Display Related Directives to this directive.
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MANUAL
DOE M 251.1-1B

Approved: 8-16-06

DEPARTMENTAL DIRECTIVES PROGRAM MANUAL

1. PURPOSE. To define requirements and responsibilities for implementing the
Department of Energy (DOE) Directives Program in support of DOE P 251.1A,
Departmental Directives Program Policy, dated 8-16-06, and DOE O 251.1B,
Departmental Directives Program, dated 8-16-06.

2. CANCELLATION. DOE M 251.1-1A, Departmental Directives System Manual, dated
1-30-98. Cancellation of a Manual does not by itself modify or otherwise affect any
contractual obligation to comply with the Manual. Contractor requirements documents
(CRDs) that have been incorporated into or attached to a contract remain in effect until
the contract is modified to either eliminate requirements that are no longer applicable or
substitute a new set of requirements.

3. APPLICABILITY.

a. Departmental Elements. Except for the exclusions in paragraph 3c, this Manual
applies to all Departmental elements. (Go to
http://www.directives.doe.gov/pdfs/reftools/org-list.pdf for the current listing of
Departmental elements.) This list automatically applies to all Departmental
elements created after the Manual is issued.

Directives containing classified or unclassified controlled information (e.g.,
official use only or unclassified controlled nuclear information) are not excluded
from following the formatting standards and conducting an appropriate review.

The Administrator of the National Nuclear Security Administration (NNSA) will
assure that NNSA employees and contractors comply with their respective
responsibilities under this Manual. Nothing in this Manual shall be construed to
interfere with the NNSA Administrator’s authority under section 3212(d) of
Public Law (P.L.) 106-65 to establish Administration-specific policies, unless
disapproved by the Secretary.

b. DOE Contractors. Except for the exclusions in paragraph 3c, the CRD
(Attachment 1) sets forth requirements. The CRD will apply to the extent set
forth in each contract.

c. Exclusions. This Manual does not apply to the development and issuance of DOE
technical standards. (See Chapter I of this Manual for general information.)

4. REFERENCES.

a. P.L. 106-65, Title 32, National Nuclear Security Administration Act, as amended,
which established a separately organized agency within the Department of
Energy.

b. P.L. 104-201, Section 3174, National Defense Authorization Act for FY 1997.

c. P.L. 104-113, National Technology Transfer and Advancement Act of 1995.

d. Title 41, Code of Federal Regulations (CFR), Part 102-193.25.

e. Office of Management and Budget Circular A-119, Federal Participation in the
Development and Use of Voluntary Standards.

f. DOE P 251.1A, Departmental Directives Program Policy, dated 8-16-06.

g. DOE O 251.1B, Departmental Directives Program, dated 8-16-06.

5. CONTACT. Questions concerning this Manual should be addressed to the Office of
Information Resources at 202-586-4716 or by electronic mail to DMTeam@hq.doe.gov.

SAMUEL W. BODMAN
Secretary of Energy

FOREWORD

This Manual supplements DOE P 251.1A, Departmental Directives Program Policy, dated
8-16-06, and DOE O 251.1B, Departmental Directives Program, dated 8-16-06, and provides
detailed Department of Energy requirements, responsibilities, processes, and procedures for
developing, coordinating, and obtaining approval for Department-wide issuance of directives.
The ten chapters are organized as follows.

* Chapter I, Directives Program Overview—describes the DOE Directives Program and the
types of directives developed and processed within the program.

* Chapter II, Directives Development—describes how to obtain approval to develop a
directive and the process for submitting a draft for coordination. Directives structure
(required content and format) is defined.

* Chapter III, Coordination: Review and Comment—defines requirements and
responsibilities for reviewing draft directives and submitting comments to be addressed
before approval.

* Chapter IV, Coordination: Comment Resolution—describes how comments from review
of draft directives are addressed.

* Chapter V, Coordination: Concurrences/Nonconcurrences/Impasse—describes how
conflicting comments and issues are evaluated and resolved.

* Chapter VI, Review and Certification—provides information on the review and
certification process for active directives (i.e., review of a directive to determine whether
it may be certified as current and necessary or must be revised or canceled).

* Chapter VII, Feedback Reporting System – provides information on how to report
feedback on directives that may not adequately address or fulfill the requirements of the
work performed.

* Chapter VIII, Supplemental Directives—describes supplemental directives (i.e.,
directives that assign responsibilities, establish procedures, or otherwise support DOE
directives).

* Chapter IX, Unauthorized Directives—explains how DOE responds to directives issued
outside the Directives Program.

* Chapter X, Exemptions—describes the process for requesting and obtaining exemption
from directives requirements.

In addition to the CRD (Attachment 1), the Manual includes a description of requirements for
assigning directives numbers (Attachment 2), and definitions of Directives Program terms
(Attachment 3).

CHAPTER I. DIRECTIVES PROGRAM OVERVIEW

1. INTRODUCTION. The Directives Program is the means by which DOE policies,
requirements, and responsibilities are developed and communicated throughout the
Department.

a. Directives include Policies, Orders, Notices, Manuals, Guides, and Technical
Standards. Technical Standards are issued by the Office of Environment, Safety
and Health and are not processed through the Directives Program. The directives
hierarchy is described in paragraphs 2 and 3 of this chapter.

b. This Manual sets forth the processes for developing, reviewing, commenting,
resolving major comments, publishing, and cataloging Policies, Orders, Manuals,
Notices, and Guides. Published directives are available online at
http://www.directives.doe.gov.

c. Directives promote safe, efficient, cost-effective DOE operations conducted in
accordance with all applicable laws, regulations, and Executive orders and
supports employees’ safe, secure, effective, and efficient job performance.

d. Directives are developed to communicate requirements, guidance, and methods
for performing work to achieve DOE missions commensurate with performance
based management. DOE directives must apply across at least two Departmental
elements that must share responsibilities for ensuring implementation of the
requirements stated in the directive.

2. DIRECTIVES ESTABLISHING REQUIREMENTS.

a. Policies.

(1) Are established through the Office of the Secretary and reflect the
philosophies and fundamental values of the Department.

(2) Do not contain requirements; however, Orders, Notices, and Manuals may
flow from Policies and must be consistent with them.

b. Orders.

(1) Establish management objectives, requirements, and assignment of
responsibilities for DOE Federal employees.

(2) Establish requirements unique to DOE and avoid duplicating information
from other directives or any existing legal source.

(3) Convey requirements necessary to perform a job or requirements in a
specific subject matter area.

(4) Establish intended requirements for contractors, which must be in the form
of a CRD, which is attached to an Order.
NOTE: An Order template is available at
http://www.directives.doe.gov/directives/writingDirective.html#templates.
c. Notices.

(1) Are similar to Orders; however, they have expiration dates that are no later
than 1 year from their publication dates. There are two types of Notices.

(2) The first type is generated because of an unexpected, serious occurrence or
situation requiring prompt action and is expedited through the directives
process, and expires after 1 year.

(a) Notices of this nature must be converted to or incorporated into
an Order or Manual within 1 year of the effective date of the
Notice.

(b) An extension may be granted through issuance of another Notice
provided work on converting the Notice to a draft Order or Manual
is in progress or provided that the Notice is being converted to a
rule.

(3) The second type is used to communicate information throughout the
Department and may reference requirements from an existing directive.
Notices of this nature are generally not coordinated; however, the Office
of Information Resources reserves the right to place the Notice in the
review and coordination process. They are issued for immediate or
short-term use and expire no later than 1 year from issuance.

NOTE: A Notice template is available at
http://www.directives.doe.gov/directives/writingDirective.html#templates.

d. Manuals supplement other directives, laws, regulations, or other requirements by
providing more instructions or details on how the provisions of those directives or
laws must be carried out throughout DOE. Manuals identify procedural
requirements in more detail than Orders for DOE Federal employees and intended
requirements for contractors, which must be in the form of a CRD attached to the
Manual.

NOTE: A Manual template is available at
http://www.directives.doe.gov/directives/writingDirective.html#templates.

3. DIRECTIVES PROVIDING GUIDANCE.

a. Guides.

(1) Provide preferred, nonmandatory, supplemental information about
acceptable methods for implementing requirements, including lessons
learned, suggested practices, instructions, and suggested performance
measures;

(2) Do not impose requirements but may quote requirements if the sources are
adequately cited; and

(3) Provide alternate methods may be used if it can be demonstrated that they
provide an equivalent or better level of performance.

b. Technical Standards are nonmandatory criteria issued under the Technical
Standards Program. These standards provide possible methodology and criteria
for meeting requirements and can be made mandatory under DOE regulatory or
contractual provisions. Technical Standards are not processed through the
Directives Program.

CHAPTER II. DIRECTIVES DEVELOPMENT

1. INTRODUCTION. This chapter gives instructions for developing DOE directives.
Figure 1in this chapter is a flow diagram of the directives process.

