PSD-8
Washington Closure Hanford (WCH)
10 CFR 851 Compliance Matrix
Rev. 0
FEBRUARY 2010
PSD-8, Rev. 0
02/08/2010
Page 1 of 70
Revision History
Revision
February 2010
Date
02/08/10
September 2009
09/17/09
PSD-8, Rev. 0
02/08/2010
Reason for Revision
Revision to incorporate:
 Hanford site-wide program for Stop Work (DOE-0343, Stop Work)
 Hanford site-wide program for Beryllium (DOE-0342, CBDPP)
 Changes to initial and requalification training requirements (BSC-1-2.4, Rev. 6)
Add Revision History.
Annual validation of all references and citations.
Revision Initiator
G. Sly
G. Sly
Page 2 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
Safety and Health Program
Responsibilities
Safety and Health Functional
Elements
(a) Management responsibilities.
Contractors are responsible for the
safety and health of their workforce
and must ensure that contractor
management at a covered workplace:
#1
(1) Establish written policy, goals,
and objectives for the worker safety
and health program;
#2
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.20 Management Responsibilities and Worker Rights and Responsibilities
Entire procedure implements program
SH-1-1.1
responsibilities.
Functional elements include:
SH-1-1.1
 Safety and health Program Management
 Construction and Industrial Safety
 Industrial Hygiene
 Fire Protection
 Fire Arms Safety (not applicable)
 Electrical Safety
 Pressure Safety
 Explosives Safety
 Biological Safety (not applicable)
 Motor Vehicle and Aviation Safety
 Occupational Medicine
“… Execution of the following elements is
PM-ESHQ-3, Sect. 1.1
the basis for the success of the WCH
program:…
3. Hold management and supervision
responsible and accountable to see that:
· Applicable rules and procedures are
established and enforced
· Effective training programs are employed
· Safety is integrated into each work task in
order to avoid occupational injuries and
illnesses
· Controls are integrated into each work
task to prevent events that could result in
radiological consequences
· Provisions for protection of the
environment, including pollution prevention
and resource conservation, are integrated
into each work task.”
“Washington Closure Hanford (WCH) is
PM-ESHQ-3, Sect. 1.0
committed to developing and maintaining a
culture based on an “injury-free workplace”
philosophy, under which all accidents are
preventable and occupational injuries and
illnesses are not acceptable. The purpose of
this document is to describe the WCH
policy and program elements that are
instrumental to the success of meeting that
commitment…”
“The purpose of this procedure is to
QA-1-1.15, Sect. 1.0
describe the methods used by Washington
Closure Hanford (WCH) to develop,
review, approve, and submit ISMS
Performance Objectives, Measures, and
Subcontractor
Procedure Citation
Page 3 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
(2) Use qualified worker safety and
health staff (e.g., a certified
industrial hygienist, or safety
professional) to direct and manage
the program;
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.20 Management Responsibilities and Worker Rights and Responsibilities
Commitments (POMCs) to DOE for
approval…”
“Safety and Health…Provide and maintain
SH-1-3.1, Sect. 4
the necessary staff and resources to
develop, implement, and maintain the WCH
ISP”
“Manager Safety and Health…Responsible
SH-1-4.1, Sect. 4
for providing and maintaining the necessary
staff and resources to develop, implement,
and maintain the WCH IH Program”
Subcontractor
Procedure Citation
#3
SH-1-5.1, Sect. 4
(3) Assign worker safety and health
program responsibilities, evaluate
personnel performance, and hold
personnel accountable for worker
safety and health performance;
SH-1-1.1, Sect. 4
BSC-1-1.9, Sect. 1
#4
BSC-1-1.8, Sect. 5
#5
(4) Provide mechanisms to involve
PSD-8, Rev. 0
02/08/2010
PM-ESHQ-3, Sect. 1.1
“Manager Safety and Health…Designates a
certified industrial hygienist as the WCH
Industrial Hygiene Program Administrator”
“1. Safety and Health (S&H) management
is responsible for providing and maintaining
the necessary fire protection staff and
resources to develop, implement, and
maintain the WCH FPP”
“Project Manager…Overall responsibility
for WCH S&H program content,
implementation, and management”
“S&H Program Leads…Responsibility for
S&H program content and requirements as
the primary S&H subject matter expert at
WCH projects and facilities”
“…The performance review process
provides an opportunity for managers and
employees to document the outcome of a
mutually beneficial dialogue focused on:
Safety…..”
“WCH requires management to establish
realistic performance objectives to
recognize and reinforce good performance
and to work with employees to meet
performance expectations. Employees are
required to perform according to the
expectations outlined in the Company’s
Standards of Conduct (Attachment A),
Conduct of Operations, Policies and
Procedures, and Federal and State Laws,
and to coordinate with appropriate
management to meet established individual
performance objectives.”
“1. Integrate safety and health
Page 4 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
workers and their elected
representatives in the development
of the worker safety and health
program goals, objectives, and
performance measures and in the
identification and control of hazards
in the workplace;
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.20 Management Responsibilities and Worker Rights and Responsibilities
considerations into business planning and
decision making processes; including
project research, development, planning,
design, construction, and demolition…”
“…Support and promote employee safety
committees (Local Safety Improvement
Teams) that provide employees a means to
communicate their safety concerns and
recommendations to management…”
SH-1-3.1, Sect. 6.1.2 (11)
PM-ESHQ-8, Sect. 4.0
PAS-2-1.1, Sect. 6.3.5
QA-1-1.15 Sect. 6.1.1
QA-1-1.15 Sect. 6.2.1
PSD-8, Rev. 0
02/08/2010
Subcontractor
Procedure Citation
“…Include employees in the work planning
and hazard identification processes..”
“Lessons Learned are reviewed with
employees to increase safety awareness and
to prevent the recurrence of accidents and
incidents”
“Local Safety Improvement
Teams…Participate in the development and
presentation of the monthly safety meetings
to the extent possible to ensure alignment of
safety meeting topics with areas of LSIT
interest.”
“The Work Control Planner and various
project and Planning Team members may
conduct walkdowns of the work area
throughout all phases of JHA and work
package planning and preparation.
Personnel participating in these walkdowns
shall read and follow all relevant safety
guidance (e.g., HCD)…”
“The ISMS Coordinator collects WCH
performance data from the Corrective
Action Management (CAM) process, ISMS
affecting assessments, VPP reviews, and
other relevant information sources to be
used as the source material for development
of a draft ISMS data summary report.”
“…These information sources (feedback
mechanism) include but are not limited to,
WCH performance measures, independent
and management assessment, readiness
assessments, RL Facility Representative
Technical surveillances/assessments, the
draft ISMS draft summary report, and
external organizational assessments.”
Page 5 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
(5) Provide workers with access to
information relevant to the worker
safety and health program;
#6
6) Establish procedures for workers
to report without reprisal job-related
fatalities, injuries, illnesses,
incidents, and hazards and make
recommendations about appropriate
ways to control those hazards;
#7
(7) Provide for prompt response to
such reports and recommendations;
#8
(8) Provide for regular
communication with workers about
workplace safety and health matters;
#9
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.20 Management Responsibilities and Worker Rights and Responsibilities
“Every employee performing work on the
PM-ESHQ-9, Sect. 1.1 (2)
Washington Closure Hanford Team has the
following guaranteed right, without fear of
reprisal, to:…
2. Access to safety and health publications,
programs, standards, procedures, and
posters applicable to the RCCC. Access
to limited information on recordkeeping
log (OSHA Form 300). Access to DOE
Form 5484.3 (OSHA Form 301), that
contains the employee’s name as the
injured or ill worker…”
PM-ESHQ-4
See DOE-0343, Stop Work
DOE-0343, Stop Work
<http://www.hanford.gov./hanford/files/
Hanford_Stop_Work_Procedure.pdf>
PM-ESHQ-4
See DOE-0343, Stop Work
DOE-0343, Stop Work
<http://www.hanford.gov./hanford/files/
Hanford_Stop_Work_Procedure.pdf>
”The purpose of this policy is to establish
PM-HR-15, Sect. 1
Washington Closure Hanford’s expectation
that all employees will work in a safety
conscious work environment in which they
are free to raise issues, concerns, and
questions without fear of retaliation …”
PM-ESHQ-4
See DOE-0343, Stop Work
DOE-0343, Stop Work
<http://www.hanford.gov./hanford/files/
Hanford_Stop_Work_Procedure.pdf>
“…This will be accomplished through
PM-HR-15, Sect. 2
management visits to the field, supervisory
training, regular communications, actively
promoting a safe work environment,
encouraging employees to ask questions
and raise concerns and responding to issues
raised in a timely and collaborative
manner.”
“Washington Closure Hanford’s (WCH)
PM-ESHQ-8, Sect. 1 and 2
policy on safety meetings is intended to
ensure safety-related information is
communicated to all employees.”
Subcontractor
Procedure Citation
“Safety meetings are a forum for improving
safety conditions, enhancing safety
awareness by sharing information on both
on-the-job and off-the-job safety issues, and
for communicating information regarding
Page 6 of 70
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Restatement of the Requirement
#10
#11
(9) Establish procedures to permit
workers to stop work or decline to
perform an assigned task because of
a reasonable belief that the task
poses an imminent risk of death,
serious physical harm, or other
serious hazard to workers, in
circumstances where the workers
believe there is insufficient time to
utilize normal hazard reporting and
abatement procedures; and
(10) Inform workers of their rights
and responsibility by appropriate
means, including posting the DOEdesignated Worker Protection Poster
in the workplace where it is
accessible to all workers.
(b) Worker rights and
responsibilities. Workers must
comply with the requirements of this
part, including the worker safety and
health program, which are applicable
to their own actions and conduct.
Workers at a covered workplace
have the right, without reprisal, to:
(1) Participate in activities described
in this section on official time;
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.20 Management Responsibilities and Worker Rights and Responsibilities
Company and Project safety initiatives…”
“…Empower employees with the
PM-ESHQ-3, Sect. 1.1(3)
responsibility and authority to stop work
when they are convinced that a situation
exists which places themselves, their
coworker(s), or the environment in
danger…”
PM-ESHQ-4
See DOE-0343, Stop Work
DOE-0343, Stop Work
<http://www.hanford.gov./hanford/files/
Hanford_Stop_Work_Procedure.pdf>
PM-ESHQ-9, Sect. 1.1(2)
CONOPS-1-0, Sect. 1.0 & 2.0
#12
PM-ESHQ-9, Sect. 1.1 (1)
PSD-8, Rev. 0
02/08/2010
Subcontractor
Procedure Citation
““Every employee performing work on the
Washington Closure Hanford Team has the
following guaranteed right, without fear of
reprisal, to:…
2. Access to safety and health
publications, programs, standards,
procedures, and posters applicable to the
RCCC. Access to limited information on
recordkeeping log (OSHA Form 300).
Access to DOE Form 5484.3 (OSHA
Form 301), that contains the employee’s
name as the injured or ill worker…”
“1.0 PURPOSE
The purpose of the Washington Closure
Hanford (WCH) Conduct of Operations
program is to ensure that facility operations
are managed, organized, and conducted in a
manner that results in a high level of
performance and therefore contributes to
safe and reliable operations. The elements
of this program are fundamental to the
manner in which operations are conducted
to comply with Department of Energy
(DOE) requirements. This procedure
implements applicable portions of CRD O
5480.19, Conduct of Operations
Requirements for DOE Facilities.
2.0 SCOPE
The requirements of this Manual apply
project wide to all RCCC facilities,
progects, and subprojects.”
“Every employee performing work on the
Washington Closure Hanford Team has the
right, without reprisal, to:
1. Participate in activities described in this
Page 7 of 70
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Restatement of the Requirement
#13
(2) Have access to:
(i) DOE safety and health
publications; (ii) The worker safety
and health program for the covered
workplace; (iii) The standards,
controls, and procedures applicable
to the covered workplace; (iv) The
safety and health poster that informs
the worker of relevant rights and
responsibilities; (v) Limited
information on any recordkeeping
log (OSHA Form 300). Access is
subject to Freedom of Information
Act requirements and restrictions;
and (vi) The DOE Form 5484.3 (the
DOE equivalent to OSHA Form
301) that contains the employee’s
name as the injured or ill worker;
(3) Be notified when monitoring
results indicate the worker was
overexposed to hazardous materials;
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.20 Management Responsibilities and Worker Rights and Responsibilities
policy on official time:”
““Every employee performing work on the
PM-ESHQ-9, Sect. 1.1 (2)
Washington Closure Hanford Team has the
following guaranteed right, without fear of
reprisal, to:…
2. Access to safety and health publications,
programs, standards, procedures, and
posters applicable to the RCCC. Access to
limited information on recordkeeping log
(OSHA Form 300). Access to DOE Form
5484.3 (OSHA Form 301), that contains
the employee’s name as the injured or ill
worker…”
PM-ESHQ-9, Sect. 1.1 (3)
#14
Subcontractor
Procedure Citation
““Every employee performing work on the
Washington Closure Hanford Team has the
following guaranteed right, without fear of
reprisal, to:…
3. Be notified when monitoring results
indicate overexposure to hazardous
materials;”
#15
(4) Observe monitoring or measuring
of hazardous agents and have the
results of their own exposure
monitoring;
PM-ESHQ-9, Sect. 1.1 (4)
““Every employee performing work on the
Washington Closure Hanford Team has the
following guaranteed right, without fear of
reprisal, to:…
4. Observe monitoring of hazardous agents
and have access to employee’s own
exposure monitoring;”
#16
(5) A representative authorized by
employees may accompany the
Director or his authorized personnel
during the physical inspection of the
workplace for the purpose of aiding
the inspection. When no authorized
employee representative is available,
the Director or his authorized
representative must consult, as
appropriate, with employees on
matters of worker safety and health;
PSD-8, Rev. 0
02/08/2010
PM-ESHQ-9, Sect. 1.1 (5)
““Every employee performing work on the
Washington Closure Hanford Team has the
following guaranteed right, without fear of
reprisal, to:…
5. Have a representative authorized by
employees accompany the Director or his
authorized personnel during the physical
inspection of the workplace for the purpose
of aiding the inspection. When no
authorized employee representative is
available, the Director or his authorized
representative must consult, as appropriate,
with employees on matters of worker safety
Page 8 of 70
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Restatement of the Requirement
#17
(6) Request and receive results of
inspections and accident
investigations;
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.20 Management Responsibilities and Worker Rights and Responsibilities
and health;”
PM-ESHQ-9, Sect. 1.1 (6)
Subcontractor
Procedure Citation
““Every employee performing work on the
Washington Closure Hanford Team has the
following guaranteed right, without fear of
reprisal, to:…
6. Request a work place inspection or
accident investigation and receive results;”
(7) Express concerns related to
worker safety and health;
PM-ESHQ-9, Sect. 1.1 (7)
#18
““Every employee performing work on the
Washington Closure Hanford Team has the
following guaranteed right, without fear of
reprisal, to:…
7. Express concerns related to worker safety
and health;”
#19
#20
(8) Decline to perform an assigned
task because of a reasonable belief
that, under the circumstances, the
task poses an imminent risk of death
or serious physical harm to the
worker coupled with a reasonable
belief that there is insufficient time
to seek effective redress through
normal hazard reporting and
abatement procedures; and
PM-ESHQ-9, Sect. 1.1 (8)
(9) Stop work when the worker
discovers employee exposures to
imminently dangerous conditions or
other serious hazards; provided that
any stop work authority must be
exercised in a justifiable and
responsible manner in accordance
with procedures established in the
approved worker safety and health
program.
PM-ESHQ-9, Sect. 1.1 (9)
PSD-8, Rev. 0
02/08/2010
““Every employee performing work on the
Washington Closure Hanford Team has the
following guaranteed right, without fear of
reprisal, to:…
8. Decline to perform an assigned task
because of reasonable belief that, under the
circumstances, the task poses an imminent
risk of death or serious physical harm to the
worker coupled with a reasonable belief that
there is insufficient time to seek effective
redress through normal hazard reporting
and abatement procedures;”
““Every employee performing work on the
Washington Closure Hanford Team has the
following guaranteed right, without fear of
reprisal, to:…
9. Stop work when the worker discovers
employee exposures to imminently
dangerous conditions or other serious
hazards; provided that any stop work
authority must be exercised in a justifiable
and responsible manner in accordance with
established procedures.”
Page 9 of 70
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Restatement of the Requirement
#21
#22
#23
(a) Contractors must establish
procedures to identify existing and
potential workplace hazards and
assess the risk of associated workers
injury and illness. Procedures must
include methods to:
(1) Assess worker exposure to
chemical, physical, biological, or
safety workplace hazards through
appropriate workplace monitoring;
(2) Document assessment for
chemical, physical, biological, and
safety workplace hazards using
recognized exposure assessment and
testing methodologies and using of
accredited and certified laboratories;
(3) Record observations, testing and
monitoring results;
#24
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.21 Hazard Identification and Assessment
“…Controls are integrated into each work
PM-ESHQ-3, Sect. 1.1(3)
task to prevent events that could result in
adverse safety and radiological
consequences.”
“…Implementing procedures provide the
SH-1-1.1, Sect. 6
content and direction to ensure that all
known and anticipated work hazards are
analyzed prior to the performance of work
and that consideration is given to potential
emergency conditions…”
“Chemical, physical, biological, or
SH-1-4.1, Sect. 6.2.2
ergonomic hazard exposure will be
evaluated through observation and/or
measurements, and by personal and/or area
sampling…”
“…Sample analysis of personal samples
SH-1-4.1, Sect. 6.2.2
will be performed by a laboratory
accredited by the American Industrial
Hygiene Association (AIHA)….”
SH-1-4.1, Sect. 6.2.2
Subcontractor
Procedure Citation
“Exposure monitoring activities are directed
by a Certified Industrial Hygienist,
following (as applicable) an established
sampling strategy, such as the AIHA, A
Strategy for Occupational Exposure
Assessment…”
“…All monitoring activities are conducted
in accordance with written procedures and
document training...”
“…Exposure monitoring and assessment
records are reported to the employee and
are maintained in the employee’s medical
record…”
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Restatement of the Requirement
(4) Analyze designs of new facilities
and modifications to existing
facilities and equipment for potential
workplace hazards;
WCH
Implementing Procedure
ENG-1-3.1, Sect.
6.2.1.2(7),(11)
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.21 Hazard Identification and Assessment
“Project Engineer, in conjunction with
appropriate SMEs, develops or reviews the
Integrated Chemical and Radiological
Hazards Evaluation for the proposed work
area/location…”
ENV-1-1.14, Sect. 6(3)
SH-1-4.3, Sect. 6.2.2
#25
SH-1-4.3, Sect. 6.2.3
PAS-2-1.4
PAS-2-1.1, Sect. 6.5.1
(5) Evaluate operations, procedures,
and facilities to identify workplace
hazards;
#26
PSD-8, Rev. 0
02/08/2010
ENV-1-1.14, Sect. 6(3)
Subcontractor
Procedure Citation
“Project Industrial Hygienist performs a
preliminary ALARA assessment on
proposed scope of work per ENG-1,
Engineering Services, ENG-1-4.3,
“ALARA Design Review”.
„The Site Evaluation/Planning/Design
Team reevaluates the initial site/facility
hazards based on new information
developed during project planning and/or
design tasks......The deliverable for these
project phases is a revision of the initial
integrated hazards evaluation worksheet...“
„The baseline evaluation identifies
chemical, physical, biological, and
ergonomic hazards, engineering controls
and use of personal protective equipment
where a number of activities are located at
one permanent site...“
„Resurveys are conducted whenever a
recognized hazard is modified or conditions
of potential exposure change. Baseline
surveys are conducted on an annual basis.
Evaluation of engineering controls, such as
ventilation, is included in re-surveys where
required to meet OSHA standards.“
Entire procedure implements this
requirement of 10 CFR 851.
“Upon completion of the JHA, the Planning
Team signs the JHA to indicate that the
appropriate controls have been identified
(e.g., engineering controls, completed
RWP) for the hazards associated with their
area of expertise…”
„The Site Evaluation/Planning/Design
Team reevaluates the initial site/facility
hazards based on new information
developed during project planning and/or
design tasks......The deliverable for these
