WSI ISMS 20Description by Ax2xkCQ

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									[NOTE:       Signed Original is on File in the Occupational Safety
             and Health Department – Building 703-B.]


    WACKENHUT SERVICES INCORPORATED-SAVANNAH RIVER SITE

   SAFETY MANAGEMENT SYSTEM DESCRIPTION (U)




                                 Terry S. Moreau
                              Deputy General Manager




                                  James H. Isom
                                 General Manager




                 UNCLASSIFIED – DOES NOT CONTAIN
           UNCLASSIFIED CONTROLLED NUCLEAR INFORMATION



             Reviewing
             Official:
                                    Thomas R. Coughenour
                                 WSI-SRS Classification Officer



             Date:                      February 19, 2008



Office of the Deputy General Manager
Wackenhut Services Incorporated-Savannah River Site
P.O. Drawer W
Aiken, South Carolina 29802
[NOTE:               Signed Original is on File in the Occupational Safety
                     and Health Department – Building 703-B.]
      WACKENHUT SERVICES INCORPORATED-SAVANNAH RIVER SITE
     SAFETY MANAGEMENT SYSTEM DESCRIPTION (U)
                                              TABLE OF CONTENTS

I.    PURPOSE.................................................................................................................. 1

II. SCOPE ..................................................................................................................... 2

III. POLICY ................................................................................................................... 3

IV. COMPONENTS .......................................................................................................... 3

      COMPONENT 1 – INTEGRATED SAFETY MANAGEMENT OBJECTIVE ........................ 3

      COMPONENT 2 – GUIDING PRINCIPLES FOR INTEGRATED SAFETY MANAGEMENT .. 4

      COMPONENT 3 – CORE FUNCTIONS FOR INTEGRATED SAFETY MANAGEMENT ....... 5

      COMPONENT 4 – MECHANISM OF INTEGRATED SAFETY MANAGEMENT ................. 5

      COMPONENT 5 – RESPONSIBILITIES FOR INTEGRATED SAFETY MANAGEMENT ....... 6

      COMPONENT 6 – IMPLEMENTATION OF INTEGRATED SAFETY MANAGEMENT......... 7

V. DISCUSSION ............................................................................................................ 7

      GLOBAL MECHANISMS ............................................................................................ 7

      DIVISIONAL MECHANISMS ...................................................................................... 26

             TRAINING DIVISION ........................................................................................ 26

             PROTECTIVE FORCE OPERATIONS DIVISION ..................................................... 28

             SPECIAL OPERATIONS DIVISION ....................................................................... 31

             ADMINISTRATION DIVISION ............................................................................. 33

             SECURITY PLANNING AND INFRASTRUCTURE DIVISION .................................. 34

             SECURITY SUPPORT DIVISION ......................................................................... 38

VI. SAFETY MANAGEMENT SYSTEM EFFECTIVENESS ................................................... 39

VII. CONCLUSION ........................................................................................................... 40
          Wackenhut Services Incorporated-Savannah River Site
                Safety Management System Description
                    February 19, 2008 (Revision 13)

I. PURPOSE
This document describes the Wackenhut Services Incorporated-Savannah River Site
(WSI-SRS) Safety Management System, which provides a formal, organized process
whereby people plan, perform, assess, and improve the safe conduct of work. The Safety
Management System establishes the company-wide safety management objective,
guiding principles, and core functions. Effective implementation of the Safety
Management System will result in complete integration of safety into all management
and work practices. This document satisfies the intent of DOE P 450.4, Safety
Management System Policy, for institutionalization of the safety management objective,
guiding principles, and core functions. In addition, preparation of this document satisfies
Safety Management System requirements found in the documents identified in Table 1,
Sources of Relevant Integrated Safety Management System Requirements, below:

           TABLE 1. SOURCES OF RELEVANT INTEGRATED
          SAFETY MANAGEMENT SYSTEM REQUIREMENTS
 Document Number         Title
 DOE P 411.1             Safety Management Functions, Responsibilities, and Authorities
                         Policy
 DOE M 411.1-1C          Safety Management Functions, Responsibilities, and Authorities
                         Manual
 DOE O 414.1C            Quality Assurance
 DOE G 414.1-2A          Quality Assurance Management System Guide
 DOE O 440.2B Chg. 1     Aviation Management and Safety
 DOE O 450.1             Environmental Protection Program
 Admin Chg. 1
 DOE G 450.3-2           Attributes of Effective Implementation
 DOE G 450.3-3           Tailoring for Integrated Safety Management Applications
 DOE M 450.4-1           Integrated Safety Management System Manual
 DOE G 450.4-1B          Integrated Safety Management System Guide (Volumes 1 and 2)
 DOE P 450.4             Safety Management System Policy
 DOE P 450.7             Department of Energy Environment, Safety and Health (ES&H)
                         Goals
 DEAR 970.5204-2         Laws, Regulations, and DOE Directives
 DEAR 970.5215-3         Conditional Payment of Fee, Profit, or Incentives
 DEAR 970.5223-1         Integration of Environment, Safety, and Health into Work Planning
                         and Execution
 10 CFR 830.121          Quality Assurance Program (QAP)

In accordance with paragraph (a) of Department of Energy Acquisition Regulations
(DEAR) clause 970.5223-1, the term safety used herein includes all aspects of
environment, safety, and health, including pollution prevention and waste minimization.



                                            1
The impact of WSI-SRS operations on the environment is a vital element of the Safety
Management System.

II. SCOPE
Every WSI-SRS employee is responsible for conducting his or her activities in
accordance with established safety programs and processes, approved safety policies and
procedures, and other relevant documentation. Therefore, the elements of this description
apply to all employees for implementation.
The WSI-SRS Worker Safety and Health Program, prepared in compliance with 10 CFR
851, Worker Safety and Health, is approved by the DOE-SR Manager. A copy of the
approved plan is available to WSI-SRS employees, or their designated representatives,
upon written request to the WSI-SRS Occupational Safety and Health Department
(OSHD). WSI-SRS submits an update to the DOE-SR Manager for review and approval
whenever a significant change or addition to the program is made. Annually, WSI-SRS
submits to DOE either an updated Worker Safety and Health Program for approval or a
letter stating that no changes are necessary. WSI-SRS incorporates in its Worker Safety
and Health Program any changes, conditions, or workplace safety and health standards
directed by DOE. Local #125 of the United Professional Pro-force of Savannah River is
given timely notice of the development and implementation of the Worker Safety and
Health Program and any updates. Nothing in the Worker Safety and Health Program
precludes WSI-SRS from taking any additional protective actions that it determines to be
necessary to protect the safety and health of its employees, the public, and/or the
environment.
In accordance with the Savannah River Site (SRS) Environmental Management System
(EMS) Policy, all WSI-SRS activities on SRS shall be conducted in compliance with
applicable laws and regulations providing for the protection of public health and the
environment. WSI-SRS is committed to reducing use of procedures and processes that
produce hazardous wastes and seeking ways to continually improve the performance of
activities protective of the environment. The objective of the SRS EMS policy is to
establish a consistent site wide approach to environmental protection through the
implementation of an EMS as part of the overall Integrated Safety Management System
(ISMS).
In accordance with the requirements of paragraph (i) of DEAR clause 970.5223-1,
paragraph (e) of DEAR clause 970.5204-2, and ESH Oversight of WSI-SRS Visitors,
Vendors, and Subcontractors (procedure 1-3120), WSI-SRS applies a graded approach in
flowing down contract clauses substantially the same as those DEAR clauses to its
subcontractors performing complex and/or hazardous work. Depending on a project’s
complexity and the hazards anticipated, WSI-SRS may require the subcontractor to adopt
the WSI-SRS Safety Management System, in whole or in part, during the project.
Alternatively, the subcontractor may be required to submit its own Safety Management
System for review and approval by the Occupational Safety and Health Department
(OSHD) before the project begins [as described in paragraph (i) of DEAR clause
970.5223-1]. However, WSI-SRS does not typically engage subcontractors in the
performance of complex and/or hazardous work.



                                           2
OSHD will review the documentation that WSI-SRS subcontractors who will be
performing complex and/or hazardous work are required to submit to ensure that the
documentation adequately addresses the hazards and controls of the planned work, in
accordance with the applicable requirements of the WSI-SRS Safety Management
System and 10 CFR 851. In accordance with the SRS Workplace Safety and Health
Policy, OSHD provides each project with a level of safety and health oversight tailored to
the nature, complexity, and hazards of the work, taking into consideration the experience
and expertise of the subcontractor personnel performing the work.
In January 2005, WSI-SRS joined Washington Savannah River Company (WSRC) and
the other major SRS organizations, including the DOE, in developing and implementing
the site’s new Point of Entry (POE) process for visitors, vendors, and subcontractors. In
response to the new POE process, WSI-SRS revised its two procedures most directly
impacted – ESH Oversight of WSI-SRS Visitors, Vendors, and Subcontractors (procedure
1-3120), and General Procurement Procedures (procedure 1-1302), as well as Form 294,
Safety and Health Evaluation of Requested Subcontract Work. An OSHD staff member
is the WSI-SRS point of contact for successful POE process implementation.

III. POLICY
WSI-SRS is committed to conducting work efficiently and in a manner that ensures
protection of workers, the public, and the environment. WSI-SRS is committed to
providing a workplace that is free from recognized hazards that are causing (or have the
potential to cause) death or serious physical harm to anyone within the workplace, as well
as ensuring that WSI-SRS employees perform their work in accordance with the
applicable environment, safety, and health requirements that have been identified.
The WSI-SRS Safety Management System consists of the following hierarchy of six
components, which facilitate the orderly development and implementation of safety
management throughout the company: 1) the objective, 2) DOE guiding principles,
3) core functions, 4) mechanisms, 5) responsibilities, and 6) implementation. The
objective, guiding principles, and core functions of safety management identified within
this document shall be used consistently in integrating safety throughout all WSI-SRS
operations. The mechanisms, responsibilities, and implementation components are
established for all work and will vary based on the nature and hazard of work being
performed.

IV. COMPONENTS
A.    Component 1 - Integrated Safety Management Objective
      WSI-SRS must systematically integrate safety into management and work
      practices at all levels so that its mission is accomplished while protecting the
      public, the worker, and the environment. This is accomplished through the
      effective integration of safety management into all facets of work planning and
      execution. The overall management of safety functions and activities must be an
      integral part of mission accomplishment.




                                            3
B.   Component 2 - Guiding Principles for Integrated Safety Management
     The guiding principles are the fundamental policies that guide WSI-SRS actions,
     from development of safety written directives to performance of work.
     1. Line Management Responsibility for Safety. Line management is directly
        responsible for the protection of the public, the workers, and the environment,
        and enforces the safety policies and procedures.
        As a complement to line management, the WSI-SRS Office of the Deputy
        General Manager (ODGM) provides safety policy, enforcement, and oversight
        of the ISMS. In addition, in late 2002, the Occupational Safety and Health
        Department (OSHD) physically relocated four of its staff members to
        operational areas. Viewed as a continuous improvement effort, the relocation
        facilitated Protective Force employees’ daily interaction with OSHD personnel.
        In early 2005, OSHD relocated another staff member to the SATA Range; and,
        from that location, he served as OSHD’s lead for occupational safety and
        health oversight of and support to the Training Division. In 2007, OSHD
        added Safety Lieutenants to its staff to strengthen the department’s operational
        background, thereby enhancing oversight of the ISMS. Also in 2007, OSHD
        personnel increased their presence during live fire training at the Training
        Division’s two firing ranges [the Small Arms Training Academy (SATA) and
        the Advanced Tactical Training Academy (ATTA)], and one Safety Lieutenant
        was assigned to the ATTA range.
     2. Clear Roles and Responsibilities. Clear and unambiguous lines of authority
        and responsibility for ensuring safety are established and maintained at all
        organizational levels within WSI-SRS. Lines of authority and responsibility
        are described in various WSI-SRS documents, including the Functions and
        Responsibilities Directive (procedure 1-01), other WSI-SRS procedures, and
        job notifications.
     3. Competence Commensurate with Responsibilities. Personnel possess the
        experience, knowledge, skills, and abilities that are necessary to discharge their
        responsibilities.
        The Training Division ensures that WSI-SRS employees obtain and maintain
        required competencies. Newly hired WSI-SRS employees receive specialized
        training immediately, as appropriate. For example, the Training Division
        conducts a comprehensive training program with the members of Basic Security
        Police Officer Training classes; and each trainee must successfully complete the
        program before field assignment. Each fiscal year, the Training Division
        publishes a new training plan that it has developed based upon the WSI-SRS
        Annual Training Needs Analysis, as described in procedure 1-6003, Developing
        the Annual Training Plan. Approved by DOE-SR, each plan addresses the needs
        of both Protective Force and non-Protective Force employees.
     4. Balanced Priorities. Resources will be allocated to address safety,
        programmatic, and operational considerations effectively. Protecting the