2. DIRECTIVES DEVELOPMENT. Directives are developed in response to legislation,
regulations, changes or development in Departmental policy, changes in technology, or
lessons learned. The steps below must be used in the development of a directive or for
major revisions or page changes to Orders and Manuals.

a. The Office of Information Resources must be contacted for consultation and
training before writing or revising a directive.

b. A justification memorandum, signed by the Secretarial Officer (SO) or senior
level designee, must be sent through the Office of Information Resources to the
Office of Management before developing a new or revised directive (Policies,
Orders, Notices, and Manuals).

(1) The justification memorandum is required for all proposed directives,
including revisions.

(2) The justification memorandum must be sent to the Office of Information
Resources no less than 30 days prior to development of draft directive.

(3) A copy of the justification memorandum is in Appendix A of this chapter
for non-NNSA directives and Appendix B of this chapter for NNSA
directives. [See DOE O 251.1B, paragraph 4a(1)].

c. Subject matter experts, other interested or affected parties, and stakeholders must
be consulted for lessons learned from operating experience where appropriate to
develop directives.

d. Staffs of the central technical authorities must be contacted early in the
development process for directives that affect nuclear safety.

e. All forms must be coordinated with the Departmental Forms Manager in the
Office of Information Resources. (For more information, see DOE G 242.1-1.)

f. All issues must be resolved within the originating organization before submitting
the draft directive to the Office of Information Resources for department-wide
coordination.

g. An editorial review will be performed to examine directive format and conformity
with the directives program, determine compatibility with other directives and
external regulations, and to make certain that provisions are stated clearly and
succinctly.

h. Before the directive is distributed for review, the office of primary interest (OPI)
will review and agree upon editorial changes. (See Chapter III of this Manual for
review and comment.)

3. CONTENT AND FORMAT REQUIREMENTS.

a. Policies. These directives must address the purpose, scope, and policy. However,
since the requirements flowing from Policies are placed in other directives, the
information in Policies should be limited to no more than 4 pages. Additional
information on formatting a Policy statement is available at
http://www.directives.doe.gov/directives/writingDirective.html#templates

b. Orders, Notices and as appropriate, Manuals. The paragraphs specified below
must be used unless a deviation is authorized by the Office of Information
Resources or the NNSA Office of Associate Administrator for Management and
Administration, after consultation with the Office of Information Resources for
NNSA elements.

(1) Purpose. Use this paragraph to define the program or subject matter and
its goals/objectives. Objectives should be stated in simple, straightforward
language, which describes the results to be achieved by the program or
subject matter.

(2) Cancellation. When a new directive replaces one currently in use, the
canceled directive is identified by number, title, and date. If a canceled
directive included a CRD, the following text must be added:
Cancellation of a directive does not, by itself, modify or
otherwise affect any contractual obligation to comply
with the directive. Contractor requirements documents
(CRDs) that have been incorporated into or attached to a
contract remain in effect until the contract is modified to
either eliminate requirement that are no longer
applicable or substitute a new set of requirements.

(3) Applicability. These paragraphs are used to indicate the applicability of a
directive to Departmental elements and contractors and to identify any
exceptions/exclusions. In the example paragraphs below, all italicized
language must be used.

(a) Departmental Elements. Except for the exclusions in
paragraph 3c, this Manual applies to Departmental elements.
(Go to http://www.directives.doe.gov/pdfs/reftools/org-list.pdf
for the most current listing of Departmental elements. This list
automatically includes Departmental elements created after the
Manual is issued.)

The Administrator of NNSA will assure that NNSA
employees and contractors comply with their respective
responsibilities under this directive. Nothing in this
Manual shall be construed to interfere with the NNSA
Administrator’s authority under section 3212(d) of Public
Law. (P.L.) 106-65 to establish Administration-specific
policies, unless disapproved by the Secretary.

In some situations, individual DOE organizations may determine
that an exemption from requirements of a DOE Order, Manual or
Notice is appropriate. A description of the process for obtaining
exemptions is included in Chapter X.

(b) DOE Contractors. If requirements in a DOE Order, Manual, or
Notice are to apply to contractors, the directive must have a CRD,
and the following italicized text must be used.

1 Except for the exclusions in paragraph 3c, the contractor
requirements document (CRD), Attachment 1, sets forth
requirements of this Order/Notice that will apply to
contracts that include the CRD.

2 The CRD must be included in contracts that....
[Here the office of primary interest (OPI) must fill in
criteria that identify to which contracts the OPI intends the
Order to apply. If the OPI intends the CRD to apply to
only certain types of work within a contract, the OPI must
describe that work here. Here also the OPI must articulate
what authority is granted to an official identified in the
responsibilities paragraph to modify the CRD.]

(4) Exclusions. Identify Departmental elements or activities that are excluded
from complying with the directive in this paragraph.

(5) Requirements. Actions that must be completed to achieve the directive’s
purpose must be written as requirements. Requirements must—

(a) be unique to DOE only (e.g., a DOE directive cannot establish
requirements for other Government agencies or the public);

(b) focus on measurable or verifiable outcomes rather than
methodology or procedures;

(c) allow for flexibility in implementation whenever possible to
encourage the most cost-effective means of compliance and ensure
an assessment of safety and risk;

(d) add value commensurate with the cost of implementation;

(e) apply to employees across organizational lines but not be written
as standard operating procedures for an office, organization, or
occupational group;

(f) not duplicate what is in other sources (such as laws, regulations,
other directives or standards) that can easily be referenced; and

(g) not be stated as responsibilities.

(6) Responsibilities. Accountability must be assigned within DOE.

Responsibilities are assigned to those who manage or enforce
requirements.

(a) Responsibilities must cross at least two organizational lines.

(b) Responsibilities must be described in terms of outcome rather than
methodology or procedure.

(7) References. List sources referenced in the directive and any additional
information sources to assist in implementing the directive. Hyperlinks
also may be included.

(8) Definitions may be included to help readers understand requirements or
terminology unique to the technical discipline addressed in the directive.

(9) Critical terms required for a common understanding of the directive and
definitions for health and safety terms in an Order, Notice, or Manual must
be included in definition paragraphs. Glossaries of terms to be used in
establishing safety and health requirements must be incorporated in CRDs
explicitly or by reference.

(10) Necessity Findings Statement must appear in all Orders relating to the
execution of environmental restoration, waste management, or technology
development activities at a defense nuclear facility (new or revised) to
justify the need and identify changes to the requirements. Use the
following boilerplate text:

“In compliance with the statutory requirements in
P.L. 104-201, Sec. 3174, DOE hereby finds that the subject
Order is necessary for the (choose any or all of the
following) (1) protection of human health and the
environment or safety, (2) fulfillment of current legal
requirements, and (3) conduct of critical administrative
functions.”

(11) Contact. Provide the name and telephone number of the responsible
organization.

(12) Contractor Requirements Document. The CRD is attached to an Order,
Manual, or Notice to define requirements that apply to contractors. CRDs
must be incorporated into contracts without alteration and should be
written with this in mind.

c. Manuals. This Manual is an example of an acceptable format.

(1) Manuals may supplement other DOE directives or other legal documents
and are used to provide details or required procedures where necessary to
enable fulfillment of requirements.

(2) Manuals may include some guidance but are primarily a means of
communicating requirements in more detail than would be found in an
Order.

(3) Requirements intended for contractors may be included in a CRD of the
Order that the Manual supplements, or a CRD may be developed for the
Manual.

d. Guides.

Guides follow a more flexible format than what is prescribed for other directives.
The format should be designed to accommodate Guide content. Guides must not
impose requirements but may quote requirements if the sources are adequately
cited.

4. REVISIONS. Changes to a directive may be made as a complete revision or a page
change. Requests for deviations from the types of revision may be submitted in writing
to the Office of Information Resources.

The NNSA Associate Administrator for Management and Administration will approve all
requests from deviations submitted by NNSA elements taking into account
recommendations from the Office of Information Resources.

Requirements that are added, deleted, or modified by a revised Order or Manual must be
presented in the form of a crosswalk showing the disposition of existing requirements.
The crosswalk must be submitted with the first draft and resubmitted with the final
package. (See portal for example, http://www.directives.doe.gov/references/index.html.)

a. Revision.

(1) If the changes increase or decrease requirements or responsibilities and
affect 25 percent or more of the Order or Manual, it is a complete
revision.

(2) When finalized, a revision must be assigned the original number suffixed
with a new capital alpha character and a new approval date.
NOTE: Revisions are not made to Notices and Policies.

b. Page Change.

(1) If proposed changes increase or decrease requirements or responsibilities
and are 24 percent or less of the Order or Manual, then it is a page
change.

(2) When a page change is completed, the directive’s number does not
change.

(3) The page-one directive identifier (upper right) will include the date for the
approved change below the original approval and certification dates.

(4) The header on each page where a change has been made will be revised to
show the change number (ex: Chg 1) and the date on which the page
change was approved. Pages where no change has been made will retain
the original date and will not list the change number.