project phases is a revision of the initial
integrated hazards evaluation worksheet...“
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Restatement of the Requirement
(6) Perform routine job activity-level
hazard analyses;
#27
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.21 Hazard Identification and Assessment
„The baseline evaluation identifies
SH-1-4.3, Sect. 6.2.2
chemical, physical, biological, and
ergonomic hazards, engineering controls
and use of personal protective equipment
where a number of activities are located at
one permanent site...
„Resurveys are conducted whenever a
SH-1-4.3, Sect. 6.2.3
recognized hazard is modified or conditions
of potential exposure change. Baseline
surveys are conducted on an annual basis.
Evaluation of engineering controls, such as
ventilation, is included in re-surveys where
required to meet OSHA standards.“
Entire procedure implements this
PAS-2-1.4
requirement of 10 CFR 851.
“Upon completion of the JHA, the Planning
PAS-2-1.1, Sect. 6.5.1
Team signs the JHA to indicate that the
appropriate controls have been identified
(e.g., engineering controls, completed
RWP) for the hazards associated with their
area of expertise…”
Entire procedure implements this
PAS-2-1.4
requirement of 10 CFR 851.
“Upon completion of the JHA, the Planning
PAS-2-1.1, Sect. 6.5.1
Team signs the JHA to indicate that the
appropriate controls have been identified
(e.g., engineering controls, completed
RWP) for the hazards associated with their
area of expertise…”
Subcontractor
Procedure Citation
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Restatement of the Requirement
(7) Review site safety and health
experience information; and
#28
#29
#30
(8) Consider interaction between
workplace hazards and other hazards
such as radiological hazards.
(b) Contractors must submit to the
Head of DOE Field Element a list of
closure facility hazards and the
established controls within 90 days
after identifying such hazards. The
Head of DOE Field Element, with
concurrence by the Cognizant 311
Secretarial Officer, has 90 days to
accept the closure facility hazard
controls or direct additional actions
to either: (1) Achieve technical
compliance; or (2) Provide
additional controls to protect the
workers.
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.21 Hazard Identification and Assessment
“The Planning Team performs the
PAS-2-1.4, Sect. 6.2.4
following activities either prior to the
walkdown or as part of the tabletop:
• Review relevant Lessons Learned and
feedback.
• Consider safety aspects associated with
protecting the environment and the public.
• The Project Engineer (or designee)
ensures that any unique, activity-specific
controls required by AB documents are
identified to the Planning Team.
• Review previous radiological and
industrial hygiene surveys where applicable
• Discuss known radiological, chemical, and
metallurgical processes either associated
with the work area directly or which sent
waste or product material to the location.
• Review drawings, notes, video,
photographs, and conduct discussions with
team members familiar with the work site to
identify hazardous locations or areas where
access cannot be given to some members of
the team (e.g., member not a beryllium
worker).
• Planner/Facilitator will relate how the
JHA and What If Analysis will be
conducted.”
Entire procedure implements this
PAS-2-1.4
requirement of 10 CFR 851.
General Statement
PAS-1-1.3, Sect. 4
Subcontractor
Procedure Citation
Contract No. DE-AC06-05RL14655,
Section J, Attachment 1 contains a complete
list of all buildings included within the
RCCC. A listing of those buildings that
meet the definition of a “closure facility”
per 10 CFR 851, will be internally
controlled by WCH. On an annual basis the
internal list will be revised to reflect
buildings that transition into “closure” as
defined per 10 CFR 851.
“Facility Administrator or
designee…controls access to assigned
facilities and ensures site-specific access
controls are satisfied….”
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Restatement of the Requirement
(c) Contractors must perform the
activities identified in paragraph (a)
of this section, initially to obtain
baseline information and as often
thereafter as necessary to ensure
compliance with the requirements in
this Subpart.
#31
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.21 Hazard Identification and Assessment
“1. Because active projects generally
SH-1-3.11, Sect. 6.3
require worker access to all project areas,
all radiological and industrial posting
should be:
a. Current;
b. Legible;
c. Accurate; and
d. In full compliance with governing
regulations.”
“Entry into and movement within inactive
PAS-1-1.3, Sect. 5
facilities will be strictly controlled due to
potential for multiple hazards including
radiological, environmental, industrial
hygiene, and general health and safety
concerns…”
“Integrated Work Control (IWC) utilizes
PAS-2-1.1, Sect. 1
multi-disciplinary teamwork and worker
involvement to support the identification
and analysis of work site hazards,
development of the work package,
performance of work and observational
approach for newly identified hazards.
…The Work Packages are developed and
approved for release utilizing a graded
approach based on risk and complexity of
the work hazards and worker competence.”
“…This report documents the hazards
BHI-01286, Sect. 1
survey that was conducted for Bechtel
Hanford, Inc. (BHI)-managed facilities…”
SH-1-4.3, Sect. 6.2.1(1), (2),
“The design phase hazard assessment is an
(3), (4)
adequate initial IH survey of the operations
involved in the project if there is sufficient
detail in the design specifications to identify
potential IH hazards of the work site, IH
participates in the design hazards
assessment.”
“The initial IH survey of a work site may be
included in the project site-specific health
and safety plan (SSHASP) for remediation
of hazardous waste sites. The SSHASP
documents the IH initial survey if it is
reviewed and approved by the Project IH or
assigned IH.”
“The initial IH survey of an operation may
be conducted for non-routine work as part
of the job hazards analysis (JHA) or activity
Subcontractor
Procedure Citation
Page 14 of 70
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Restatement of the Requirement
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.21 Hazard Identification and Assessment
hazards analysis (AHA). The JHA or AHA
is an adequate IH survey of the evaluated
operation, if the Project IH or assigned IH
participates in the JHA/AHA and signs the
document.”
“For routine work (operations), the initial
IH survey will be conducted by the Project
IH, or assigned IH, when an IH hazard is
first identified, or as requested by the Field
Safety Representative, Site Supervisor, or
workers. The initial IH survey can be
developed from existing IH data, IH data
that is representative of the operation or
location or from Data collected specifically
during the survey.”
“Re-surveys are conducted whenever a
SH-1-4.3, Sect. 6.2.3
recognized hazard is modified or conditions
of potential exposure change. Baseline
surveys are generally conducted on an
annual basis. Evaluation of engineering
controls, such as ventilation, is included in
re-surveys where required to meet OSHA
standards.”
Subcontractor
Procedure Citation
Page 15 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
(a) Contractors must establish and
implement a hazard prevention and
abatement process to ensure that all
identified and potential hazards are
prevented or abated in a timely
manner.
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.22 Hazard Prevention and Abatement
PM-ESHQ-3, Sect. 1.1(3)
“Controls are integrated into each work task
to prevent events that could result in
adverse safety and radiological
consequences…”
PAS-2-1.1, Sect. 1
“Integrated Work Control (IWC) utilizes
multi-disciplinary teamwork and worker
involvement to support the identification
and analysis of work site hazards,
development of the work package,
performance of work and observational
approach for newly identified hazards.
…The Work Packages are developed and
approved for release utilizing a graded
approach based on risk and complexity of
the work hazards and worker competence.”
ENG-1-3.1,
Sect. 6.2.1.2(7),(11)
“Project Engineer, in conjunction with
appropriate SMEs, develops or reviews the
Integrated Chemical and Radiological
Hazards Evaluation for the proposed work
area/location…”
#32
(1) For hazards identified either in
the facility design or during the
development of procedures, controls
must be incorporated in the
appropriate facility design or
procedure.
#33
PSD-8, Rev. 0
02/08/2010
Subcontractor
Procedure Citation
“Project Industrial Hygienist performs a
preliminary ALARA assessment on
proposed scope of work per ENG-1,
Engineering Services, ENG-1-4.3,
“ALARA Design Review”.
ENV-1-1.14, Sect. 6(3)
„The Site Evaluation/Planning/Design
Team reevaluates the initial site/facility
hazards based on new information
developed during project planning and/or
design tasks......The deliverable for these
project phases is a revision of the initial
integrated hazards evaluation worksheet...“
SH-1-4.3, Sect. 6.2.2
„The baseline evaluation identifies
chemical, physical, biological, and
ergonomic hazards, engineering controls
and use of personal protective equipment
where a number of activities are located at
one permanent site...“
Page 16 of 70
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Restatement of the Requirement
WCH
Implementing Procedure
SH-1-4.3, Sect. 6.2.3
(2) For existing hazards identified in
the workplace, contractors must:
(i) Prioritize and implement
abatement actions according to the
risk to workers; (ii) Implement
interim protective measures pending
final abatement; and (iii) Protect
workers from dangerous safety and
health conditions;
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.22 Hazard Prevention and Abatement
„Resurveys are conducted whenever a
recognized hazard is modified or conditions
of potential exposure change. Baseline
surveys are conducted on an annual basis.
Evaluation of engineering controls, such as
ventilation, is included in re-surveys where
required to meet OSHA standards.“
PAS-2-1.1, Sect. 6.2.5
Subcontractor
Procedure Citation
“The RM completes Section 3 of the WPF,
including selection of the Senior
Management Review Team (SMRT) or
workability review (if desired) and provides
any additional instructions.
NOTE: The RM may require a SMRT or
workability review at any time during the
Work Package preparation process.”
PAS-2-1.4
Entire procedure implements this
requirement of 10 CFR 851.
PAS-1-1.3, Sect. 4
“Project Safety Representative…monitors
the implementation and enforcement of
safety requirements and advises FAs on the
safety implications generated by changing
conditions at facilities.”
#34
“Facility administrator or
designee…controls access to assigned
facilities and ensures site-specific access
controls are satisfied.”
PAS-1-1.3, Sect. 5
“Entry into and movement within inactive
facilities will be strictly controlled due to
potential for multiple hazards including
radiological, environmental, industrial
hygiene, and general health and safety
concerns…”
PM-ESHQ-4
See DOE-0343, Stop Work
<http://www.hanford.gov./hanford/files/
DOE-0343, Stop Work
Hanford_Stop_Work_Procedure.pdf>
(b) Contractors must select hazard
controls based on the following
hierarchy: (1) Elimination or
substitution of the hazards where
#35
feasible and appropriate; (2)
Engineering controls where feasible
and appropriate; (3) Work practices
and administrative controls that limit
worker exposures; and (4) Personal
PSD-8, Rev. 0
02/08/2010
SH-1-4.1, Sect. 6.2.3 (1), (2),
(3)
“The WCH adheres to the hierarchy of
controls required in OSHA and DOE
standards. This hierarchy, in descending
order of application, consists of the
following:
1.
Engineering controls will be the
primary method used to control health
hazards, where feasible. These
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Restatement of the Requirement
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.22 Hazard Prevention and Abatement
controls are designed into the process
or job and are generally independent
of worker operation. Examples of
engineering controls include local
exhaust ventilation, noise and
vibration shielding and dampening,
isolation of a toxic substance or
operation from the worker,
substitution of toxic chemicals with
materials of lower toxicity, and dust
control.
protective equipment.
#36
(c) Contractors must address hazards
when selecting or purchasing
equipment, products, and services.
SH-1-3.1, Sect. 6.1.2(2)
2.
Administrative controls may include
minimizing the time the worker is
exposed to the hazardous agent,
warning signs, and written operating
procedures or site-specific health and
safety plan operating limits. Worker
rotation as an administrative control is
not recommended as a primary control
method for a carcinogen.
3.
Personal protective equipment (PPE)
is used when required by standards,
when engineering controls are not
technically feasible, for short-term
operations such as sampling or
cleaning up spills, or in other cases
where controls are not effective. PPE
may also be used to improve worker
comfort or on a voluntary basis, as
long as there is no adverse affect on
the overall safety of the work. PPE
includes, but is not limited to,
respirators, safety glasses, safety
shoes, coveralls, ear plugs, hard hats,
and cooling vests.”
Subcontractor
Procedure Citation
“Hazards are addressed when selecting or
purchasing equipment, products, or
services.”
<http://www.hanford.gov/files.cfm/Chronic_
Beryllium_Disease_Prevention_Program_CBDPP.pdf>
PSD-8, Rev. 0
02/08/2010
Page 18 of 70
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Restatement of the Requirement
#37
(a) Contractors must comply with
the following safety and health
standards that are applicable to the
hazards at their covered workplace:
(1) Title 10 Code of Federal
Regulations (CFR) 850, “Chronic
Beryllium Disease Prevention
Program.”
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.23 Safety and Health Standards
SH-1-4.9
Entire procedure implements requirements
of 10 CFR 850 and DOE-0342, Hanford Site
Chronic Beryllium Disease Prevention
Program.
.
DOE-0342, Hanford Site
Chronic Beryllium Disease
<http://www.hanford.gov/files.cfm/Chronic_
Prevention Program.
Beryllium_Disease_Prevention_Program_
CBDPP.pdf>
(2) Title 29 CFR, Parts 1904.4
through 1904.11, 1904.29 through
1904.33; 1904.44, and 1904.46,
“Recording and Reporting
Occupational Injuries and Illnesses.”
SH-1-2.7, Sect. 9
29 CFR 1904.4 through 1904.11, 1904.29
through 1904.33, 1904.44 and 1904.46,
“Recording and Reporting Occupational
Injuries and Illnesses,” Code of Federal
Regulations, as amended, Washington, D.C.
(3) Title 29 CFR, Part 1910,
“Occupational Safety and Health
Standards,” excluding 29 CFR
1910.1096, “Ionizing Radiation.”
SH-1-2.5, Sect. 6(1)
“Comply with the following worker
protection requirements:
#40
(4) Title 29 CFR, Part 1915,
“Shipyard Employment.”
N/A
Not applicable
#41
(5) Title 29 CFR, Part 1917, “Marine
Terminals.”
N/A
Not applicable
(6) Title 29 CFR, Part 1918, “Safety
and Health Regulations for
Longshoring.”
N/A
Not applicable
#42
(7) Title 29 CFR, Part 1926, “Safety
and Health Regulations for
Construction.”
SH-1-2.5, Sect. 6(1)
“Comply with the following worker
protection requirements:
(8) Title 29 CFR, Part 1928,
“Occupational Safety and Health
Standards for Agriculture.”
N/A
#38
#39
#43
#44
PSD-8, Rev. 0
02/08/2010
Subcontractor
Procedure Citation
Title 29 of the Code of Federal
Regulations (CFR), Part 1910,
Occupational Safety and Health
Standards…”
a.
Title 29 of the Code of Federal
Regulations (CFR), Part 1926,
Safety and Health Regulations
for Construction”
Not applicable
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Restatement of the Requirement
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.23 Safety and Health Standards
“…The American Conference of
Governmental Industrial Hygienists
(ACGIH), “Threshold Limit Values for
Chemical Substances and Physical Agents
and Biological Exposure Indices” are to be
used as the limit for comparing sample and
exposure monitoring results when the
ACGIH Threshold Limit Values (TLVs) are
lower (more protective) than permissible
exposure limits in 29 CFR 1910. When the
ACGIH TLVs are used as exposure limits,
contractors must nonetheless comply with
the other provisions of any applicable
expanded health standard found in 29 CFR
1910.
SH-1-4.1, Sect. 6.1.1
#45
(9) American Conference of
Governmental Industrial Hygienists
(ACGIH), “Threshold Limit Values
for Chemical Substances and
Physical Agents and Biological
Exposure Indices” when the ACGIH
Threshold Limit Values (TLVs) are
lower (more protective) than
permissible exposure limits in 29
CFR 1910. When the ACGIH TLVs
are used as exposure limits,
contractors must nonetheless comply
with the other provisions of any
applicable expanded health standard
found in 29 CFR 1910.
SH-1-4.6
Entire procedure implements requirements
of 10 CFR 851.
#46
(10) American National Standards
Institute (ANSI) Z88.2, “American
National Standard Practices for
Respiratory Protection,” (1992)
(incorporated by reference see §
851.27).
(11) ANSI Z136.1, “Safe Use of
Lasers,” (2000) (incorporated by
reference see § 851.27).
SH-1-2.5, Sect. 6(2)
“For work activities/topics listed in the
following table, go to the referenced OSHA
standard for applicable safety and health
requirements…
#47
Subcontractor
Procedure Citation
…1926.54, Nonionizing Radiation & ANSI
Z136.1, Safe Use of Lasers…”
#48
#49
#50
(12) ANSI Z49.1, “Safety in
Welding, Cutting and Allied
Processes,” sections 4.3 and E4.3
(1999) (incorporated by reference
see § 851.27).
SH-1-2.5, Sect. 6
“…ANSI Z49.1, Safety in Welding, Cutting
and Allied Processes”
(13) National Fire Protection
Association (NFPA) 70, “National
Electrical Code,” (2005)
(incorporated by reference see §
851.27).
PAS-1-2.3, Sect. 1
“The purpose of the Washington Closure
Hanford (WCH) Electrical Safety Program
is to provide the requirements for
establishing an electrically safe workplace
and provide direction to implement electrical
safety compliant with the requirements of
NFPA 70E, Standard for Electrical Safety in
the Workplace, and DOE Richland
Requirement Document (RRD) # 005,
Worker Safety, Sections D and E.”
(14) NFPA 70E, “Electrical Safety
in the Workplace,” (2004)
(incorporated by reference see §
PAS-1-2.3, Sect. 1
PSD-8, Rev. 0
02/08/2010
“The purpose of the Washington Closure
Hanford (WCH) Electrical Safety Program
is to provide the requirements for
Page 20 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.23 Safety and Health Standards
establishing an electrically safe workplace
and provide direction to implement electrical
safety compliant with the requirements of
NFPA 70E, Standard for Electrical Safety in
the Workplace, and DOE Richland
Requirement Document (RRD) # 005,
Worker Safety, Sections D and E.”
Entire procedure implements requirements
of NFPA 70E.
851.27).
#51
(b) Nothing in this part must be
construed as relieving a contractor
from complying with any additional
specific safety and health
requirement that it determines to be
necessary to protect the safety and
health of workers.
PSD-8, Rev. 0
02/08/2010
SH-1-2.5, Sect. 2.0
Subcontractor
Procedure Citation
“…Nothing in this procedure is construed as
relieving WCH from complying with any
additional specific safety and health
requirement that it determines necessary to
protect the safety and health of workers.”
Page 21 of 70
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Restatement of the Requirement
WCH
Implementing Procedure
SH-1-1.1, Sect. 2.0 and
Attachment 1 (Summary not
direct citation)
#52
(a) Contractors must have a
structured approach to their worker
safety and health program which at a
minimum, include provisions for the
following applicable functional areas
in their worker safety and health
program: construction safety; fire
protection; firearms safety;
explosives safety; pressure safety;
electrical safety; industrial hygiene;
occupational medicine; biological
safety; and motor vehicle safety.
WCH-4, Appendix H and
Appendix J
#53
(b) In implementing the structured
approach required by paragraph (a)
of this section, contractors must
comply with the applicable standards
and provisions in Appendix A of this
part, entitled “Worker Safety and
Health Functional Areas.”
PSD-8, Rev. 0
02/08/2010
WCH
Procedure Citation
Subpart C 10 CFR 851.24 Functional Areas
Program procedure reflects the specific
functional areas as identified in 10 CFR
851, including an additional functional area
to address Safety and Health Program
Management.
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
Appendix H and Appendix J
Page 22 of 70
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Restatement of the Requirement
(a) Contractors must develop and
implement a worker safety and
health training and information
program to ensure that all workers
exposed or potentially exposed to
hazards are provided with the
training and information on that
hazard in order to perform their
duties in a safe and healthful
manner.
#54
WCH
Implementing Procedure
BSC-1-2.4, Sect. 6.1.1
BSC-1-2.4, Sect. 6.3.1
BSC-1-2.4, Sect. 6.3.3
BSC-1-2.4, Sect. 6.3.3.1
BSC-1-2.4, Sect. 6.3.3.2
BSC-1-2.4, Sect. 6.3.3.3
BSC-1-2.4, Sect. 6.3.8
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.25 Training and Information
“All temporary, part-time, and full-time
workers must receive HGET initially upon
employment with the RCCC, and annually
thereafter…”
“Employees who work in the presence of
any hazardous materials or chemicals must
be trained at the time of their initial
assignment and whenever a new hazard is
introduced into their work area…
“Hazardous Waste Operations
(HAZWOPER) training is required for all
Hanford Site workers who work at a RCRA,
CERCLA, or RCRA TSD site and could
have a reasonable possibility of being
exposed to safety and/or health hazards.
Supervisors who supervise or are directly
responsible for operations at such sites are
also required to take the training.”
“The worker will become familiar with the
procedures to be performed, safety and
health risks, and equipment and field
conditions expected. The requirement for
8-hour and 24-hour supervised field