                                           4
         public, the workers, and the environment shall be a priority whenever activities
         are planned and performed.
     5. Identification of Safety Standards and Requirements. Before work is
        performed, the associated hazards will be evaluated and an agreed-upon set of
        safety standards and requirements will be established. These standards and
        requirements, when properly implemented, will provide adequate assurance
        that the public, the workers, and the environment are protected from adverse
        consequences.
     6. Hazard Control Tailored to Work Being Performed. Administrative and
        engineering controls, designed to manage the hazards, will be tailored to the
        work to be performed and the hazards that will be encountered.
     7. Operations Authorization. The conditions and requirements to be satisfied for
        operations to be initiated and conducted will be clearly established and agreed
        upon, in advance, by all affected personnel (including, but not limited to, the
        personnel who will assign the work, representative personnel who will perform
        the work, and personnel from the Office of the Deputy General Manager).
C.   Component 3 - Core Functions for Integrated Safety Management
     Five core safety management functions provide the necessary structure for any
     work activity that could potentially affect the public, the workers, and the
     environment. The functions are applied as a continuous cycle with the degree of
     rigor appropriate to address the type of work activity and the hazards involved.
     1. Define the Scope of Work. Missions are translated into work, expectations are
        set, tasks are identified and prioritized, and resources are allocated.
     2. Analyze the Hazards. Hazards associated with the work are identified,
        analyzed, and categorized.
     3. Develop and Implement Hazard Controls. Applicable procedures are identified
        and agreed upon, controls to prevent/mitigate hazards are identified, the safety
        envelope is established, and controls are implemented.
     4. Perform Work within Controls.          Readiness is confirmed, and work is
        performed safely.
     5. Provide Feedback and Continuous Improvement. Feedback information on the
        adequacy of controls is gathered, opportunities for improving the definition and
        planning of work are identified and implemented, line and independent
        oversight is conducted, and, if necessary, procedural enforcement actions
        occur.
D.   Component 4 - Mechanisms of Integrated Safety Management
     Safety mechanisms define how the core safety management functions are
     performed. The mechanisms may vary, based on the hazards and the work being
     performed, and may include:
        WSI-SRS expectations expressed through written directives and policies.



                                           5
        Written directives on the identification and analysis of hazards and the
         performance of safety analyses.
        Written directives that establish processes to be used in setting safety policies.
     WSI-SRS policies, procedures, and documents (e.g., Risk Analysis Reports,
     Training Risk Assessments, test plans for equipment/supplies, and scopes of work
     for non-WSI-SRS personnel who perform work onsite) are established to
     implement safety management principles and fulfill mission commitments.
     As required by WSI-SRS policy and paragraph (a) of DEAR clause 970.5204-2,
     WSI-SRS complies with applicable federal, state, and local regulatory
     requirements, including applicable DOE regulations (commonly referred to as
     ―List A‖). In addition, WSI-SRS complies with the applicable DOE requirements
     contained in DOE directives transmitted to WSI-SRS via the Contract
     Administrator Notice (CAN) process, as required in paragraph (b) of DEAR clause
     970.5204-2 (commonly referred to as ―List B‖).
     WSI-SRS has developed a Standards/Requirements Identification Document
     (S/RID), which contains an appropriately tailored set of ESH requirements. The
     S/RID contains the ESH portions of ―List A‖ and ―List B,‖ as well as applicable
     ESH requirements that are not regulatory requirements or DOE directives. Section
     J, Attachment E of the WSI-SRS contract requires WSI-SRS to adhere to the
     requirements identified in the S/RID.
     In accordance with paragraph (c) of DEAR clause 970.5204-2 and with DOE O
     251.1B, Departmental Directives Program, changes to the S/RID require the
     DOE-SR Manager’s approval. However, omission of any applicable law or
     regulation from the S/RID for any reason does not affect the obligation of
     WSI-SRS to comply, in accordance with the requirements of paragraph (a) of
     DEAR clause 970.5204-2.

     WSI-SRS continues to use its existing process of Standards/Requirements
     Program Phase I and Phase II assessments to ensure that appropriate implementing
     documents exist and are being properly implemented. For a more detailed
     explanation of the link between the contractor responsibilities contained in the
     DOE-SR Directives Compliance System, the WSI-SRS Standards/Requirements
     Program utilizing the CAN process, and creation/revision of WSI-SRS
     implementing procedures, refer to page 13.
E.   Component 5 - Responsibilities for Integrated Safety Management
     Responsibilities must be clearly defined in documents appropriate to the activity.
     WSI-SRS responsibilities are defined in WSI-SRS written directives. For each
     management mechanism employed to satisfy a safety management principle or
     function, the associated approval authority must be established. The review and
     approval levels may vary commensurate with the type of work and the hazards
     involved.




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F.    Component 6 - Implementation of Integrated Safety Management
      Implementation involves specific instances of work definition and planning,
      hazard identification and analysis, definition and implementation of hazard
      controls, performance of work, development and implementation of operating
      procedures, and monitoring and assessment of performance for improvement.

V. DISCUSSION
Global Mechanisms
Mechanisms, the means by which safety management functions are implemented and
performed, are closely linked to both the Core Functions and the Guiding Principles.
Tables 2 and 3 illustrate the linkage between the principal mechanisms described below
and the Core Functions and the Guiding Principles, respectively.
Specific WSI-SRS policies and procedures define the principal mechanisms for Safety
Management System implementation throughout the company. As stated in the
Functions and Responsibilities Directive (procedure 1-01), all WSI-SRS employees at all
levels within the company are ―fully responsible and accountable for the WSI-SRS
occupational safety and health program. WSI-SRS considers the safety and health of its
employees to be a fundamental value of the organization, and employee safety and health
takes precedence over routine mission responsibilities.‖ In addition, procedure 1-01
details the safety responsibilities of specific organizations within the company. For
example, procedure 1-01 states that the Office of the Deputy General Manager is
―responsible for instituting and maintaining cost-effective assessment, quality, and
environment, safety and health programs that provide a workplace that is free from or
protected against occupational safety and health hazards, and that protects the quality of the
environment and the health of the public.‖
However, the safety and health responsibilities of all employees are more fully presented
in the General Safety Procedure (procedure 1-3100). This comprehensive procedure
establishes a number of key Safety Management System concepts, including the
following:
          Any at-risk behavior or condition observed on-the-job requires corrective
           measures, and the first individual to observe such behaviors or conditions
           must initiate the appropriate corrective measures (if trained/qualified and
           authorized to do so) or contact a supervisor who can initiate those measures.
          Employees have the right to lodge formal complaints about deficient safety
           and health practices, conditions, or procedures.
          All employees are responsible and accountable for safety, and they ―own‖ the
           company’s safety and health program.
          All employees are expected to abide by all safety and health rules, regulations,
           policies, procedures, signs, signals, and boundaries/barriers established by
           WSI-SRS or other contractors, including personal protective equipment and
           radiological protection requirements.



                                              7
          Employees are empowered to observe the activities of all coworkers and site
           employees to ensure that they are accomplishing all tasks and functions in a safe
           manner; challenge, caution, and correct any person observed not abiding by
           safety rules and regulations; report all unsafe acts to supervision;
           IMMEDIATELY STOP WORK or activities of any person(s) engaging in or
           about to engage in at-risk behavior (observable actions that increase the
           probability of an accident occurring) that places the health or safety of people or
           the environment in imminent danger; and question, without fear of reprisal, any
           Directives or Orders that require the completion of tasks in a manner that
           violates published ESH-related procedures.
          Managers and supervisors must identify the hazards and controls associated
           with new or significantly modified performance-based tasks and activities,
           with direct input from affected employees, before WSI-SRS employees
           perform them. In addition, managers and supervisors are empowered, without
           fear of reprisal, to amend, modify, or change directives, orders, procedures or
           practices; and postpone, reschedule, or cancel any activity, function, or task that
           places the health or safety of employees or the environment at an unacceptable
           risk during the accomplishment of routine mission responsibilities.

Procedure 1-3100 also addresses subcontractor safety responsibilities, employee safety
concerns/complaints, correction of unsafe conditions, Imminent Danger situations, STOP
WORK authority, the role of the Executive Safety Committee in granting exemptions to
safety requirements, and general safety precautions.
In addition to the STOP WORK authority of WSI-SRS employees, WSI-SRS recognizes
that, in accordance with the requirements of paragraph (g) of DEAR clause 970.5223-1,
the DOE-SR Contracting Officer can issue a STOP WORK order at any time if WSI-SRS
acts or fails to act in a way that causes substantial harm or imminent danger to the
environment or the health and safety of WSI-SRS employees, subcontractor employees, or
the public.
On June 1, 2005, WSI-SRS launched the Wackenhut Employee Behavior-Based Safety
(WEBBS) process, a voluntary process that WSI-SRS encourages all employees to
assimilate. For WEBBS administration, WSI-SRS is divided into 10 individual Work
Elements; and each Work Element has its own Work Element Coordinator, who serves as
the point of contact for the employees working in that Work Element. The Senior Safety
Technician leads the Work Element Coordinators to encourage employee participation,
provide feedback and positive reinforcement, produce observation cards, and disseminate
WEBBS results.
Two WEBBS behaviors are featured each month. The first behavior is work
element-specific and is selected by the Work Element Coordinator, while the second
behavior is shared by all Work Elements simultaneously and is selected by the Employee
Safety and Health Committee. Both behaviors are printed on single cards, and supplies
of the cards are located at the WEBBS deposit boxes, which have been strategically
placed in the Work Elements.




                                             8
Each employee observes his fellow employees and documents the observation on one of
the cards. Employees drop completed cards in the WEBBS deposit boxes, and the Work
Element Coordinators gather and compile the information each month.
At least every two months, new behaviors are selected for observation. The Work
Element Coordinators keep employees informed about the Work Element’s success
during meetings or musters. In addition, the Work Element Coordinators meet with the
Senior Safety Technician regularly to discuss the progress of the WEBBS process and to
analyze the data that has been submitted.
WSI-SRS has established several mechanisms to help ensure that all employees
continually possess a level of competence commensurate with their job duties, functions
and associated responsibilities. WSI-SRS recruits and hires new personnel who satisfy
the pre-established requirements of the vacant positions they have been hired to fill, as
described in procedure 1-2510, WSI-SRS Internal and External Recruitment Program.
Once hired, all WSI-SRS non-Protective Force employees’ performance is evaluated at
least annually, as described in procedure 1-2531, WSI-SRS Employee Performance
Evaluation System. Annually, the Training Division ensures that the training needs of all
WSI-SRS employees are identified and satisfied by preparing for, conducting throughout
the year, and documenting the training that is provided in accordance with the
DOE-SR-approved Annual Training Plan, developed by the Training Division in
accordance with its procedure 1-6003, Developing the Annual Training Plan. Several
other Training Division procedures also describe mechanisms that contribute to ensuring
the continual demonstration of competence:
             Developing Written and Performance Tests for Training (procedure 1-6000)
             Conducting and Documenting Training Analyses (procedure 1-6001)
             Developing and Conducting On-The-Job Training (OJT) (procedure 1-6002)
             Developing & Processing Training Materials (procedure 1-6004)
             Evaluating Training (procedure 1-6005)
             Administration of Training for Safeguards and Security Personnel
              (procedure 1-6008)
             Fitness Observation (procedure 1-6511)