(5) Revised or deleted text on the changed pages must be identified by vertical
lines.

NOTE: Page changes are not made to Guides.

c. Erratas are cover sheets placed on top of directives to indicate corrections to
names of Departmental elements, titles of officials, legal citations, simple
omissions or typographical errors. Erratas are used at the discretion of the Office
of Information Resources and do not require approval.

5. RESPONSIBILITIES.

a. Secretarial Officers or Senior Level Designees.

(1) Initiate and submit to the Office of Management through the Office of
Information Resources a justification memorandum that describes the
compelling need for a proposed directive.

(2) Ensure that writers, directives points of contact (DPCs), and others receive
training on a yearly basis as appropriate.

b. DOE or NNSA Central Technical Authorities (CTAs) submit
concurrence/nonconcurrence with all changes to directives affecting nuclear
safety.

c. Offices of Primary Interest/Writers.

(1) Contact the Office of Information Resources for consultation and to
schedule training as appropriate.

(2) Under the direction of SOs, develop justification memorandums that
include cost-benefit analysis identifying impact on programs and affected
entities, need for the directive, value added potential, impact on other
directives, and a processing schedule (see definition in Attachment 3).

(a) For non-NNSA elements, the memorandums are submitted to and
concurred on by the Office of Management (see DOE M 251.1 1B,
Chapter II, Appendix A).

(b) NNSA elements will coordinate with the Office of Information
Resources (within the Office of Administration, Office of
Management) prior to beginning development or revision of
directives. A recommendation is forwarded by the Office of
Management to the NNSA Associate Administrator for
Management and Administration for a decision. (See Appendix B
of this chapter.)

(3) Develop draft directives in accordance with legislative, regulatory,
program, and mission needs and management direction.

(4) The OPI should consult with program counsel in GC at the initiation of a
directive and throughout the drafting process. NNSA elements should
consult with their General Counsel at the initiation of a directive and
throughout the drafting process.

(5) Identify requirements added, deleted, or modified by a revised Order or
Manual. This information must be presented in the form of a crosswalk
showing the disposition of existing requirements and must be submitted to
the Office of Information Resources for the first draft and resubmitted
with the final package.

(6) Coordinate draft directive with representatives from Headquarters, field
elements, management and operating contractors (as appropriate), and
stakeholders prior to submission to the Office of Information Resources.

(7) Coordinate draft directives that affect nuclear safety with the staffs of the
central technical authorities prior to submission for Department-wide
review and comment.

(8) Obtain approval of forms placed in draft directives through the
Departmental Forms Manager, Office of Information Resources. NNSA
elements must coordinate with the Departmental Forms Manager
regarding forms in draft directives.

(9) Coordinate with the DOE Departmental Representative to the Defense
Nuclear Facilities Safety Board on all draft directives affecting safety and
health at defense nuclear facilities.

(10) Collaborate with their organizations’ DPCs on draft directives to ensure
that they are coordinated within their organizations and resolve any
internal conflict prior to the draft being submitted to the Office of
Information Resources.

(11) Attend initial training within 18 months of the publication of this Manual
and annual directives refresher training.

d. Headquarters Directives Points of Contact (DPCs).

(1) Attend initial training within 18 months of the publication of this Manual
and annual directives refresher training.

(2) Contact the Office of Information Resources to schedule training upon
assuming the role of DPC.

(3) Collaborate with their organizations’ writers to ensure that there are no
internal issues on the draft directives by obtaining consensus from each
office in their organization.

e. Office of Information Resources.

(1) Provides training and consultation to DPCs, OPIs, and others.

(2) Reviews and recommends concurrence or nonconcurrence and appropriate
processing track for directives justification memorandums.

(3) Monitors compliance with the requirements of DOE P 251.X, DOE
O 251.1B and this Manual.

(4) Supports the OPI in the development of draft directives. This includes
providing expert advice, guidance, consultation, and participation in
development teams, assigning directives numbers, and providing editorial
assistance.

(5) Reviews and approves for non-NNSA elements requests for deviation
from the format of Orders and Notices. Reviews and coordinates NNSA
requests for deviation from the format of Orders and Notices.

(6) With input from the OPI, determines the degree and extent of coordination
required for page changes.

f. Director, Office of Management.

(1) Concurs/non-concurs and assigns a directives track for non-NNSA
elements’ justification memorandum for processing in the Directives
Program.

(2) For NNSA justification memorandums, recommends approval/disapproval
and suggests the directives processing track to the Associate Administrator
of Management and Administration.

g. NNSA Associate Administrator for Management and Administration.

(1) Approves or disapproves all justification memorandums for the
development of new or revised directives for NNSA elements taking into
account recommendations from the Office of Management.

(2) Approves or disapproves NNSA elements’ deviations from established
processing tracks.

h. Departmental Forms Manager reviews and approves for non-NNSA elements all
forms in draft directives. Reviews and coordinates use of forms in NNSA
directives.

i. Office of Human Capital Management provides the Office of Information
Resources an updated organization list, as appropriate.

Figure 1. Flow Diagram of the Directives Process. (See PDF file)

APPENDIX A SAMPLE MEMORANDUM FOR NON-NNSA ELEMENTS

MEMORANDUM FOR: INGRID KOLB
DIRECTOR, OFFICE OF MANAGEMENT

THRU: ROBIN TOPOLSKI
ACTING DIRECTOR, OFFICE OF INFORMATION RESOURCES

FROM: XXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXX

SUBJECT: Notice of Intent to Develop or Revise (identify directive’s
number and title)

PURPOSE: (Identify the basis for the directive and the expected outcomes.)

JUSTIFICATION: (Identify why the new or revision to the directive is required and any
requirements/ obligations this directive is intended to satisfy. Identify
how this directive helps to fulfill the Department’s mission, vision and
strategy. The goal for processing directives actions is 90 days. If you
are seeking an alternative processing time of thirty, sixty, or one
hundred and twenty days, explain why an alternative processing is
necessary.)

(State whether this directive action is included in your Review and
Certification of your organization’s directives. If it is not, please
attach the proposed development schedule. If it is, does the proposed
schedule need to be revised?)

IMPACT: [Include a cost-benefit analysis identifying impact on programs and
affected entities; value added potential; the technical impact (positive
or negative) if appropriate, and impact on other directives, technical
standards, procedures, contracts, etc.]

CONTACT: (Please provide name and telephone number of the point of contact.)

DECISION:
Concur:

Nonconcur:

Timeframe: ___ 30 days ___ 60 days ___ 90 days ___ 120 days

Date:

APPENDIX B—SAMPLE MEMORANDUM FOR NNSA ELEMENTS

MEMORANDUM FOR: MICHAEL KANE
ASSOCIATE ADMINISTRATOR FOR
MANAGEMENT AND ADMINISTRATION

THRU: INGRID KOLB
DIRECTOR, OFFICE OF MANAGEMENT

FROM: XXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXX

SUBJECT: Request to Develop or Revise (identify directive’s number and title)

PURPOSE: (Identify the basis for the directive and the expected outcomes.)

JUSTIFICATION: (Identify why the directive is required and any requirements/
obligations this directive is intended to satisfy. Identify how this
directive fits with the Department’s mission, vision and strategy.)

CONTACT: (Please provide name and telephone number of the point of contact.)

RECOMMENDATION: That you approve the subject directive for development/revision.

OFFICE OF MANAGEMENT’S RECOMMENDATION:
Recommend Approval:

Recommend Disapproval:

Timeframe: ___ 30 days ___ 60 days ___ 90 days ___ 120 days

Date:

NNSA’S DECISION:
Approved:

Disapproved:

Date:

CHAPTER III. COORDINATION: REVIEW AND COMMENT

1. INTRODUCTION. This chapter lists requirements and responsibilities for coordination
(review and comment) of draft directives. Draft directives must be coordinated using
only the RevCom tool.

2. COORDINATION OF DIRECTIVES PROCESS TRACK SCHEDULE. After
development approval and prior to publication, each directive must undergo a review and
comment period using one of four tracks (See Table 1 of this chapter).

3. REVIEW AND COMMENT. For more information on the process, go to
http://www.directives.doe.gov.

a. Drafts of new or revised directives prepared as described in Chapter II will be
submitted to the Office of Information Resources for coordination into the
directives process.

b. All affected DOE and contractor organizations must have the opportunity to
review and comment on new or revised directives.

c. All draft directives will be made available to Departmental elements and
appropriate contractors for comment.

(1) Comments for Policies, Notices, Orders, and Manuals must be categorized
as either “major comments” or “suggested comments.” (See Attachment 3
for a definition of major and suggested comments/issues.)

(2) Comments for Guides will all be categorized as “suggested” and must be
addressed by the OPI.

(3) Comments on page changes must be based only on review of the changed
text. Comments on other areas in the directive will be addressed at the
OPI’s discretion unless accompanied by the express written consent of the
appropriate SO or senior level designee.

