SAD-OTSAM-450, Rev. 2
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Management System: Safety and Health
Subject Area: Integrated Safety
Management System (ISMS) Description
Management System Owner: John Sattler
Point of Contact: Ken Armstrong
Issue Date: 3/3/16
CBC MS Revision: 2
1.0 Introduction
Purpose and Objectives:
This Integrated Safety Management System Description (ISMSD) defines how the U.S
Department of Energy, Environmental Management Consolidated Business Center (EMCBC)
and participating Small Sites implement DOE O 450.2, Integrated Safety Management (ISM)
and conduct work following the seven ISM Guiding Principles, the five ISM Core Functions, and
incorporates the four Supplemental Safety Culture Principles (adopted from the EM ISMSD).
The EMCBC ISMS also integrates important aspects of the EMCBC Quality Assurance Program
and Environmental Management System into the ISMS process and describes how this process is
used to identify the flow down of requirements critical not only to safety but also to the
environment and to the quality of the EMCBC services. This ISMSD also describes how the
EMCBC participating small sites ensure that the EMCBC small site contractors meet the
expectations of the Department of Energy Acquisition Regulation (DEAR) clause 48 Code of
Federal Regulations 970.5223-1, Integration of Environment, Safety, and Health into work
planning and execution by establishing the requirements to develop, implement, and maintain
ISM Systems.
Overview of the ISM System:
The EMCBC ISMSD program is developed around the EMCBC Mission, Vision, Values and
Goals as defined in the EMCBC Strategic Plan (December 2015).
Mission: To provide an integrated services center with a valued, dedicated and well-trained staff to execute exemplary core business and technical services that are focused on the safe, compliant and efficient execution of EM activities at supported sites.
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The EMCBC has two primary mission assignments as noted above:
Execute Core Business Services (such as contracting and cost estimating)
Execute Core Technical Services (such as environmental, safety and quality oversight)
These activities although non-operation in nature still have direct impact on the performance of
work in the field. Using the guidance in Attachment 7 of DOE G 450.4-1C, Integrated Safety
Management System Guide, the following shows how each applicable EMCBC mission affects
the Safety, Quality, and Environmental impact of DOE and small site personnel.
The EMCBC Strategic Plan contains three over-riding goals – People, Mission Delivery and
Effectiveness/Efficiency. The EMCBC Strategic Plan goals are then broken down into
objectives, strategies and actions that discuss how the EMCBC defines the scope, identifies
requirements, mitigates hazards, executes the mission and then continuously learns and improves
processes.
PROVIDE CORE BUSINESS SERVICES: Translating missions into meaningful scopes of work Define scopes of work in sufficient detail to identify the applicable hazards and
requirements Flow down requirements to contractors through contract mechanisms
PROVIDE CORE TECHNICAL SERVICES: Establish Safety, Quality and Environmental programs Perform oversight and self-assessments to assure compliance
Maintain operational awareness of operational activities and share Lessons Learned Establish Federal Occupational Safety and Health Plans to assure the safety of our
federal workers.
Mission Vision
Goals
Values
Objectives
Strategies
Actions
People
Mission Delivery
Effectiveness/Efficiency
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The EMCBC Goals are accomplished through programs, policies, and procedures. These
programs, policies, and procedures also implement the guiding principles and core functions of
the EMCBC ISMSD as defined in the EMCBC ISMS Implementation Matrix, (Attachment A).
The EMCBC ISMS program is applicable to the EMCBC but may be adopted by the EMCBC
Small Sites provided the EMCBC ISMS Implementation Matrix is reviewed and modified to
adequately describe the implementing policies, procedures, and programs.
2.0 Implementation of the Five Core Functions
Core Function 1: Defining Scope of Work: Missions are translated into work, expectations are set, tasks are identified and prioritized,
quality assurance standards are applied, reporting is formulated and resources are
allocated.
The EMCBC Strategic Plan (Goal 1) defines how each EMCBC function establishes a
workload baseline. The EMCBC provides a wide range of business and technical services
based on Service Level Agreements with customer sites, and providing line management and
oversight of the Small Sites. Based on these requirements, the EMCBC develops a workload
baseline which is a compilation of EMCBC customer requirements and the associated
staffing requirements (e.g., required credentials, estimate of hours required to perform tasks).