experience must be gained under the
supervision of a trained, experienced
supervisor.”
“The 8-hour Manager/Supervisor Training
course is a one-time course that is required
for supervisors, managers, team leaders,
crew leaders, etc., that are directly
responsible for supervising personnel
engaged in hazardous waste remediation
activities. “
“Hazardous Waste Refresher Training
course is required annually for both 24-hour
and 40-hour trained workers…”
“Employees are required to have some level
of Asbestos Training prior to the following:
- Work in or adjacent to sites containing
asbestos-containing material (ACM)
Subcontractor
Procedure Citation
- Work on sites where airborne
concentrations of asbestos exceed, or
there is a reasonable possibility that
airborne concentrations may exceed, the
permissible exposure limit
- Performing OSHA Class I through Class
PSD-8, Rev. 0
02/08/2010
Page 23 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
#54
(cont.)
WCH
Implementing Procedure
(cont.)
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.25 Training and Information
IV asbestos operations
Subcontractor
Procedure Citation
- Performing ancillary to asbestoscontaining product installation or OSHA
Class I through Class IV operations…”
(a) Contractors must develop and
implement a worker safety and
health training and information
program to ensure that all workers
exposed or potentially exposed to
hazards are provided with the
training and information on that
hazard in order to perform their
duties in a safe and healthful
manner.
“Asbestos safety is required for work in or
adjacent to sites containing ACM.”
“Asbestos Awareness Training (2-hour) is
required for employees who perform tasks
ancillary to OSHA Class I through Class IV
asbestos operations or for employees who
are likely to be exposed to airborne asbestos
concentrations in excess of the permissible
exposure limit.”
“Asbestos Worker Training (32-hour) is
required for employees who install or
remove asbestos products or perform
OSHA Class I and Class II asbestos
operations.”
“Asbestos Competent Person (Asbestos
Supervisor) Training (40-hour) is required
for supervisors of OSHA Class I and Class
II operations.”
“Asbestos Project Designer Training (24hour) is required for employees who design
any of the following activities:…”
‘Asbestos Inspector Training (24-hour) is
required for employees who perform initial
inspections to determine the presence,
location, and/or assess condition of ACM
by visual observation, physical
examination, or bulk sampling.”
BSC-1-2.4, Sect. 6.3.9
PSD-8, Rev. 0
02/08/2010
“Asbestos Management Planning Training
(16-hour) is required for personnel who
prepare asbestos management plans.”
“Workers who may be exposed to lead in
the workplace must receive the following
training:…”
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Restatement of the Requirement
#54
(cont.)
(cont.)
(a) Contractors must develop and
implement a worker safety and
health training and information
program to ensure that all workers
exposed or potentially exposed to
hazards are provided with the
training and information on that
hazard in order to perform their
duties in a safe and healthful
manner.
WCH
Implementing Procedure
BSC-1-2.4, Sect. 6.3.10
BSC-1-2.4, Sect. 6.3.12
BSC-1-2.4, Sect. 6.4.2
BSC-1-2.4, Sect. 6.4.3
BSC-1-2.4, Sect. 6.4.4
BSC-1-2.4, Sect. 6.4.5
BSC-1-2.4, Sect. 6.4.6
BSC-1-2.4, Sect. 6.4.7
BSC-1-2.4, Sect. 6.4.8
PSD-8, Rev. 0
02/08/2010
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.25 Training and Information
“In accordance with 29 CFR 850 and SH-14.9, “Beryllium” training is required for
employees potentially exposed to beryllium
at work sites, for employees who have a
medical work restriction related to past
exposures to beryllium, and for supervisors
of such employees.”
“Annual training on bloodborne hazards,
required protective equipment, and the jobspecific hazard control plan is required for
all personnel who are occupationally
exposed to blood, body fluids, or other
biological material capable of the
transmission of bloodborne diseases.”
Based on the type of equipment to be
operated, training is required for personnel
who will be performing tasks in accordance
with PAS-1, Project Activities and Support,
Section 3.11, “Rigging” and Section 3.0,
“Equipment”.
“Confined Space Training is required for
workers who perform the following:…”
Subcontractor
Procedure Citation
“Workers who are potentially exposed to
fall hazards must receive Fall Protection
Training. “
“Workers who may be exposed to the
unexpected releases of hazardous energy or
of stored energy that could cause injury
during service or maintenance of machines
and/or equipment shall receive
Lockout/Tagout Training.”
“Workers who serve as a fire watch during
hot work activities must complete Fire
Watch Training and a hands-on Fire
Extinguisher Training prior to qualification
for fire watch duties.”
“Respirator users are required to receive
annual training in the proper use and
limitations of the respirator type of
respirator that will be used.”
“Work crews performing work at remote
field locations shall have at least one person
on the crew with valid certification in first
aid/CPR.”
Page 25 of 70
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Restatement of the Requirement
(cont.)
WCH
Implementing Procedure
BSC-1-2.4, Sect. 6.4.10
(a) Contractors must develop and
implement a worker safety and
health training and information
program to ensure that all workers
exposed or potentially exposed to
hazards are provided with the
training and information on that
hazard in order to perform their
duties in a safe and healthful
manner.
#55
Subcontractor
Procedure Citation
“NFPA-70E, Standards for Electrical
Safety – Electrical workers who work on or
near exposed energized electrical parts of
50 volts or more must be trained in
accordance with 29 CFR 1910, Subpart S
and 29 CFR 1926, Subpart K and National
Fire Protection Association (NFPA) 70E. “
“Supervisor Training – First-line managers,
supervisors, and safety representatives shall
have at least the same level of electrical
safety training as the workers for whom
they are responsible or for whom they plan
or supervise work, since the first-line
managers, supervisors, and safety
representatives participate in decisions on
electrical safety, such as personal protective
equipment (PPE) used for a task.”
#54
(cont.)
(b) The contractor must provide:
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.25 Training and Information
“Electrical Training Basic – All employees
must be trained in basic electrical safety.
The module in HGET fulfills this
requirement.”
BSC-1-2.4, Sect. 6.1.1
“Worker – If the worker is unfamiliar with
the construction or operation of the
equipment or the hazards associated with
the task, additional training or instruction is
required.”
Same policy and commitment basis as 10
CFR 851.25(a).
(1) Training and information for new
workers, before or at the time of
initial assignment to a job involving
exposure to a hazard;
PSD-8, Rev. 0
02/08/2010
Page 26 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
(2) Periodic training as often as
necessary to ensure that workers are
adequately trained and informed; and
WCH
Implementing Procedure
BSC-1-2.4, Sect. 6.1.1
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.25 Training and Information
“All temporary, part-time, and full-time
workers must receive HGET initially upon
employment with the RCCC, and annually
thereafter…”
BSC-1-2.4, Sect. 6.3.3.3
“The 8-hour Refresher Training course is
required annually for both 24-hour and 40hour trained workers.”
BSC-1-2.4, Sect. 6.3.8
“Class I, II, III, and IV Asbestos Worker
Training: 32-hour training provided by a
vendor for RCCC employees with annual
requalification….”
Subcontractor
Procedure Citation
“Asbestos Awareness Training: 2-hour
training for employees who perform tasks
ancillary to asbestos projects within the
asbestos regulated area (annual
requalification provided in HGET)…”
“Competent Person Training: 40-hour
training with annual requalification…”
Asbestos Project Designer Training: 24hour training with annual requalification…”
#56
“Asbestos Inspector Training: 24-hour
training with annual requalification…”
“Asbestos Management Planner Training:
16-hour training with annual
requalification…”
BSC-1-2.4, Sect. 6.3.9
PSD-8, Rev. 0
02/08/2010
“Workers who may be exposed to lead in
the workplace must receive the following
training:
· Lead (Pb) Hazard Communication
Training is required for those workers who
may be exposed to lead but only at
concentrations below the action level of
0.030 mg/m3 as an 8- hour time weighted
average (TWA).
· Lead (Pb) Worker and Respiratory
Protection Training is required for those
workers who may be exposed to lead at or
above the action level of 0.030 mg/m3 as an
8-hour TWA.”
Page 27 of 70
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Restatement of the Requirement
WCH
Implementing Procedure
BSC-1-2.4, Sect. 6.3.10
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.25 Training and Information
“…General awareness training [beryllium]
is provided to employees annually in HGET
and through company publications…”
Subcontractor
Procedure Citation
“…Annual training is required for assigned
beryllium workers. Additional job-specific
training is provided in work site
meetings…”
#57
BSC-1-2.4, Sect. 6.3.12
“…Annual training on bloodborne hazards,
required protective equipment, and the jobspecific hazard control plan is required for
all personnel who are occupationally
exposed to blood, body fluids, or other
biological material capable of the
transmission of bloodborne diseases..”
BSC-1-2.4, Sect. 6.4.2
“Ironworker/Riggers must receive Wire
Rope and Rigging Hardware Inspection
Training and Wire Rope and Rigging
Hardware Inspection Requal Training…”
BSC-1-2.4, Sect. 6.4.6
“…Both of these training courses [Fire
Watch Training] require annual retraining.”
BSC-1-2.4, Sect. 6.4.7
“…Annual refresher training on airpurifying respirators and supplied-air
respirators…”
BSC-1-2.4, Sect. 6.4.8
“…Retraining for First Aid is every 3 years
and for CPR is annually...”
(3) Additional training when safety
and health information or a change
in workplace conditions indicates
that a new or increased hazard exists.
BSC-1-2.4, Sect. 6.3.1
“Employees who work in the presence of
any hazardous materials or chemicals must
be trained at the time of their initial
assignment and whenever a new hazard is
introduced into their work area…”
I Contractors must provide training
and information to workers who
have worker safety and health
program responsibilities that is
necessary for them to carry out those
responsibilities.
BSC-1-2.4, Sect. 4.0
“Management/Supervisor…..Ensure his/her
employees are trained and qualified to
perform their assigned work and to provide
continuing training to personnel to maintain
their job proficiency.”
#58
“The Manager/Supervisor has
responsibility to identify when special
training is required during work planning.
“Subcontract Technical Representative
(STR)…Ensure that the subcontractors
have the necessary training to perform work
on the Hanford Site according to the
PSD-8, Rev. 0
02/08/2010
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Restatement of the Requirement
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.25 Training and Information
applicable subcontract document…”
Subcontractor
Procedure Citation
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
(a) Recordkeeping. Contractors
must:
(1) Establish and maintain complete
and accurate records of all hazard
inventory information, hazard
assessments, exposure
measurements, and exposure
controls.
#59
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
SH-1-4.1, Sect. 7.0
SH-1-4.3, Sect. 7.0
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.26 Recordkeeping and Reporting
“…Reporting requirements, retention of
records, and access to records comply with
applicable OSHA and DOE Standards.”
Subcontractor
Procedure Citation
“1. Initial IH surveys or baseline surveys
requested for routine or ongoing work are
documented by Inter-Office Memorandum
(IOM) or e-mail with minimum distribution
to site management, Field Safety
Representative, and ^WCH Records &
Document Control (R&DC).”
“2. Baseline surveys of operations with
engineering controls and a complicated set
of potential hazards can be documented on
form WCH-QSH-014. The Industrial
Hygienist conducting the survey identifies
on the survey form whether the form is the
initial baseline or a revision. If it is a
revision, some notation of the purpose of
the revision must be noted on the form. The
completed form is then sent to R&DC and
assigned a DOCS Open number. This
group of records is retained by R&DC as
IH-type electronic records. The current and
previous baseline survey forms can then be
recovered by location using DOCS Open
software.”
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Restatement of the Requirement
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.26 Recordkeeping and Reporting
“3. For each initial baseline or subsequent
baseline revision, the IH conducting the
survey shall send an e-mail (as a minimum)
to work site management and the Safety
Representative, notifying them that an IH
baseline or baseline re-survey has been
completed.”
Subcontractor
Procedure Citation
“4. Initial or baseline surveys can be used
to evaluate an employee’s past occupational
exposure and, as such, are subject to the
recordkeeping requirements in 29 Code of
Federal Regulations (CFR) 1910.1020,
“Access to Employee Exposure and
Medical Records.””
#60
#61
#62
(2) Ensure that the work-related
injuries and illnesses of its workers
and subcontractor workers are
recorded and reported accurately and
consistent with DOE Manual 231.11A, Environment, Safety and Health
Reporting Manual, September 9,
2004 (incorporated by reference, see
§851.27).
SH-1-2.7, Sect. 4.0
“Safety and Health…Maintain and record
all job-related illnesses and injuries in
accordance with Occupational Safety and
Health Administration (OSHA) and DOE
requirements.”
SH-1-3.20, Sect. 6.1(2)
“NOTE: Requirements for notification,
investigation, and reporting of
injuries/illnesses and near misses are found
in SEM-3-2.1, “Accident/Incident
Investigating and Reporting Requirements.”
(3) Comply with the applicable
occupational injury and illness
recordkeeping and reporting
workplace safety and health
standards in § 851.23 of this part at
their site, unless otherwise directed
in DOE Manual 231.1-1A.
SH-1-2.7, Sect. 4.0
“Safety and Health…Comply with the
applicable occupational injury and illness
recordkeeping and reporting workplace
safety and health standards in 10 CFR
851.23 unless otherwise directed in DOE
Manual 231.1-1A.”
SH-1-3.20, Sect. 4.0
“Project Director/Functional Manager or
Designee… Comply with the applicable
occupational injury and illness
recordkeeping and reporting workplace
safety and health standards in 10 CFR
851.23 unless otherwise directed in DOE
Manual 231.1-1A.”
(4) Not conceal nor destroy any
information concerning noncompliance or potential
noncompliance with the
requirements of this part.
SH-1-3.14, Sect. 6.1(4)
PSD-8, Rev. 0
02/08/2010
“No person shall conceal nor destroy any
information concerning non-compliance or
potential noncompliance with the
requirements of this part.”
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Restatement of the Requirement
(b) Reporting and investigation.
Contractors must:
(1) Report and investigate accidents,
injuries and illness; and
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.26 Recordkeeping and Reporting
SH-1-3.1, Sect. 6.1.2(9);
„The following describe the required
actions and activities that constitute
implementation of the ISP:...
9. Investigations are conducted to establish
the cause(s) of incidents and events that
resulted or could have resulted in injuries,
death, or significant property loss and to
identify methods to prevent recurrence.“
SH-1-3.14, Sect. 6.1(3)
SEM-3-2.1, Sect. 4.0
#63
Subcontractor
Procedure Citation
„All occupational injuries and illnesses, no
matter how slight, must be reported to your
supervisor immediately. If you are injured
on the job and do not report the occurrence
to your supervisor, the company will not be
responsible for any medical expense
incurred by you on your own.“
“Employees... WCH employees are
responsible for providing immediate
notification to 911 if necessary. In
addition, all WCH employees, including
subcontractors, are responsible for ensuring
a hazard-free work environment, for
providing assistance during upset
conditions, and for making notification to
supervision/management if they observe or
are involved in an incident or condition that
has, or could have, an adverse effect on
personnel safety and health, quality,
security, operations, or the environment.“
“Supervisors… are responsible for
providing additional notifications to
management, directing any necessary
response actions and placing the scene in a
safe condition.”
“Project Management… line management is
responsible for providing notification to
U.S. Department of Energy (DOE),
assigning investigation responsibilities,
providing resources for the investigation,
and approving investigation reports.
“Field Safety Representative…provide
personnel injury information to the
Occupational Medical Coordinator…”
PSD-8, Rev. 0
02/08/2010
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Restatement of the Requirement
#64
(2) Analyze related data for trends
and lessons learned (reference DOE
Order 225.1A, Accident
Investigations, November 26, 1997).
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
WCH
Subcontractor
Procedure Citation
Implementing Procedure
Subpart C 10 CFR 851.26 Recordkeeping and Reporting
SH-1-3.1, Sect. 6.1.2(10)
“The following describe the required
actions and activities that constitute
implementation of the ISP:…
Subcontractor
Procedure Citation
10. Analyses of accidents and injury data
are performed to evaluate performance,
identify trends, identify potential problem
areas, and develop lessons learned.”
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Restatement of the Requirement
WCH
Implementing Procedure
WCH
Procedure Citation
Subpart C 10 CFR 851.27 Reference Sources
“Standards (as listed in Part 851.27) which
are not otherwise set forth in Part 851 are
incorporated by reference and made a part
of Part 851. The standards listed in this
section have been approved for
incorporation by reference by the Director
of the Federal Register in accordance with 5
U.S.C. 552(a) and 1 CFR Part 51.”
SH-1-2.5, Sect. 6.0
#65
(a) Materials incorporated by
reference. (1) General. The
following standards which are not
otherwise set forth in Part 851 are
incorporated by reference and made
a part of Part 851. The standards
listed in this section have been
approved for incorporation by
reference by the Director of the
Federal Register in accordance with
5 U.S.C. 552(a) and 1 CFR Part 51.
SH-1-2.5, Sect. 6.0
#66
(2) Availability of standards. The
standards incorporated by reference
are available for inspection at:
(i) National Archives and Records
Administration (NARA). For more
information on the availability of
this material at NARA, call 202-7416030, or go to:
http://www.archives.gov/federal_reg
ister/code_of_federal_regulations/ibr
_locations.html
“The standards incorporated by reference
are available for inspection at:
National Archives and Records
Administration (NARA). For more
information on the availability of this
material at NARA, call 202-741-6030, or go
to:
http://www.archives.gov/federal_register/co
de_of_federal_regulations/ibr_locations.ht
ml”
SH-1-2.5, Sect. 6.0
#67
(ii) U.S. Department of Energy,
Office of Environment, Safety and
Health, Forrestal Building, 1000
Independence Ave., SW,
Washington, DC 20585.
“U.S. Department of Energy, Office of
Environment, Safety and Health, Forrestal
Building, 1000 Independence Ave., SW,
Washington, DC 20585.”
SH-1-4.6
Entire procedure implements requirements
of 10 CFR 850.
#68
(b)(1) American National Standards
Institute (ANSI) Z88.2, “American
National Standard Practices for
Respirator Protection.” The ANSI
standards listed in this paragraph
may be obtained form the American
National Standards Institute (1992).
(2) ANSI Z136.1, “Safe Use of
Lasers,” (2000).
SH-1-2.5, Sect. 6(2)
“For work activities/topics listed in the
following table, go to the referenced OSHA
standard for applicable safety and health
requirements…
#69
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
…1926.54, Nonionizing Radiation & ANSI
Z136.1, Safe Use of Lasers…”
#70
(3) ANSI Z49.1, “Safety in Welding,
Cutting and Allied Processes,”
sections 4.3 and E4.3 (1999).
PSD-8, Rev. 0
02/08/2010
SH-1-2.5, Sect. 6
“…ANSI Z49.1, Safety in Welding, Cutting
and Allied Processes”
Page 33 of 70
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Restatement of the Requirement
WCH
Implementing Procedure
(4) National Fire Protection
Association (NFPA) 70, “National
Electrical Code,” (2005).
PAS-1-2.3, Sect. 1
(5) NFPA 70E, “Electrical Safety in
the Workplace,” (2004).
PAS-1-2.3, Sect. 1
(6) DOE Manual 231.1-1A,
Environment, Safety and Health
Reporting Manual, September 9,
2004.
Contract No. DE –AC0605RL14655
(7) DOE Manual 440.1-1, DOE
Explosives Safety Manual, March
29, 1996.
SH-1-3.13, Sect. 1
#71
#72
#73
WCH
Procedure Citation
Subpart C 10 CFR 851.27 Reference Sources
“This procedure provides electrical safety
requirements. The basis for these
requirements include 29 Code of Federal
Regulations (CFR) 1910, Subpart S; 29
CFR 1926, Subpart K; and NFPA 70E,
Standard for Electrical Safety In the
Workplace.”
Subcontractor
Procedure Citation
“The purpose of the Washington Closure
Hanford (WCH) Electrical Safety Program
is to provide the requirements for
establishing an electrically safe workplace
and provide direction to implement
electrical safety compliant with the
requirements of NFPA 70E, Standard for
Electrical Safety in the Workplace, and
DOE Richland Requirement Document
(RRD) # 005, Worker Safety, Sections D
and E.”
Entire procedure implements requirements
of NFPA 70E.
“The following is an all-inclusive list of
applicable DOE Directives
DOE Manual 231.1-1A, Chg 2,
Environment, Safety and Health Reporting
Manual.”
“The procedure implements applicable
requirements from the following River
Corridor Closure (RCC) contract
requirements:

DOE-M-440.1-1A, DOE
Explosives Safety Manual,
Attachment 2, “Contractor
Requirements Document”

CRD-M-440.1-1A
(Supplemented Rev. 0), DOE
Explosives Safety Manual,
“Contractor Requirements
Document”
#74
PSD-8, Rev. 0
02/08/2010
Subcontractor
Implementing Procedure
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Restatement of the Requirement
A1
WCH
Implementing Procedure
(a) For each separately definable
construction activity (e.g.,
excavations, foundations, structural
steel, roofing) the construction
contractor must:
PAS-2-1.1, Sect. 2
(1) Prepare and have approved by
the construction manager an activity
hazard analysis prior to
commencement of affected work.
Such analyses must:
PAS-2-1.1, Sect. 6.5.9, 6.5.10
& 6.5.11
(i) Identify foreseeable hazards and
planned protective measures;
PSD-8, Rev. 0
02/08/2010
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
“6.5.9 The RM reviews and approves the
JHA by signing the JHA cover sheet. The
JHA form shall be maintained with the
associated Work Package.
6.5.10 The RM reviews the completed JHA
and Work Package to ensure that
• The Work Package is suitable for the
scope,
• Current references are incorporated,
• All hazard controls from the JHA have
been incorporated into Type I Task
Instructions, or that the Craft Work Package
JHA is suitable to protect the workers,
• Any special controls (e.g., technical safety
requirement [TSR], documented safety
analysis [DSA], authorization agreement
[AA]) are correctly and completely
contained in the Work Package, and
• The work will not defeat or compromise
these hazard control strategies.
A2
A3
WCH
Procedure Citation
Attachment J.1 – 1. Construction Safety
“The IWC (including Attachment 1) is
applicable to all work activities managed
and performed by WCH and its
subcontractors… “
PAS-2-1.4
6.5.11 When satisfied that the work team
will be properly directed and that all
anticipated hazards have corresponding
controls/mitigation in the Work Package,
the RM approves the Work Package by
signing the appropriate block on the cover
sheet.”
Entire procedure implements this
requirement of 10 CFR 851.
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Restatement of the Requirement
WCH
Implementing Procedure
(ii) Address further hazards revealed
by supplemental site information
(e.g., site characterization data, asbuilt drawings) provided by the
construction manager;
PAS-2-1.4
(iii) Provide drawings and/or other
documentation of protective
measures for which applicable
Occupational Safety and Health
Administration (OSHA) standards
require preparation by a Professional
Engineer or other qualified
professional, and
PAS-1-2.4, Sect. 6.2.4
WCH
Procedure Citation
Attachment J.1 – 1. Construction Safety
Entire procedure implements this
requirement of 10 CFR 851.
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
A4
A5
“The Planning Team performs the
following activities either prior to the
walkdown or as part of the tabletop:
• Review relevant Lessons Learned and
feedback.
• Consider safety aspects associated with
protecting the environment and the public.
• The Project Engineer (or designee)
ensures that any unique, activity-specific
controls required by AB documents are
identified to the Planning Team.
• Review previous radiological and
industrial hygiene surveys where applicable
• Discuss known radiological, chemical, and
metallurgical processes either associated
with the work area directly or which sent
waste or product material to the location.
• Review drawings, notes, video,
photographs, and conduct discussions with
team members familiar with the work site to
identify hazardous locations or areas where
access cannot be given to some members of
the team (e.g., member not a beryllium
worker).
 • Planner/Facilitator will relate how the
JHA and What If Analysis will be
conducted.”
A6
(iv) Identify competent persons
required for workplace inspections
of the construction activity, where
PSD-8, Rev. 0
02/08/2010
PAS-2-1.1, Sect. 6.3.5
“The Work Control Planner and various
project and Planning Team members may
conduct walkdowns of the work area
Page 36 of 70
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Restatement of the Requirement
WCH
Implementing Procedure
required by OSHA standards.
(3) Require that workers
acknowledge being informed of the
hazards and protective measures
associated with assigned work
activities. Those workers failing to
utilize appropriate protective
measures must be subject to the
construction contractor’s disciplinary
process.
PAS-2-1.1, Sect. 6.6.7
“The Work Supervisor conducts a Pre-Ev
daily prior to work commencement, and
includes a work site walkdown, as needed.
The initial Pre-Ev for extensive or complex
work should familiarize the crew members
with the full scope of the work package.
Each Pre-Ev shall be documented on a PreEvolution Briefing Checklist (WCH-FS210).”
SH-1-6.1, Sect. 6.4
“Workers shall be briefed prior to entering a
facility/waste site, mobilization, and/or
performing work on the site, and whenever
there are changes to applicable HCDs such
as the initial safety and health plan,
SSHASP, or JHA. Safety briefings shall be
documented….”
PAS-2-1.1, Sect. 6.6.7
“The Work Supervisor conducts a Pre-Ev
daily prior to work commencement, and
includes a work site walkdown, as needed.
The initial Pre-Ev for extensive or complex
work should familiarize the crew members
with the full scope of the work package.
Each Pre-Ev shall be documented on a PreEvolution Briefing Checklist (WCH-FS210).”
BSC-1-1.8, Sect. 5
“WCH requires management to establish
realistic performance objectives to
recognize and reinforce good performance
and to work with employees to meet
performance expectations. Employees are
required to perform according to the
expectations outlined in the Company’s
Standards of Conduct (Attachment A),
Conduct of Operations, Policies and
Procedures, and Federal and State Laws,
and to coordinate with appropriate
management to meet established individual
performance objectives.”
A8
PSD-8, Rev. 0
02/08/2010
WCH
Procedure Citation
Attachment J.1 – 1. Construction Safety
throughout all phases of JHA and work
package planning and preparation.
Personnel participating in these walkdowns
shall read and follow all relevant safety
guidance (e.g., HCD)…”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
Page 37 of 70
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Restatement of the Requirement
A9
A10
WCH
Implementing Procedure
(b) During periods of active
construction (i.e., excluding
weekends, weather delays, or other
periods of work inactivity), the
construction contractor must have a
designated representative on the
construction worksite who is
knowledgeable of the project’s
hazards and has full authority to act
on behalf of the construction
contractor. The contractor’s
designated representative must make
frequent and regular inspections of
the construction worksite to identify
and correct any instances of
noncompliance with project safety
and health requirements.
SH-1-6.1, Sect. 6.4
(c) Workers must be instructed to
report to the construction
contractor’s designated
representative, hazards not
previously identified or evaluated. If
immediate corrective action is not
possible or the hazard falls outside of
project scope, the construction
contractor must immediately notify
affected workers, post appropriate
warning signs, implement needed
interim control measures, and notify
the construction manager of the
action taken. The contractor or the
designated representative must stop
work in the affected area until
appropriate protective measures are
established.
PAS-2-1.1, Sect. 6.7.1
WCH
Procedure Citation
Attachment J.1 – 1. Construction Safety
“…Other SSHASP requirements include the
identification and qualifications of the Field
Superintendent or other individual with full
authority and responsibility for onsite
implementation of the SSHASP. The Field
Superintendent (or other designated
individual) must be present on the work site
during any project work activity…”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
“Workers and Supervisors must practice a
questioning attitude and be sensitive to
changed conditions to maintain a safe
working environment. Examples of when to
pause the work and reevaluate the work
activity are:
• When a new tool or new equipment is
introduced to the ongoing task,
• When additional tasks not addressed in the
scope of work or Pre-Ev must be performed
to complete the work,
• When performing similar tasks that may
have different hazards, and
• When environmental conditions change
from the expected conditions.”
PAS-2-1.1, Sect. 6.7.2
“Work Supervisors should implement the
Observational Approach methodology in
instances where the nature of the work is
prone to unknowns and hazards are not
readily apparent (e.g., Burial Ground
Remediation). During work activities, stop
work if:
• Additional work or work scope not
identified in the package needs to be
performed
• A Work Package step cannot be
performed as written (including sequence)
PSD-8, Rev. 0
02/08/2010
Page 38 of 70
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Restatement of the Requirement
WCH
Implementing Procedure
WCH
Procedure Citation
Attachment J.1 – 1. Construction Safety
• Following the Work Package will create
an unsafe or noncompliant condition
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
• An unexpected hazard or condition is
encountered or hazard controls are
determined to be inadequate.”
PAS-2-1.1, Sect. 6.7.5(3)
“Assess the situation and prepare to restart
work as follows:…
4. The Work Supervisor and/or RM will
initiate appropriate changes to work
packages and/or work areas to resolve the
issues(s). Subcontractors will coordinate
all such changes through the STR.”
PM-ESHQ-4
DOE-0343, Stop Work
A11
(d) The construction contractor must
prepare a written construction
project safety and health plan to
implement the requirements of this
section and obtain approval of the
plan by the construction manager
prior to commencement of any work
covered by the plan. In the plan, the
contractor must designate the
individual(s) responsible for on-site
implementation of the plan, specify
qualifications for those individuals,
and provide a list of those project
activities for which subsequent
hazard analyses are to be performed.
The level of detail within the
construction project safety and
health plan should be commensurate
with the size, complexity and risk
level of the construction project. The
332 content of this plan need not
duplicate those provisions that were
previously submitted and approved
as required by § 851.11 of this part.
PSD-8, Rev. 0
02/08/2010
See DOE-0343, Stop Work
<http://www.hanford.gov./hanford/files/
Hanford_Stop_Work_Procedure.pdf>
PAS-2-1.1, Sect. 6.3.5
“The Work Control Planner and various
project and Planning Team members may
conduct walkdowns of the work area
throughout all phases of JHA and work
package planning and preparation.
Personnel participating in these walkdowns
shall read and follow all relevant safety
guidance (e.g., HCD)…”
PAS-2-1.1, Sect. 6.9
“The responsibility for determining whether
changes are major or minor lies with the
RM. The JHA must be reviewed for
adequacy whenever there is a change in
scope, work area conditions, identification
of new hazards, or a regulatory or procedure
change that affects the work package.
Whenever a work package is changed, the
JHA is reviewed by the RM, and applicable
SMEs, (as determined by the RM), for
adequacy. The RM will determine if/when a
work package will be changed, revised or a
new work package will be written.”
SH-1-6.1, Sect. 6.1
All WCH projects shall be evaluated for
recognized hazards that could affect the
safety or health of workers or the
environment in accordance with the scope
and applicability of standards in 29 CFR
1910.120(b) through (o) and 29 CFR
1926.65(b) through (o), “Hazard Waste
Operations and Emergency Response.”
Page 39 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
WCH
Procedure Citation
Attachment J.1 – 1. Construction Safety
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
Page 40 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
(a) Contractors must implement a
comprehensive fire safety and
emergency response program to
protect workers commensurate with
the nature of the work that is
performed. This includes appropriate
facility and site-wide fire protection,
fire alarm notification and egress
features, and access to a fully
staffed, trained, and equipped
emergency response organization
that is capable of responding in a
timely and effective manner to site
emergencies.
WCH
Implementing Procedure
SH-1-5.1. Sect. 1
WCH
Procedure Citation
Attachment J.1 – 2. Fire Protection
“This procedure documents responsibilities
for developing, implementing and
maintaining the Washington Closure
Hanford (WCH) fire protection program
(FPP). It ensures the level of fire protection
on WCH-managed operations and facilities
is adequate to meet the objectives of U.S.
Department of Energy (DOE) Orders CRD
O 440.1A, CRD O 420.1B, Attachment 2,
and CRD O 420.1B (Supplemented Rev.4),
and to fulfill requirements for the “best
protected” class of industrial risks.”
SEM-2-1.0, Sect.1
“The purpose of this procedure is to
establish the bases for the Washington
Closure Hanford LLC (WCH) Emergency
Management Program. Implementation of
the WCH Emergency Management Program
ensures readiness to safely and effectively
respond to, and mitigate as necessary any
emergency or abnormal condition
associated with a WCH facility while
protecting the safety and health of the
workforce and the public and while
protecting property and the environment.
The WCH Emergency Management
Program structure allows for complete
integration into the Hanford Emergency
Management Plan.”
SH-1-5.1, Sect. 4.2.3
“4.2.3 Hanford Fire Department
Interface/Support
A12
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
1. The FPP interface with the Hanford Fire
Department includes:
a. A WCH fire protection engineer will be
the fire protection point of contact (FPPOC)
for the Hanford Fire Department.
b. The FPPOC is an appointed Deputy Fire
Marshal representing the Hanford Fire
Marshal, as part of the Hanford Fire
Protection Program and pursuant to the
authority granted by the US DOE-RL
through the Hanford Fire Marshal’s Charter.
c. A WCH fire protection engineer will be
the plant safety expert for plant fire
PSD-8, Rev. 0
02/08/2010
Page 41 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
WCH
Implementing Procedure
WCH
Procedure Citation
Attachment J.1 – 2. Fire Protection
protection systems.
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
d. The FPPOC will review and validate the
categorization of system restrictions and
emergency impairments
e. The FPP interface will oversee overall
operation, maintenance (corrective and
preventive), testing, design, and
configuration management of the fire
protection systems within WCH-managed
facilities.
2. The Hanford Fire Department is
chartered as follows:
a. Maintain command of emergency
response forces to perform the necessary
actions to control and terminate fire-related
incidents, to provide emergency medical
patient care, and to act as the incident
command agency for hazardous materials
emergency incidents
b. Perform fire alarm and protection system
functional testing for all WCH-managed
facilities and maintain self-contained
breathing apparatus equipment
c. Maintain an active fire prevention
program through facility tours and
inspections; develop pre-incident
emergency plans
d. Maintain a highly trained emergency
response organization whose members are
certified under a 3-year, Washington Stateapproved firefighter apprenticeship
program.”
A13
(b) An acceptable fire protection
program must include those fire
protection criteria and procedures,
analyses, hardware and systems,
apparatus and equipment, and
personnel that would
comprehensively ensure that the
objective in paragraph 2(a) of this
section is met. This includes meeting
applicable building codes and
PSD-8, Rev. 0
02/08/2010
Contract No. DE-AC0605RL14655
Mandatory Hanford Site Service - AMH
responsibility.
SH-1-5.1, Sect. 1.0
“This procedure documents responsibilities
for developing, implementing, and
maintaining the Washington Closure
Hanford (WCH) fire protection program
(FPP). It ensures the level of fire protection
on WCH-managed operations and facilities
is adequate to meet the objectives of
Contractor Requirements Document (CRD)
U.S. Department of Energy (DOE) Orders
CRD O 440.1A, Attachment 2, CRD O
Page 42 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
WCH
Implementing Procedure
National Fire Protection Association
codes and standards.
SH-1-5.1, Sect. 4.2.3
WCH
Procedure Citation
Attachment J.1 – 2. Fire Protection
420.1B, Attachment 2, and CRD O 420.1B
(Supplemented Rev. 4), and to fulfill
requirements for the “best protected” class
of industrial risks. This procedure
implements general program requirements
of 10 Code of Federal Regulations (CFR)
851, “Worker Safety and Health Program.”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
4.2.3 Hanford Fire Department
Interface/Support
…d. The FPP interface will oversee overall
operation, maintenance (corrective and
preventive), testing, design, and
configuration management of the fire
protection systems within WCH-managed
facilities.
2. The Hanford Fire Department is
chartered as follows:
a. Maintain command of emergency
response forces to perform the necessary
actions to control and terminate fire-related
incidents, to provide emergency medical
patient care, and to act as the incident
command agency for hazardous materials
emergency incidents
b. Perform fire alarm and protection system
functional testing for all WCH-managed
facilities and maintain self-contained
breathing apparatus equipment
c. Maintain an active fire prevention
program through facility tours and
inspections; develop pre-incident
emergency plans
d. Maintain a highly trained emergency
response organization whose members are
certified under a 3-year, Washington Stateapproved firefighter apprenticeship
program.”
Contract No. DE-AC0605RL14655
PSD-8, Rev. 0
02/08/2010
Mandatory Hanford Site Service - AMH
responsibility.
Page 43 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
A14
WCH
Implementing Procedure
(a) Contractors responsible for the
use of explosive materials must
establish and implement a
comprehensive explosives safety
program.
SH-1-3.13, Sect. 1
(b) Contractors must comply with
the policy and requirements
specified in the DOE Manual 440.11, DOE Explosives Safety Manual,
March 29, 1996 (incorporated by
reference, see § 851.27). A
Contractor may choose a successor
version, if approved by DOE.
SH-1-3.13, Sect. 1
WCH
Procedure Citation
Attachment J.1 – 3. Explosives Safety
“The purpose of the procedure is to provide
the basic information and requirements
needed to ensure effective management
oversight of the transportation, storage, use
of explosives and discovery of unexploded
ordinance (UXO) by Washington Closure
Hanford (WCH) and/or WCH
subcontractors.”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
” The procedure implements applicable
requirements from the following River
Corridor Closure (RCC) contract
requirements:
A15
SH-1-3.13, Sect. 4