(4) A request to limit the number of reviewing organizations for a draft
directive must be included in the Justification Memorandum and agreed to
by MA, GC and the OPI.

d. Comments will be submitted at each organizational level within hierarchical
families, consolidated, and filtered up as follows.

(1) Subject matter experts will submit comments to their DPCs; contractors
will submit comments to their field element DPCs; and delegates and field
DPCs will eliminate duplicated comments and submit consolidated
comments to Headquarters DPCs.

(2) Headquarters DPCs will eliminate duplicated comments and present
consolidated comments for all organizations in their hierarchical family to
their SOs or senior level designees for review and approval.

(3) All consolidated comment packages must be approved by the SO or senior
level designee prior to submitting to the OPI and Office of Information
Resources.

NOTE: Issues and comments received after the initial or extended due date may
not be considered until the next change. Any deviations from comment
period must be requested in writing and final decisions will be made on a
case-by-case basis by the Office of Information Resources or as
appropriate, the NNSA Office of the Associate Administrator for
Management and Administration.

Table 1. Directives Process Tracks

Track type Track 1 Track 2 Track 3 Track 4
Type of Directive Policy Policy, Order Order, Manual Manual
or Notice or Notice or Guide or Guide

P Acceptance/ 1 2 3 3
R Post into
O RevCom
C
E First Draft 10 20 30 35
S Review and
S Comment
I
N Comment 5 15 30 50
G Response/
Issue
D Resolution
A
Y Formatting/ 1 2 3 3
S 2nd Posting
into RevCom

Second Draft 7 10 10 10
Review/
Concurrence

OPI -Finalize 1 4 5 10
directive

Nonconcurrence 15 15 15 15
Resolution/
Impasse

Approval 5 7 9 9

TOTAL 30 60 90 120

TOTAL WITH
IMPASSE 45 75 105 135

Criteria TRACK 1
The directive—
(1) is new or
(2) is accompanied by supporting documentation (i.e., direction from
Secretary, change in laws, regulation, etc.) and
(3) is 2-5 pages in length

TRACK 2
The directive—
(1) is new or
(2) is a limited revision to a current directive,
(3) does not contain complex issues, and
(4) is 6-20 pages in length.

TRACK 3
The directive—
(1) is new or
(2) is an extensive revision and
(3) has complex issues.

TRACK 4

The directive—
(1) is new or
(2) is an extensive revision and
(3) has complex issues.
_________________________________________________________________________________

4. RESPONSIBILITIES.

a. Office of Information Resources.

(1) Manages the directives review process.

(2) Modifies established due dates as appropriate.

b. DOE or NNSA Central Technical Authorities. In cases where draft directives
affect nuclear safety:

(1) Review draft directives.

(2) Provide comments and offer solutions.

(3) Meet established due dates.

c. Departmental Elements (Commenting Organizations).

(1) Review draft directives.

(2) Provide comments and offer solutions to their respective DPCs. To be
considered, the comments must be approved by the SO or senior level
designee and forwarded to the Office of Information Resources.

(3) Meet established due dates. Notify DPCs when extensions of due date are
needed during review and comment.

d. Secretarial Officers or Senior Level Designees approve and submit through their
DPCs their organizations’ consolidated comments on all directives.

e. Offices of Primary Interest (Writers).

(1) Submit draft directives to the Office of Information Resources for
coordination.

(2) Ensure that the Departmental Representative to the DNFSB has a copy of
the draft directive when content includes safety and health in nuclear
facilities.

(3) Ensure that the central technical authority has a copy of the draft directive
when content includes nuclear safety.

(4) Allow flexibility for Departmental elements to negotiate extensions as
long as they adhere to overall processing timeframes. Notify the Office of
Information Resources to extend due date in RevCom. For NNSA
elements, negotiate extensions with the Office of the NNSA Associate
Administrator for Management and Administration and notify the Office
of Information Resources to extend due date in RevCom.

f. Directives Points of Contact.

(1) Establish due dates for commenting on directives for all offices within
their organizations.

(2) Ensure that all offices within their organizations have the opportunity to
comment on draft directives as appropriate.

(3) In consultation with their organization’s management, assign subject
matter experts and delegates as needed for each draft directive issued for
coordination in the Directives Program.

(4) Submit written requests for extension of comment due dates.

(5) Consolidate and eliminate duplication of comments from within their
organizations.

(6) Obtain approval of comments and annotate the SOs or senior level
designees that authorized the comment. The official file copies must be
maintained and available upon request.

(7) Submit comments on behalf of their organizations.

g. Departmental Representative to the Defense Nuclear Facilities Safety Board.

(1) Ensures that the DNFSB is provided an opportunity to comment on draft
directives during the comment review period.

(2) Provides comments from the DNFSB to OPI with a copy to the Office of
Information Resources for resolution.

CHAPTER IV. COORDINATION: COMMENT RESOLUTION

1. INTRODUCTION. This chapter describes how comments from review of draft
directives are addressed. (See Chapter III Table 1 for coordination directives process
tracks schedule.)

2. COMMENT RESOLUTION.

a. All comments authorized by the SO or senior level designee must be responded to
by the scheduled due date. All other comments not authorized by the SO or
senior level designee must not receive response.

b. If the OPI’s proposed resolutions package has not been submitted by the end of
the due date, the directive will automatically be placed in an “on-hold” status.
This will allow the OPI the opportunity to complete the resolution process.

c. If the proposed resolution package has not been completed within a 60 day period
of being on hold, then the directive is withdrawn and the OPI may have to start
the coordination process over from the beginning.

NOTE: The Office of Information Resources will coordinate with the OPI to
make a determination regarding each directive on a case-by-case basis.

d. All comments adopted during the comment resolution period must be
incorporated into a second draft notated in redline/strikeout.

3. RESPONSIBILITIES.

a. Offices of Primary Interest/Writers.

(1) After the comment period has ended, respond to all comments forwarded
under the signatures of SOs or their designees within the specified time
frames.

(2) Generate and submit second drafts to the Office of Information Resources
along with the crosswalk. (See information on the portal at
http://www.directives.doe.govreferences/index.html.)

(3) Obtain approval from SO or senior level designee on responses (resolution
package) prior to submitting to the Office of Information Resources.

b. Office of Information Resources will work with the OPI/writer to respond to all
comments relating to the Directives Program.

c. OPI SO or Senior Level Designee reviews and approves all organizational
responses to comments under their purview.

CHAPTER V. COORDINATION:
CONCURRENCES/NONCONCURRENCES/IMPASSE

1. INTRODUCTION. This chapter describes the concurrence phase of the directives
process. (See Chapter III Table 1 for coordination of directives process track schedule.)
For purposes of this process, where the OPI is an NNSA element, the term
“concurrence” will be construed as “acceptance of proposed resolution” and the term
“nonconcurrence” will be construed as “objection."

2. CONCURRENCE/NONCONCURRENCE PROCESS.

a. A second draft of the proposed changes (notated in redline/strikeout) must be
made available for a final review to allow interested parties an opportunity to
view the cumulative effect of changes produced during the review.

b. Any new requirements or responsibilities added to or deleted from the draft
Policy, Order, Notice, or Manual after the review of the second draft must be
concurred on by NNSA or DOE General Counsel, coordinated with affected
Departmental elements and approved by the Office of Information Resources
and by the Office of NNSA Associate Administrator for Management and
Administration, taking into account the recommendations of the Office of
Information Resources.

(1) Concurrence. If a major comment has been submitted and is incorporated
satisfactorily into the second draft, then the OPI will request a written
concurrence from the Departmental element (SO or senior level designee)
that submitted the major comment.

(2) Nonconcurrence.

(a) Each Departmental element that has submitted major comments on
the directive but does not agree with how the comment(s) have
been incorporation must respond with a nonconcurrence and a
written justification. This must be done with the written approval
of their SO or senior level designee.

(b) Departmental elements that did not comment but are concerned
that the incorporation of others’ comments have an adverse impact
on their organizations’ missions may submit nonconcurrence with
the written approval of the SO or senior level designee and must
provide written justification for the nonconcurrence.

(c) A nonconcurrence must be withdrawn if opposing parties reach
resolution within the review time frame for the second draft.

(d) All nonconcurrences must be resolved before approval for
publication is obtained.

(e) If nonconcurrences cannot be resolved within the second draft
review timeframe, then the opposing parties must follow the
impasse process in paragraph 3 below.

