply universally
across all ORISE facilities.
1) NFPA1, Uniform Fire Code

2) NFPA 10, Standardfor Portable Fire Extinguishers
3) NFPA 14, Standpipe and Hose Systems
4) NFPA 30, Flammable and Combustible Liquids Code
5) NFPA 30B, Aerosol Products, Manufacture, and Storage
6) NFPA 45, Fire Protection for Laboratories Using Chemicals
7) NFPA 51B, Cutting Welding and Other Hot Work
8) NFPA 54, National Fuel Gas Code
9) NFPA 55, Compressed Gases and Cryogenic Fluids
10) NFPA 58, Liquefied Petroleum Gas Code
11) NFPA 70, National Electrical Code
12) NFPA70E, Electrical Safety in the Workplace
13) NFPA 72, NationalFire Alarm Code
14) NFPA 75, Protection of Information Technology Equipment
15) NFPA 101, Life Safety Code
May 2007 (Rev. 1) 50

Appendix C
Functional Area Descriptions
C.1 Construction Safety
The purpose of the ORISE construction safety program is to assure that all work is performed safely
at all times. It provides a system for identifying and evaluating potential hazards and implementing a
process for controlling them consistent with 29 CFR1926 and related requirements.
Several techniques and communication channels are utilized to identify, report, and document
potential facilities related hazards and conditions with the potential to adversely affect ORISE and
subcontractor employees. First and foremost, all ORAU employees and subcontractors are
encouraged to report potential hazards and potentially unsafe conditions. Individual employee
vigilance and impromptu reporting of this type accounts for a large portion of workplace hazard
identifications. Other, more methodical techniques of identifying and reporting potential workplace
hazards include periodic Site Safety Representative inspections, periodic Facilities Management
Services (FMS) engineering and management inspections, scheduled building inspections,
maintenance mechanic surveillance and reporting as part of routine preventive and corrective
maintenance activities, and frequent customer communications. FMS maintenance mechanics are
fully empowered to mitigate identified deficiencies on-the-spot, which is often the case. Instances of
identified deficiencies, which cannot be handled immediately, are reported either to the Maintenance
Team Leader, Maintenance Service Desk, or to FMS management. ESH subject matter experts also
provide construction site inspections and oversight activities. Any identified deficiencies are logged
into the maintenance work order system for processing, scheduling, and tracking on a priority basis.
FMS team leaders and managers remain heavily involved in the construction safety management
process. The Maintenance Team Leader maintains almost daily contact with all of their employees
and many of their customers. During these visits, safe conduct of operations and relevant safety
items on a particular job maybe discussed. In addition, the team leaders organize and conduct safety
planning for non-routine jobs. Notification and planning of upcoming projects, particularly those
items regarding safety and communications, are discussed with Building Representatives and other
customers requesting maintenance or custodial services. Team leaders also lead their respective
Natural Work Teams (NWI) in regular meetings. These meetings have proven to be an effective
vehicle for communicating and resolving safety issues and concerns. FMS management reviews all
individual work requests to ensure safety planning and permitting requirements have been addressed.
FMS management may also lead large project and new service contract pre-bid and project "kickoff"
meetings. Project safety requirements are discussed and clarified at these meetings. FMS management
also conducts periodic work area walk-throughs, initiates informal project safety discussions, meets
with individual employees and departmental customers to discuss various safety related issues, holds
weekly team meetings and quarterly departmental safety meetings, and tracks the resolution of safety
related findings assigned to FMS
For DOE-funded construction subcontracts the ES&H expectations are formally communicated to
construction subcontractors in contract specifications. Facilities Management Service Procedure
FMS-7, Safe Subcontractor Work is the primary tool for including ES&H requirements in Subcontract
Technical Specifications. Specifically, the expectations of a safety and health plan (program) are
identified in Master Technical Specifications general requirements.
May 2007 (Rev. 1) 51

