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U.S. Department of Energy POLICY
Washington, D.C. DOE P 226.1
Approved: 6-10-05
SUBJECT: DEPARTMENT OF ENERGY OVERSIGHT POLICY
PURPOSE AND SCOPE
The purpose of this Policy is to establish a Department-wide oversight process to protect the
public, workers, environment, and national security assets and to perform its business operations
effectively through continuous improvement. As used in this Policy, any reference to DOE is
also meant to include the National Nuclear Security Administration (NNSA).
The scope of this Policy includes assurance systems implemented by DOE contractors and DOE
organizations that manage or operate on site; oversight programs implemented by DOE line
management (both Headquarters and field elements); and DOE independent oversight
Organizations. This Policy covers such operational aspects as environment, safety, and health;
safeguards and security; cyber security; emergency management; and business operations.
TERMINOLOGY
“Assurance systems” encompass all aspects of the activities designed to identify deficiencies and
opportunities for improvement, report deficiencies to the responsible managers, and complete
corrective actions effectively.
“DOE Oversight” encompasses activities performed by DOE organizations to determine the
effectiveness of Federal and contractor programs and management systems, including assurance
and oversight systems. Oversight programs include operational awareness activities, onsite
reviews, assessments, self-assessments, performance evaluations, and other activities that
involve evaluation of contractor organizations and Federal organizations that operate
Government-owned sites.
“Site programs” refers to programs that protect the public, workers, environment, and national
security interests or are essential to support mission activities. Site programs specifically include
environment, safety, and health; safeguards and security; cyber security; emergency
management; and business operations programs.
“Site management systems” refers to required management systems that provide the framework
for a set of related site programs. Site management systems specifically include Integrated
Safety Management and Integrated Safeguards and Security Management.
POLICY
It is DOE policy to protect the public, workers, environment, and national security assets and to
perform its business operations effectively. To meet this goal, all DOE organizations must
implement an assurance system that ensures compliance with applicable requirements, pursues
excellence through continuous improvement, provides for timely identification and correction of
deficient conditions, and verifies the effectiveness of completed corrective actions. Additionally,
DOE oversight programs must determine whether programs, management systems, and
assurance systems comply with requirements and are effectively implemented.
It is DOE policy to implement assurance systems and oversight programs that include four
essential elements:
* a comprehensive and rigorous assurance system at all sites implemented by the contractor
(for Government-owned/contractor-operated sites) and Federal organizations (for
Government-owned/Government-operated sites) that manage or operate on a DOE site;
* DOE field element line management oversight processes, such as inspections, reviews,
surveillances, surveys, operational awareness, and walkthroughs, that evaluate programs
and management systems and the validity of the site assurance system;
* DOE Headquarters line management oversight processes that are focused on the DOE
field elements and also look at contractor activities to evaluate the implementation and
effectiveness of field element line management oversight; and
* independent oversight processes that are performed by DOE organizations that do not
have line management responsibility for the management of the activity and thus provide
an independent perspective for senior management on the effectiveness of programs and
activities at all organizational levels (Headquarters, field, and contractor).
The four elements are designed to work as a comprehensive system to provide assurance that
DOE activities are safe and secure. Oversight of high consequence activities, such as high
hazard nuclear operations, require additional rigor, such as instituting Central Technical
Authorities for core nuclear safety functions. The assurance system puts responsibility and
accountability at the appropriate organizational level (both Federal and contractor) to implement
comprehensive and rigorous processes that ensure adequate protection of the public, workers,
environment, and national security assets and effective and efficient operations. The DOE
Headquarters and field element line management oversight processes put responsibility and
accountability on line management to determine the effectiveness, on an ongoing and regular
basis, of site operations and to ensure timely corrective actions if performance does not meet
expectations. The independent oversight processes determine whether Headquarters, field, and
contractor line management are effectively implementing their responsibilities and provide an
additional basis for credibility throughout the system. These assurance systems and oversight
activities will be tailored to meet the needs and unique differences of each site or activity.
Consistent with quality assurance objectives, thorough, rigorous assessments and corrective
actions are required to ensure performance and quality improvement.
ATTRIBUTES OF EFFECTIVE OVERSIGHT
An effective oversight process incorporates the following attributes into the four essential
elements of oversight as appropriate.
Program Plan
Documented program plans need to identify the program areas to be reviewed, the periodicity of
reviews, the reviews necessary to maintain the baseline oversight program, the qualifications of
review personnel, and the source of review criteria. Documented program plans need to describe
the various oversight methods used, how they are used, and how the results of the various
methods are integrated and considered as a whole to give an accurate oversight picture.
Continuous Improvement
Assurance systems and oversight processes will identify ways to make programs more effective
and efficient through improved performance and report such opportunities to line managers for
their consideration. Line managers at all levels—from the Secretary of Energy to the DOE
program office to the field element to the contractor—are responsible for using the results of
DOE line and independent oversight processes and assurance systems. These results are to be
used to make informed decisions about corrective actions that will improve the effectiveness and
efficiency of their programs and operations and about the acceptability of residual risks. The use
of external, nationally recognized experts should be considered to carry out independent risk and
vulnerability studies and to validate that contractor management systems meet applicable
standards. DOE sites and DOE line management must have effective processes for
communicating issues up the management chain to senior management using a graded approach
that considers hazards and risks. The processes must provide sufficient technical basis to allow
managers to make informed decisions. Processes for resolving disputes about oversight findings
and other significant issues shall also be implemented and include provisions for independent
technical reviews of significant issues.