3. IMPASSE PROCESS. This formal process is designed to assist contending
Departmental elements in reaching a resolution/decision. The Office of Information
Resources, as a neutral third party, will facilitate resolution of the issues between the
parties during the following steps of the process.

a. By the end of the second draft review, the OPI must inform the Office of
Information Resources in writing of the major issues that cannot be resolved and
identify the contending Departmental elements.

b. Within 7 days after the closing period of the second draft review, the Office of
Information Resources will facilitate resolution of issues between the OPI and the
commenters.

c. If the issues cannot be resolved at that level, then within the next 8 days the issues
will be elevated to the SOs of the contending Departmental elements for
resolution.

d. If the issues cannot be resolved, the Office of Information Resources will provide
the Deputy Secretary or designee a decision paper that details the contending
Departmental elements’ issues/concerns and their positions.

e. The Deputy Secretary or designee will render a decision based on the
documentation provided.

f. Once the Deputy Secretary has rendered a decision on the issues and approved the
directive for publication, an approval date will be placed on the directive.

NOTE: In cases where NNSA is one of the contending Departmental elements,
only the Secretary or Deputy Secretary can render a decision.

4. SUBMISSION FOR APPROVAL.

a. Once all concurrences are received on the draft directive, it will be forwarded to
the Secretary or Deputy Secretary for approval. An approval date is placed on the
directive.

NOTE: Orders and Manuals must be reviewed and a determination made as to
whether the directive will be revised, certified or canceled. This review
will occur every 4 years after the approval date. A certification date is
placed under the approval date if the Order or Manual continues without
changes. (See Chapter VI, Review and Certification.)

b. Final directives must not be revised for at least 3 months unless the proposed
revisions relate to safety, health, or security.

5. RESPONSIBILITIES.

a. Secretary of Energy approves Policies, Orders, Notices and Manuals or delegates
approval authority to the Deputy Secretary.

b. Deputy Secretary.

(1) As the Secretary’s designee, approves Policies, Orders, Notices, and
Manuals.

(2) Renders a decision on issues that cannot be resolved by the OPI and
opposing Departmental elements (may designate an individual or an ad hoc
working group to resolve issues except when issues involve NNSA
elements).

c. Secretarial Officers or Senior Level Designees.

(1) Review and approve all concurrences and nonconcurrences prior to
submitting to the OPI and Office of Information Resources.

(2) Concur on final draft directives within their purview and co-sign with the
Office of Management on the approval package to the Deputy Secretary.

(3) In the event of an impasse, make every attempt to resolve issues before
elevating to the final level.

d. Assistant Secretary for Environment, Safety and Health works in cooperation with
CTAs to resolve comments concerning directives that affect nuclear safety.

e. Director, Office of Management.

(1) Co-signs with the OPI on action/approval memorandum to the Secretary or
designee, recommending approval/disapproval of final draft directives.

(2) During impasse, mediates issue resolution between SOs of contending
Departmental elements. (This may be delegated to the Director, Office of
Administration).

f. Director, Office of Administration.

(1) Concurs on or for NNSA elements, coordinates all final drafts of Policies,
Orders, Notices and Manuals.

(2) As delegated, during impasse, mediates issue resolution between SOs of
contending Departmental elements. (This may be delegated to the Director,
Office of Information Resources).

g. Director, Office of Information Resources.

(1) Concurs on or for NNSA elements, coordinates all final drafts of Policies,
Orders, Notices and Manuals.

(2) Approves Guides for publication.

(3) As delegated during impasse, mediates issue resolution between SOs of
contending Departmental elements.

h. Office of Information Resources.

(1) Prepares and distributes second draft directives and crosswalks.

(2) Manages the impasse process.

(3) Prepares decision papers with input from contending Departmental
elements.

(4) As a neutral third party, facilitates issue resolution between contending
commenters.

(5) Works with OPIs to prepare approval packages for directives.

i. Offices of Primary Interest (Office Directors and Writers).

(1) Obtain from Departmental elements concurrence on second draft directives.

(2) Resolve comments with the DNFSB in coordination with the Office of the
Departmental Representative to the DNFSB.

(3) Resolve comments with the CTA and in cooperation with ES&H when
directives affect nuclear safety.

(4) When impasse occurs, alert the organizations’ DPCs, SOs or senior level
designees, and the Office of Information Resources by the end of the
10-day second draft directive review.

(5) Comply with the impasse resolution process (paragraph 3 of this chapter).

(6) Obtain the signature of the organizations SO (or senior level designee) on
the approval memorandum and submit it with the final draft directive to the
Office of Information Resources for final processing. (For further details,
see the portal at http://www.directives.doe.gov.)

j. Directives Points of Contact.

(1) With the approval of organizations’ SOs or senior level designees, ensure
that written concurrence or nonconcurrence is provided to the OPI and the
Office of Information Resources within the specified time frame.

(2) Submit detailed comments justifying nonconcurrences and annotate the
SOs or senior level designees that authorized the comments. Official file
copies must be maintained and available upon request.

k. Departmental Representative to the Defense Nuclear Facilities Safety Board
collaborates with the Office of Information Resources to ensure that all issues
have been resolved between the DNFSB and OPI on all directives affecting safety
and health at defense nuclear facilities [see paragraph 5i(3) of DOE O 251.1B].

l. DOE or NNSA Central Technical Authorities.

(1) In cooperation with the Assistant Secretary for Environment, Safety and
Health, work with the OPI to resolve comments concerning directives that
affect nuclear safety.

(2) Submit concurrence/nonconcurrence on final draft directives that affect
nuclear safety prior to publication in RevCom.

CHAPTER VI. REVIEW AND CERTIFICATION

1. INTRODUCTION. It is incumbent upon Departmental elements to ensure that DOE
Policies, Orders, Manuals and Guides remain current. To accomplish this, Orders and
Manuals must be reviewed every 4 years to certify the accuracy and the continued
relevance of the directive or to determine whether any action (i.e., revision or
cancellation) is necessary.

Policies are initiated by the Secretary of Energy; therefore, policy reviews will be at the
discretion of the Secretary. Guides, which do not contain requirements, must be
reviewed if the directives or regulations they supplement are revised or canceled.
There are no cyclical review requirements associated with Notices, which expire 1 year
after issuance unless they are extended (see Chapter I of this Manual).

2. REVIEW AND CERTIFICATION PROCESS. This process provides instructions on the
review of directives and the procedures for certifying the accuracy and the continued
relevance.

a. Assessment of directives will be conducted by the Office of Information
Resources on a yearly basis to determine which directives are due for review.

b. By October 1 of each year, the Office of Management will notify Departmental
elements in writing of the directives under their purview that are in need of action
(certification, revision, or cancellation).

NOTE: The Departmental Representative to the DNFSB must concur on
cancellation of directives that affect safety and health at defense nuclear
facilities and for NNSA elements, consult on cancellation of directives
addressing safety and health at defense nuclear facilities. The
appropriate CTA must concur on the cancellation of directives affecting
nuclear safety.

c. The OPI, under direction of the SO or designee, must review the directives to
determine if there are changes in responsibilities, requirements or references and
recommend revision, certification or cancellation.

d. Under the signature of the SO or senior level designee, the DPC must submit to
the Office of Information Resources by January 15 of each year—

(1) a response to the October 1 call specifying which directives will be
certified, revised, or canceled;

(2) a letter certifying the accuracy and continued relevance of directives, and

(3) a proposed schedule for directives that are subject to revision or
cancellation and new directives unless a justification memorandum has
already been submitted.

NOTE: The proposed schedule must include directives numbers, titles,
dates of submission of justification memorandums, proposed start
and completion dates to include pre-coordination time frame for
each directive and approval dates.

e. All new or revised directives must follow the requirements in Chapters II
through V of this Manual.

f. All proposed schedules will be consolidated into the master DOE directives
review schedule. Proposed schedules will be identified by the color yellow.
After submission of the justification memoranda, a directives processing track
will be assigned. Once the track is assigned, the directive schedule will be
modified and notated in green to reflect acceptance for processing in the
directives program. The master schedule will be available on the directives portal
at http://www.directives.doe.gov and is subject to updates resulting from quarterly
reviews conducted by Office of Information Resources.

g. If the schedule cannot be met, the directive in question will be subject to
withdrawal, rescheduled for a later available date, and notated in red in the
master DOE directives review schedule.

3. RESPONSIBILITIES.

a. Director, Office of Management reviews and approves or for NNSA elements,
coordinates SOs’ directives schedules for the upcoming year. This can be
designated to the Director, Office of Information Resources.
b. Secretarial Officers or Senior Level Designees.

(1) By January 15 of each year, certify that directives under their purview
have been reviewed for accuracy and continued relevance. (see
paragraphs 1 and 2 of this chapter).

(2) Approve annual list of directives scheduled for review by January 15 of
each year.

c. Office of Information Resources.

(1) By October 1 of each year, provides to the OPIs, a written list of directives
under their purview that are in need of action (certification, revision, or
cancellation).

(2) As designated, reviews and approves for NNSA elements, coordinates
SOs’ directives schedules for the upcoming year.

(3) Assists and advises the OPI in determining whether a directive needs to be
certified, revised, or canceled.

(4) Collaborates with OPIs/DPCs in developing schedules for review of
directives.