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                   TABLE 2. LINK BETWEEN THE GLOBAL SAFETY MANAGEMENT SYSTEM MECHANISMS
                        AND THE FIVE CORE FUNCTIONS OF INTEGRATED SAFETY MANAGEMENT
  Define the                                                  Develop and Implement             Perform Work             Provide Feedback and
                            Analyze the Hazards
Scope of Work                                                    Hazard Controls                within Controls         Continuous Improvement
WSI-SRS Written      Training Risk Assessments (TRAs) for    WSI-SRS Written Directive        STOP WORK authority     WSI-SRS Employee Performance
Directive System     all performance-based training lesson   System (1-02) and WSI-SRS        of all employees per    Evaluation System (1-2531)
(1-02) and           plans                                   policies and procedures          General Safety
WSI-SRS policies                                                                              Procedure (1-3100)      Improvement/Corrective Action
and procedures       Safety Risk Evaluation (1-3113)         Standards/Requirements                                   Management Program (1-3700)
                                                             Program (Phase 1                 Standards/
Training lesson      Integrated and Executive Safety         Assessments)                     Requirements Program    Deficiency Risk Assessment
plans and risk       Committees (1-3107)                     (1-3300)                         (Phase 2 Assessments)   (1-3701)
assessments                                                                                   (1-3301)
                     Risk Analysis Reports                   Training lesson plans and risk                           Causal Analysis (1-3702)
Integrated and                                               assessments, test plans for      Performance Testing
Executive Safety     Temperature Extremes (1-3122)           equipment/supplies, and          and Assessment          Deficiency Analysis Group (DAG)
Committees                                                   scopes of work for               Department Procedure    (1-3706)
(1-3107)             Industrial Hygiene Program (1-3152)     non-WSI-SRS personnel who        (1-3509)
                                                             perform work onsite                                      Corrective Action (1-3703)
                                                                                              PTAD No-Notice
                                                             Pollution Prevention and         Performance Test        Employee Safety and Health
                                                             Spill Response Measures          Procedure (1-3508)      Recognition Programs (1-3102)
                                                             (1-3214)
                                                                                              Completion of the
                                                                                                                      WSI-SRS Operating Experience
                                                                                              approved Annual
                                                             Hazardous Waste                                          Program (1-3708)
                                                                                              Training Plan
                                                             Management (1-3201)
                                                                                                                      Occurrence Reporting (1-3710)
                                                             Standards/Requirements
                                                             Program Functional Areas 13                              ELITE – Employees Leading and
                                                                                                                      Improving Toward Excellence
                                                             Standards/Requirements                                   Suggestion Program (1-3302)
                                                             Program Functional Areas 20
                                                                                                                      Employee Concerns Program
                                                                                                                      (1-2560)

                                                                                                                      Incident Reporting and
                                                                                                                      Investigation (1-3144)


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              TABLE 3. LINK BETWEEN THE GLOBAL SAFETY MANAGEMENT SYSTEM MECHANISMS
                 AND THE SEVEN GUIDING PRINCIPLES OF INTEGRATED SAFETY MANAGEMENT
                                                                  Identification Hazard Control
Line Management     Clear Roles        Competence
                                                       Balanced      of Safety   Tailored to the                            Operations
  Responsibility        and         Commensurate with  Priorities Standards and   Work Being                               Authorization
    for Safety     Responsibilities   Responsibilities
                                                                  Requirements     Performed
Functions and         Functions and        WSI-SRS ESH Training         Annual    WSI-SRS Written    WSI-SRS Written    Integrated and
Responsibilities      Responsibilities     Analysis                     budget    Directive System   Directive System   Executive Safety
Directive (1-01)      Directive (1-01)                                  process   (1-02) and         (1-02) and         Committees (1-3107)
                                           WSI-SRS ESH Training                   WSI-SRS policies   WSI-SRS policies
Environmental         General Safety       Matrix                                 and procedures     and procedures     Safety Risk
Management System     Procedure                                                                                         Evaluation (1-3113)
Implementation Plan   (1-3100)             WSI-SRS Environmental                  Standards/         Standards/
(1-05)                                     Protection Department                  Requirements       Requirements       General Safety
                      WSI-SRS              Training Matrix                        Program (Phase 1   Program (Phase 2   Procedure (1-3100)
WSI-SRS Conduct of    Employee                                                    Assessments)       Assessments)
Operations Manual     Performance          Instructional System                   (1-3300)           (1-3301)
(1-04)                Evaluation System    Development
                      (1-2531)             Model used for training
General Safety                             development
Procedure (1-3100)    Administration of
                      Discipline           Developing and Conducting
Management            (1-2550)             On-The-Job Training (OJT)
Walkdown                                   (1-6002)
(1-3304)              Operational Safety
                      Officer Program      Administration of Employee
                      (2-121, 3-5100,      Development
                      3-5319, and          (1-6035)
                      3-5910)
                                           Tuition Reimbursement
                                           Program
                                           (1-6030)




                                                                        11
The Occupational Safety and Health Department updates the WSI-SRS Occupational
Safety and Health Training Matrix periodically. This document identifies required
training subjects by position and by name, and identifies the frequency of the required
training. The Training Division uses this document to ensure that all required safety
training is captured, scheduled, and documented in the annual Training Needs Analysis
and Annual Training Plan development process. Additionally, the Training Division
tracks the identified training to ensure that all designated employees attend.
WSI-SRS has developed a Job Analysis or a Task Analysis for all Protective Force
positions in accordance with Conducting and Documenting Training Analyses (procedure
1-6001). The Job Analysis produces a ―Task List‖ that serves as a basis from which all
training is developed. The Job Analysis, which is updated annually, identifies the
knowledge and skills required to perform the tasks associated with the job. In addition,
the Job Analysis indicates how the separate tasks should be trained and evaluated. If
performance is involved in the training evaluation, a risk assessment is required.
WSI-SRS offers its employees the opportunity to enhance their professional skills in
many ways. The Multi-Media Learning Lab consists of various computer-based training
topics, including computer software programs such as Word, PowerPoint, and Access.
The lab also includes professional and personal development topics provided by the
American Management Association (e.g., Mega Memory, Reading Power, and
Supervising in Today’s Workplace). Upon completion, a training roster is signed and
entered in the individual’s training files.
Employees are also eligible to attend off-site and on-site training courses in accordance
with Administration of Employee Development (procedure 1-6035). Employees can take
a variety of professional development courses, addressing topics such as writing skills,
reading skills, computer skills, and occupational safety and health. Typically, the
employee and his or her supervisor determine the need for such training during the
employee’s performance evaluation process.
WSI-SRS also offers a tuition reimbursement program to all full-time employees as
explained in Tuition Reimbursement Program (procedure 1-6030). Each employee must
submit a Tuition Reimbursement Application requesting approval for the degree
program. Once approved, the employee begins the program and is reimbursed for each
course based on demonstration of successful completion.
Although poor safety performance is never expected, the Administration of Discipline
procedure (procedure 1-2550) does address the possible consequences. The procedure
states that all employees are responsible for reading, understanding, and following all
applicable work rules, WSI-SRS policies and procedures, and DOE Orders and
regulations, while supervisors are responsible and accountable for enforcing them in a
consistent and fair manner. Form 160-A, Company Safety Rules, which the procedure
references, identifies the possible consequences of specific violations.
The WSI-SRS Written Directive System (procedure 1-02) establishes the framework to
provide for the development and implementation of all company policies and procedures,
including those that describe and assign specific responsibilities for environment, safety, and
health matters.      WSI-SRS procedures apply the requirements contained in the
DOE/WSI-SRS contract, DOE Orders, and applicable federal and state laws/statutes to the


                                              12
activities performed by WSI-SRS. WSI-SRS directives require senior management
approval. However, in order to become authorized company policy based on a single
signature (other than the General Manager), newly drafted or revised procedures must first
be coordinated with the organizations primarily affected and tasked with specific
responsibilities and/or with compliance. Nonconcurrence must be resolved before approval
and distribution. It is imperative that the impact of the new/revised procedure on safety and
operations be understood completely before approval. The proponent of each new/revised
procedure must include the Deputy General Manager in the review process when a potential
safety concern is anticipated. All of the procedures assigned to the Occupational Safety and
Health and Environmental Protection Departments fall within the numbering range of 3100
to 3299.
WSI-SRS identifies the need to create or revise procedures based upon its continuing
execution of the contractor responsibilities contained in the DOE-SR Directives Compliance
System.     The WSI-SRS Standards/Requirements Program (Phase 1 Assessments)
(procedure 1-3300) describes the process of reviewing and evaluating current implementing
documents to determine whether they specify the actions and conditions necessary for
compliance with requirements contained in new/revised DOE directives. By properly
executing Phase 1 assessments, WSI-SRS ensures that requirements applicable to WSI-SRS
are identified and that employees are provided sufficient procedural guidance to enable
compliance. Procedure 1-3300 explains that Phase 1 assessments are performed on all
directives transmitted via a Contract Administrator Notice (CAN). The procedure also
explains how draft directives are processed for review and comment. Utilizing the same
process, WSI-SRS also creates or revises procedures based on discovery of new/revised
government regulations (e.g., Occupational Safety and Health Administration or
Environmental Protection Agency) or national consensus standards (e.g., National Fire
Protection Association).
Two companion procedures — Standards/Requirements Program (Phase 2 Assessments)
(procedure 1-3301) and WSI-SRS Assessment Program (procedure 1-3400) — describe
how self-assessments and independent assessments are used to support the requirement
for Phase 2 assessments. Both types of assessments determine whether actions and
conditions conform to requirements contained in the applicable implementing procedures.
Although Phase 2 assessments give priority to areas of high risk or known weaknesses, the
schedule for the assessments ensures that all functional areas are addressed at reasonable
intervals. The methods used to obtain conclusions are observations, interviews, walkdowns,
inspections, and exercises to determine the level of adherence to requirements and "real
time" implementation of procedures. Assessments must occur at all levels within
WSI-SRS. Self-assessment of functional areas by directors, managers, and supervisors,
combined with performance-based independent assessments, provide senior management
with the information necessary to conduct management assessments of the effectiveness
of all integrated systems, including the Safety Management System.
Requirements of the WSI-SRS Assessment Program include the following:
      Internal self-assessment and independent assessment programs must be
       proceduralized [e.g., Quality Assurance Audit and Surveillance Program
       (procedure 1-3307)].



                                             13
      WSI-SRS personnel who conduct self-assessments and independent assessments
       must forward the results to the Program Review and Analysis Department. The
       Quality and Performance Analysis Department captures in a database and tracks the
       results of Phase 1 and Phase 2 assessments. Deficiencies resulting from Phase 2
       assessments are tracked/processed in accordance with the WSI-SRS
       Improvement/Corrective Action Management Program.

The WSI-SRS Improvement/Corrective Action Management Program (procedure
1-3700) describes the process by which identified opportunities for improvement and
deficiencies (including environment, safety, and health deficiencies) formally assessed
against WSI-SRS by any internal or external assessment, inspection, or audit agency are
managed to ensure adequate, timely, and coordinated correction throughout the company.
This process includes deficiency data collection, risk assessment, causal analysis,
corrective action, cost/benefit analysis, verification, validation, deficiency corrective
action tracking, reporting and trending. This procedure applies to all WSI-SRS
organizations required to respond to any internal or external audit, appraisal, assessment,
surveillance, or inspection that results in the formal transmittal of a deficiency statement,
and to internal assessment and validation organizations. WSI-SRS requires the
following: (1) identified deficiencies in operations, programs, and processes must be
documented, analyzed, and resolved in a timely and cost-effective manner; (2) resulting
corrective actions must be verified to ensure both implementation and deficiency
correction; (3) the extent of causal analysis and the application of corrective actions must
be commensurate with the importance and significance of the identified problems; and
(4) formal responses and follow-up reports must be timely and complete. The procedure
also assigns specific responsibilities; for example, managers within the Office of the
Deputy General Manager must evaluate the adequacy of proposed corrective actions for
deficiencies identified internally and externally, as well as validate the effectiveness of
implemented corrective actions for deficiencies identified internally.
Two companion procedures — Deficiency Risk Assessment (procedure 1-3701) and
Causal Analysis (procedure 1-3702) — further describe the deficiency management
process. Deficiency Risk Assessment establishes the method used to assess the risk posed
by identified deficiencies (including environment, safety, and health deficiencies) in
WSI-SRS operations, systems, or programs. Deficiency risk assessment objectively
quantifies the risk posed by the existence of a known deficiency within a program or system.
Causal Analysis establishes the structured method used to identify the causes of deficiencies
[identified as Immediate (or Direct) Causes, Contributory Causes, and the Root Cause] in
WSI-SRS operations, systems, or programs. Both procedures apply to all WSI-SRS
organizations required to respond to any internal or external audit, appraisal, assessment,
surveillance, or inspection that results in the formal transmittal of a deficiency statement.
Prompt identification of unsafe conditions and work practices can often result in relatively
simple corrections before more serious deficiencies develop. WSI-SRS management
personnel (including Senior Management, Directors, and Managers, but excluding
Protective Force Operations and Special Operations Directors and Managers) conduct
management walkdowns in accordance with Management Walkdown (procedure 1-3304)
and a published, weekly schedule.



