[DOE LETTERHEAD]
August 5, 2005
The Honorable A. J. Eggenberger
Chairman
Defense Nuclear Facilities
Safety Board
625 Indiana Avenue, NW, Suite
700
Washington, DC 20004
Dear Mr. Chairman:
As called for by Commitment 21
in the Department’s 2004-1 implementation plan, this letter provides the
Department’s decision and basis on whether to issue the Department’s Integrated
Safety Management (ISM) vision (described in Appendix F of the Department’s
2004-1 Implementation Plan) as a complementary ISM Policy or Notice. The Department has carefully considered this
matter and has decided that the issuance of a complementary ISM policy or
notice is not necessary or desirable at this time. The Department’s ISM vision has been clearly
defined and communicated in the 2004-1 implementation plan, approved by the
Secretary on June 10, 2005. This vision
is being reinforced through ongoing dialogue with responsible managers
throughout the Department, as demonstrated by the attached internal memo.
As described in the 2004-1
implementation plan, the Department’s first formal step within the Directives
system will be to establish clear requirements for federal offices to develop
and implement ISM systems. Commitment 22
calls for a new ISM manual, containing these expectations, to be issued by
December 2005. Ultimately, as described in
the Implementation Plan, all ISM directives, including the ISM policy, ISM
guide, Team leader’s handbook, and ISM DEAR clause, will be reviewed and
upgraded as necessary, to make them consistent with the ISM manual and to
reflect ongoing learning about how to effectively implement ISM. The plan calls for the full suite of ISM directives
to be reviewed after at least one year of experience is gained in meeting the new
ISM expectations, as contained in the ISM manual. This remains the Department’s plan and path
forward on ISM directives.
The current ISM policy (Guiding
Principles and Functions) is firmly established within the DOE complex. Feedback from the field, most recently during
review of Appendix F of the 2004-1 Implementation Plan, indicates that any
change to the ISM policy requires a thoughtful and deliberate approach. The approach described in the 2004-1 Implementation
Plan will allow for directed evolution of the Department’s ISM systems, without
over-specifying the form and content of these systems. Lessons learned during implementation of the
ISM manual can be reflected in the revision to other ISM directives. Ultimately, it appears highly likely that the
current ISM policy (DOE P 450.4) will need to be revised to be consistent with
the Department’s expanded ISM vision. The updated vision is fundamentally consistent
with the current ISM policy; the changes are mostly related to extending and
emphasizing portions of the original vision. Hence, it is unnecessary to change the ISM
policy at this time and it can be done more efficiently and effectively later,
as necessary, after implementation experience is gained and the vision can be
honed for institutionalization.
Please provide any further
feedback to me at (202) 586-2550, or have your staff provide feedback to the
2004-1 project leader, Ms. Kim Davis, at (202) 586-3771.
Sincerely,
Bruce M. Carnes
Associate Deputy Secretary
cc: Mark B. Whitaker, Jr., DR-1
Jerry
Paul, NA-2
David
Garman, US-ESE
John
Shaw, EH-1