(5) Maintains the Department’s master directives review schedule on the
directives portal.

(6) Provides monthly directives status reports to the Deputy Secretary.

(7) Upon receipt of certification, enters the certification date on the directive.

d. Offices of Primary Interest (Writers).

(1) Review lists of directives received from the Office of Information
Resources and recommend to their SOs whether the directives should be
certified, revised, or canceled.

(2) Consult with the DOE Departmental Representative to the DNFSB when
canceling directives that affect safety and health at defense nuclear
facilities and consult with the CTA when canceling directives that affect
nuclear safety.

(3) For those directives that will remain in effect, prepare letters of
certification acknowledging their accuracy and continued relevance.

(4) Collaborate with their organizations DPC(s) and the Office of Information
Resources in developing schedules for new or revised directives.

(5) Revise directives when there are significant changes to requirements
and/or responsibilities in accordance with Chapters II through V of this
Manual.

(6) Ensure that directives are processed through the Directives Program
according to schedule.

e. Directives Points of Contact.

(1) By January 15 of each year, submits SOs’ responses to the Office of
Information Resources specifying which directives will be certified,
revised or canceled.

(2) Collaborate with their organization SOs or senior level designees, writers,
and the Office of Information Resources in developing schedules for new
or revised directives.

(3) Maintain schedules of review dates for their organizations’ directives.

CHAPTER VII. FEEDBACK REPORTING SYSTEM

1. INTRODUCTION. This chapter provides information on how to report feedback on
suggested improvements, best practices, or lessons learned of a directive.

2. PROCESS.

a. Report feedback on the directives portal at http://www.directives.doe.gov. A
running list of the feedback will be generated and maintained at this website.

b. Identify directives by number and title when reporting suggested improvements,
best practices, or lessons learned on the directives portal. The system will
generate a response that the feedback has been received.

c. The Office of Information Resources will work with the OPI to determine if—

(1) the directive must be revised immediately or

(2) the changes to the directive may wait until the next revision.

d. If the directive must be revised immediately, then the requirements in Chapters II
through V of this Manual must be followed.

e. If the changes to the directive may wait until the next revision, then
documentation of identified reported deficiencies, best practices, or lessons
learned will be maintained by the Office of Information Resources.

3. RESPONSIBILITIES.

a. Departmental Elements report suggested improvements, best practices, or lessons
learned to the OPI and the Office of Information Resources.

b. Office of Primary Interest (owner of directive).

(1) Review all feedback and work with the Office of Information Resources to
determine the appropriate action.

(2) Revise directive(s) as necessary.

c. Office of Information Resources.

(1) Reviews feedback in the system.

(2) Assists the OPI in determining appropriate action.

(3) Maintains documentation of suggested improvements, best practices, or
lessons learned until next revision of subject directive.

CHAPTER VIII. SUPPLEMENTAL DIRECTIVES

Supplemental directives are issued by a Headquarters or field element for use by that
organization and its contractors.

1. HEADQUARTERS DIRECTIVES.

a. Assigns requirements, responsibilities and establishes procedures at the
Headquarters level.

b. State the relationship to DOE directives clearly.

c. Must not contradict, delete, or duplicate provisions in any applicable Policy,
regulation, Order, Notice, or Manual.

d. Must follow the same process and format as DOE directives, except they are
coordinated only Headquarters-wide.

e. Must have a CRD if the directive contains contractor requirements.

2. FIELD ELEMENT DIRECTIVES.

a. Assign requirements and responsibilities and establish procedures at the field
level.

b. State relationships to DOE directives clearly.

c. Must not contradict, delete, or duplicate provisions in any applicable Policy,
regulation, Order, Notice, or Manual.

d. Must have CRDs if the directives contain contractor requirements.

CHAPTER IX. UNAUTHORIZED DIRECTIVES

1. INTRODUCTION. This chapter describes a process for handling documents that should
be within the Directives Program but have been issued outside the program.

a. Requirements that cross organizational lines (i.e., apply to more than one
organization) but are not issued within the Directives Program are considered
unauthorized directives.

b. The concerns with unauthorized directives are as follows.

(1) They may fail to receive appropriate evaluation by all affected parties.

(2) They could be ignored or forgotten over time, due to lack of accessibility
in a structured retrieval system.

(3) The contents could result in unintended technical, financial, or legal
consequences.

c. Requirements not properly established in a DOE directive’s CRD and
incorporated into a contract will not be governed by specific contract terms and
conditions.

2. HANDLING UNAUTHORIZED DIRECTIVES. The Office of Information Resources
will review all suspected unauthorized directives to determine whether they should be in
the Directives Program and work with the appropriate OPI to disposition the document in
one of the following ways.

a. The OPI may withdraw the document if it no longer requires compliance.

b. The OPI may modify the document (e.g., restrict its applicability to one
organization) so that it no longer fits the description of an unauthorized
directive.

c. The OPI may propose converting the document to a directive following the
process described in Chapters II through V of this Manual.

3. RESPONSIBILITIES.

a. Departmental Elements.

(1) Notify the Office of Information Resources of documents that may
improperly distribute information outside the Directives Program.

(2) Provide the Office of Information Resources a copy of the suspected
unauthorized document.

b. Office of Information Resources.

(1) Reviews all suspect documents received to determine whether they
contain material that should be included in the Directives Program.

(2) Requests appropriate actions on handling unauthorized directives as stated
in paragraph 2 of this chapter.

(3) Reports to all concerned parties as appropriate.

CHAPTER X. EXEMPTIONS

1. GENERAL PROVISIONS. An exemption under the Directives Program is a release
from one or more requirements in a DOE Order, Notice, or Manual that has been granted
to a DOE element or a contractor.

If the Order, Notice, or Manual includes specific provisions for exemptions,
equivalencies, or other forms of relief from the requirements in the document, then those
provisions must be applied.

If the document does not include specific provisions for relief, the process in this chapter
applies to granting permanent or temporary relief from the applicable requirements in
those documents.

This exemption process does not apply to requirements in regulations.

An approved exemption must be submitted to the Office of Information Resources.

a. Requirements for Federal Employees.

When a DOE Order, Notice, or Manual is issued, the requirements in that
document automatically apply to Federal elements as stated in the document. To
acquire exemption from a requirement in a directive, a Federal element must use
the relief process specifically included in the directive, or if there is no relief
process in the directive, the exemption process in this chapter. Federal elements
are required to meet all applicable directives requirements unless relief is granted
through one of these processes. An exemption granted to a contractor does not
relieve Federal elements from the responsibility to obtain an exemption to related
requirements for Federal elements.

b. Requirements for Contractors.

(1) Requirements in DOE Orders, Notices, and Manuals apply to contractors
to the extent that they are incorporated in the contract. Contracting
officers incorporate requirements from directives by referencing or
copying sections of the CRD into the contracts.

(2) As stated in Department of Energy Acquisition Requirements (DEAR)
48 CFR 970.0470(b), the program office must identify requirements in the
Directives System that are applicable to a contract, develop a list of
applicable requirements, and provide the list to the contracting officer.
The contracting officer must include that list in the contract. That list
constitutes the list of applicable directives referred to as List B in
48 CFR 970.5204-2.

(3) In some cases, requirements included in List B will be tailored to the
specific hazards and needs of activity through a DOE-approved process.
Such processes include the Standards/Requirements Identification (S/RID)
Process, the Work Smart Standards Process, and the Safety Management
System [See 48 CFR 970.0470(c) and (d)]. If a requirement from a
directive is excluded from List B using one of these processes, then it is
not a contract requirement and does not require requesting an exemption.

(4) If a requirement of a directive is included in List B of the contract and
temporary or permanent relief from the requirement is sought, use this
exemption process (unless there is another relief process specifically
included in the directive).

2. EXEMPTION APPROVAL PROCESS.

a. NNSA Facilities and Activities.

(1) Review and Approval.

(a) The approval authority must provide copies of the exemption
request, appropriate supporting documentation, and the draft
exemption, and with respect to each exemption request views from
the following parties before granting an exemption:

1 the CSO;

2 the OPI;

3 EH for environment, safety, and health (ES&H)
requirements; and

4 the NNSA CTA for requirements listed on the NNSA Index
of Baseline Nuclear Safety Requirements.

(b) The approval authority may not grant the exemption until—

1 the parties have indicated that there is no objection or

2 thirty (30) calendar days have passed without objection
after providing the parties the draft exemption and
associated documentation (If a party requests additional
information they will be granted an additional 14 calendar
days after requested additional information has been
provided).

1 Work with the objecting party to resolve any issues and
withdraw the objection.

2 For unresolved objections from NNSA personnel, raise the
issue to the NNSA Administrator or designee for
resolution.

3 For unresolved objections from parties outside of NNSA,
raise the matter through the NNSA Administrator or
designee to the Deputy Secretary for resolution.

(2) Approval Authority. Unless otherwise stated in the directive, approval is
as follows.