The ORAU/ORISE Procurement program uses the Subcontract Safety Clause Matrix'when acquiring
construction services with ES&H implications to ensure the appropriate ES&H provisions and
clauses are included in the subcontract.
The general contractor is required to submit a job-specific safety plan with associated Job Hazard
Analyses in accordance with the FMS ISMS Plan, lie plan must be approved by the ORAU Project
Manager and the ORAU Environmental, Safety and Health Department prior to the commencement
of the field work.
After subcontract award and during performance, serious safety violations or willful repeated
violations of safety and health laws, regulations, and requirements maybe cause for termination for
default under the clause Default, and/or suspension of work under Safety and Health.
The subcontractor must ensure that all required training is carried out and documented for
Subcontractor employees and all lower-tier subcontractors before personnel start work and that
training is continued throughout all phases of construction. The Subcontractor must inform each
employee of the known or potential hazards before workers begin the work and their responsibility
to work safely and prevent occupational injury. The Subcontractor must ensure that records of all
required training are maintained and made available upon request by the Contractor.
The construction superintendent or his competent alternate must be present on the worksite at all
times during the performance of project work activities. The construction superintendent shall
designate a site safety and health representative to perform frequent inspections of the worksite. The
frequency shall be determined on a case-by-case basis considering the size and scope of the contract.
Records of inspections shall be available to employees of the subcontractor, ORAU Safety and
Heakh personnel, FTD personnel, and others as needed. In no case shall the requirement for or
presence of dedicated Safety and Health personnel relieve the superintendent of full and complete
responsibility for compliance with all project Safety and Health requirements. Failure to comply with
all project Safety and Health requirements may be sufficient cause for removal of the superintendent
from the project.
The subcontractor must ensure that all required training is carried out and documented for
Subcontractor employees and all lower-tier subcontractors before personnel start work and that
training is continued throughout all phases of construction as required. The Subcontractor must
inform each employee of their responsibility to work safely and prevent occupational injury. The
Subcontractor shall ensure that records of all required training are maintained and made available
upon request by the Contractor.
The on-site Subcontractor construction superintendent is fully responsible for enforcing all safety
and health requirements as well as administering disciplinary actions for violations. All observed
safety violations will be dealt with and corrected immediately. Personnel responsible for the violation
will be instructed on the exact nature of the violation and issued clear warning that safety violations
will not be tolerated. Repeated safety violations, willfully or otherwise, by the same individual may
result in their suspension or permanent removal from the job site. Individual violations, depending
on their severity, may be sufficient cause for employee removal from the job site.
Each Subcontractor must agree to enforce these actions as directed and participate in the ORAU
Performance Based Safety Target Construction Subcontract Clause, which includes the following:
May 2007 (Rev. 1) 52