                                             14
Preparing Training Risk Assessments (TRAs) is another way WSI-SRS personnel identify
job hazards, describe the potential injuries/illnesses associated with each job step, and
outline measures that can be implemented to eliminate or mitigate the hazards before an
injury or illness occurs. WSI-SRS has developed TRAs for all performance-based training
lesson plans. The TRAs break down each work activity, identifying potential hazards and
corrective measures. TRAs always identify the following information: (1) the procedures
and activities to be performed by training participants; (2) the risk and hazard associated
with each procedure or activity, including tasks and subtasks; and (3) the recommended
controls and limits for each risk or hazard identified. WSI-SRS has found the TRA to be
very effective in identifying hazards associated with performing a specific job.
The requirements for TRAs are found in Safety Risk Evaluation (procedure 1-3113). TRAs
are conducted to ensure that potential hazards (and the risks associated with them) are
systematically identified and assessed for mitigation purposes. A risk assessment ensures
the desired training requirements are completed in a safe manner by requiring that
appropriate control measures be implemented before the start of training. TRAs must be
prepared on performance-based training or evaluation methods involving, but not limited
to, firearms, nonroutine tactical operations, practical training, unique training (e.g.,
defensive driving), and limited scope performance tests (LSPTs). The subject matter
experts responsible for preparing the lesson plans must prepare the TRAs, with assistance
from the Occupational Safety and Health Department. TRAs must be prepared during the
development of the training course and lesson plan and before the start of the training.
Safety Risk Evaluation (procedure 1-3113) also establishes a method for assessing the
risks associated with workplace hazards for use in worker protection applications.
Assisted by the Occupational Safety and Health Department, the Infrastructure Projects
Department ensures that a safety review is conducted prior to the design, planning, and
construction phase of new or modified projects or facilities occupied and/or operated by
WSI-SRS.
Risk evaluation is the process by which the hazards and controls associated with specific,
planned tasks/activities are identified to determine and document the feasibility of
successful performance within an acceptable level of risk. A written, risk evaluation
document addresses, in specific terms, the hazards and controls for all tasks/activities to be
performed, including the locations where the tasks/activities may be performed and the
specific personnel requirements, if any. In addition, the risk evaluation document identifies
all operational and personal protective equipment that may be used in the performance of
the tasks/activities (e.g., ESS Equipment, Dye Marking Cartridges, and respiratory
protection). The risk evaluation’s description of controls includes the steps that will be
taken to identify, eliminate (if possible), mark, and/or mitigate all of the hazards associated
with the various tasks/activities to be performed.
Safety Risk Evaluation (procedure 1-3113) explains the WSI-SRS policy regarding risk.
The overall risk category for training, activities, and non-training special events must be
identified (i.e., ―low,‖ ―medium,‖ or ―high‖) and documented by the proponent WSI-SRS
work elements, with assistance from OSHD. If the evaluation of risk results in a ―high‖ risk
category, the proponent will not proceed until he or she has completed the following steps in
order: (1) contact the OSHD Manager; (2) with the OSHD Manager’s concurrence, contact
the DOE-SR Senior Facility Representative; (3) with the DOE-SR Senior Facility


                                              15
Representative’s concurrence, obtain the approval of the Integrated and Executive Safety
Committees; and (4) contact the OSHD Manager for assistance in preparing a letter to the
DOE-SR Director, Office of Safeguards, Security and Emergency Services, requesting
approval of the ―high‖ risk category training, activity, or non-training special event.
The Office of the Deputy General Manager assesses all approved training, activities, or
non-training special events with a ―high‖ risk category annually to determine if
appropriate engineering and administrative controls are in place. The scope of the
assessments must be sufficient to identify deficiencies (e.g., the identified controls are
inadequate, or the identified controls are implemented inadequately or inconsistently). If
a safety concern is identified within the context of a risk activity, it is given a finding
number; and findings that are safety-related receive the highest priority and require
immediate corrective action.
Both the WSI-SRS Integrated Safety Committee (ISC), which principally consists of
multidisciplinary Department Manager-level personnel and subject matter experts, and the
WSI-SRS Executive Safety Committee (ESC), which is chaired by the Deputy General
Manager and includes all of the Directors, are involved in hazard analysis/risk analysis.
The ISC evaluates lesson plans and makes recommendations to the ESC regarding new
performance-based training. In addition, the ISC evaluates recommendations for first-time
purchases of new Protective Force duty equipment, special use vehicles, post equipment,
and office furniture for special applications before purchase, distribution, or deployment.
The ESC is also involved in these same activities, usually after the ISC has finalized its
review and has submitted a recommendation to the ESC for approval. Procedure 1-3107,
Integrated and Executive Safety Committees, governs the activities of these committees,
which meet monthly.
On February 21, 2005, the WSI-SRS Safety Performance Analysis Committee (SPAC)
was formed. The SPAC has eight members, including the WSI-SRS Deputy General
Manager, who serves as Chairperson. The SPAC analyzes historical and/or current safety
performance of individual WSI-SRS employees, work elements, and/or WSI-SRS as a
whole, using established criteria to select topics for discussion and analysis. The SPAC
also identifies performance that conforms or does not conform to established goals and
objectives, policies and procedures, site requirements, and/or applicable regulatory
requirements. In addition, the SPAC identifies actions that one or more of the SPAC
members can take to address the nonconforming performance and recommends actions
other WSI-SRS employees or work elements can take to address nonconforming
performance. The Wackenhut Services Incorporated–Savannah River Site Safety
Performance Analysis Committee (SPAC) Charter, which was last revised by the Deputy
General Manager in February 2008, describes the functioning of the SPAC.
WSI-SRS employees are encouraged to participate actively in various Safety Management
System mechanisms. For example, WSI-SRS employees are encouraged to attend the
monthly Integrated Safety Meetings. During the meetings, recent safety performance is
reviewed, Spot Safety Award winners are recognized, and topical safety information is
presented (often by guest speakers). In addition, representative employees from all
divisions participate in the Employee Safety and Health Committee (ESHC), which meets
monthly to review safety issues/concerns of current interest to coworkers. The ESHC also
selects monthly Spot Safety Award winners.


                                            16
WSI-SRS employees can utilize two additional mechanisms – the ELITE Employees
Leading and Improving Toward Excellence Suggestion Program and the Employee
Concerns Program (ECP) – to identify possible deficiencies. As described in the ELITE
Employees Leading and Improving Toward Excellence Suggestion Program (procedure
1-3302), ELITE is a Total Quality incentive program that was established to encourage
employees to submit their ideas and suggestions about improvements to operations,
techniques, or standard procedures that are not part of their normal job duties. If
implemented, the suggested improvements should result in one or more of the following:
(1) time or cost savings, (2) improved morale or working conditions, (3) improved work
processes or procedures, or (4) improved safety or quality.
As described in Employee Concerns Program (procedure 1-2560), the WSI-SRS ECP is
an avenue for employees to come forward, without fear of reprisal, with information they
believe is evidence of unsafe, unlawful, fraudulent, or wasteful practices. The preferred
method for voicing a concern is through supervision. However, if for any reason
employees believe this is not the right avenue for them, they may use the ECP.
The Occupational Safety and Health Department and the Environmental Protection
Department have established additional procedures designed to address specific program
elements within the WSI-SRS Integrated Safety Management System:
      Employee Safety and Health Recognition Programs (procedure 1-3102)
       The objective of the programs is to enhance employee safety and health awareness
       through employee participation in proactive safety and health activities.
      Hazard Communication Program (procedure 1-3103)
       Establishes policies, assigns responsibilities, and defines procedures for the written
       Hazard Communication Program, which satisfies the requirements of the
       Occupational Safety and Health Administration’s Hazard Communication standard
       (29 CFR 1910.1200). The procedure addresses purchase and receipt, Material
       Safety Data Sheets, chemical inventories, container labeling, and employee
       training.
      Hearing Conservation Program (procedure 1-3104)
       Establishes policies, assigns responsibilities, and defines procedures for the written
       Hearing Conservation Program, which satisfies the requirements of the Occupational
       Safety and Health Administration’s Occupational Noise Exposure standard (29 CFR
       1910.95). The procedure addresses audiometry, monitoring, hearing protection,
       warning signs, and training.
      Radiation Protection Program (procedure 1-3106)
       Establishes policies, assigns responsibilities, and defines procedures for the
       written Radiation Safety Program. The procedure addresses the company’s
       ALARA policy, compliance with the requirements contained in the Washington
       Savannah River Company’s 5Q Radiological Control Manual, protection
       practices for internal and external radiation, dosimetry, bioassays, dose limits and
       administrative control levels, training, and reporting radiological deficiencies.



                                            17
   WSI-SRS Readiness Team (procedure 1-3108)
    Addresses the classification of investigations, notification requirements, support for
    DOE Type A and B investigations, and the WSI-SRS Readiness Team.
   Occupational Respiratory Program (procedure 1-3109)
    The procedure addresses fit-testing; selection, issuance, use, inspection,
    maintenance, and exchange of equipment; self-contained breathing apparatus;
    medical evaluation; and training.
   Laser Safety Program (procedure 1-3111)
    Specifies the responsibilities of the Laser Safety Officer and Laser System
    Supervisors. The procedure addresses general safety rules, warning signs, training,
    and medical surveillance.
   Fire Prevention Program (procedure 1-3114)
    Assigns responsibilities for the inspection and maintenance of fire protection
    equipment, identifies fire prevention measures, and describes visual checks of fire
    extinguishers.
   Lead Control Program (procedure 1-3116)
    Establishes policies, assigns responsibilities, and defines procedures for the written
    Lead Control Program, which satisfies the requirements of the Occupational Safety
    and Health Administration’s Lead standard (29 CFR 1910.1025). The procedure
    addresses exposure assessment, monitoring, control measures, medical
    surveillance/biological monitoring, and training.
   WSI-SRS Munitions Safety Program (procedure 1-3118)
    Addresses the transportation, storage, use, and handling of munitions. Specific
    topics include general safety requirements, receipt and storage of munitions, onsite
    transportation, HazMat training for employees involved in offsite transportation,
    canine explosives detection training, and inventory.
   Emergency Eyewashes/Showers (procedure 1-3119)
    Addresses locations, design/performance criteria, travel distance, identification and
    lighting, inspection, and personal eyewashes.
   Danger, Caution, and Warning Tags (procedure 1-3121)
    Addresses the use of tags, the responsibilities of WSI-SRS building custodians, and
    use of CAT for lockout/tagout training.
   Temperature Extremes (procedure 1-3122)
    Addresses risk factors for and signs/symptoms of heat/cold stress disorders and
    provides guidelines for prevention.




                                         18
   Personal Protective Equipment (procedure 1-3123)
    Addresses hazard assessments for personal protective equipment, head protection,
    eye and face protection, foot protection, hearing protection, gloves, and training.
   Flammable and Combustible Liquids (procedure 1-3125)
    Addresses purchase and use, handling and storage, container labeling, dispensing
    and delivery by Stores, and fire prevention measures.
   Compressed Gas Cylinders/Pressure Safety (procedure 1-3126)
    Addresses general safety requirements, storage, and operating procedures for
    compressed gas cylinders, as well as general pressure safety requirements and air
    compressors.
   Maintenance of Self-Contained Breathing Apparatus (procedure 1-3129)
    Addresses monthly visual inspections conducted by individuals appointed by
    managers/supervisors, semiannual inspections, and repair conducted by the Senior
    Safety Technician.
   Motor Vehicle Safety (procedure 1-3136)
    Establishes the safety requirements for motor vehicle operation. Addresses the
    inspection of vehicles, tagging of unsafe vehicles, driving requirements, and other
    operating requirements.
   Firearms Cleaning (procedure 1-3138)
    Addresses storage of firearms cleaning materials, firearms cleaning, ammunition,
    use of personal protective equipment, and requirements for the cleaning area.
   Powered Industrial Trucks (procedure 1-3139)
    For powered industrial trucks, addresses general requirements, operator training,
    truck operation, traffic regulations, loading, fueling, maintenance, and inspection.
   Incident Reporting and Investigation (procedure 1-3144)
    Addresses supervisory responsibilities, reporting, medical attention for the injured,
    and coordination/conduct of investigations.
   Bloodborne Pathogens Exposure Control Plan (procedure 1-3148)
    Establishes policies, assigns responsibilities, and defines procedures for the written
    Exposure Control Plan, which satisfies the requirements of the Occupational Safety
    and Health Administration’s Bloodborne Pathogens standard (29 CFR 1910.1030).
    The procedure identifies employees who could be exposed during normal duties,
    universal precautions, engineering and work control practices, labels, personal
    protective equipment, housekeeping, medical evaluation, spills and decontamination,
    annual plan review, training, and CPR/First Aid.