(a) Heads of Departmental NNSA elements (which include operations
and field office managers) approve exemptions to requirements in
DOE Orders, Notices, and Manuals for activities and facilities
under their direction except as provided in paragraph 2a(2)(b).

(b) For ES&H requirements in Orders, Notices, and Manuals for
hazard category 1 nuclear facilities, the Under Secretary for
Nuclear Security approves exemptions. This authority may be
delegated to other heads of Departmental NNSA elements.
b. ESE Facilities and Activities.

(1) Concurrence.

(a) The approval authority must provide copies of the exemption
request, appropriate supporting documentation, and the draft
exemption, and request concurrence on each exemption from the
following parties before granting an exemption:

1 the CSO;

2 the OPI;

3 EH for environment, safety, and health (ES&H)
requirements; and

4 the ESE CTA for requirements listed on the ESE Index of
Baseline Nuclear Safety Requirements.

(b) The approval authority may not grant the exemption until—

1 the parties have concurred or

2 thirty (30) calendar days have passed without
nonconcurrence after providing the parties the draft
exemption and associated documentation (if a party
requests additional information they will be granted an
additional 14 calendar days after requested additional
information has been provided).

1 Work with the nonconcurring party to resolve any issues
and withdraw the nonconcurrence.

2 For nonconcurrences from DOE personnel, raise the issue
to the Under Secretary for Energy or the Under Secretary
for Science, as appropriate for resolution.

3 For nonconcurrences from parties outside of ESE, raise the
matter to the Deputy Secretary for resolution.

(2) Approval Authority. Unless otherwise stated in the directive approval is as follows.

(a) Heads of Departmental elements (which include operations and
field office managers) approve exemptions from requirements
from DOE Orders, Notices, and Manuals for activities and
facilities under their direction except as provided in Paragraph
2b(2)(b).

(b) For ES&H requirements in Orders, Notices, and Manuals for
hazard category 1 nuclear facilities, the Under Secretary for
Energy, Science and Environment approves exemptions to
requirements in DOE Orders, Notices, and Manuals. This
authority may be delegated to other heads of Departmental
elements.

c. Other than NNSA or ESE Facilities and Activities.

(1) Concurrence.

(a) The approval authority must provide copies of the exemption
request, appropriate supporting documentation, and the draft
exemption and request concurrence on each exemption from the
following parties before granting an exemption:

1 the CSO;

2 the OPI; and

3 EH, for environment, safety, and health (ES&H)
requirements.

(b) The approval authority may not grant the exemption until—

1 the parties have concurred, or

1 Work with the nonconcurring party to resolve any issues
and withdraw the nonconcurrence.

2 Raise the matter to the Deputy Secretary for resolution.

(2) Approval Authority. Unless otherwise stated in the directive, heads of
Departmental elements (which include operations and field office
managers) approve exemptions from DOE Orders, Notices, and Manuals
for activities and facilities under their direction.

3. EXEMPTION REQUESTS.

a. Requests for exemptions must include the following information.

(1) Site or facility for which an exemption is being requested.

(2) Reference to the requirements for which exemption is sought.

(3) Identification and justification of the acceptance of any additional risks
that will be incurred if the exemption is granted.

(4) Benefits to be realized by providing the exemption.

(5) Whether the exemption being requested is temporary or permanent and for
temporary exemptions, indication of when compliance will be achieved.

(6) Identification of other pertinent data or information used as a basis for
obtaining an exemption.

b. Requests for exemptions to environment, safety, and health requirements must
also address the following:

(1) A description of any special circumstances that warrant the granting of an
exemption, including whether—

(a) application of the requirement in the particular circumstances
would conflict with another requirement;

(b) application of the requirement in the particular circumstances
would not achieve, or is not necessary to achieve its underlying
purpose;

(c) application of the requirement in the particular circumstances
would not be justified by any safety and health benefit;

(d) the exemption would result in a health and safety benefit that
compensates for any detriment that would result from granting the
exemption; or

(e) other material circumstances that exist were not considered when
the requirement was adopted for which it is in the public interest to
grant an exemption.

(2) Steps to be taken to provide adequate protection of health, safety, and the
environment, and a statement that adequate protection will be provided.

(3) A description of any alternative or mitigating actions that have or will be
taken to ensure adequate safety and health and protection of the public, the
workers, and the environment for the period the exemption will be
effective.

4. APPROVAL CRITERIA.

For all exemption decisions, the basis for approving the exemption must be documented
in the approval and the approving authority may grant an exemption only if the
exemption—

a. is not prohibited by law;

b. would not present an undue risk to public health and safety, the environment,
facility workers, or security; and

c. is warranted under the circumstances.

CONTRACTOR REQUIREMENTS DOCUMENT
DOE M 251.1 1B, Departmental Directives Program, dated 8-16-06

Regardless of the performer of the work, the contractor is responsible for complying with the
requirements of this contractor requirements document (CRD). The contractor is responsible for
flowing down the requirements of this CRD to subcontractors at any tier to the extent necessary
to ensure the contractor’s compliance with the requirements.

1. The contractor must comply with directions from the contracting officer regarding
participation in DOE’s directives comment and review process.

2. The contractor must comply with requirements stated in Appendix A when it believes an
exemption is necessary or appropriate for a requirement in any CRD made a part of its
contract.

APPENDIX A. CONTRACTOR EXEMPTION

1. GENERAL PROVISIONS.

An exemption under the Directives Program is a release from one or more requirements
included in a DOE Order, Notice, or Manual that has been granted to a DOE element or a
contractor. Specific provisions for exemptions, equivalencies, or other forms of relief
from the requirements in an Order, Notice, or Manual must be used when applying for or
approving exemptions. If the document does include specific provision for relief, the
contractor must use the process in this appendix to grant permanent or temporary relief
from the applicable requirements in those documents. This exemption process does not
apply to requirements in regulations. Requirements for contractors are as follows.

a. Requirements in DOE Orders, Notices, and Manuals apply to contractors to the
extent they are incorporated in the contract. Contracting officers incorporate the
requirements from applicable directives by referencing or copying sections of the
contractor requirements document (CRD) into the contract.

b. As stated in Department of Energy Acquisition Requirements (DEAR) 48 CFR
970.0470(b), the program office must identify the requirements in the Directives
System that are applicable to a contract, develop a list of applicable requirements,
and provide the list to the contracting officer. The contracting officer must
include that list in the contract. That list constitutes the list of applicable
directives referred to as “List B” in 48 CFR 970.5204-2.

c. In some cases, the list of requirements included in List B will be tailored to the
specific hazards and needs of activity through a DOE-approved process. Such
processes include the Standards/Requirements Identification Process (S/RID), the
Work Smart Standards Process, and the Safety Management System [See 48 CFR
970.0470(c) and (d)]. If a requirement from a directive is excluded from List B
using one of these processes, then it is not a contract requirement and the
contractor do not need to request an exemption.

d. If a CRD or set of requirements from a directive is included in List B of the
contract and temporary or permanent relief from the requirement is sought, the
contractor must work with DOE officials to follow the process described in this
CRD (unless there is another relief process specifically included in the CRD for
the directive).

2. EXEMPTION REQUESTS.

a. Requests for exemptions must include the following information.

(1) Site or facility for which an exemption is being requested.

(2) Reference to the requirements for which exemption is sought.

(3) Identification and justification of the acceptance of any additional risks
that will be incurred if the exemption is granted.

(4) Benefits to be realized by providing the exemption.

(5) Whether the exemption being requested is temporary or permanent and,
for temporary exemptions, indication of when compliance will be
achieved.

(6) Identification of other pertinent data or information used as a basis for
obtaining an exemption.

b. Requests for exemptions to environment, safety, and health requirements must
also address the following:

(7) A description of any special circumstances that warrant the granting of an
exemption, including whether—

(a) application of the requirement in the particular circumstances
would conflict with another requirement;

(b) application of the requirement in the particular circumstances
would not achieve, or is not necessary to achieve, the underlying
purpose of the requirement;

(c) application of the requirement in the particular circumstances
would not be justified by any safety and health benefit;

(d) the exemption would result in a health and safety benefit that
compensates for any detriment that would result from granting the
exemption; or

(e) there exists any other material circumstance that was not
considered when the requirement was adopted but for which it is in
the public interest to grant an exemption.

(8) Steps to be taken to provide adequate protection of health, safety, and
the environment, and a statement that adequate protection will be
provided.

(9) A description of any alternative or mitigating actions that have or will be
taken to ensure adequate safety and health and protection of the public, the
workers, and the environment for the period the exemption will be
effective.

3. APPROVAL CRITERIA.

For all exemption decisions, the basis for approving the exemption must be documented
in the approval and the approving authority may grant an exemption only if the
exemption—

a. is not prohibited by law;

b. would not present an undue risk to public health and safety, the environment,
facility workers, or security; and

c. is warranted under the circumstances.