DOE-M-440.1-1A, DOE
Explosives Safety Manual,
Attachment 2, “Contractor
Requirements Document”

CRD-M-440.1-1A
(Supplemented Rev. 0), DOE
Explosives Safety Manual,
“Contractor Requirements
Document” “
“Project Director or designee…If the scope
of work to be conducted requires the use of
explosives, ensure that contractual
requirements applicable to explosives (see
Section 1.0) are “flowed down” to the
subcontractor.”
“Project Director or designee…Prior to
issuing a requisition for a subcontract,
determine if the scope of work to be
conducted requires the use of explosives. If
so, notify WCH Safeguards and Security.”
A16
I Contractors must determine the
applicability of the explosives safety
directive requirements to research
and development laboratory type
operations consistent with the DOE
level of protection criteria described
in the explosives safety directive.
PSD-8, Rev. 0
02/08/2010
NA
Not Applicable
Page 44 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
A17
A18
WCH
Implementing Procedure
WCH
Procedure Citation
Attachment J.1 – 4. Pressure Safety
“…Unless otherwise noted, the design,
fabrication , construction,
decommissioning, demolition, testing, and
maintenance of facilities used to support ER
shall be based on applicable sections of the
codes and standards, regulations, and other
reference documents listed in Section 10.0.
Additional applicable regulatory
requirements may be cited, and the edition
(revision) of the codes and standards as
determined by project-specific requirements
shall be used...”
(a) Contractors must establish safety
policies and procedures to ensure
that pressure systems are designed,
fabricated, tested, inspected,
maintained, repaired, and operated
by trained and qualified personnel in
accordance with applicable and
sound engineering principles.
WCH-56. Sect. 1.5
(b) Contractors must ensure that all
pressure vessels, boilers, air
receivers, and supporting piping
systems conform to:
WCH-56, Sect. 5.1
“…If required, pressure vessels shall be
designed and initially inspected and tested
in accordance with the requirements of the
American Society of Mechanical Engineers
(ASME) Boiler and Pressure Vessel Codes
(ASME F00230), with the exception that no
code stamp shall be applied to such vessels
unless specified for the project. Welding of
such vessels shall be in accordance with the
ASME F00230…”
(2) The applicable ASME B.31
Standards of Pressure Piping; and or;
WCH-56, Table 5-1
“…
(3) The strictest applicable state and
local codes.
WCH-56, Sect. 1.5
“…Unless otherwise noted, the design,
fabrication , construction,
decommissioning, demolition, testing, and
maintenance of facilities used to support ER
shall be based on applicable sections of the
codes and standards, regulations, and other
reference documents listed in Section 10.0.
Additional applicable regulatory
requirements may be cited, and the edition
(revision) of the codes and standards as
determined by project-specific requirements
shall be used...’
Various
See Below for specifics. (A22 to A24.)
(1) The applicable American Society
of Mechanical Engineers (ASME)
Boilers and Pressure Vessel Code;
sections I through section XII
including applicable Code Cases
Piping
A19
ASME
B31.3
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
ASME b31.3,
ANSI-N278.1
…”
A20
I When national consensus codes are
not applicable (because of pressure
A21
range, vessel geometry, use of
special materials, etc.), contractors
must implement measures to provide
PSD-8, Rev. 0
02/08/2010
Page 45 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
WCH
Implementing Procedure
WCH
Procedure Citation
Attachment J.1 – 4. Pressure Safety
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
equivalent protection and ensure a
level of safety greater than or equal
to the level of protection afforded by
the ASME or applicable state or
local code. Measures must include
the following:
A22
(1) Design drawings, sketches, and
calculations must be reviewed and
approved by a qualified independent
design professional (i.e., professional
engineer). Documented
organizational peer review is
acceptable.
ENG-1-4.5, Sect. 6.1 (1)
“…The Project Engineer appoints a
qualified originator and checker and, if
required, reviewer to prepare and check and
the calculation, respectively.”
ENG-1-4.7, Att. 1 (4.6)
1.
“…When required by the State
of Washington or by Federal law, as
determined by the Project Engineer or by
the client, design drawings shall be
stamped/sealed, signed, and dated by a
registered professional engineer of the
appropriate discipline. Registered
professional engineers can only stamp/seal
drawings for which they have prepared or
supervised the preparation…”
(2) Qualified personnel must be used
to perform examinations and
inspections of materials, in-process
fabrications, non-destructive tests,
and acceptance test.
WCH-56, Sect. 1.5
“…Unless otherwise noted, the design,
fabrication , construction,
decommissioning, demolition, testing, and
maintenance of facilities used to support ER
shall be based on applicable sections of the
codes and standards, regulations, and other
reference documents listed in Section 10.0.
Additional applicable regulatory
requirements may be cited, and the edition
(revision) of the codes and standards as
determined by project-specific requirements
shall be used...”
(3) Documentation, traceability, and
accountability must be maintained
for each pressure vessel or system,
including descriptions of design,
pressure, testing, operation, repair,
and maintenance.
WCH-56, Sect. 5.1
“…If required, pressure vessels shall be
designed and initially inspected and tested
in accordance with the requirements of the
American Society of Mechanical Engineers
(AS Boiler and Pressure Vessel Codes
(ASME F00230), with the exception that no
code stamp shall be applied to such vessels
unless specified for the project. Welding of
such vessels shall be in accordance with
ASME F00230....”
WCH-56, Sect. 5.2
For non-safety-related and important-tosafety (ITS) mechanical equipment that
may include pressure piping, pressure
vessels, boilers, and air receivers, this
A23
A24
PSD-8, Rev. 0
02/08/2010
Page 46 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
WCH
Implementing Procedure
WCH
Procedure Citation
Attachment J.1 – 4. Pressure Safety
equipment shall be:
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
a. Designed in accordance with the
applicable national standards and codes
identified by the project's technical
specifications. Where project-specific
technical specifications are not available,
the equipment shall be designed in
accordance with the applicable sections of
ASME 631.3, Process Piping, or the ASME
Boiler and Pressure Vessel Code.
b. Examined and inspected by qualified
personnel as identified in the project's
technical specifications. Where projectspecific technical specifications are not
available, pressure piping shall be examined
and inspected in accordance with applicable
sections of ASME B31.3, Chapter VI,
Inspection, Examination and Testing.
Examination and inspection of pressure
vessels, boilers, and air receivers shall be in
accordance with applicable sections of the
ASME Boiler and Pressure Vessel Code.
PSD-8, Rev. 0
02/08/2010
Page 47 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
NA
A25
(a) A contractor engaged in DOE
activities involving the use of
firearms must establish firearms
safety policies and procedures for
security operation, and training to
ensure proper accident prevention
controls are in place.
WCH
Procedure Citation
Attachment J.1 – 5. Fire Arms Safety
Not Applicable
NA
 Not Applicable
A26
(1) Written procedures must address
firearms safety, engineering and
administrative controls, as well as
personal protective equipment
requirements.
(2) As a minimum, procedures must
be established for:
NA
 Not Applicable
NA