4. The successful subcontractor must "qualify* to be viable candidate for safe work on an
ORAU/ORISE site by meeting a stipulated minimum EMR rating.
5. During the life of the contract, ORAU/ORISE will make payments aggregating up to 90% of
the contract amount and hold back amounts on each invoice aggregating to 10% of the face
amount of the subcontract.
6. The only condition under which the subcontractor can collect the full 10% retainage at the end
of the contract is if the job is completed safely with no recordable and reportable as defined by
OSHA accidents. The rate of permanent reduction of payments under the subcontract for each
official recorded and OSHA reported accident shall be five percent (5%) of the then current
balance of ten percent (10%) retainer.
7. For each officially recorded accident, the subcontractor agrees in advance to a reduction of a
portion of the 10% retainage, which computes to 0.5% (one-half of one percent) of the face
value of the contract. The subcontractor may experience a reduction in final payment aggregating
up to five percent (5%) of the face amount of the subcontract should mukiple recordable and
OSHA recordable accidents occur under this subcontract. The contract specialist will approve
final payment. The contract specialist may, depending on circumstances, choose to utilize
his/her sole discretion to mitigate any individual reduction levied by the above formula by
further reducing the assessment by up to 50% resulting in an actual reduction equal to 025
percent (one-fourth of one percent) of the face amount of the subcontract award
G2 Fire Protection
ORAU manages a comprehensive fire protection program with the objective of providing an
acceptable level of safety from fire and related hazards for ORISE personnel and for the public. This
program is described in the ORAU Fm Safety Program Document found in the ORAU Health <& Safety
Manual Certain procedures are also described in the ORAU/ORISE Emergency Preparedness Manual
Together these documents cover facility fire protection, fire alarm notification and egress features,
fire department response, fire protection criteria and procedures, apparatus and equipment, and
personnel responsibilities.
Fire safety is an integral part of all activities and that facilities have been designed with both active
and passive fire protection features such that reliance will not be placed on only one means to ensure
an acceptable level of fire safety. This is also characterized by the demonstration of a continuing
interest on the part of management and employees in minimizing losses from fire and related hazards
and the implementation of preventive features necessary to ensure the satisfaction of objectives
related to fire safety. FMS provides or coordinates the work of subcontractors for the design,
installation, operability, inspection, maintenance, and testing of fire protection systems. The
applicable codes and standards will be those in effect when facility design commences ("code of
record"). When significant modifications to a facility occur, the current edition of the code or
standard will apply to the modification.
The Oak Ridge Fire Department provides fire prevention and suppression services for all
ORAU/ORISE facilities. This includes semi-annual inspections and oversight for plan review and
code compliance.
Key components of the ORISE fire protection program are as follows:

■ Coordination by FTD with ESH for facilities-related issues.
■ Training for employees and management in the recognition of fire hazards.
May 2007 (Rev. 1) 53

Prompt and documented investigation of all reports of potential problems reported.
Review of past ORAU/ORISE safety and health inspection documents for potential fire
hazards ensuring that analyses are conducted for all problem jobs and similar jobs.
Completion and maintenance of appropriate records.
Review of proposals, plans, and drawings to identify factors that may contribute to fire safety.
Use of appropriate outside resources as necessary to insure fire safety program success.
C3 Explosives Safety
Explosives are not used in ORISE facilities or operations.
C4 Pressure Safety
Pressure vessel safety is managed by the FMS. All ORISE boilers, pressure vessels, and relief devices
are inspected and tested in strict accordance with the Tennessee Boiler and Unfired Pressure Vessel
Inspection Law, Rules, and Regulations. These requirements are consistent with the American
Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Safety Code, Section I and
Section VIII, and the American National Standards Institute (ANSI)/ASME B.31 Process Piping Code.
ORAU has no boilers operating at or above 15 psi, which makes all ASME identified codes and
standards N/A.
FMS maintains reviews the operation of all boilers and pressure vessels at the Oak Ridge site through
the FMS Preventive Maintenance Scheduler Application program to ensure all boilers, pressure
vessels, and relief devices are inspected and documented in accordance with the above regulatory
requirements. FMS also maintains a copy of all state of Tennessee inspection reports and
certifications in its central files.
C5 Firearms Safety
Firearms are not used in ORISE facilities or in its operations.
C6 Industrial Hygiene
The ORISE ESH office manages a comprehensive industrial hygiene program to reduce the risk of
work-related disease or illness. The industrial hygiene program is described in the ORAU/ORISE
Health and Safety Manual. It has several key elements, and these are described in procedural documents
within the manual and are readily accessible to all employees on line, as follows:
Hazard Communication
Chemical Hygiene Plan
Ergonomics Program
Respiratory Protection
Bloodborne Pathogens Exposure Control Plan
Hearing Protection
May 2007 (Rev. 1) 54