The workload baselines mentioned in the Strategic Plan are derived from the two primary
missions of the EMCBC:
a) Provide Core Business Services: The EMCBC procurement process uses the
Integrated Project Team concept to translate missions into meaningful scopes of
work. The Integrated Project Team formed from Contracting Officers, Technical
Subject Matter Experts, and knowledgeable site personnel define contract scopes of
work in sufficient detail to identify the applicable hazards and requirements. In
addition, the IPT Team identifies and flows down requirements to contractors through
contract mechanisms.
b) Provide Core Technical Services: The EMCBC works with the small sites and
service level agreement sites to identify specific needs such as ISMS Declaration
support, ISMS Assessments, QA Assessments, Environmental Opportunity
Assessments, Safety Conscious Work Environment Assessments, Document Reviews
Strategy – Workload Baseline, Manpower Assessment and Succession Plan Establish a Workload Baseline that identifies all EMCBC customer requirements and the associated staffing requirements (e.g., required credentials, estimate of hours required to perform tasks). Perform subsequent Manpower Assessment to identify existing staff capabilities, current workload assignments and associated performance metrics.
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and other Oversight needs on an annual basis. The EMCBC also has the overriding
responsibility to provide for an environment where worker safety is our first priority.
Work at EMCBC office locations is defined by the Strategic Plan and analyzed using
PP-OTSAM-450-01, EMCBC Federal Occupational Safety and Health (FEOSH)
Plan.
Core Function 2: Identifying the Hazards: Hazards associated with work are identified, analyzed and categorized.
a) Provide Core Business Services: The EMCBC technical support staff, technical
support contractors and other subject matter experts are utilized to identify
requirements associated with the work scope (Statement of Work or Performance
Work Statement) in each procurement action and resulting contract. Each statement
of work is thoroughly analyzed to assure that significant safety, environmental, and
quality aspects are identified and communicated to the contractor. Applicable Federal
Regulations and applicable DOE Directives are compiled for inclusion in the Request
for Proposal. In addition, other significant requirements are included such as project
agreements and significant correspondence.
b) Provide Core Technical Services: The EMCBC identifies hazards to the public and
environment through multiple Federal processes. These include but are not limited to
the EMCBC and project level National Environmental Policy Act processes. The
EMCBC uses quality assurance oversight mechanisms such as management and
independent assessments, document reviews, readiness reviews and other activities to
assure that significant safety, environmental, and quality aspects are identified and
communicated to the contractor. Worker safety hazards analysis for Federal work
activities at the EMCBC help develop an understanding of the potential for the
hazards to affect the health and safety of the Federal worker, the public, and the
environment. The EMCBC uses PP-OTSAM-450-01, FEOSH Plan and SAP-
OTSAM-450-03, Job Hazard Analysis Procedure to identify hazards in the
workplace as well as periodic work space inspections.
Core Function 3: Developing and Implementing Hazard Controls:
Applicable standards and requirements are identified and agreed upon; controls to prevent
or mitigate hazards are identified and implemented.
a) Provide Core Business Services: The EMCBC flows down requirements to
contractors through contract mechanisms. The EMCBC considers legal and
contractual authorities, its policies, local or regional issues and its obligations and
responsibilities to EMCBC small sites. These requirements are typically documented
in the statement of work and by listing the applicable Federal Regulations and
applicable DOE Directives. This process is documented in the Office of Contracting
in IP-540-11, Management of an Integrated Project Team (IPT)/Source Evaluation
Board (SEB) at the EMCBC. In addition, other significant requirements are included
such as project agreements and significant correspondence.
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b) Provide Core Technical Services: The EMCBC uses quality assurance oversight
mechanisms such as management and independent assessments, document reviews,
readiness reviews and other activities to assure that significant safety, environmental,
and quality aspects are identified and communicated to the contractor. For design
review and construction activities in EMCBC facilities, the EMCBC utilizes the
processes of the General Services Administration to support the design review and
construction of new space. Significant environmental aspects are determined based on
the relative impact to the environment for the work scope performed by the EMCBC
and documented in MSD-OD-111, Rev. 2, EMCBC Environmental Management
System Description. Federal worker safety hazard mitigation is accomplished through
PP-OTSAM-450-01, FEOSH Plan, SAP-OTSAM-450-03, Job Hazard Analysis
Procedure. Recurring FEOSH inspections of Federal workspace helps to ensure
continued due diligence in maintaining and proper hazard controls are appropriate
and functioning. Personal Protective Equipment (PPE) is provided through SAP-
OTSAM-445-02, Purchasing Personal Protective Equipment Procedure. In addition,
the EMCBC anticipates and plans for mitigation of emergencies through PP-
OTSAM-151-02, EMCBC Occupant Emergency Plan.