A28
(ii) Activities such as loading,
unloading, and exchanging firearms.
These procedures must address use
of bullet containment devices and
those techniques to be used when no
bullet containment device is
available;
(iii) Use and storage of pyrotechnics,
explosives, and/or explosive
projectiles;
NA
Not Applicable
A29
A30
(iv) Handling misfires, duds, and
unauthorized discharges;
NA
Not Applicable
A31
(v) Live fire training, qualification,
and evaluation activities;
NA

A32
(vi) Training and exercises using
engagement simulation systems;
NA
Not Applicable
A33
(vii) Medical response at firearms
training facilities; and
NA
Not Applicable
NA
Not Applicable
A34
(viii) Use of firing ranges by
personnel other than DOE or DOE
contractor protective forces
personnel.
A35
(b) Contractors must ensure that
personnel responsible for the
NA
Not Applicable
Restatement of the Requirement
A27
WCH
Implementing Procedure
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
(i) Storage, handling, cleaning,
inventory, and maintenance of
firearms and associated ammunition;
PSD-8, Rev. 0
02/08/2010
Not Applicable
Not Applicable
Page 48 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
WCH
Implementing Procedure
WCH
Procedure Citation
Attachment J.1 – 5. Fire Arms Safety
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
direction and operation of the
firearms safety program are
professionally qualified and have
sufficient time and authority to
implement the procedures under this
section.
NA
Not Applicable
A36
I Contractors must ensure that
firearms instructors and armorers
have been certified by the
Safeguards and Security National
Training Center to conduct the level
of activity provided. Personnel must
not be allowed to conduct activities
for which they have not been
certified.
NA
Not Applicable
A37
(d) Contractors must conduct formal
appraisals assessing implementation
of procedures, personnel
responsibilities, and duty
assignments to ensure overall policy
objectives and performance criteria
are being met by qualified personnel.
NA
Not Applicable
A38
(e) Contractors must implement
procedures related to firearms
training, live fire range safety,
qualification, and evaluation
activities, including procedures
requiring that:
NA
Not Applicable
A39
(1) Personnel must successfully
complete initial firearms safety
training before being issued any
firearms. Authorization to remain in
armed status will continue only if the
employee demonstrates the technical
and practical knowledge of firearms
safety semiannually;
NA
Not Applicable
A40
(2) Authorized armed personnel
must demonstrate through
documented limited scope
performance tests both technical and
practical knowledge of firearms
handling and safety on a semi-annual
basis;
A41
(3) All firearms training lesson plans
must incorporate safety for all
NA
Not Applicable
PSD-8, Rev. 0
02/08/2010
Page 49 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
WCH
Implementing Procedure
WCH
Procedure Citation
Attachment J.1 – 5. Fire Arms Safety
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
aspects of firearms training task
performance standards. The lesson
plans must follow the standards 336
set forth by the Safeguards and
Security Central Training
Academy’s standard training
programs;
NA
Not Applicable
A42
(4) Firearms safety briefings must
immediately precede training,
qualifications, and evaluation
activities involving live fire and/or
engagement simulation systems;
NA
Not Applicable
A43
(5) A safety analysis approved by the
Head of DOE Field Element must be
developed for the facilities and
operation of each live fire range
prior to implementation of any new
training, qualification, or evaluation
activity. Results of these analyses
must be incorporated into
procedures, lesson plans, exercise
plans, and limited scope
performance tests;
6) Firing range safety procedures
must be conspicuously posted at all
range facilities; and
NA
Not Applicable
A44
NA
Not Applicable
A45
(7) Live fire ranges, approved by the
Head of DOE Field Element, must
be properly sited to protect personnel
on the range, as well as personnel
and property not associated with the
range.
(f) Contractors must ensure that the
transportation, handling, placarding,
and storage of munitions conform to
the applicable DOE requirements.
NA
b. Not Applicable
A46
PSD-8, Rev. 0
02/08/2010
Page 50 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
Contractors must implement a
comprehensive industrial hygiene
program that includes at least the
following elements:
(a) Initial or baseline surveys and
periodic resurveys and /or exposure
monitoring as appropriate of all
work areas or operations to identify
and evaluate potential worker health
risks;
WCH
Implementing Procedure
SH-1-4.1, Sect. 1
SH-1-4.3; Sect. 1 & 2
WCH
Procedure Citation
Attachment J.1 – 6. Industrial Hygiene
“This procedure describes the Washington
Closure Hanford (WCH) Industrial Hygiene
(IH) Program. It establishes a
comprehensive and effective industrial
hygiene program as required by 10 Code of
Federal Regulations (CFR) 851, "Worker
Safety and Health Program.””
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
“This procedure provides requirements for
conducting initial and baseline Industrial
Hygiene (IH) surveys of Washington
Closure Hanford (WCH) work sites or
operations.”
“This procedure applies to all WCH direct
hire work sites or operations. However, if
the same operation, by the same
organization, is conducted at multiple sites,
an initial or baseline IH survey would not
be required at each site. Work areas where
only consumer type hazardous materials are
used such as office buildings or trailers,
common conveyances such as trucks or
cars, and outdoor areas that are not part of
an active site remediation operation are also
not required to have initial or baseline IH
surveys.”
A47
“This procedure does not apply to worksites
managed by WCH subcontractors.
Subcontractor requirements for industrial
hygiene surveys of work sites and
operations under their control are included
in their safety and health programs, as
required in the subcontract documents.”
SH-1-6.1, Sect. 6.4
PSD-8, Rev. 0
02/08/2010
“Title 29 CFR 1910.120 and 29 CFR
1926.65 “Hazardous Waste Operations and
Emergency Response” standards, are
applicable on most WCH work sites and,
therefore, require preparation of a health
and safety plan. [10 CFR 851.A1] The
HASP/SSHASP identifies hazards and
mitigating controls represented by general
site work and environmental conditions
(e.g., weather, types of biological hazards,
fall protection, hearing conservation, etc.)
and IWCP exempted work activities.
Page 51 of 70
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Restatement of the Requirement
WCH
Implementing Procedure
WCH
Procedure Citation
Attachment J.1 – 6. Industrial Hygiene
NOTE: In some cases (e.g., company level
activities), the WSHP Plan may serve as the
health and safety plan (HASP).
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
The first revision of the health and safety
plan may be developed during the design
phase. Subsequent revisions of the HASP or
SSHASP continue to add detail.”
(b) Coordination with planning and
design personnel to anticipate and
control health hazards that proposed
facilities and operations would
introduce;
SH-1-4.1, Sect. 3
“Industrial Hygiene (IH) is the science of
protecting the health of workers by
minimizing exposure to physical, chemical,
and biological hazards. This is
accomplished by (1) identifying hazards
during work planning, (2) performing a
comprehensive evaluation of hazards during
the conduct of work, (3) controlling hazards
and other environmental factors that can
cause illness/disability or significant
discomfort to Washington Closure Hanford
(WCH) workers, and (4) training workers to
recognize and avoid hazards in the
workplace.”
I Coordination with cognizant
occupational medical,
environmental, health physics, and
work planning professionals;
SH-1-4.1, Sect. 4
“IH Program Administrator
A48
A49

Provides IH technical support to WCH
management, functions, and projects.

Provides support and oversight for IH
education and training. · Coordinates
IH issues within the WCH and with
external customers. · Reviews external
reports, bulletins, newsletters, and
other documents for trends and
lessons learned that are applicable to
WCH project work sites.

Provides technical review of safety
and health procedures.

Provides input to responses for facility
representative reports and other
regulatory assessments.”
“Project IH

PSD-8, Rev. 0
02/08/2010
Communicates hazard assessments,
results of evaluations, and control
recommendations to management for
information and/or corrective action.
Page 52 of 70
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Restatement of the Requirement
WCH
Implementing Procedure
SH-1-4.1, Sect. 6.4
WCH
Procedure Citation
Attachment J.1 – 6. Industrial Hygiene

Monitors employee workplace
exposure to chemical, biological, and
physical agents.

Notifies employees of the results of
exposure monitoring in accordance
with Occupational Safety and Health
Administration (OSHA) and U.S.
Department of Energy (DOE)
requirements.

Participates in critiques and
investigations.

Provides technical direction to
subcontractors in accordance with
contract requirements.

Provides IH support to projects for the
development of work control
documents such as Job Hazards
Analysis, Activity Hazards Analysis
and Site Specific Health and Safety
Plans.