                                         19
   Industrial Hygiene Program (procedure 1-3152)
    Describes the Occupational Safety and Health Department’s responsibilities for the
    identification, evaluation, and control of health hazards, including conduct of initial
    baseline and annual workplace surveys, as well as ad hoc monitoring.
   Automated External Defibrillator Program (procedure 1-3153)
    Describes WSI-SRS’s automated external defibrillator (AED) program, including
    the Case Management Officer’s responsibilities for program administration. The
    procedure also identifies the AED locations and provides the requirements for AED
    maintenance, use, and testing.
   Safety Analysis Review of Aerial Firing (procedure 1-3196)
    Describes the use of a helicopter as a firing platform in other than a training
    environment, the operational hazards associated with its use, and the engineering
    and administrative controls in place to eliminate or reduce these hazards.
   Risk Analysis Report of the Advanced Tactical Training Academy (ATTA)
    (procedure 1-3197)
    Describes the ATTA facility, operational hazards associated with its use, and the
    engineering and administrative controls in place to eliminate or reduce these
    hazards to acceptable levels.
   Risk Analysis Report of the Small Arms Training Academy (SATA) (procedure
    1-3198)
    Describes the SATA facility, operational hazards associated with its use, and the
    engineering and administrative controls in place to eliminate or reduce these
    hazards to acceptable levels.
   Ballistic Risk Assessment of the WSI-SRS Live Fire Shoot Houses (procedure
    1-3199)
    Evaluates the operational safety envelope using a comprehensive ballistics
    analysis to analyze the following: 1) the safety of personnel using the Elevated
    Observation Control Platform during live fire operations, 2) the 360 degree
    circular danger zone, 3) the simultaneous clearing of multiple rooms, 4) the
    ricochet potential of rounds fired resulting from unauthorized firearms discharges,
    and 5) the use of adjacent range facilities during live fire operations. The Ballistic
    Risk Assessment is qualitative in nature and focuses primarily on the
    administrative controls that ensure safe operations (e.g., policies, procedures,
    training requirements, personnel selection, qualification, certification
    requirements, and management oversight).
   Environmental Management System Implementation Plan (procedure 1-05)
    Describes the program to manage environmental aspects of WSI-SRS operations
    and demonstrate a commitment to prevention of pollution, compliance with
    regulatory requirements, conformance with the ISO 14001 standard and DOE Order
    450.1, Environmental Protection Program.



                                          20
   Hazardous Waste Management (procedure 1-3201)
    Establishes policy, assigns responsibilities, and defines procedures to ensure
    compliance with the South Carolina Hazardous Waste Management Regulations
    (SCHWMR).
   Erosion and Sediment Control Plan Procedure (procedure 1-3202)
    Establishes policy, assigns responsibilities, and defines procedures to ensure
    compliance with the National Pollution Discharge Elimination System (NPDES)
    for Storm Water Discharge Associated with Construction Activity, the South
    Carolina Pollution Control Act, and the Clean Water Act.
   Management of Batteries Containing Hazardous Waste (procedure 1-3204)
    Establishes policy, assigns responsibilities, and defines procedures for
    accumulation and disposal of batteries containing hazardous waste constituents
    such as cadmium [nickel cadmium batteries (NiCad)], mercury, lithium, and silver.
   Waste Minimization (procedure 1-3205)
    Along with the Waste Minimization Plan (attached to the procedure), establishes
    policy, assigns responsibilities, and defines procedures for pollution
    prevention/waste minimization. Addresses the evaluation of process modifications,
    material substitutions, and procedural changes for waste minimization potential;
    spill prevention; inventory control; and recycled materials.
   Federal Motor Carrier Safety Regulations for On-Site/Off-Site Transfers of
    Hazardous Materials (procedure 1-3206)
    Establishes minimum qualifications and requirements for WSI-SRS personnel who
    are involved with the operation of government-owned, commercial motor vehicles
    (CMVs) used to transport hazardous materials on the SRS or public access roads.
    This procedure serves as the facility-specific safety document for WSI-SRS
    hazardous material transfers at SRS, including shipments of Special Nuclear
    Materials, explosives, munitions, and ammunition (in quantities greater than those
    required for duty).
   Hazardous Material Transportation (procedure 1-3207)
    Establishes policy, assigns responsibilities, and defines procedures to ensure
    compliance with the U.S. Department of Transportation (DOT) regulations and
    DOE directives governing the shipment of hazardous materials. This procedure
    applies to all WSI-SRS personnel who handle, package, label, ship, and receive
    hazardous materials, hazardous substances, and hazardous wastes.
   NEPA Compliance (procedure 1-3209)
    Establishes policy, assigns responsibilities, and defines procedures to ensure
    compliance with the National Environmental Policy Act (NEPA). This procedure
    applies to all WSI-SRS personnel involved in project development activities where
    the proposed project could potentially have an environmental impact (e.g., any




                                        21
    facility maintenance, repair, or project activity being initiated or requested by
    WSI-SRS).
   Aerosol Can Disposal Procedure (procedure 1-3210)
    Establishes policy, assigns responsibilities, and defines procedures to ensure
    compliance with requirements governing aerosol can disposal. Addresses purchase
    of non-aerosol products, use of the N-Area can crusher, and transfer of cans to the
    N-Area Environmental Facilities - Excess Chemical Building.
   Shop Towel Management (procedure 1-3211)
    Establishes policy, assigns responsibilities, and defines procedures for the proper
    management of shop towels. Addresses use of a laundry contractor, process
    changes, or the use of new chemicals that could change the character of the shop
    towels, and storage.
   ZEP System Management (procedure 1-3212)
    Establishes policy, assigns responsibilities, and defines procedures to ensure that
    the Dyna-clean solvent (ZEP) systems are properly managed to eliminate potential
    releases to the environment. Addresses use of the system, waste generation, system
    maintenance, spill response, and training.
   Pollution Prevention and Spill Response Measures (procedure 1-3214)
    Establishes policy, assigns responsibilities, and defines procedures to ensure
    compliance with Federal Spill Prevention Control and Countermeasures (SPCC)
    Plan requirements. Addresses notifications, documentation and recordkeeping,
    chemical spill drills, training, spills originating from WSI-SRS operations,
    non-WSI-SRS spills, and training.
   Green Shield Usage and Disposal (procedure 1-3216)
    Establishes policy, assigns responsibilities, describes training requirements, and
    defines procedures for the safe use and disposal of the Green Shield disinfectant
    and algaecide that WSI-SRS uses in its evaporative cooler units and water
    reservoirs.
   Management of Used Oil (procedure 1-3217)
    Establishes policy, assigns responsibilities, and defines procedures for managing
    used oil at WSI-SRS. The procedure addresses topics such as container labeling,
    storage area requirements, daily facility inspections, and spill response.
   Cleaning and Sanitizing of Drinking Water Cooler Units (procedure 1-3218)
    Establishes policy, assigns responsibilities, and defines procedures for the
    cleaning and sanitizing of all drinking water cooler units at WSI-SRS. The
    procedure facilitates in-place cleaning of the above units, and eliminates the need
    to transfer the units to an alternate location for cleaning and sanitizing.




                                        22
   Environmental Protection Department Assessment Program (procedure 3-3203)
    Establishes policy, assigns responsibilities, and defines procedures for conducting
    assessments, surveillances, evaluations, and self-assessments.

The Emergency Management Section has established additional procedures designed to
address specific program elements within the WSI-SRS Integrated Safety Management
System.
   Emergency Management Procedure (1-6816)
    Outlines responsibilities, policies, and procedures that address the WSI-SRS
    Emergency Management Program, derived from the WSRC SCD-7, SRS Emergency
    Plan.
   Pager Utilization (1-6818)
    Describes the procedures to be followed by all WSI-SRS personnel who are
    assigned a digital display pager direction for use while serving on the WSI-SRS
    Emergency Response Organization, Readiness Team, or Crisis Negotiations
    Team/Mobile Command Post, including management, staff, and Protective Force
    (PF) personnel.
   B-Area Emergency Procedure (1-6819)
    Provides the plan for the orderly response to emergencies affecting WSI-SRS
    facilities in B-Area.
   SATA and ATTA Accident/Incident Plan (1-6820)
    Addresses the responsibilities of all personnel who utilize the SATA or ATTA
    firearms ranges and the procedures they will follow for quickly handling, treating,
    and evacuating injured personnel. Also, describes the emergency response drills
    carried out at ATTA and SATA at least annually to test preparedness.
   Command Post Operation Procedure (1-6821)
    Identifies the responsibilities of the WSI-SRS personnel who establish and operate
    an incident command post during a protracted emergency, and describes the concept
    of operation for the command post.
   Crisis Negotiation Team (1-6823)
    Establishes policy and procedures for the administration, operation, and training of
    the WSI-SRS Crisis Negotiations Team (CNT).
   Emergency Security Operations Procedure (2-201)
    Provides the procedures that Protective Force members and Operations Security
    Specialists use to satisfy their responsibilities during emergencies, which include
    Demonstrations, Intrusions, Operation/Security Emergencies, Nuclear Incidents,
    Toxic Chemical Emergencies, Natural Disaster Emergencies, Hostage/Crisis
    Situations, or Bomb Threats.




                                        23
The Quality and Performance Analysis Department has also established additional
procedures designed to address specific program elements within the overall Safety
Management System.
   Quality Assurance Plan (procedure 1-03)
    Establishes programmatic guidance for implementation of the WSI-SRS Quality
    Assurance (QA) Program, which incorporates QA Plan requirements into all
    company work processes. Risk is the fundamental consideration in determining
    to what extent the QA Program should be applied to mission and financial
    management. Through planned and periodic administrative and/or performance
    based management assessments, the Quality and Performance Analysis
    Department has the freedom necessary to identify problems, to conduct objective
    evaluations of adequacy and effectiveness, and to recommend solutions.
    The relationship between the QA Plan’s ten criteria and the ISM Core Functions
    and Guiding Principles is shown in the table below.

          CORE                           QUALITY PLAN CRITERIA
        FUNCTIONS                1   2   3  4    5   6   7   8            9    10
     Define the Scope of
     Work
                                                               
     Analyze the Hazards
                                                     
     Develop & Implement
     Controls
                                                          
     Perform Work within
     Controls
                                                                         
     Provide Feedback &
     Continuous Improvement
                                                                       

        GUIDING
       PRINCIPLES
     Line Management
     Responsibility for Safety
                                                     
     Clear Roles &
     Responsibilities
                                                                      
     Competence
     Commensurate with
                                                                  
     Responsibilities
     Balanced Priorities
                                                                             
     Identification of Safety
     Standards &
                                                                      
     Requirements
     Hazard Control Tailored
     to Work Being
                                                                  
     Performed
     Operations Authorization
                                                                   

   WSI-SRS Conduct of Operations Manual (procedure 1-04)
    Provides WSI-SRS’s interpretation of DOE Order 5480.19, Conduct of
    Operations; establishes guidelines; and discusses their applicability to WSI-SRS
    operations. This manual provides a means to assure disciplined operations and


                                         24
    timely identification of deficiencies. The guidelines assist in developing policies
    and procedures with the result being improved quality, efficiency, and enhanced
    safe operations.
   Deficiency Analysis Group (DAG) (procedure 1-3706)
    Deficiency Analysis Group (DAG) meetings provide a structured method for
    ensuring a thorough analysis is conducted on each deficiency assessed to
    WSI-SRS. The thorough analysis involves conducting risk assessments, causal
    analysis, cost-benefit analysis (if applicable), identifying corrective actions, and
    assigning responsibility for those actions to specific personnel.
   WSI-SRS Operating Experience Program (procedure 1-3708)
    The purpose of developing ―lessons learned‖ is to share information. It is
    WSI-SRS policy that lessons learned from our operating experiences and the
    reported experiences of other organizations are documented, analyzed, shared,
    and utilized to improve the safety, efficiency, and effectiveness of work processes
    and operations.
   Occurrence Reporting (procedure 1-3710)
    A system has been established that ensures timely and consistent reporting of
    WSI-SRS operations information in the event of an unusual or abnormal event.
    Corrective actions are determined and implemented as a result of the processing
    of that information. A response will be immediately initiated upon receiving
    information that may generate an Incident Report or Occurrence Report to
    mitigate the occurrence and return the facility to a safe and/or secure condition.
   WSI-SRS Concern Notification (procedure 1-3711)
    Defines the process that ensures that mitigating actions are taken for concerns or
    potential concerns within WSI-SRS areas of responsibility; that each department
    within WSI-SRS is promptly notified of concerns; and that concerns are being
    addressed on a sitewide basis. In many cases, it is likely that a concern identified
    in one area may also exist in other areas. This procedure is generally geared
    toward incidents, situations, or other occurrences which indicate a need for
    mitigating action and which have the potential for site wide applicability.
   Improvement/Corrective Action Management Process Responsibilities (procedure
    3-3700)
    Outlines the process by which identified deficiencies formally assessed to
    WSI-SRS in any internal or external assessment report are managed. A root cause
    analysis is conducted on deficiencies to identify causal factors, summarization
    and categorization of deficiencies, and recommendations as to applicable
    corrective actions. Information from assessment report deficiencies and other
    data sources is compared to historical data, identifying patterns in deficiencies and
    determining the effectiveness of corrective actions. A review of proposals is
    conducted to determine risk factors and impact on organizational operations.