Core Function 4: Performing Work within Controls:
Readiness is confirmed and work is performed safely.
a) Provide Core Business Services: The EMCBC performs oversight of contractors in
a number of ways. Monthly Performance Reviews (PMRs), input into the DOE
Project Assessment and Reporting System (PARS II) and other project related
reporting systems. Oversight of contractor business performance is accomplished
through the Federal Project Directors, the Contracting Officers and the contracting
officer technical representatives.
b) Provide Core Technical Services: The EMCBC uses quality assurance oversight
mechanisms such as management and independent assessments, document reviews,
readiness reviews and other activities to assure that both DOE Field office and
Contractor personnel are operating within defined parameters. Results of EMCBC
assessments are presented in formal assessment reports with deficiencies being
written to document the non-conformance. Deficiencies are tracked to closure
through the contractor, small site, or SAP-OTSAM-414B-01, EMCBC Corrective
Action Procedure. Monthly performance metrics are also an important tool for
monitoring implementation of safety, quality, and environmental policies. Managers
and personnel perform self-assessments to assure that EMCBC systems and processes
are being used as described. In addition recurring FEOSH inspections of Federal
work space are conducted using SAP-OTSAM-414C-01, Assessment/Management
Assessment and Oversight Procedure to ensure work is performed within the bounds
defined and proper hazard controls are appropriate and functioning.
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Core Function 5: Provide Feedback and Continuous Improvement:
Feedback information on the adequacy of controls are gathered, opportunities for improving the
definition and planning of work are identified and implemented, line and independent oversight
is conducted, and if necessary, regulatory and enforcement actions occur.
Continuous improvement is one of the cornerstones (Objective 3.3) of the EMCBC Strategic
Plan (Goal 3: Effectiveness/Efficiency) and is promulgated through multiple measures that
support all aspects of the EMCBC work scope.
a) Provide Core Business Services: This is a cornerstone of the EMCBC Strategic
Plan and is promulgated through multiple measures that support all aspects of the
EMCBC work scope. The EMCBC utilizes the Lessons Learned process for quality
for continuous improvement. As an example: Following each significant contract
award, Source Evaluation Boards generate lessons learned for future use within the
DOE contracting community.
b) Provide Core Technical Services: The EMCBC uses Operating Experiences and
Lessons Learned in accordance with EMCBC procedures to flow lessons learned
down from Headquarters and incorporate lessons learned from other DOE-EM
projects. Worker safety is improved through continuous improvement in all aspects of
Federal work activities. The EMCBC implements Customer Satisfaction Surveys and
uses the results to improve performance. The EMCBC uses Self-Assessment and
Management Assessment activities to assess compliance with procedural or
regulatory requirements. The results of Self-Assessments and Management
Assessments are used for continuous improvement opportunities.
3.0 Implementation of the Seven ISM Guiding Principles, and Four
Supplemental Safety Culture Principles
Principle 1: Line Management Responsibility for Safety: EMCBC and Small Site Line Management are responsible and accountable for protection of
the public, workers, and the environment. This is documented in the EMCBC Strategic Plan
and flows down through the EMCBC Mission and Function Statement, EMCBC Functions
Responsibilities and Authorities (FRA), Procurement Authorities, Delegations of safety,
environmental and quality authorities, and responsibilities outlined in individual position
descriptions and performance plans.
Continuous Improvement Using results from the APR, customer surveys and other sources, implement a continuous improvement culture that drives innovation in delivering results.
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Principle 2: Clear Roles and Responsibilities: Clear and unambiguous lines of authority and responsibility for ensuring safety is
documented, communicated, and maintained through the FRA and the EMCBC Management
System.
Principle 3: Competence Commensurate with Responsibilities: EMCBC employees possess the experience, knowledge, skills, and abilities necessary to
discharge their responsibilities. These are documented in formal qualification programs such
as PD-361-03, Rev. 1, Technical Qualification Program (TQP) and SAP-OTSAM-414D-01,
Qualification of Assessment Personnel procedure and Individual Development Plans.
Principle 4: Balanced Priorities:
EMCBC resources are effectively allocated to address safety and programmatic and
operational considerations. When necessary, technical support contractors are available to
support EMCBC and small site needs. Protecting the public, workers, and the environment is
an overriding priority as documented in the EMCBC Strategic Plan and EMCBC
Management Systems. Priorities for program and technical support are captured in the
EMCBC Fiscal Year Action Plans. Individual organizational planning is accomplished and
documented in plans such as the Office of Technical Support and Asset Management
(OTSAM) Integrated Assessment Schedule and the Office of Contracting Workload
Management System.