Provides site specific worker training
on IH hazards.”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
“Occupational Medical Surveillance
The Project IH or design support IH
identifies medical surveillance required by
standards, regulations and procedures
during project design and planning. These
requirements are communicated to project
supervision. The project supervisor,
working with the employee, revises the
Employee Job Task Analysis (EJTA). The
EJTA is then reviewed and approved by IH
and the medical surveillance indicated by
the EJTA is scheduled with the Site
Occupational Medical Provider.”
(d) Policies and procedures to
mitigate the risk from identified and
potential occupational carcinogens;
A50
PSD-8, Rev. 0
02/08/2010
SH-1-4.7
“This procedure identifies the requirements
and responsibilities for managing
Washington Closure Hanford (WCH)
asbestos-containing material (ACM) or
presumed asbestos-containing material
(PACM), to ensure worker safety and
environmental protection. It establishes the
WCH policy to maintain employee asbestos
fiber exposures to the lowest level possible
Page 53 of 70
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Restatement of the Requirement
WCH
Implementing Procedure
SH-1-4.9
DOE-0342, Hanford Site
Chronic Beryllium Disease
Prevention Program.
WCH
Procedure Citation
Attachment J.1 – 6. Industrial Hygiene
using (in order of precedence) engineering
controls, administrative controls and
personal protective equipment (PPE). This
procedure integrates WCH Industrial
Hygiene (IH), Supervision, and employee
responsibilities for safe handling of
asbestos.”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
This procedure establishes the Washington
Closure Hanford (WCH) Chronic Beryllium
Disease Prevention Program (CBDPP) and
implements controls necessary to minimize
the exposure of WCH employees to
beryllium, to provide medical surveillance,
and to prevent the spread of beryllium from
identified controlled areas by adopting in
full DOE-0342, Hanford Site Chronic
Beryllium Disease Prevention Program.
This procedure implements employer
requirements found in 10 Code of Federal
Regulations (CFR) 850 for WCH work
sites, and integrates these requirements into
the WCH Integrated Environment, Safety
and Health Management System (ISMS)
work flow process. This procedure also
requires that WCH subcontracts adopt in
full DOE-0342, HSCBDPP as a
requirement for beryllium work activities
conducted by subcontractors. [10 CFR
851.23]
This entire procedure implements
requirements of the WCH Worker Safety
and Health Program Plan for compliance to
Title 10, Code of Federal Regulations, Part
851."
Entire procedure and DOE-0342
implements the requirement.
SH-1-4.10
PSD-8, Rev. 0
02/08/2010
“This procedure implements the
requirements for working with cadmium as
specified in 29 Code of Federal Regulations
(CFR) 1926.1127. Cadmium is the cause of
a wide variety of health effects. Short-tem
overexposure to cadmium can cause severe
lung irritation, while long-term
overexposure is characterized by lung
injury (emphysema) and kidney
dysfunction. Cadmium is also listed as a
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Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
WCH
Implementing Procedure
WCH
Procedure Citation
Attachment J.1 – 6. Industrial Hygiene
suspected human carcinogen. Work with
and around cadmium requires careful
planning to reduce or eliminate exposure
potential.”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
Entire procedure implements the
requirement.
(e) Professionally and technically
qualified industrial hygienists to
manage and implement the industrial
hygiene program; and
SH-1-4.1. Sect. 4
“Manager Safety & Health

