Interface Manual    DOE M 140.1-1B Interface with the DNFSB

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1. IDENTIFYING SAFETY ISSUES. In analyzing Board recommendations and other Board letters and requests for action, the Responsible Manager should identify the salient safety issues being raised. Correct identification and formulation of the underlying safety issues establishes a framework to focus Departmental efforts. Full understanding and ownership of the safety issues involved are precursors to developing an effective, enduring resolution. By focusing on the underlying safety issues, the Department can more efficiently and effectively apply resources to achieving real safety improvements. The Safety Issues Management System is designed to facilitate line management efforts in managing and closing safety issues.

2. MAKING COMMITMENTS.

a. The Department establishes commitments in order to resolve identified safety issues. A commitment to the Board is defined as any documented obligation by the Secretary, or designee, that describes products to be delivered on a specified schedule. Only the Secretary, a Secretarial Officer, or a properly designated representative may make commitments to the Board. Departmental elements may agree to take actions within their authorities in response to Board and Board staff requests and inquiries. These action items also need to be satisfied to maintain an effective working relationship with the Board and its staff; they must be tracked and managed at the Departmental level where the action items are undertaken.

b. The principal source of Departmental commitments is the implementation plans developed in response to Board recommendations. Commitments may also be made in other types of correspondence to the Board, such as responses to trip reports or responses to Board letters requesting Departmental action or information. Additionally, documented Board requests taken for action are also considered commitments because it is the Department's policy to respond to such formal requests originating from the Board.

c. Prior to authorizing new Departmental commitments in response to Board initiatives, the cognizant Secretarial Officer must consider the appropriateness and value derived. If new commitments are needed, preference should be given to building upon existing programs and activities rather than creating new programs and activities. The cognizant Secretarial Officer should designate a Responsible Manager to assist in assessing the need and formulating new commitments.

d. The Responsible Manager must ensure that each newly proposed commitment is clearly delineated in its source document. The Responsible Manager should ensure that each commitment is uniquely numbered and includes the following information:

(1) a complete statement of the commitment;

(2) the manager responsible for implementing the commitment (i.e., Responsible Manager);

(3) applicable facilities and programs;

(4) implementing activities and deliverables (i.e., specific work products) to demonstrate completion; and

(5) specific due dates for those deliverables.

e. As part of implementing assigned commitments, the designated Responsible Manager must provide status updates to the Safety Issues Management System and prepare a closure package upon commitment completion. For commitments related to a Board recommendation and the associated implementation plan, the designated Responsible Manager for the implementation plan must perform tracking and closure for all associated commitments. The Responsible Manager may designate a technical lead to assist in coordinating implementation, tracking, and closure.

f. The following is an example of the desired presentation for commitments attached to outgoing correspondence to the Board.

Commitment #

Commitment Statement: Deficiencies observed during Phase I and Phase II assessments will be tracked and managed in local corrective action management systems. Resources allocated to address findings resulting from confinement ventilation system and other assessments within this Implementation Plan will be identified on an annual basis.

Deliverable: Summary of resources allocated within the FY 2003 budget request to Congress.

Applicability: All Departmental defense nuclear facilities and programs.

Responsible Manager: Assistant Secretary for Environment, Safety and Health; Assistant Secretary for Environmental Management; Deputy Administrator for Defense Programs.

Due Date: February 2002.

The Responsible Manager, with the support of the Departmental Representative staff, should describe the proposed commitments to the cognizant Board member or Board staff member prior to finalizing them. The Responsible Manager must obtain appropriate Departmental concurrence and approval of outgoing correspondence containing commitments.