■ Asbestos Management
■ Biohazards
■ Personal Protective Equipment
■ Non-ionizing Radiation
■ Indoor Air Quality
ORAU managers insure that hazards are addressed at all stages of work planning and performance.
At the institutional level, all known hazards with a potential to affect ORISE operations have been
assessed and analyzed The results are listed in the ORAU/ORISE Hazards Survey. This
comprehensive assessment is used as a building-specific tool for the evaluation, design, and control
of potential hazards that could adversely impact workers, the public, or the environment. The
document serves a two-fold purpose. It is an inventory of potential sources of occupational exposure
and environmental damage. It also serves as a planning guide for emergency preparedness and
response actions.
At the program and department level, the primary method used to identify hazards is contained
within the work unit ISMS plan. These plans are tailored to the facilities and circumstances of the
work that is performed, and each program/department lists its own potential hazards. In areas where
hazardous materials are stored or used, inventories are maintained to assure that Material Safety Data
Sheet (MSDS) collections are complete, current, and readily accessible to all employees. Postings are
required for all areas where radiological substances and hazardous materials are stored or used.
Additionally, ESH subject matter experts must approve the purchase of all chemical and radiological
materials.
Quarterly management inspections are conducted to evaluate all workspaces and processes. These
work unit inspections are augmented with surveys, monitoring, and assessments by members of the
ESH and FID programs where appropriate.
At the activity level, workers use Job Hazard Analyses (JHAs) extensively. Copies of JHAs are
available to all employees electronically, and hard copies are maintained, where applicable. The
OSHA-recommended format for JHAs is used, listing "Activity/Hazard/ Control" for each step in
potentially hazardous operations. Employee input is solicited in the development and review of
JHAs. Training to cover the content of JHAs is provided to appropriate employees.
When new work is planned or when the work that is presently being performed is modified,
managers are required to complete and submit an ISMS Pre-Job Hazard Checklist form. This must
be completed prior to the initiation of any work that is not addressed in the program/department
ISMS Plan. The function of the ISMS Pre-Job Hazard Checklist form is to serve as a hazards
inventory only and not as a plan or a work process control document. If a plan is required due to the
potential hazards involved, the ISMS Plan for New or Modified Work or a formal Health and Safety
Plan is also required.
C7 Biological Safety
Biological and etiological agents are not in use in ORISE facilities or in its operations.
May 2007 (Rev. 1) 55

C8 Occupational Medicine
ORISE provides a comprehensive program to protect and enhance the physical and mental health of
its employees, to ensure fitness for work, and to promote good public health practices. The program
establishes responsibilities and procedures for the Occupational Medical Program (OMP) are
addressed in ORAU Policy and Procedure GP-1100, Occupational Medicine.
The objectives of the OMP are summarized as follows:
1) To assist management in protecting employees from health hazards in the work environments.
2) To assist management in assuring the placement of employees in work that can be performed in
a reliable and safe manner consistent with the requirements of the Americans with Disabilities
Act of 1990.
3) To provide support to management in the medical, mental, and substance abuse aspects of
personnel reliability and fitness for duty.
4) To assist in the early detection, treatment, and rehabilitation of employees who are ill, injured, or
otherwise impaired.
5) To practice preventive medicine and to provide health education and health promotion
programs in order to facilitate optimal employee health.
6) To provide professional guidance and consultation to management on all health-related issues.
7) To provide employees, as appropriate, with professional medical evaluation, guidance,
counseling, and referrals in support of optimal physical and mental health.
8) To protect the privacy of employees and the confidentiality of their medical records in
accordance with applicable laws and regulations.
9) To reduce morbidity and mortality by providing support to management and DOE through the
collection and analysis, when requested, of employee health data for the purpose of early
detection and prevention of occupational and non-occupational illnesses and injuries.
C9 Motor Vehicle Safety
The purpose of the ORAU/ORISE motor vehicle safety program is to ensure the safe operation of
corporate owned and government owned or leased motor vehicles in order to protect the safety of
the drivers, passengers, the public, and to rninimize physical damages to our vehicle fleet.
The operation of government or corporate owned vehicles is restricted to those authorized