Principle 5: Identification of Safety Standards/Requirements (S/R):
Before EMCBC work is performed, the associated hazards are evaluated, and an agreed-upon
set of safety S/R are established which provide adequate assurance that the public, workers,
and the environment are protected from adverse consequences. The EMCBC FEOSH Job
Hazard Analysis process is used for safety hazards and applicable standards. For Integrated
Acquisition, Financial & Project Management and Program & Technical Support these
requirements are typically documented in the statement of work and by listing the applicable
Federal Regulations and applicable DOE Directives using the Office of Contracting
procedures including management of an Integrated Project Team (IPT)/Source Evaluation
Board (SEB) at the EMCBC.
Principle 6: Hazard Controls Tailored to Work Being Performed:
The EMCBC uses administrative and engineering controls to prevent and mitigate hazards
and tailors them to the work and associated hazards. The EMCBC identifies and tailors
hazard controls through EMCBC PP-OTSAM-450-01, FEOSH Plan and SAP-OTSAM-450-
03, Job Hazard Analysis Procedure.
Principle 7: Operations Authorization: The conditions and requirements for operations to be initiated and conducted are agreed upon
and clearly established. Although the EMCBC does not perform work authorization, the
EMCBC has line responsibility for the small sites. Program and Technical Support personnel
assist in Baseline Reviews, Readiness Reviews, ISMS, QA and other reviews in accordance
with procedures such as SAP-OTSAM-414C-04, Rev. 1, Document Reviews Procedure,
SAP-OTSAM-414C-02, Rev. 3, Independent Assessments Procedure and, SAP-OTSAM-
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414C-01, Rev. 3, Assessment/Management Assessment and Oversight to ensure that
conditions and requirements for operations are in place prior to work authorization. Contracts
are authorized through IP-540-15, Rev.1A, Review and Approval of Proposed Sales,
Procurement, Financial Assistance and Subcontract Actions Procedure.
EM Safety Culture Principle 1: Individual Attitude and Responsibility for Safety: Every EMCBC individual accepts responsibility for safe mission performance. EMCBC
employees are coached through monthly safety meetings and news letters to demonstrate a
questioning attitude, challenge assumptions, investigate anomalies, and considering potential
adverse consequences of planned actions. Through the PP-OTSAM-450-01, FEOSH Plan,
each EMCBC employee is mindful of work conditions that may impact safety, and assist
each other in preventing unsafe acts or behaviors.
EM Safety Culture Principle 2: Operational Excellence: The EMCBC achieves sustained, high levels of operational performance, encompassing all
DOE and contractor activities to meet mission, safety, productivity, quality, environmental,
and other objectives. The EMCBC achieves this through a focus on operations, quality
decision-making, open-communications, deference to expertise, and systematic approaches
to eliminate or mitigate error-likely situations.
EM Safety Culture Principle 3: Oversight for Performance Assurance: The EMCBC has established a competent, robust, periodic and independent oversight
program that provides feedback that verifies expectations are being met and identifies
opportunities for improvement. The EMCBC accomplishes this through the Management
Assessment and Independent Assessment processes. These assessments verify that standards
and requirements are being met. The EMCBC performs assessments in accordance with an
integrated assessment schedule for continuous safety and performance improvement.
EM Safety Culture Principle 4: Organizational Learning for Performance
Improvement: The EMCBC demonstrates excellence in performance monitoring, problem analysis, solution
planning, and solution implementation through our SAP-OTSAM-414B-01, EMCBC
Corrective Action Procedure and IP-230-01, Rev.2, EMCBC Corporate Operating
Experience and Lessons Learned Procedure. The EMCBC encourages openness and trust,
and cultivates a continual learning environment.
4.0 Management Commitments and Expectations
The DOE-EM ISMSD provides the overarching DOE-EM commitment and expectations for
safety. In summary, safety is first. It overrides every other priority. In addition, safety is the
responsibility of every employee and it is the expectation of the EMCBC management that
each employee embrace their role in the implementation of the safety systems described in
this ISMSD. This commitment is expressed in the EMCBC Strategic Plan Values which are
People, Service and Safety:
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Responsibilities and management expectations of each EMCBC employee are also described
in PP-OTSAM-450-01, EMCBC Federal Employees Occupational Safety and Health Plan.
In addition, the PO-OTSAM-451-01, EMCBC Environmental Management Policy has been
published to demonstrate our organizational commitment to ensure a healthy and protective
environment for workers and the public through every day sustainable practices that adhere
to applicable environmental protection laws, regulations and standards.