                                         25
Divisional Mechanisms
Training Division
The Training Division includes the Tactical Operations Training, Training Operations,
and Training & Academic Support Departments. Safety is an integral part of operations
in the Training Division and the responsibility of every member of the Training Division,
especially line management. For several years, safety goals and requirements for all
Training Division personnel have been evaluated in the performance evaluation system.
All three Training Division managers are voting members of the Integrated Safety
Committee. The Director of Training is a voting member of the Executive Safety
Committee, and the Senior Physical Fitness Instructor is a member of the Safety
Performance Analysis Committee. The Training Division’s committee participation
ensures that safety is built into training and not the other way around.
The Tactical Operations Training Department’s Range Master is a member of the Firearms
Quality Panel, which provides guidelines and requirements for firearms safety and training
for the DOE complex. The Tactical Operations Training Department Manager is a member
of the DOE Special Response Team Quality Panel, which provides policy and training
recommendations to DOE-HQ to include a review of training safety risk assessments for
the SPO III Basic Qualification Course. The roles and responsibilities for safety within the
Division are found in several places. The first is in the WSI-SRS Functions and
Responsibilities Directive, where general safety responsibilities are outlined for the
Director and managers. However, other very specific safety roles and responsibilities are
found within the Training Division’s standard operating procedures. Several of these
procedures are identified below:
      Fitness for Duty (1-6025)
      Training Records Management System (1-6028)
      SATA and ATTA Range Operations and Safety Procedure (1-6904)
      Specialized Training (1-6504)
      Dye Marking Cartridge Training (1-6503)
      Live Fire Shoot House (1-6911)
      Attending Training at the Department of Energy National Training Center (NTC)
       (1-6032)
      Administration of Employee Development (1-6035)
      Training Division Administration and Operations (3-6001)
The procedures clearly outline what each position’s role is in the area of safety and
training. Several administrative procedures that outline the processes within the Training
Division ensure that each position understands the process for building safety into
training. For example, procedure 1-6004, Developing Training Materials, ensures that if
Subject Matter Experts (SMEs) understand a lesson plan addresses performance, then
they also understand that a risk assessment must be prepared. The SME and one or more
representatives from the Office of the Deputy General Manager work together to ensure


                                            26
that all recognized risks are mitigated; and an OSHD representative must then approve
the risk assessment.
The Training and Academic Support Section oversees this process and ensures lesson
plans with risk assessments receive Occupational Safety and Health Department approval
before being sent to the Director of Training for final approval. Again, this is to ensure
that safety is built into training. This process is one of the ways hazards and risks are
assessed and mitigated. This is also the method by which hazard controls are selected
and tailored to the work to be performed.
All instructors are required to attain initial certifications such as the National Training
Center (NTC) Basic Instructor Training Course. Some are also required to attain and
maintain certifications in NTC specialty subjects such as Firearms, Intermediate Force,
and Security Police Officer III Instructor Course. If the instructor is not certified, he or
she is not allowed to teach that subject. The Training Division’s Training Administrative
Section tracks these certifications.
Other site certification requirements also apply. For example, WSI-SRS procedures
require that instructors who work with Dye Marking Cartridge training first be certified
firearms instructors and then complete a physical certification of the Dye Marking
Cartridge Facility and the rules and regulations that apply. Additionally, satisfaction of
these requirements must be documented in the instructors’ files; and requalification is
required. Site certification checklists must also be completed for Lead Instructors in the
areas of Law Enforcement, Protective Force, SPO III (SRT), and Firearms training
activities.
Annually, Training Division managers budget professional development for instructors
based on their Individual Development Plans. Additional training is required for other
areas of professional development. Some instructors also attend safety training that is
designed to keep them informed about such things as hearing conservation, lead, and
bloodborne pathogens. All Firearms Instructors and Physical Fitness Instructors are
required to hold certifications in First Aid and CPR. There are additional requirements
that are addressed in procedure 1-6009, Instructional Staff Requirements.
Safety is the key consideration in every training mission and operation, and resources are
allocated to ensure that the proper equipment and training are obtained. There is also the
Operational Safety Officer Program, which utilizes operations personnel who are trained
and responsible for ensuring that check sheets are filled out before specific
performance-based training is conducted.
WSI-SRS conducts self-assessments and audits on performance training to ensure that
work is conducted safely. The Training Division’s Senior Instructors are required to
critique the assigned instructors to ensure that training is conducted properly.
The procedures for training require that warm-up exercises, established by the Physical
Fitness Section, be conducted prior to some performance training (e.g., Intermediate
Force). Additionally, a safety briefing must be conducted prior to teaching lesson plans
that include performance training tasks. Activities such as tactics or scenarios require a
safety walkthrough before training begins and identification of play/no-play areas and
areas to avoid. Instructors may also be assigned the roles and responsibilities of safety



                                            27
officers for certain activities. The Physical Fitness Section conducts safety briefings for
personnel who want to use the WSI-SRS Fitness Facility. The Training Division utilizes
procedure 1-3122, Temperature Extremes, which establishes the guidelines and standards
that dictate when training, running, or physical activity can occur.
The Training Division completes a Job/Task Analysis process, which identifies all tasks
that must be trained, for all Protective Force positions annually. A training needs
analysis is also conducted annually as described in procedure 1-6003, Developing the
Annual Training Plan. This process determines how and where subjects identified in the
JTA process are taught. This process identifies deficiencies to include safety issues and
addresses long-term solutions.
The Training Division uses a critique system to obtain feedback on several items
including safety. In addition, when internal audits are conducted by other WSI-SRS
organizations (e.g., the Office of the Deputy General Manager), they provide summaries
to the Director and managers.
The Training Division works very closely with the Office of the Deputy General
Manager to ensure that safety is an integral part of the training program. The Training
Division’s managers are also concerned with environmental matters associated with
training.

Protective Force Operations Division
The Protective Force Operations Division consists of the following elements: 100-K,
100-L, 200-F Tank Farm, 200-H, Tritium, Special Response Team (SRT), and Site
Commanders as well as all PAAC (Plantwide Alternate Alarm Center) and SRSOC
(Savannah River Site Operations Command). The roles and responsibilities of Protective
Force Operations personnel for safety are described in detail within a large number of
written procedures, including the Post Orders for each position and standard procedures
(e.g., 3-4000, Protective Force Operations Manual (U)).
Procedure 2-312, Daily Security Exercise Operating Procedure, establishes which
exercises shall be included in the training process for the purposes of achieving and
maintaining skills and assessing individual and team competency levels. This procedure
requires a briefing of safety considerations at every muster. Personnel who report for
duty after the muster briefing receive the briefing before assuming post. Exercise play is
monitored to identify and prevent deviation from the approved exercise and violation of
safety procedures.
In addition to procedure 2-312, Protective Force Operations Division personnel also
utilize the following:
      Orders, Exceptions, and Responsibilities (2-101)
      Issuance, Control, and Use of Badges, Passes, and Credentials (2-103)
      Site Access (2-104)
      Communications (2-105)
      Government and Company Property (2-106)


                                            28
      Classified Materials, Documents, and Information (2-108)
      Shipment Security (2-109)
      Arrest Authority and Use of Force (2-110)
      Occupational Safety and Health (2-111)
      Physical Protection of Security Interests (2-112)
      Prohibited and Controlled Articles (2-113)
      Material and Property Control (2-114)
      Aircraft (2-115)
      Site Inspection and Search Requirements (2-116)
      Firearms Safety and Maintenance (2-117)
      Intrusion Detection Devices and Systems (2-119)
      Operation and Testing of Special Equipment (2-120)
      Special Response Team (SRT) (2-121)
      Emergency Security Operations Procedure (ESOP) (2-201)

Protective Force Operations Division utilizes several different methods to ensure the
competence of its personnel: post inspections by shift supervisors, participation in the
PTAD Performance Testing Program, daily exercises conducted by immediate
supervision, no-notice training exercises conducted by area management, special training
provided on area-specific topics, quarterly training classes, and validation of training
comprehension through conduct of Limited Scope Performance Tests (LSPTs).
Within each area, Protective Force Operations personnel utilize daily musters to brief new
safety items of interest and to discuss recurring items of concern (e.g., weapons safety,
vehicle safety, and daily exercise rules). All of the items that are discussed are recorded
on the WSI-SRS Muster Checklist (WSI-SRS Form 821).
Some shift supervisors within Protective Force Operations are trained as exercise
controllers/evaluators, and they are trained to observe activities that have a high-risk
potential (e.g., loading and unloading weapons). In addition, each shift supervisor
completes one post check per shift, visiting each post in the area to check on personnel
and to inspect for any safety hazards or concerns. In addition, the shift supervisor is the
initial contact person for Protective Force Operations personnel who exercise Stop Work
authority.
A joint safety and health walkdown of any post – permanent or temporary – at any time
may be appropriate based on newly discovered information or employee concerns. For
immediate assistance, the Protective Force Security Manager/Major (or Lieutenant) can
contact the OSHD Manager by telephone or pager. Following a joint safety and health
walkdown, OSHD sends the Protective Force Security Manager/Major (or Lieutenant)
documentation of its evaluation of the post, including specific work practice/hazard control



                                            29
recommendations, as appropriate, and a statement of OSHD’s concurrence/nonconcurrence
with the creation of the post.
Immediately before unusual or special operations occur (e.g., Force-on-Force
performance tests), additional walkdowns are performed; and the identified risks are
eliminated/mitigated and then briefed to all participants.
The Protective Force Operations Division relies on the Job Analysis process to ensure the
appropriateness of hazard controls. During work on Job Analyses, job analysts work with
subject matter experts and expert performers to ensure that the description of the training
needed for a particular job position is appropriate. During the training development
process, a risk assessment is completed; then, immediately before the training is
administered, the trainees are briefed on the identified hazards and controls associated with
the training.
Within SRT, recurring items of safety concern, weapons safety, vehicle safety, and random
exercise rules are permanent parts of SRT’s WSI-SRS Muster Checklist (WSI-SRS Form
821). In addition, shift supervisors are trained and perform as exercise
controllers/evaluators; and they receive training to observe activities that have a high-risk
potential. The Shift Safety Officer is the initial point of contact for SRT employees who
exercise Stop Work authority; and he/she also reviews lesson plans and risk assessments to
ensure compliance.
Within Protective Force Operations, safety is first considered at the planning stage. Once a
scope of work is defined, safety walkdowns are conducted to ensure that the work can be
performed safely. For example, before the initial staffing of either a new permanent post or
a temporary post that is expected to exist for more than five consecutive 24-hours days, the
Protective Force Security Manager/Major (or a Lieutenant acting on his/her behalf)
contacts the Occupational Safety and Health Department (OSHD) to schedule a joint safety
and health walkdown of the post [described in procedure 3-4000, Protective Force
Operations Manual (U)]. The purpose of the walkdown is to identify the hazards
associated with the work to be performed, the applicable standards and/or requirements,
and the appropriate controls to be implemented before the work is performed. In addition,
the Protective Force Security Manager/Major (or Lieutenant) contacts OSHD before the
initial staffing of any temporary post that is expected to exist for less than five consecutive
24-hour days when any party has already identified potential safety concerns.
SRT’s Shift Safety Officers conduct safety inspections in training areas as well as work
areas, and they review lesson plans and risk assessments.
Annex E, SRT Shift Safety Officer Program, of Security Order 2-121, Special Response
Team (SRT), and procedure 3-5100, AOD Security Helicopter Operations Procedure,
establish policy, assign responsibilities, and define procedures for the division’s Operational
Safety Officers, who ensure that all designated performance-based training conducted by
their organizations is supported by current lesson plans, risk assessments, or flight manuals.
The SRT Shift Safety Officers are responsible for: (1) completing Designated
Performance-Based Training Checklists and forwarding them to the SRT Commander;
(2) validating the completion of the Live Fire Range Activation Checklist for live-fire
training; (3) verifying Lesson Plan approval dates prior to conducting training;