employees who require the use of such vehicles for official business and who possess a valid state
driver's license for the category of vehicle being operated. All ORAU/ORISE vehicle management
operations must be conducted in accordance with all applicable policies, procedures, regulations
and/or laws contained in ORAU Policy and Procedure FM-300, Vehicle Management Policy. Also, all
vehicle operations must be operated in accordance with the ORAU Vehicle Management Implementation
Procedures issued through the ORAU Facilities and Transportation Department / Records, Property,
and Relocation Section.
General requirements for employees in the operation of motor vehicles are as follows:
1) Inspect vehicle for safe operating condition (brake operation, obvious tire defects, clear visibility,
and fuel level) prior to each use.
2) Wear a seat belt and ensure that each passenger wears a seat belt.
3) Observe all federal, state, and local laws and regulations and posted speed limits.
4) Report promptly any vehicle damage or theft to ESH.
May 2007 (Rev. 1) 56

5) Complete a Report of Motor Vehicle Accident form (available in the vehicle glove compartment)
in the event of an accident and submit it to ESH
6) Report any malfunctions of the vehicle to FTD.
7) Lock the vehicle when unattended.
8) Completely fill out log sheet for each use.
9) Report promptly any personal moving traffic violations over $250.00, or other violations
involving the use of a personal vehicle to the ESH office.
10) Report any change in license status (e.g., if your license has been suspended or revoked) to the
ESH office.
11) Pay all driver related traffic violations and citations.
C10 Electrical Safety
The ORISE electrical safety program provides a framework for identifying and controlling potential
electrical hazards that are present in the workplace. The applicable OSHA, NFPA, and other related
design and testing standards provide the underlying foundation for those electrical program elements.
ORISE Procedure FMS-1, Safe Electrical Work Processes, establishes general guidelines and
requirements for conducting work on electrical systems. The electrical safety program applies to
activities in maintenance, laboratories, and office environments involving potential exposure to
operational electrical hazards.
Its purpose is summarized as follows:
1) Ensure that electrical maintenance work and electrical construction work are performed in such a
manner so as to prevent electrical shock resulting from direct or indirect contact with energized
electrical equipment.
2) Establish guidelines for assessing training needs and ensuring provisions are available for
conducting electrical training.
3) Ensure that only trained and qualified individuals conduct electrical maintenance work and that
only qualified employees or employees under the immediate direction of qualified employees
conduct electrical installation work.
4) Ensure electrical engineering design work is conducted and certified by qualified licensed
electrical engineers.
5) Establish standards for identifying electrical panels, circuits, outlet covers, switches, and other
electrical equipment.
6) The electrical safety program applies to activities in maintenance, laboratories, and office
environments involving potential exposure to operational electrical hazards.
C11 Other Functional Areas Needed to Address Workplace Hazards
No other functional areas are needed to address workplace hazards.
G12 Chronic Beryllium Disease Prevention Program (CBDPP)

ORISE is not required to have a CBDPP.
May 2007 (Rev. 1) 57

Appendix D
ORISE 10 CFR 851 FACILITIES
*Note: Current occupant numbers are as of February, 2007. Current numbers can be obtained from the ORAU
Human Resources Department.
May 2007 (Rev. 1) 58

May 2007 (Rev. 1) 59
Appendix E
ORISE Acronyms and Abbreviations
AH[ Authority Having Jurisdiction
ANSI American National Standards Institute
ASME American Society of Mechanical Engineers
ATDL Atmospheric Turbulence and Diffusion Laboratory
CHP Certified Health Physicist
CAIRS DOE Computerized Accident and Incident Reporting System
QH Certified Industrial Hygienist
GOHN-S Certified Occupational Health Nurse Specialist
CSP Certified Safety Specialist
EMR Experience Modification Rate
ESH ORAU/ORISE Environment, Safety & Health Office
ES&H Environment, safety and health
FTD ORAU/ORISE Facilities and Transportation Department
FMS ORAU/ORISE Facilities Management Service
ISM Integrated Safety Management
ISMS Integrated Safety Management System
ISO International Organization for Standardization
JHA Job Hazard Analysis
MSDS Material Safety Data Sheet
NFPA National Fire Protection Association
NOAA National Oceanic and Atmospheric Administration
NWT Natural work team
May 2007 (Rev. 1) 60