A51
Responsible for providing and
maintaining the necessary staff and
resources to develop, implement, and
maintain the WCH IH Program.
Designates a certified industrial hygienist as
the WCH Industrial Hygiene Program
Administrator.”
A52
(f) Use of respiratory protection
equipment tested under the DOE
Respirator Acceptance Program for
Supplied-air Suits (DOE-Technical
Standard-1167-2003) when National
Institute for Occupational Safety and
Health-approved respiratory
protection does not exist for DOE
tasks that require such equipment.
For security operations conducted in
accordance with Presidential
Directive Decision 39, U.S. POLICY
ON COUNTER TERRORISM, use
of Department of Defense military
type masks for respiratory protection
by security personnel is acceptable.
PSD-8, Rev. 0
02/08/2010
SH-1-4.6
“The purpose of this procedure is to provide
information and requirements for
respiratory protection, which includes the
proper use of respirators in radiological
control areas and toxic environments. These
requirements are derived from Occupational
Safety and Health Administration’s
(OSHA’s) 29 Code of Federal Regulations
(CFR) 1910.134 (29 CFR 1910.134
incorporates 29 CFR 1926.103) and
American National Standards Institute
(ANSI) standard ANSI Z88.2-1992 (ANSI
1992).”
Presidential Directive Decision 39 does not
apply for WCH activities.
Page 55 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
NA
WCH
Procedure Citation
Attachment J.1 – 7. Biological Safety
Not Applicable
NA
Not Applicable
A54
(i) Review any work with biological
etiologic agents for compliance with
applicable Center for Disease
Control (CDC), National Institutes
of Health (NIH), World Health
Organization (WHO), and other
international, Federal, state, and
local guidelines and 338 assess the
containment level, facilities,
procedures, practices, and training
and expertise of personnel; and
NA
Not Applicable
A55
(ii) Review the site’s security,
safeguards, and emergency
management plans and procedures to
ensure they adequately consider
work involving biological etiologic
agents.
NA
Not Applicable
A56
(2) Maintains an inventory and status
of biological etiologic agents, and
provide to the responsible field and
area office, through the laboratory
IBC (or its equivalent), an annual
status report describing the status
and inventory of biological etiologic
agents and the biological safety
program.
NA
Not Applicable
A57
(3) Provides for submission to the
appropriate Head of DOE Field
Element, for review and concurrence
before transmittal to the Center for
Disease Control (CDC), each
Laboratory Registration/Select
Agent Program registration
application package requesting
registration of a laboratory facility
for the purpose of transferring,
receiving, or handling biological
select agents.
Restatement of the Requirement
A53
(a) Contractors must establish and
implement a biological safety
program that:
WCH
Implementing Procedure
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
(1) Establishes an Institutional
Biosafety Committee (IBC) or
equivalent. The IBC must:
PSD-8, Rev. 0
02/08/2010
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Washington Closure Hanford 10 CFR 851 Compliance Matrix
NA
A58
(4) Provides for submission to the
appropriate Head of DOE Field
Element, a copy of each CDC Form
EA-101, Transfer of Select Agents,
upon initial submission of the Form
EA-101 to a vendor or other supplier
requesting or ordering a biological
select agent for transfer, receipt, and
handling in the registered facility.
Submit to the appropriate Head of
DOE Field Element the completed
copy of the Form EA-101,
documenting final disposition and/or
destruction of the select agent,
within 10 days of completion of the
Form EA-101.
WCH
Procedure Citation
Attachment J.1 – 7. Biological Safety
Not Applicable
NA
Not Applicable
A59
(5) Confirms that the site safeguards
and security plans and emergency
management programs address
biological etiologic agents, with
particular emphasis on biological
select agents.
NA
Not Applicable
A60
(6) Establishes an immunization
policy for personnel working with
biological etiologic agents based on
the evaluation of risk and benefit of
immunization.
Restatement of the Requirement
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
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Restatement of the Requirement
A61
(a) Contractors must establish and
provide comprehensive occupational
medicine services to workers
employed at a covered work place
who:
WCH
Implementing Procedure
SH-1-3.21, Sect. 4.2
(1) Work on a DOE site for more
than 30 days in a 12-month period;
or
A62
(2) Are enrolled for any length of
time in a medical or exposure
monitoring program required by this
rule and/or any other applicable
Federal, State or local regulation, or
other obligation.
A63
(b) The occupational medicine
services must be under the direction
of a graduate of a school of medicine
or osteopathy and licensed for the
practice of medicine in the state in
which the site is located.
A64
c) Occupational medical physicians,
occupational health nurses,
physician’s assistants, nurse
practitioners, psychologists,
employee assistance counselors, and
other occupational health personnel
providing occupational medicine
services must be licensed, registered,
or certified as required by Federal or
State law where employed.
A65
d) Contractors must provide the
occupational medicine providers
access to hazard information by
promoting its communication,
coordination, and sharing among
operating and environment, safety,
and health protection organizations.
PSD-8, Rev. 0
02/08/2010
WCH
Procedure Citation
Attachment J.1 – 8. Occupational Medicine
“The supervisor is responsible for initiating
an EJTA for every employee upon hire to
ensure placement of the employee in
necessary medical qualifications: and
monitoring based on the job requirements,
hazards, exposures, and overall risk
associated with the assigned work scope.”
Contract No. DE –AC0605RL14655
“…This procedure introduces the EJTA for
that purpose and to facilitate compliance
with requirements in the Occupational
Safety and Health Administration (OSHA)
29 CFR 1910 and 29 CFR 1926 that require
medical qualification examinations or
medical monitoring programs when specific
activities are being performed or when
specified hazards and exposures are
encountered.”
Mandatory Hanford Site Service - AMH
responsibility.
Contract No. DE –AC0605RL14655
Mandatory Hanford Site Service - AMH
responsibility.
SH-1-2.7, Sect. 6.2(2)
“2. Coordination and teaming between
industrial hygiene, health physics, safety
professionals, and worker participants, in
conjunction with occupational medicine
personnel, emphasize the importance of
identifying the physical, chemical, and
biological hazards present at the work site.
This teaming effort is essential for the
promotion of a healthful work
environment.”
SH-1-3.21, Sect. 4.0
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
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Restatement of the Requirement
WCH
Implementing Procedure
SH-1-3.21, Sect. 4.0
SH-1-4.4, Sect. 6.3
(1) Contractors must provide the
occupational medicine providers
with access to information on the
following:
SH-1-3.21 Sect. 3.0;
“…Employee job task analysis (EJTA): An
electronic database form used by managers
and supervisors to compile job
requirements, hazards, exposures, and
overall health risk for an employee’s jobs
and tasks. The completed form is used to
determine the appropriate medical
qualification and monitoring programs for
the employee. The Risk Management and
Medical Surveillance/EJTA Database is
owned and administered by the
AdvanceMed Hanford (AMH)…”
SH-1-4.1, Sect. 6.2.2
“…Exposure monitoring and assessment
records are reported to the employee and
are maintained in the employee’s medical
record…”
SH-1-4.1, Sect. 6.4
“…The Project IH or design support IH
identifies medical surveillance required by
standards, regulations and procedures
during project design and planning. These
requirements are communicated to project
supervision. The project supervisor,
working with the employee, revises the
Employee Job Task Analysis (EJTA). The
EJTA is then reviewed and approved by IH
and the medical surveillance indicated by
the EJTA is scheduled with the Site
Occupational Medical Provider…”
SH-1-3.21 Sect. 3.0
“…Employee job task analysis (EJTA): An
electronic database form used by managers
and supervisors to compile job
requirements, hazards, exposures, and
(i) Current information about actual
or potential work-related site hazards
(chemical, radiological, physical,
biological, or ergonomic);
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A67
(ii) Employee job-task and hazard
analysis information, including
essential job functions;
PSD-8, Rev. 0
02/08/2010
WCH
Procedure Citation
Attachment J.1 – 8. Occupational Medicine
“The U.S. Department of Energy (DOE)
CRD O 440.1A, Contractor Occupational
Medical Program, Worker Protection
Management for DOE Federal and
Contractor Employees, Section 19,
“Occupational Medical,” requires that
EJTA information shall be provided to the
medical contractor…”
“Medical Reports and copies of written
notification letters are submitted to the
SOMC for inclusion into the individual’s
medical file for each calendar quarter by the
end of the following month.”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
Page 59 of 70
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Restatement of the Requirement
(iii) Actual or potential work-site
exposures of each employee; and
WCH
Implementing Procedure
SH-1-3.21 Sect. 3.0
“…Employee job task analysis (EJTA): An
electronic database form used by managers
and supervisors to compile job
requirements, hazards, exposures, and
overall health risk for an employee’s jobs
and tasks. The completed form is used to
determine the appropriate medical
qualification and monitoring programs for
the employee. The Risk Management and
Medical Surveillance/EJTA Database is
owned and administered by the
AdvanceMed Hanford (AMH)…”
SH-1-4.1, Sect. 6.2.2
“…Exposure monitoring and assessment
records are reported to the employee and
are maintained in the employee’s medical
record…”
SH-1-4.1, Sect. 6.4
“…The Project IH or design support IH
identifies medical surveillance required by
standards, regulations and procedures
during project design and planning. These
requirements are communicated to project
supervision. The project supervisor,
working with the employee, revises the
Employee Job Task Analysis (EJTA). The
EJTA is then reviewed and approved by IH
and the medical surveillance indicated by
the EJTA is scheduled with the Site
Occupational Medical Provider…”
SH-1-3.21 Sect. 3.0
“…Employee job task analysis (EJTA): An
electronic database form used by managers
and supervisors to compile job
requirements, hazards, exposures, and
overall health risk for an employee’s jobs
and tasks. The completed form is used to
determine the appropriate medical
qualification and monitoring programs for
the employee. The Risk Management and
A68
(iv) Personnel actions resulting in a
change of job functions, hazards or
exposures.
A69
PSD-8, Rev. 0
02/08/2010
WCH
Procedure Citation
Attachment J.1 – 8. Occupational Medicine
overall health risk for an employee’s jobs
and tasks. The completed form is used to
determine the appropriate medical
qualification and monitoring programs for
the employee. The Risk Management and
Medical Surveillance/EJTA Database is
owned and administered by the
AdvanceMed Hanford (AMH)…”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
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Restatement of the Requirement
A70
(2) Contractors must notify the
occupational medicine providers
when an employee has been absent
because of an injury or illness for
more than 5 consecutive workdays
(or an equivalent time period for
those individuals on an alternative
work schedule);
WCH
Implementing Procedure
SH-1-3.21, Sect. 6.3
WCH
Procedure Citation
Attachment J.1 – 8. Occupational Medicine
Medical Surveillance/EJTA Database is
owned and administered by the
AdvanceMed Hanford (AMH)…”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
“Supervisor…notify the OHPC when an
employee has been absent because of an
injury or illness for more than 5 consecutive
workdays (or an equivalent time period for
those individuals on an alternative work
schedule)…”
“OHPC…notify the occupational medicine
provider when an employee has been absent
because of an injury or illness for more than
5 consecutive workdays (or an equivalent
time period for those individuals on an
alternative work schedule)…”
SH-1-2.7, Sect. 4.0
A71
(3) Contractors must provide the
occupational medicine provider
information on, and the opportunity
to participate in, worker safety and
health team meetings and
committees;
“Safety and Health….Provide the
occupational medicine provider information
on, and the opportunity to participate in,
worker safety and health team meetings and
committees...”
SH-1-2.7, Sect. 4.0
A72
(4) Contractors must provide
occupational medicine providers
access to the workplace for
evaluation of job conditions and
issues relating to workers’ health.
“Safety and Health…Provide the
occupational medicine provider access to
the workplace for evaluation of job
conditions and issues relating to workers’
health…”
(e) A designated occupational
medicine provider must:
Contract No. DE –AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
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A74
(1) Plan and implement the
occupation medicine services; and
(2) Participate in worker protection
teams to build and maintain
necessary partnerships among
workers, their representatives,
managers, and safety and health
protection specialists in establishing
and maintaining a safe and healthful
workplace.
SH-1-2.7, Sect. 6.2(2)
Contract No. DE –AC0605RL14655
PSD-8, Rev. 0
02/08/2010
“Coordination and teaming between
industrial hygiene, health physics, safety
professionals, and worker participants, in
conjunction with occupational medicine
personnel, emphasize the importance of
identifying the physical, chemical, and
biological hazards present at the work site.
This teaming effort is essential for the
promotion of a healthful work
environment.”
Mandatory Hanford Site Service – AMH
responsibility.
Page 61 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Contract No. DE –AC0605RL14655
A75
(f) A record, containing any medical,
health history, exposure history, and
demographic data collected for the
occupational medicine purposes,
must be developed and maintained
for each employee for whom
medical services are provided. All
occupational medical records must
be maintained in accordance with
Executive Order 13335, Incentives
for the Use of Health Information
Technology.
WCH
Procedure Citation
Attachment J.1 – 8. Occupational Medicine
Mandatory Hanford Site Service – AMH
responsibility.
Contract No. DE –AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
A76
(1) Employee medical,
psychological, and employee
assistance program (EAP) records
must be kept confidential, protected
from unauthorized access, and stored
under 341 conditions that ensure
their long-term preservation.
Psychological records must be
maintained separately from medical
records and in the custody the
designated psychologist in
accordance with 10 CFR
712.38(b)(2).
Contract No. DE –AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
A77
(2) Access to these records must be
provided in accordance with DOE
regulations implementing the
Privacy Act and the Energy
Employees Occupational Illness
Compensation Program Act.
Contract No. DE –AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
A78
(g) The occupational medicine
services provider must determine the
content of the worker health
evaluations, which must be
conducted under the direction of a
licensed physician, in accordance
with current sound and acceptable
medical practices and all pertinent
statutory and regulatory
requirements, such as the Americans
with Disabilities Act.
A79
(1) Workers must be informed of the
purpose and nature of the medical
evaluations and tests offered by the
occupational medicine provider.
Contract No. DE –AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
Restatement of the Requirement
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
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Contract No. DE –AC0605RL14655
A80
(i) The purpose, nature and results of
evaluations and tests must be clearly
communicated verbally and in
writing to each worker provided
testing;
WCH
Procedure Citation
Attachment J.1 – 8. Occupational Medicine
Mandatory Hanford Site Service – AMH
responsibility.
A81
(ii) The communication must be
documented in the worker’s medical
record; and
Contract No. DE –AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
Contract No. DE –AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
A82
(2) The following health evaluations
must be conducted when determined
necessary by the occupational
medicine provider for the purpose of
providing initial and continuing
assessment of employee fitness for
duty.
Contract No. DE –AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
A83
(i) At the time of employment
entrance or transfer to a job with
new functions and hazards, a
medical placement evaluation of the
individual’s general health and
physical and psychological capacity
to perform work will establish a
baseline record of physical condition
and assure fitness for duty.
Contract No. DE –AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
A84
(ii) Periodic, hazard-based medical
monitoring or qualification-based
fitness for duty evaluations required
by regulations and standards, or as
recommended by the occupational
medicine services provider, will be
provided on the frequency required.
Contract No. DE –AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
A85
(iii) Diagnostic examinations will
evaluate employee’s injuries and
illnesses to determine workrelatedness, the applicability of
medical restrictions, and referral for
definitive care, as appropriate.
Contract No. DE- AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
Restatement of the Requirement
(iv) After a work-related injury or
illness or an absence due to any
injury or illness lasting 5 or more
consecutive workdays (or an
A86
equivalent time period for those
individuals on an alternative work
schedule), a return to work
evaluation will determine the
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
Page 63 of 70
Washington Closure Hanford 10 CFR 851 Compliance Matrix
Restatement of the Requirement
WCH
Implementing Procedure
WCH
Procedure Citation
Attachment J.1 – 8. Occupational Medicine
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
individual’s physical and
psychological capacity to perform
work and return to duty.
A87
(v) At the time of separation from
employment, individuals shall be
offered a general health evaluation to
establish a record of physical
condition.
SH-1-3.21, Sect. 6.2
“Supervisor…prior to employee separation
from the company, notify the OHPC to
schedule any required medical closeout
examinations.”
Contract No. DE- AC0605RL14655
A88
(h) The occupational medicine
provider must monitor ill and injured
workers to facilitate their
rehabilitation and safe return to work
and to minimize lost time and its
associated costs.
“OHPC…Schedule employee medical
qualification and monitoring examinations
as indicated on the EJTA and as directed by
the supervisor.”
Mandatory Hanford Site Service – AMH
responsibility.
Contract No. DE- AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
A89
(1) The occupational medicine
provider must place an individual
under medical restrictions when
health evaluations indicate that the
worker should not perform certain
job tasks. The occupational medicine
provider must notify the worker and
contractor management when
employee work restrictions are
imposed or removed.
Contract No. DE- AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
A90
(i) Occupational medicine provider
physician and medical staff must, on
a timely basis, communicate results
of health evaluations to management
and safety and health protection
specialists to facilitate the mitigation
of worksite hazards.
Contract No. DE- AC0605RL14655
Mandatory Hanford Site Service – AMH
responsibility.
A91
(j) The occupational medicine
provider must include measures to
identify and manage the principal
preventable causes of premature
morbidity and mortality affecting
worker health and productivity.
(1) The contractor must include
programs to prevent and manage
these causes of morbidity when
evaluations demonstrate their cost
SH-1-2.7, Sect. 6.1(1)
A92
PSD-8, Rev. 0
02/08/2010
“The WCH occupational health program
provides occupational health services to
employees, with an emphasis on the earliest
possible detection and mitigation of
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Restatement of the Requirement
WCH
Implementing Procedure
effectiveness.
A93
A94
(2) Contractors must make available
to the occupational medicine
provider appropriate access to
information from health, disability,
and other insurance plans (identified
as necessary) in order to facilitate
this process.
PM-HR-5, Sect. 1.3
“Only management, supervisory, and
administrative personnel with a legitimate
business need to know, may be permitted to
access another employee’s personnel file.
Proper identification and justification must
be provided.”
(k) The occupational medicine
services provider must review and
approve the medical and behavioral
aspects of employee counseling and
health promotional programs,
including the following types:
PM-HR-11
“…Washington Closure Hanford (WCH)
will provide confidential employee
assistance to eligible employees and/or
members of their immediate families to help
with problems that may affect the
employee’s job performance.”
BSC-1-1.10, Sect. 4.3
“…3. Maintains an EAP that is available to
all employees to help solve their personal
problems including substance abuse…”
Contract No. DE- AC0605RL14655
(1) Contractor-sponsored or
contractor-supported EAPs;
PM-HR-11
A95
Contract No. DE- AC0605RL14655
A96
WCH
Procedure Citation
Attachment J.1 – 8. Occupational Medicine
occupational illness and injury.”
(2) Contractor-sponsored or
contractor-supported alcohol and
other substance abuse rehabilitation
programs; and
BSC-1-1.10, Sect. 4.3
(3) Contractor-sponsored or
contractor-supported wellness
programs.
SH-1-2.7, Sect. 6.2
Contract No. DE- AC0605RL14655
A97
Contract No. DE- AC0605RL14655
PSD-8, Rev. 0
02/08/2010
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
Mandatory Hanford Site Service – AMH
responsibility.
“…Washington Closure Hanford (WCH)
will provide confidential employee
assistance to eligible employees and/or
members of their immediate families to help
with problems that may affect the
employee’s job performance.”
Mandatory Hanford Site Service – AMH
responsibility.
“…3. Maintains an EAP that is available to
all employees to help solve their personal
problems including substance abuse…”
Mandatory Hanford Site Service – AMH
responsibility.
“3. The WCH encourages regular work
site visits by occupational medical
physicians and selected medical staff to
promote familiarity and awareness of
existing or potential work-related health
hazards, employee job tasks, and work site
environments.”
Mandatory Hanford Site Service – AMH
responsibility. In addition, medical
benefits, including wellness programs may
be implemented through the Hanford Site
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Restatement of the Requirement
(4) The occupational medicine
services provider must review the
medical aspects of immunization
programs, blood-borne pathogens
programs, and bio-hazardous waste
programs to evaluate their
conformance to applicable
guidelines.
WCH
Implementing Procedure
SH-1-4.13, Sect. 1.0
A98
SH-1-4.13, Sect. 4.0
A99
(5) The occupational medicine
services provider must develop and
periodically review medical
emergency response procedures
included in site emergency and
disaster preparedness plans. The
medical emergency responses must
be integrated with nearby
community emergency and disaster
plans.
PSD-8, Rev. 0
02/08/2010
Contract No. DE- AC0605RL14655
WCH
Procedure Citation
Attachment J.1 – 8. Occupational Medicine
benefits program as administered by a
separate DOE-RL contractor.
“…The purpose of this procedure is to
protect employees from occupational
exposure to bloodborne pathogens (BBP)
and other potentially infectious materials
(OPIM). This procedure satisfies the
requirements specified in 29 CFR 1910,
Subpart Z, Toxic and Hazardous
Substances, 1910.1030, Bloodborne
Pathogens, and provides the requirements
and necessary precautions for preventing
occupational exposure to HBV, HIV, and
other BBPs…”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
“Project Director/Functional Manager (or
Designee)…Ensures that the Hanford
Occupational Medical Contractor evaluates
any worker involved in an exposure
incident…”
Mandatory Hanford Site Service – AMH
responsibility.
SEM-3-2.1, Sect. 4.0
“Field Safety Representative…provide
personnel injury information to the
Occupational Medical Coordinator…”
SEM-3-2.1, Sect. 6.2.1 (5)
“For injury events, the project Field Safety
Rep must notify the Occupational Medicine
Coordinator.”
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Restatement of the Requirement
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WCH
Implementing Procedure
WCH
Procedure Citation
Attachment J.1 – 9. Motor Vehicle Safety
“…WCH Vehicle Use requirements apply
to River Corridor Closure Contract
employees who are required to drive or ride
in a WCH (including rental vehicles) or
Client owned (Department of Energy
[DOE]) or leased vehicles for the purpose
of conducting business for WCH.”
(a) Contractors must implement a
motor vehicle safety program to
protect the safety and health of all
drivers and passengers in
Government-owned or -leased motor
vehicles and powered industrial
equipment (i.e., fork trucks, tractors,
platform lift trucks, and other similar
specialized equipment powered by
an electric motor or an internal
combustion engine).
SH-1-3.22, Sect. 2
SH-1-3.17, Sect. 1
“This procedure provides the general
requirements and direction necessary to
execute the Washington Closure Hanford
(WCH) forklift truck program in
accordance with applicable requirements set
forth in the Occupational Safety and Health
Administration, Department of Labor, Code
of Federal Regulations (OSHA) 29 CFR
1910.178 (l) “Powered Industrial Trucks.”
(b) The contractor must tailor the
motor vehicle safety program to the
individual DOE site or facility, based
on an analysis of the needs of that
particular site or facility.
SH-1-3.22, Sect. 2
“…WCH Vehicle Use requirements apply
to River Corridor Closure Contract
employees who are required to drive or ride
in a WCH (including rental vehicles) or
Client owned (Department of Energy
[DOE]) or leased vehicles for the purpose
of conducting business for WCH.”
SH-1-3.17, Sect. 1 & 2
“This procedure provides the general
requirements and direction necessary to
execute the Washington Closure Hanford
(WCH) forklift truck program in
accordance with applicable requirements set
forth in the Occupational Safety and Health
Administration, Department of Labor, Code
of Federal Regulations (OSHA) 29 CFR
1910.178 (l) “Powered Industrial
Trucks…”
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Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
“This procedure applies to all forklift truck
operation conducted by WCH and/or that
take place within WCH facilities or as part
of WCH operations, construction,
demolition, or otherwise.”
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(c) The motor vehicle safety
program must address, as applicable
to the contractor’s operations:
(1) Minimum licensing requirements
PSD-8, Rev. 0
02/08/2010
SH-1-3.22, Sect. 6.1.2
“2. WCH or Client owned or leased vehicle
operators must have a current state/federal
license/endorsement/certification and be
medically qualified if required under
state/federal regulations to operate the
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Restatement of the Requirement
WCH
Implementing Procedure
(including appropriate testing and
medical qualification) for personnel
operating motor vehicles and
powered industrial equipment;
(2) Requirements for the use of seat
belts and provision of other safety
devices;
SH-1-3.22, Sect. 6.2.6
WCH
Procedure Citation
Attachment J.1 – 9. Motor Vehicle Safety
involved vehicle. ”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
“6. Drivers and passengers MUST wear seat
belts, at all times, when driving or riding in
a WCH or Client owned or leased vehicle
including rental vehicles when driving on
paved or maintained gravel/dirt roadways.
NOTE: Drivers that operate a WCH or
Client owned or leased vehicle in
designated areas such as queues or parking
lots are exempt from seat belt use.”
A103
SH-1-3.17, Sect. 6.1(5&6)
“5. If the forklift is equipped with a seat
belt, seat belt use is mandatory.
6. The forklift shall have an overhead guard
for protection against falling objects.”
(3) Training for specialty vehicle
operators;
SH-1-3.22, Sect. 6.1.1
“WCH employees that are required by their
work to use WCH or Client owned or leased
vehicles will be instructed by their
supervisor to read and follow these
requirements before being allowed to use a
WCH vehicle.”
SH-1-3.17, Sect. 4.0
“Field Superintendent…ensures that forklift
truck operators are trained and qualified in
accordance with this procedure.”
SH-1-3.22, Sect. 6.5
“1. Each driver to use a WCH or Client
owned or leased vehicle will perform a
daily inspection. The driver will look for
proper tire inflation, fluid leaks, windshield
cracks and any damage or defect that will
interfere with the safe operation of the
vehicle. All defects must be reported to
your immediate supervisor.
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(4) Requirements for motor vehicle
maintenance and inspection;
A105
2. The oil will be checked each time a WCH
or Client owned vehicle is refueled. If the
oil level is low, either add the necessary oil
or report it to your immediate supervisor
who will arrange with a vehicle
maintenance company to add oil as needed.
3. If emergency repair is needed while an
employee has a WCH or Client owned or
PSD-8, Rev. 0
02/08/2010
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Restatement of the Requirement
WCH
Implementing Procedure
SH-1-3.17, Sect. 6.12
WCH
Procedure Citation
Attachment J.1 – 9. Motor Vehicle Safety
leased vehicle off-site, the employee is
authorized to repair the vehicle as needed to
ensure safe operation of the vehicle. The
WCH will reimburse all expenses incurred
by the employee for vehicle repair.”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
“1. A pre-operations safety inspection shall
be performed at the beginning of each shift
by the operator.
2. A forklift shall be tagged and taken out
of service when defects are found.
3. Only certified mechanics are permitted to
perform repairs.”
(5) Uniform traffic and pedestrian
control devices and road signs;
NA
Roads on the Hanford Site that are
maintained by FHI are subject to State and
County regulations, including uniform
traffic and pedestrian control devices and
road signs. Roads that are designated as
non-maintained are not required to meet
uniform traffic and pedestrian control
devices and road signs and therefore are not
subject to requirements under 10 CFR 851
related to uniformity. Roads that are
associated with private office buildings are
required to be maintained by the Landlord
of the facility and are not subject to
requirements under 10 CFR 851.
(6) On-site speed limits and other
traffic rules;
SH-1-3.22, Sect. 6.2(1)
WCH employees will comply with all
federal, state and local motor vehicle laws
while using and/or operating any motor
vehicle owned, leased, or rented by WCH
or its client. [10 CFR 851.A9, RCW
46.08.030]
(7) Awareness campaigns and
incentive programs to encourage safe
driving; and
NA
Awareness campaigns and incentives are
integrated into the overall WCH S&H
awareness and incentive and the safety
management programs.
(8) Enforcement provisions.
NA
Enforcement of roads that are subject to
State and County motor vehicle regulations
is conducted by the Benton County
Sheriff’s Department through a contract
between DOE and Benton County.
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PSD-8, Rev. 0
02/08/2010
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Restatement of the Requirement
A110
10. Electrical Safety. Contractors
must implement a comprehensive
electrical safety program appropriate
for the activities at their site. This
program must meet the applicable
electrical safety codes and standards
referenced in § 851.23.
PSD-8, Rev. 0
02/08/2010
WCH
Implementing Procedure
PAS-1-2.3, Sect. 1
WCH
Procedure Citation
Attachment J.1 – 10. Electrical Safety
“The purpose of the Washington Closure
Hanford (WCH) Electrical Safety Program
is to provide the requirements for
establishing an electrically safe workplace
and provide direction to implement
electrical safety compliant with the
requirements of NFPA 70E, Standard for
Electrical Safety in the Workplace, and
DOE Richland Requirement Document
(RRD) # 005, Worker Safety, Sections D
and E.”
Subcontractor
Implementing Procedure
Subcontractor
Procedure Citation
Page 70 of 70