                                              30
(4) completing a review of the applicable lesson plan, or DOE M473.2-1, Firearms
Qualification Courses Manual, and the risk assessment to ensure that the training to be
conducted is approved; and (5) ensuring that any equipment listed in the lesson plan is
present, has been inspected as required, and is in good repair.
Special Operations Division
The Special Operations Division includes Aviation Operations Department (AOD), Law
Enforcement (LE), Special Operations Administration Department, Material
Transportation and Security Department (MTSD), and the Perimeter Protection
Department (PPD).
Within Special Operations, safety is first considered at the planning stage. Once a scope of
work is defined, safety walkdowns are conducted to ensure that the work can be performed
safely. For example, before the initial staffing of either a new permanent post or a
temporary post that is expected to exist for more than five consecutive 24-hours days, the
Security Manager (or a Lieutenant acting on his/her behalf) contacts the Occupational
Safety and Health Department (OSHD) to schedule a joint safety and health walkdown of
the post (described in procedure 3-5000, Perimeter Protection Department Operations
Manual). The purpose of the walkdown is to identify the hazards associated with the work
to be performed, the applicable standards and/or requirements, and the appropriate controls
to be implemented before the work is performed. In addition, the Security Manager/Major
(or Lieutenant) contacts OSHD before the initial staffing of any temporary post that is
expected to exist for less than five consecutive 24-hour days when any party has already
identified potential safety concerns.
The roles and responsibilities of Special Operations personnel for safety are described in
detail within a large number of written procedures (many of the same procedures utilized
by Protective Force Operations personnel), including the Post Orders for each position,
Standard Procedures (e.g., the Level 1 5100, 5200, and 5300 series; procedure 2-312,
Daily Security Exercise Operating Procedure; and procedure 3-5000, Perimeter
Protection Department Operations Manual), Security Orders and other documents
applicable to aviation operations and facilities (e.g., General Operations Manual for Part
135 Operators), and the following Security Orders:
      Orders, Exceptions, and Responsibilities (2-101)
      Issuance, Control, and Use of Badges, Passes, and Credentials (2-103)
      Site Access (2-104)
      Communications (2-105)
      Government and Company Property (2-106)
      Classified Materials, Documents, and Information (2-108)
      Shipment Security (2-109)
      Arrest Authority and Use of Force (2-110)
      Occupational Safety and Health (2-111)
      Physical Protection of Security Interests (2-112)


                                            31
      Prohibited and Controlled Articles (2-113)
      Material and Property Control (2-114)
      Aircraft (2-115)
      Site Inspection and Search Requirements (2-116)
      Firearms Safety and Maintenance (2-117)
      Intrusion Detection Devices and Systems (2-119)
      Operation and Testing of Special Equipment (2-120)
      Law Enforcement/General Site Security (2-122)
      Emergency Security Operations Procedure (2-201)

Special Operations has two Operational Safety Officers – the Aviation Safety Officer and
the Law Enforcement Safety Officer. The Aviation Safety Officer’s responsibilities are
described in section V.D of procedure 3-5100, AOD Security Helicopter Operations
Procedure, and section VI.C.(3) of procedure 3-5319, Aviation Operations Department
Internal Oversight Program. The Law Enforcement Safety Officer’s responsibilities are
described in procedure 3-5910, Law Enforcement Safety Officer and Traffic Safety
Programs.
Special Operations utilizes several different methods to ensure the competence of its
personnel: post inspections by shift supervisors, participation in the PTAD Performance
Testing Program, daily training exercises conducted by immediate supervision, no-notice
exercises conducted by management, special training provided on specific topics, pilot
training (per 3-5106, Security Helicopter Training Program), and validation of training
comprehension through conduct of Limited Scope Performance Tests (LSPTs). In
addition, Special Operations relies on the results/feedback provided by LE’s Conduct of
Operations Committee and Safety Observer activities to monitor safe work performance.
Within Special Operations, PPD/LE supervisors utilize daily musters to brief new safety
items of interest and to discuss recurring items of concern (e.g., weapons safety, vehicle
safety, and daily exercise rules). All of the items on the WSI-SRS Muster Checklist
(WSI-SRS Form 821) are reviewed during muster, and items that are discussed in detail
are recorded in the Notes section on the Field Operations Muster Checklist.
Several PPD/LE supervisors and Operations Security Specialists are trained as exercise
controllers/evaluators. In addition, each PPD shift supervisor completes one post check
per shift, visiting each post on the general plant site to check on personnel and to inspect
for any safety hazards or concerns. Each barricade post is contacted by telephone at least
once during each shift if a physical check cannot be completed. Also, the shift supervisor
is the initial contact person for LE personnel who exercise Stop Work authority.
The LE Safety Lieutenant reviews training on and field implementation of LE’s
procedures and training lesson plans for safety considerations and conducts traffic safety
presentations for groups sitewide upon request.




                                            32
Within AOD, safety items are briefed between the Pilot-in-Command, the
Second-in-Command, and the SRT Lieutenant following each shift change, and the
results are recorded on the AOD/SRT Shift Briefing Form (WSI-SRS Form 830).
Recurring items of safety concern are noted on the pilot’s Pass-On Book, located in the
flight planning area. Each crew member is required to read the Pass-On Book upon
assuming duty. Hazards concerning a helicopter landing zone (HLZ) are recorded on the
HLZ inspection checklist as required by 3-5103, Aerial Inspection of Facilities/Flight
Hazards Survey. The checklist is posted each time a hazard is detected and is updated
monthly by the Aviation Safety Officer. In addition, the Aviation Safety Officer
conducts the Quarterly Aviation Safety Appraisal in accordance with 3-5100, AOD
Security Helicopter Operations Procedure. Operational hazards are reported through
AOD’s Operational Hazard Report Program as described in 3-5117, Aviation Operational
Hazard Report (OHR).
Each on-duty pilot completes a Shift Change Checklist (WSI-SRS Form 829) daily.
AOD’s aircraft are operated in accordance with the BK 117 A-3 Approved Rotorcraft
Flight Manual and with Federal Aviation Administration Regulations, Parts 91 and 135.
All aircraft maintenance is completed in accordance with the Approved Aircraft
Inspection Program (AAIP) and the applicable requirements from Federal Aviation
Regulations, Parts 43 and 135.
The Special Operations Division relies on the Job Analysis process to ensure the
appropriateness of hazard controls. During work on Job Analyses, job analysts work with
subject matter experts and expert performers to ensure that the description of the training
needed for a particular job position is appropriate. During the training development
process, a risk assessment is completed; then, immediately before the training is
administered, the trainees are briefed on the identified hazards and controls associated with
the training.
Individual performance goals, including safety goals, are established for Special
Operations personnel during the performance evaluation process, which places a
premium on supervisors’ attitude and performance on safety issues. Surveillances and
appraisals conducted by Office of the Deputy General Manager personnel help monitor
safety performance as an element of the performance of all daily duties.

Administration Division
The Administration Division includes the following administrative departments:
Accounting, Compensation & Benefits, Contracts & Resources Management, Employee
Relations, Labor Relations, Information Resource Management, and Logistics. Safety
considerations are given the utmost priority in the planning and execution of all
Administration Division work. This policy is articulated in its standard operating
procedures. Based on this established policy, it is incumbent on all Administration
Division personnel to work safely and to ensure that safety is given due consideration
when allocating resources. Consequently, separate budget line items are established
within each operational area for safety supplies and equipment to ensure that funds are set
aside for the acquisition of such equipment. Management ensures that all necessary
resources, such as training opportunities and personal protective equipment, are available
for all Administration Division personnel.


                                             33
The Administration Division’s divisional implementation plan incorporates the actions
contained in the company’s strategic plan. Many of these implementing actions are
carried down to the employee level by being integrated into the performance evaluation
system as individual measures, goals, and objectives.
The Administration Division’s standard procedures define the roles and responsibilities
with respect to safety considerations pertaining to all functional areas. Job responsibilities
requiring safety-related certifications or other necessary training are incorporated into a
training matrix that is updated periodically to ensure that employees are scheduled for
and receive the appropriate training.
When tasks are identified which might potentially expose Administration Division
personnel to hazards, a risk evaluation is completed. A scope of work must be defined
prior to the work being performed. Representatives from the Office of the General
Manager, or other subject matter experts, are requested to assist in the evaluation to ensure
that all hazard control methods or devices that might mitigate the hazard are employed.
Once mitigating factors have been identified (e.g., use of personal protective equipment,
training, user aids or safety guards/shields), they are incorporated into standard procedures
to ensure consistency throughout the company. Senior management must approve these
procedures.
The Administration Division has established its own Safety Committee, which is chaired
by the Division Director. The roles and responsibilities of the committee’s members are
described in a written charter. Non-billable funds are budgeted each year to support the
committee and its activities. The Administration Division promotes employee awareness
of the committee. Employees may bring topics of concern before the committee so they
can be appropriately addressed.
Safety-related information is disseminated in divisional safety meetings. In addition, a
safety bulletin board is used to display pertinent information, including performance
goals and measures.
Administration Division personnel have been trained regarding the responsibility to stop
work if they perceive an unsafe condition exists. They are also made aware of the
avenues available for reporting safety concerns or issues openly or in a confidential
manner. In addition, Administration Division personnel serve on the Integrated Safety
Committee, the Executive Safety Committee, and the Safety Performance Analysis
Committee.

Security Planning and Infrastructure Division
The Security Planning and Infrastructure Division (SPID) includes the Security Programs
and Planning Department, the Infrastructure Projects Department, and the Performance
Testing and Assessment Department. Safety considerations are given the utmost priority
in the planning and execution of all SPID work. This policy is articulated in the
Functions and Responsibilities Directive, as well as applicable standard procedures
within the division. Based on this established policy, it is incumbent on all SPID
employees to perform work in a safe manner and in accordance with applicable company
and site safety policies.



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Within the SPID, the Security Programs and Planning Department (SPPD) provides
cost-effective safeguards and security planning and analysis functions in support of
WSI-SRS operations. The primary functions of this department are management of the Site
Safeguards and Security Planning Program (SSSP) for WSI-SRS, which includes
participation in the development of Safeguards and Security Management Reports (SSMRs)
and Vulnerability Analyses; management of WSI-SRS staffing requirements and force
authorizations; assignment/reassignment of Protective Force personnel; maintenance of
Protective Force contingency plans, procedures, security orders, and post orders; and
strategic planning. These functions are performed with a constant concern for safety.
Specific safety roles and responsibilities are found within the SPPD’s standard operating
procedures. Applicable procedures are identified below:

      WSI-SRS Operational Readiness Review (ORR) Procedure (1-8102)
       Establishes the process for conducting Operational Readiness Reviews (ORRs) that
       are accomplished before the operation of a new or restarted process, operation,
       facility or program. Ensures safety is a major topical area during the conduct of all
       ORRs.
      Security Alarms/Device Acceptance (1-8103)
       Outlines responsibilities for accepting new security alarms/devices from Washington
       Savannah River Company (WSRC) for operation by WSI-SRS personnel. Provides
       appropriate guidance if a safety issue arises.
      Staffing & Mission Essential/Major Equipment Authorization Management (1-8107)
       Establishes policy and procedure for management of personnel staffing
       authorizations, for management of the temporary subcontract personnel program,
       and for management of major equipment allocations. Ensures applicable resources
       are available to support the safety program.
      Contingency Planning (1-8110)
       Outlines the policy and process to be employed by WSI-SRS in the development,
       coordination and implementation of contingency plans or procedures to be used by
       the Protective Force in providing for the physical protection of DOE security
       interests at the SRS. Ensures safety concerns are addressed during development of
       all contingency plans.
      WSI-SRS Strategic Planning Process (1-8111)
       Describes the process for development, review, approval, dissemination and
       utilization of the WSI-SRS Strategic Plan and accompanying Division
       Implementation Plans. Defines the company’s mission, vision, core values,
       strategic goals, objectives and strategies to ensure our future success as an
       organization to include safety considerations.
      Integrated and Executive Safeguards and Security Committees (1-8112)
       Establishes policy, assigns responsibilities, and defines procedures for the Integrated
       Safeguards and Security Committee (ISSC) and the Executive Safeguards and


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    Security Committee (ESSC). Supports the Guiding Principles for the Integrated
    Safeguards and Security Management (ISSM) System. Provides linkage with the
    Integrated Safety Management process.
   Security Orders, ESOP, Post Orders Administrative System (2-309)
    Establishes procedures for the development, coordination, review, change and
    distribution of Security Orders (SO), the Emergency Security Operations Procedure
    (ESOP), and Post Orders (PO), which are utilized to direct members of the
    Protective Force in the physical protection for DOE security interests at the SRS.
    Ensures safety considerations are addressed during development of these orders.