OMP ORISE Occupational Medicine Program
ORAU Oak Ridge Associated Universities
ORISE Oak Ridge Institute for Science and Education
OSHA Occupational Safety and Heath Administration
PE Professional Engineer
RA Registered Architect
REAC/TS Radiation Emergency Assistance Center/Training Site
Safety 1st ORAU/ORISE Safety 1« website
VPP Voluntary Protection Program
WSS Work Smart Standards
May 2007 (Rev. 1) 61

10 CFR 851 Health Safety Final Approved

Uploaded by

Copyright:

Available Formats

10 CFR 851 Health Safety Final Approved

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

10 CFR 851 Health Safety Final Approved

Uploaded by

Copyright:

Available Formats

Department of Energy

Oak Ridge Operations

Dr. Ronald D. Townsend, Director

Dear Dr. Townsend:

CONTRACT NO. DEAC05-06OR23100, OAK RIDGE INSTITUTE FOR SCIENCE AND

Robert J. Brown, M-2, ORO

Oak Ridge Institute

Oak Ridge Institute for Science and Education

Ronald D. Townsend date

Gerald G. Boyd <iat

May 2007 (Rev. 1)

Office of Science Program Elements & Review Criteria

The information in this program description is intended to provide an understanding of the

ORISE is designated as a non-nuclear, radiological low-hazard faciKty. Its focus is on scientific

May 2007 (Rev. 1)

May 2007 (Rev. 1)

Integrated Safety Management System

Flowdown of Worker Safety and Health Requirements

May 2007 (Rev. 1)

4-2 Technical Staff and ES&H Responsibilities

Other staff that have credentials in hazardous material management, training,

4*3 Procurement Interface

May 2007 (Rev. 1)

Subcontractor Safety and Review

For construction or other business contracts through the procurement process,

May 2007 (Rev. 1)

Lower Tier Subcontractors

Guest workers and students on occasion work at ORISE on a temporary basis in

The Visitor and Subcontractor Handbook provides pertinent ES&H information to

May 2007 (Rev. 1)

5-2 WSH Program - General Requirements (10 CFR 851.10)

May 2007 (Rev. 1)

Accountability of personal performance is also addressed in ORAU Policy and Procedure

May 2007 (Rev. 1)

Many opportunities are provided to employees to become involved in ORISE safety

Procedures, program descriptions, management system descriptions, subject

May 2007 (Rev. 1) 10

Through memoranda of understanding and other agreements with other

5.3.3 Program Updates

5.4 Implementation (10 CFR 851.12)

5.5 Compliance (10 CFR 851.13)

5.6 Worker Protection Goals and Objectives, Management Responsibilities,

May 2007 (Rev. 1) H

Management responsibilities, worker rights and responsibilities, and systems to ensure

57 Hazard Identification and Assessment (10 CFR 851.21)

The Hazards Survey serves a two-fold purpose. It is an inventory of potential sources

May 2007 (Rev. 1) 12

Hazard Prevention and Abatement (10 CFR 85122)

May 2007 (Rev. 1) 13

As mentioned previously in the Hazard Identification and Assessment section, JHAs

In addition to the above, FMS management, in conjunction with affected employees,

As an integral and parallel function of the hazard abatement process, Procurement

May 2007 (Rev. 1) 14

5.10 Applicable Functional Areas (10 CFR 851.24)

5.10.1 Construction Safety (Appendix Q

5.10.2 Fire Protection (Appendix Q

5.10.3 Explosive Safety (Appendix Q

5.10.4 Pressure Safety (Appendix Q

5.10.5 Fire Arms Safety (Appendix Q

5.10.6 Industrial Hygiene (Appendix Q