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DOE O 422.1, Conduct of Operations

Functional areas: Safety,

This Order defines the requirements for establishing and implementing Conduct of Operations Programs at Department of Energy (DOE), including National Nuclear Security Administration (NNSA), facilities and projects. Cancels DOE O 5480.19. Admin Chg 1, 6-25-13

o422.1Final6-29-10.pdf -- PDF Document, 284 KB

Writer: Earl Hughes
Subjects:
  • Safety
ID: DOE O 422.1
Type: Order
OPI: HS - Office of Health, Safety and Security
Status: Archive
Approved Date: Jun 29, 2010
CRD: Yes
DNFSB: No
Invoking Directive: No
Conduct of Operations
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David Williams says:
Oct 20, 2014 05:03 PM

Reference Item 2.i.(1)(a) of Attachment 2, Appendix A: The 7th bullet states "Placement and verification of locks/tags." Are these two separate activities; e.g., placement being one and verification the other?
My understanding from my past experience is that they are two separate activities; however, the way the LOTO procedure is written at my present place of employment suggests it is only one person that installs the lockout and verifies it's installation. They seem to think that verification is aligned with IV and that IV is only for safety-related components.

Secondly, same reference item, the 9th and 11th bullets are not clear that the removal of locks/tags and documenting positioning of the item after removal is documented by the Remover and that the removal and positioning of component is verified by another person. Should this be the case?

Section for Independent Verification on Page A-35 uses the heading for Lockouts and Tagouts.

Items 2.j.(1)(c) and (e) is interpreted by management at my present location to mean that only safety-related system components be considered for independent verification.

Item 2.j.(2)(b), Does this item infer that independent verification is required when taking equipment out of service and returning it to service is required for lockout/tagout, it seems to me that it would because this is why lockout/tagout is performed - to affect repairs where needed. Again, management at my present place of employment seems to think independent verification is only needed when directed by management, that it is an elective activity instead of required at all times when performing lockout/tagout. I think people get confused by the term independent verification - connotation that QA must be involved; needs to make distinction between QA type IV and Independent Peer Verification.

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