Requirements and Performance Objectives
DOE oversight programs and assurance systems will evaluate performance against requirements
and performance objectives, which may include laws, regulations, national standards, DOE
directives, DOE-approved plans and program documents (e.g., security plans, authorization basis
documents, and quality assurance plans), site-specific procedures/manuals, criteria review and
approach documents, other contractually mandated requirements, and contractual performance
objectives. Requirements and performance objectives are established and interpreted through
approved processes so that they are relevant to the site and mission.
Personnel Competence
Personnel responsible for managing and performing assurance and oversight functions will
possess experience, knowledge, skills, and abilities commensurate with their responsibilities.
Line managers are responsible for ensuring that their personnel with oversight responsibilities
meet applicable qualifications standards. Continuing training and professional development
activities are encouraged to supplement individual experience and provide a means to maintain
awareness of changes and advances in the various fields of expertise.
Baseline Oversight Program and Priorities
Headquarters, field and contractor line management are responsible and accountable for
establishing and implementing a baseline oversight program that provides for an adequate
assessment of programs, management systems, and assurance systems. Clear and unambiguous
lines of authority and responsibility for performing line management oversight functions will be
established and maintained. Line management will provide its oversight processes with
sufficient resources and access to conduct an effective oversight program. Site assurance
systems and DOE oversight processes will be tailored to be effective and efficient and will take
into account hazards and risks (including risks associated with potentially hazardous activities
and risks to DOE missions including schedule, cost, and scope uncertainties). Oversight
priorities are to be based on a systematic analysis of hazards, risks, and past performance of
organizations, programs, and facilities, including previous assessment results. Higher hazard or
risk activities (e.g., facilities with a higher nuclear material attractiveness level) and less mature
programs will be assessed more frequently and/or in more depth. The scope and results of
reviews by external regulators (e.g., the Environmental Protection Agency) and organizations
(e.g., the Defense Nuclear Facilities Safety Board) are important factors in determining oversight
priorities but are not a substitute for effective line management oversight.
DOE Headquarters and field element line management regularly assess site assurance systems to
determine the appropriate level of overlap and redundancy of DOE Headquarters and field
element line management oversight. Accordingly, DOE line management organizations may
increase their frequency and/or depth based on performance deficiencies or events or may
decrease the frequency and/or depth of line management oversight assessments to reflect
sustained effective site performance. Although external organization reviews and the
effectiveness of assurance systems are considered in determining DOE line management
oversight priorities and the scope and frequency of oversight activities, DOE line management
must always maintain an adequate minimum baseline oversight program that enables DOE line
management to understand the hazards and risks of activities.
Performance Indicators and Measures
Performance indicators and measures will be used as one mechanism to help line management
identify adverse trends and promote improvements. This data is considered in a variety of
management decisions, such as allocating resources, establishing goals, identifying performance
trends, identifying potential problems, and applying lessons learned and good practices. Site
performance criteria will focus on results and system-based metrics to drive improvements in site
programs and management systems at DOE sites.
Self-Assessments of Line Management Functions
DOE Headquarters, field element and contractor line management must perform self-
assessments of its activities, including its oversight activities and activities necessary to support
site assurance and mission activities. Headquarters, field element, and contractor management
organizations are responsible for establishing effective management assessments and line
management oversight processes and to address shortcomings, identified through self-
assessments, in their oversight programs.
Federal Responsibility and Accountability for Activities
DOE line management will require that contracts adequately delineate contractor responsibilities
for programs, management systems, and assurance programs. Contractors are responsible for
complying with the terms of their contracts and providing adequate assurances (through
assurance systems) that their contracts are implemented in a safe, secure, and effective manner.
DOE line management and contractors may perform some assessments jointly to increase
efficiency and promote common understanding of processes and results. However, DOE line
management is responsible and accountable for understanding and accepting the hazards and
risks associated with activities. To accomplish this, DOE has the right and responsibility to
perform oversight at the level necessary to understand the hazards and risks, to ensure
compliance with applicable requirements, to pursue excellence through continuous improvement,
to ensure timely identification and correction of deficient conditions, and to verify the
effectiveness of completed corrective actions.
SAMUEL W. BODMAN
Secretary of Energy
DOE contractors are those that operate under contracts governed by 48 CFR 970.5204-2, Laws, Regulations, and DOE
Directives; however, this Policy should also apply to contracts governed by 48 CFR 952.204-2, Security Requirements;
48 CFR 952.204-70, Classification/Declassification; and/or 48 CFR 952.223-71, Integration of Environment, Safety, and
Health into Work Planning and Execution.
DOE line management refers to the management chain with responsibility for the site. This chain typically extends from the
responsible site organization (e.g., site office or field office) to the responsible program office or Under Secretary and ultimately
to the Deputy Secretary and Secretary of Energy.
Independent oversight refers exclusively to oversight by DOE Headquarters organizations that do not have line management
responsibility for the activity.