4. EXEMPTION APPROVAL PROCESS.

a. If the contractor is the organization initiating an exemption request, the
exemption request must be submitted to the contracting officer (or the contracting
officer’s representative if so directed).

b. DOE’s concurrence process.

(1) Unless otherwise stated in the relevant directive, the Approval Authority is
as follows:

(a) Heads of Departmental elements (which include operations and
field office managers) approve exemptions to requirements in DOE
Orders, Notices, and Manuals for activities and facilities under
their direction unless otherwise provided.

(b) For ES&H requirements in Orders, Notices, and Manuals for
hazard category 1 nuclear facilities, the Under Secretary for
Energy, Science and Environment approves exemptions. This
authority may be delegated to other heads of Departmental
elements.

(2) The Approval Authority must provide copies of the exemption request,
appropriate supporting documentation, and the draft exemption, and
request concurrence on each exemption from the following parties before
granting an exemption:

(a) the Cognizant Secretarial Officer;

(b) the office of primary interest for the specific directive;

(d) the Central Technical Authority, if applicable.

(3) The approval authority may not grant the exemption until—

(a) the parties have concurred or

(b) thirty (30) calendar days have passed without nonconcurrence after
providing the parties the draft exemption and associated
documentation (a party who requests additional information will be
granted an additional 14 calendar days after requested additional
information has been provided).

(4) If one of the parties submits nonconcurrence, the approval authority must
do the following or deny the exemption:

(a) Work with the conflicting parties to resolve any issues and
withdraw the nonconcurrence.

(b) Raise the issue to the applicable higher authority or authorities for
resolution.

DIRECTIVES NUMBERING SYSTEM

1. NUMBERING DIRECTIVES.

All Policies, Orders, Notices, Manuals, and Guides have a letter identifying the type of
document, a three-digit number identifying the subject matter category, a suffix showing
the sequence within that subject matter category, and for revisions, a capital alpha
character indicating the revision level. In the case of page changes or administrative
changes, the numbering stays the same.

2. EXAMPLES. The following examples show how the numbering system works for
various directives.

a. Policies. In DOE P 111.1, Departmental Organization Management System,
“P” stands for Policy, 111 is the subject matter category (Organization and
Structure), and “.1” indicates the first policy directive in this category.
Subsequent revisions will be “.1A,” “.1B,” etc.

b. Orders. In DOE O 151.1, Comprehensive Emergency Management System, “O”
stands for Order, “151” is the subject matter category (Public Affairs in
Emergencies), and “.1” indicates that this is the first Order in this category.
Subsequent revisions will be “.1A,” “.1B,” etc.

c. Notices. In DOE N 251.1, Cancellation of Directives, “N” stands for Notice,
“251” is the subject matter category (Directives Program), and “.1” indicates that
this is the first of sequential issuance to the Notice.

d. Manuals. In DOE M 251.1-1A, Directives Program Manual, “M” stands for
Manual, “251” is the subject matter category (Directives), “.1” indicates that this
Manual supplements DOE O 251.1, “-1” indicates that this is the first Manual
supplementing that particular Order, and A indicates a revision to that Manual. If
the Order is revised to be DOE O 251.1A, there is no change in the number of the
Manual. If the Manual were revised, its number would become DOE M
251.1-1B.

e. Guides are numbered the same as Manuals, but the initial letter designator is “G.”
To accommodate circumstances in which regulations, rather than Orders, contain
the requirements, the primary three-digit code would be used. For example, a
quality assurance Guide might be labeled DOE G 414.1-1 because it is based on a
regulation rather than an Order.

DEFINITIONS

1. Certification. Process for reviewing and certifying directives that have been in effect for
4 or more years, for accuracy and continued relevance. A certification date will be placed
below the approval date on the directive.

2. Cognizant Secretarial Office (CSO). A Program Secretarial Office that has responsibility
as an owner for a program-specific (programmatic) facility or area present on a site that is
owned by another program office (the LSO). The CSO coordinates with the site owner
(the LSO) to ensure needed infrastructure support is planned and provide for its
facilities/area.

3. Contractor. For purposes of the directives system, corporate organizations under contract
with DOE to perform services with the clause at DEAR 970.5204-2, laws, regulations and
DOE directives, in their contract.

4. Coordination. Process of appropriate review for all draft directives involving all
affected/interested organizations, including contractors, to have the opportunity to review
and comment on draft directives.

5. Comment Resolution. Process of OPI responding to comments received during the
review of draft directives. All major comments submitted on behalf of the SO or senior
level designee must be addressed and resolved before a directive is approved.
6. Central Technical Authorities. The designated line managers in the Department and the
National Nuclear Security Administration who are responsible for maintaining
operational awareness, especially with respect to complex, high-hazard nuclear
operations, and for ensuring that the Department’s nuclear safety policies and
requirements are implemented adequately and properly.

7. Decision Paper. Document prepared by the Office of Information Resources and the
contending Departmental elements when an impasse occurs on a draft directive and must
be referred to the Deputy Secretary for resolution. Decision papers contain opposing
viewpoints representing all parties.

8. Departmental Elements. First-tier organizations reporting directly to the Secretary,
Deputy Secretary, or Under Secretaries. The National Nuclear Security Administration is
a Departmental element. First-tier organizations at Headquarters include the Secretary,
Deputy Secretary, Under Secretaries, and Secretarial Officers (Assistant Secretaries and
staff Office Directors). First-tier organizations include managers of the field offices and
Administrators of the Power Marketing Administrations.

9. Directives. Official communications of policies, requirements and procedures.
Directives are used to inform, direct, and guide employees in the performance of their
work and to enable employees to work effectively within the Department and with other
Government agencies, contractors, and the public. Directives include Policies, Orders,
Notices, Manuals, and Guides.

10. Directives Point of Contact (DPC). The DPC is designated by the Departmental element
and provides the liaison between his/her organization and the DOE Directives Program.
(See http://www.directives.doe.gov/directives/rolesDpc.html for a comprehensive
description of DPC roles and responsibilities.)

11. Deviations (from requirements). Failure to comply with the requirements.

12. Exemptions (from requirements). Formal request from appropriate parties to allow
Departmental elements or contractor to be excluded from complying with the
requirements of the directive.

13. Field Elements. Consist of operation offices, service centers, site offices, area offices,
power marketing administrations, regional offices of federally staffed laboratories.

14. Impasse. A process to elevate the issues quickly through the management chain of
contending Departmental elements when resolution cannot be obtained at staff level.
Major issues are first attempted to be resolved between the OPI and commenters. If
issues are not resolved then it is elevated to the office directors of contending
Departmental elements for resolution. Issues that cannot be resolved at that level are
elevated to the SOs of the contending Departmental elements for resolution. Issues that
cannot be resolved at the SO level are elevated to the Deputy Secretary or designee to
render a decision.

15. Major Issue/Comment. A category of review comments that addresses issues serious
enough to preclude or significantly hamper the Department’s ability to—

a. accomplish policy objectives and missions;

b. comply with applicable laws, rules, and regulations; and

c. fulfill contractual obligations and formal commitments.

16. Necessity Findings Statements. A paragraph in Orders required by P.L. 104-201, Sec.
3174, to justify the need for an Order.

17. Office of Primary Interest. The author’s office. The office responsible for originating the
directive.

18. Page Change. When an Order or Manual is modified to affect less than 25 percent of the
requirements or responsibilities.

19. Pre-coordination. Preliminary coordination of draft directives with affected stakeholders
to help alleviate unanticipated issues received during the department-wide coordination
process.

20. Processing schedule. The time frame in which the OPI requests that the draft directive be
processed through the directives program.

21. RevCom. A web-based work-flow application used by the Department of Energy for the
development and coordination of draft directives, technical standards, and regulations.

22. Review Date. The date on the directive in which the office of primary interest must
complete the review of their directive to determine whether it must be revised, continued
as is, or canceled.

23. Requirement. Activities that must be performed to fulfill the Department’s mission, law
or regulations.

24. Revision. When directives are modified to affect more than 25 percent of the
requirements or responsibilities or contents.

25. Secretarial Officer. Secretarial Officers are: the Secretary, Deputy Secretary, and Under
Secretaries; and the Assistant Secretaries and Program Office Directors reporting to the
Secretary either directly or through the Deputy Secretary or Under Secretaries. The
NNSA Administrator and Deputy Administrators are Secretarial Officers.

26. Suggested Comment. A category of review comment not related to any potentially
serious, adverse effects that might devolve on an organization, through implementation of
a draft directive.

27. Supplemental Directives. Directives issued by a Headquarters or field element for use by
that organization and its contractors.

28. Unauthorized Directives. Documents containing information that should be within the
Directives Program but has been issued outside the Program (e.g., requirements
documents that cross organizational lines/apply to more than one organization).
Sometimes referred to as rogue directives.

29. Variance (from requirements). The difference between what is expected and what
actually occurs.