The Infrastructure Projects Department (IPD) is responsible for the initiation,
coordination, and management of infrastructure projects identified to support WSI-SRS
operations. This responsibility includes the development of design and engineering
requirements for each project of which safety is a critical consideration. IPD also
serves as the main point of contact for tracking and monitoring of all maintenance
requests pertaining to WSI-SRS operations. IPD provides oversight and assists all
WSI-SRS Building Coordinators in the reporting, coordination and resolution of
maintenance requests. Quarterly meetings are conducted with all WSI-SRS Building
Coordinators in order to provide status updates and discuss pertinent issues related to
proper upkeep of WSI-SRS facilities. Applicable procedures are identified below:

   WSI-SRS Facility Maintenance and Housekeeping (1-8100)
    Establishes guidelines for the coordination, reporting and tracking of work requests
    that are necessary in order to properly maintain facilities occupied or operated by
    WSI-SRS. Provides housekeeping guidelines for WSI-SRS personnel occupying
    these facilities. Identifies and provides a mechanism to resolve maintenance items
    that have the potential to degrade the safety and health of WSI-SRS employees.
    Ensures design modifications or system enhancements associated with infrastructure
    projects adhere to Integrated Safety Management principles and functions.
   Change in Facility Operation/Occupancy (1-8101)
    Outlines responsibilities for accepting new or modified facilities from Washington
    Savannah River Company (WSRC) or abandoning existing facilities due to
    relocation, mission change, or personnel down-sizing. Identifies the potential
    safety/health implications associated with the occupancy or training use of the
    facility. Provides mechanism to coordinate revisions of existing Risk Analysis
    Reports, Lesson Plans, and risk assessments, as needed. Provides for a safety
    review during the design, planning, and construction phases of new or modified
    projects or facilities. Provides provision for a walkdown of a facility scheduled for
    abandonment in order to document facility condition and the status of existing
    safety/health hazards at the time of abandonment.
   WSI-SRS Infrastructure Projects (1-8106)
    Establishes guidelines for the proper management of infrastructure projects
    identified for existing WSI-SRS facilities and/or for new facilities that WSI-SRS


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    will occupy or operate. Requires safety reviews of design modifications or system
    enhancements associated with infrastructure projects to ensure adherence with
    Integrated Safety Management principles and functions.

The Performance Testing and Assessment Department (PTAD) provides safe and
comprehensive evaluations and assessments of the effectiveness of Protective Force
operations through the conduct of performance tests and performance-based
independent assessments. PTAD has a three-fold commitment to safety: the manager
is responsible for establishing a pro-safety working environment; for modeling
appropriate safety behavior through the execution of WSI-SRS procedures, and for
assuring personnel under his supervision have received appropriate safety training
commensurate with the scope and complexity of their jobs. Applicable procedures are
identified below:

   Performance Testing and Assessment Department Procedure (procedure 1-3509)
    Establishes a comprehensive program of performance testing and Safeguards and
    Security (S&S) self-assessments of Protective Force operations and S&S
    programs. This comprehensive program provides WSI-SRS management and its
    customers a means for timely identification of deficiencies, suggestions, and
    lessons learned that enables determination of root causes and implementation of
    appropriate corrective actions.
   PTAD No-Notice Performance Test Procedure (procedure 1-3508)
    Establishes guidelines for the conduct of No-Notice Performance Tests (NNPT),
    thereby ensuring that NNPTs are conducted in a safe and realistic manner. Safety
    considerations are outlined and must be followed. Planned/Scheduled NNPTs are
    run to provide an objective evaluation of PF response capabilities. NNPTs may
    be conducted to test the quality of response of specific PF elements [e.g., Canine
    and Special Response Team (SRT)]. Any violations of WSI-SRS safety
    procedures are annotated in the NNPT report as findings or suggestions requiring
    corrective actions. A structured method for the correction of the causes of
    deficiencies within WSI-SRS programs and operations are found within
    procedure 1-3703, Corrective Action.
   PTAD Limited Scope Performance Test Procedure (procedure 1-3507)
    This procedure ensures Limited Scope Performance Tests (LSPTs) are approved
    by WSI-SRS management and conducted in a safe manner. This procedure
    applies to all WSI-SRS employees and is applicable during all LSPTs. For all
    ESS-supported LSPTs, the use of safety rules and qualified controllers and
    evaluators ensures the safe conduct of each test. This procedure also provides for
    the following: meaningful and realistic evaluation of all essential elements of
    Protective Force (PF) operations and facility protection strategies; identification
    of deficiencies, suggestions, and lessons learned; and appropriate corrective
    actions in accordance with related company policies and DOE directives.




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      PTAD Force-on-Force Exercise Procedure (procedure 1-3506)
       This procedure ensures Force-on-Force (FOF) exercises are approved by
       WSI-SRS management and conducted in a safe manner. This procedure applies
       to all WSI-SRS employees and is applicable during all FOF exercises. Use of
       safety rules and qualified controllers and evaluators ensures the safe conduct of
       each exercise. This procedure also provides for the following: meaningful and
       realistic evaluation of all essential elements of Protective Force (PF) operations
       and facility protection strategies; identification of deficiencies, suggestions, and
       lessons learned; and appropriate corrective actions in accordance with related
       company policies and DOE directives.
      ESS Exercise and Performance Test Manual (procedure 3-3506)
       This manual applies to all WSI-SRS personnel for planning, supporting, and
       conducting ESS exercises and performance tests. Establishes guidance for
       conducting overview briefings for the activity objectives, scenario timelines, and
       rules of engagement. A chapter is dedicated to safety and health protection issues
       that must consistently be considered from the inception to completion of an ESS
       activity. While meeting the program objective of administering realistic ESS
       activities, dedicated efforts are made to minimize all risks associated with hazards
       to personnel, equipment, and the environment.
      PTAD Safeguards and Security Self-Assessment (S&SSA) Program Manual
       (procedure 3-3503)
       This manual applies to all PTAD personnel for planning, supporting, conducting,
       and evaluating Protective Force operations and S&S programs. It establishes a
       generic program of periodic self-assessments and special assessments of
       Protective Force operations and S&S programs. During assessments, team
       members are constantly looking for safety concerns. Numerous findings and
       suggestions have stemmed from team members’ vigilance for safety concerns.
       When safety findings and suggestions are identified, corrective action plans are
       implemented and individual corrective actions are tracked to completion.

The SPID’s Division Implementation Plan incorporates the implementing actions for
applicable goals and objectives contained in the company’s strategic plan. Implementing
actions are carried down to the employee level by integration into the performance
evaluation system as individual measures, goals, and objectives. Safety-related
information is disseminated in weekly divisional meetings. SPID employees serve on the
Integrated Safety and Executive Safety Committees. All SPID employees have the
responsibility to stop work if they perceive an unsafe condition exists. They are also
made aware of the avenues available for reporting safety concerns or issues openly or in a
confidential manner.

Security Support Division
The Security Support Division (SSD) includes the Information and Personnel Security
Department and the Site Security Support Department. Members of SSD are routinely
reminded of the need to incorporate safety into their work processes through staff meetings,


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bulletins, participation in all company safety initiatives, and by following the example set
by Division management.
Each employee’s annual performance review contains at least one safety goal. This
emphasizes the requirement to integrate safety considerations into annual performance. All
division employees are trained on the ―Stop Work‖ process when unsafe conditions are
present. Employees are recognized through various rewards for being alert to safety in the
workplace. Members of the Division serve on the Employee Safety Committee, the
Integrated Safety Committee, the Executive Safety Committee, and the Safety Performance
Analysis Committee.
Both departments have sponsored the WSI-SRS Integrated Safety monthly meetings.
Participation included development of a safety topic and presentation of a program.
Employees were actively involved in ensuring the success of the meeting.
Division members participate in the off-site safety conference sponsored by the
Washington Savannah River Company. This conference is held annually, and participants
return with additional information that is shared in team meetings.
Division members are encouraged to support the WEBBS process. Continued emphasis
will contribute to personal safety as well as supporting the safety of their peers in the
workplace.

VI. SAFETY MANAGEMENT SYSTEM EFFECTIVENESS
In accordance with the requirements of paragraphs (d) and (e) of DEAR clause
970.5223-1, WSI-SRS responds to DOE-SR program and budget execution guidance by
developing, committing to, implementing, and meeting ESH milestones and performance
measures which are described in the Strategic Execution Guidance (SEG). The SEG
clearly defines DOE-SR's specific expectations to meet SRS Strategic Plan goals. This
document is updated at specific intervals to align with the budget formulation and
execution process. Upon receipt of the SEG, WSI-SRS develops a Management and
Staffing Plan that identifies projected staffing authorizations necessary to accomplish the
mission based upon our guidance. The Management and Staffing Plan is then utilized as
the baseline planning document in the development of the Annual Operational Plan
(AOP). The AOP is developed during the 4th quarter of each fiscal year to define the
upcoming fiscal year's tasks, along with baseline cost estimates, milestones and schedules
for performance under the FAR services contract. Funding levels identified in this plan
may be modified through the change control process. The execution of these tasks is
monitored through the Performance Evaluation Committee by determination of incentive
and award fees.
In accordance with the requirements of DOE M 450.4-1, Integrated Safety Management
System Manual, WSI-SRS monitors the effectiveness of its ISMS in different ways. For
example, WSI-SRS conducts an annual internal self-assessment of the effectiveness of
Safety Management System implementation.            The assessment addresses the
establishment, documentation, and implementation of the performance objectives,
performance measures, and commitments developed in response to the program and
budget execution guidance received from DOE-SR. The self-assessment team conducts
the fieldwork and prepares a written report, utilizing lines of inquiry identified or


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developed in advance. In addition, WSI-SRS prepares and submits to DOE-SR an annual
ISM declaration, which DOE-SR uses, along with the annual ISM declarations submitted
by other SRS organizations, to prepare an annual ISM declaration for DOE-SR and SRS
as a whole. DOE-SR submits that declaration to DOE-HQ. WSI-SRS can use the annual
ISM declaration process to identify ISM improvement opportunities with potential
application outside WSI-SRS and/or across all SRS organizations.
The Quality and Performance Analysis Department (QPAD) conducts a formal
Deficiency Analysis Group meeting to address all of the findings described in the final
self-assessment report, and representatives from all of the affected organizations attend
the meeting. In addition, the Directors ensure that informal meetings are conducted to
address all of the observations documented in the self-assessment report. Once corrective
actions (for findings) and improvement actions (for observations) are identified, QPAD
utilizes the Improvement/Corrective Action Tracking System to track all of those actions
to completion.

VII. CONCLUSION
WSI-SRS has developed and implemented a Safety Management System that effectively
weaves safety into the fabric of daily operations, thereby ensuring the safety and health of
all WSI-SRS employees and protection of the public and the environment on a continuing
basis. This document summarizes system elements as they are currently designed and
executed; however, WSI-SRS workplaces are no different than any others – change is
one of very few constants. Managing this change safely is the challenge for all WSI-SRS
employees.
In their quest for continuous improvement in all aspects of their work, WSI-SRS
employees will continue to identify safer and more efficient ways to conduct business.
Consequently, changes in work processes, equipment, and training will continue to
emerge; and revisions to this document will become necessary periodically.




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