5.0 Integration of ISMS, Environmental Management System, and Quality
Assurance Plan
The EMCBC Strategic Plan defines the primary strategic themes (work scope) of the
EMCBC and establishes goals for achieving the EMCBC mission. The ISMS management
process defines how significant safety, environmental, and quality aspects are identified,
controlled, work is performed and feedback is obtained. Significant quality and
environmental management aspects are integrated into the ISMS process using the five Core
Functions. The EMCBC EMS requires work to be done in a four step process consistent with
the five Core Functions. This is commonly referred to as the “Plan-Do-Check-Act-Cycle”.
Significant environmental aspects are identified, managed, assessed, and reviewed using the
same management process as significant safety aspects.
6.0 Implementation of Safety Management at Small Sites
Safety Management flows down to the DOE-EM small sites through prime contracts.
EMCBC assures the flow down of safety management using DOE-EM Line Management
beginning with the Federal Project Directors of each small site. DOE Oversight and
Contractor Assurance are used to verify and validate implementation of safety. The tools and
mechanisms used rely on site specific plans, procedures and resources supplemented where
needed by EMCBC plans, procedures and Federal employee resources.
7.0 Measuring Safety Performance
The DOE-EM ISMSD provides the Safety Performance Objectives, Measures and
Commitments that the EMCBC strives to meet. The EMCBC FEOSH Plan ensures
continuous monitoring/inspections to verify a safe working environment is maintained.
Regular feedback to management concerning occupational safety and health hazards is
Safety at all times: • Our highest priority is to support the EM program in protecting
employees, the public and the environment. • We foster a culture that encourages and embraces the opinions of
workers and customers. • We conduct our work using the core functions and guiding principles of
Integrated Safety Management (ISM).
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provided and work related injuries/illnesses are reported in the Computerized Accident
Incident Reporting System (CAIRS). Data for the CAIRS system is collected through the
SAP-OTSAM-450-04, Reporting Injuries procedure. Monitoring of Environmental
Management goals and performance measurement is described in the EMCBC
Environmental Management System (EMS) Program Description.
8.0 Contents
Procedures Procedure Content
SAP-OTSAM-445-02, Purchasing
Personal Protective Equipment
Describes how the EMCBC employees
purchase personal protective equipment.
SAP-OTSAM-450-03, Job Hazard
Analysis
Describes the process for identifying
work-related hazards faced by employees
in Department occupied space, at DOE
sites, or while on official travel.
Defines the process for conducting Job
Hazard Analysis (e.g., job safety analysis
and comprehensive safety and health
surveys)
SAP-OTSAM-450-04 Reporting
Injuries
Describes the process for reporting
injuries or illnesses including data entry
into the Computerized Accident Incident
Reporting System (CAIRS).
SAP-OTSAM-414C-01,
Assessment/Management
Assessment and Oversight
Describes the process for conducting
Management Assessments and Oversight
of both DOE and Contractor Activities.
9.0 Related Information
9.1 Requirements
10 CFR 830, Nuclear Safety Management
DOE O 226.1B, Implementation of Department of Energy Oversight Policy
DOE O 231.1B Admin Change 1, Environment, Safety and Health Reporting
DOE O 440.1B Admin Change 1, Worker Protection Management for DOE
(including The National Nuclear Security Administration) Federal Employees
DOE O 450.2, Integrated Safety Management
DOE 414.1D, Quality Assurance
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9.2 References
DOE-HDBK-3027-99, Integrated Safety Management Systems Verification Team
Leader’s Handbook
DOE G 450.4-1C, Integrated Safety Management Guide
EMCBC Strategic Plan
9.3 Other Documents
Federal Employee Occupational Safety and Health Program (FEOSH) Plan
Figure 1: Flow Down of DOE Goals
EMCBC ISMS Implementation Matrix
10.0 Definitions - See EMCBC MS Definition List
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EMCBC RECORD OF REVISION
DOCUMENT TITLE: Integrated Safety Management System (ISMS) Description
If there are changes to the controlled document before the two-year review cycle, the revision
number stays the same; one of the following will indicate the change:
l Placing a vertical black line in the left margin adjacent to sentence or paragraph that was
revised; or
l Placing the words GENERAL REVISION at the beginning of the text. This statement is
used when entire sections of the document are revised.
If changes and updates occur at the two-year review cycle, the revision number increases by one.
Rev. No. Description of Changes Revision on Pages Date ______
0 Initial Document 8-9-12
1 Significant revision as ISMS All 5-15-14
Description Document
2 Changes reflect update of FEOSH Multiple 3-3-16
Plan, addition of FEOSH Procedures,
and the newly revised Strategic Plan
FM-OD-410B-02-F1, Rev. 0