3. TRACKING COMMITMENTS.

a. The Departmental Representative's staff should review implementation plans and incoming and outgoing correspondence containing commitments to identify each commitment and enter the corresponding commitment information into the Safety Issues Management System database. The Departmental Representative's staff should obtain the concurrence from the Responsible Manager that the commitment information has been correctly identified and entered.

b. Before the end of each month, the Responsible Managers should provide an updated implementation status of assigned commitments by forwarding any changes to the corresponding Issue Lead. For overdue commitments, the Responsible Manager should provide the actions being taken to complete the commitment and the estimated completion schedule. The Issue Lead should review this updated information for completeness and accuracy and the Departmental Representative's staff should update the Safety Issues Management System database as requested. The Departmental Representative's staff should make these monthly updates available to Responsible Managers, Points of Contact, Secretarial Officers, and other interested Departmental elements. If a Responsible Manager does not provide a status report on his or her overdue commitments or does not make substantive progress in completing the plan's commitments, the Departmental Representative should escalate attention to the responsible Secretarial Officer for action.

c. The Responsible Manager should anticipate and manage implementation problems so that they have a minimum impact on commitment due dates. The Responsible Manager and the Issue Lead should inform the cognizant Board staff member in advance (i.e., not later than the planned completion date for the milestone) of any planned milestone due dates that will be missed. The Responsible Manager should provide prior written notification to the Board on the status of any Departmental commitment that will not be completed by the planned milestone date. For each commitment, this written notification should describe the reason(s) for the schedule variance from the Department's plans, current actions underway to fulfill the commitment, and an estimated completion date. If commitment completion will be delayed by a substantial period (e.g., more than 3 months) from the committed due date, or if the approach to fulfilling the commitment has been or needs to be changed, the Responsible Manager should obtain approval from the same authorization level that made the original commitment (i.e., the Secretary in the case of Departmental implementation plans).

d. The Departmental Representative should monitor overall performance in fulfilling Departmental commitments to the Board and take appropriate action to focus necessary Departmental resources to resolve underlying safety issues. The Departmental Representative should prepare quarterly reports on commitment performance.

4. REVISING COMMITMENTS.

a. Commitments may be revised during their execution. Revisions to commitments require the same authorization as for the original commitments. For example, if the original commitment went out under a Secretarial signature, then the Secretary must approve any subsequent commitment revisions, whether in content or in due date. Outgoing correspondence to the Board that contains commitment revisions must be prepared by the Responsible Manager and must clearly identify and describe the revisions, and the basis for the revisions. Acceptable reasons for revising commitments include the following examples:

(1) an improved or more cost-effective method of accomplishment is identified;

(2) additional or supplemental actions are needed;

(3) commitments are no longer applicable due to a change in mission or need; or

(4) schedule changes are necessary due to changes in Departmental priorities.

b. The Responsible Manager, supported by the Departmental Representative's staff, should discuss commitment revisions in advance with the Board staff. The Responsible Manager should address any Board staff concerns with the proposed revisions. If necessary, the cognizant Secretarial Officer and the Departmental Representative should interface with the cognizant Board member to review proposed commitment revisions.

c. Alternatively, the Responsible Manager may report the status of commitments to the Board as late. Such reports should describe the reason(s) for late completion, the current actions underway to complete the commitment, and the estimated completion date.

d. As a general policy, Responsible Managers should revise late commitments to correctly reflect the current schedule. This is desirable for the following reasons: (1) a large list of overdue commitments reflects poorly on Department management, (2) a due date in the future is more motivating, and (3) a new due date ensures a future management review on a set schedule. Responsible Managers should make maximum effort to ensure that no outstanding commitments are over 12 months old.

5. CLOSING COMMITMENTS.

a. A commitment is considered complete when the commitment activities are implemented, deliverables are developed and approved, and a closure package is prepared and ready for Board staff review. A closure package is the set of documents that provides objective evidence of completion of commitment implementing activities. When the Responsible Manager determines that a commitment is complete and ready for closure, he/she must prepare and transmit a closure package that includes the following items:

(1) the original commitment statement,

(2) a description of how the Department satisfied the commitment, and

(3) the promised deliverables or evidence of completion of the implementing activities.

b. The Responsible Manager must obtain concurrence on the closure package transmittal from those Departmental elements necessary to ensure that the completed actions are consistent with the original commitment. As with other outgoing Board correspondence, the Responsible Manager must obtain concurrence from and provide the Departmental Representative with a copy of closure package transmittals.

c. To propose closure of commitments, the Responsible Manager must prepare the closure package transmittal letter using the following sentence: "The Department has completed the actions identified under this commitment, and proposes closure of the commitment." After transmittal, the Responsible Manager, with the assistance of the Issue Lead, should contact the Board staff to arrange discussions or review the closure package, if desired.

d. The Departmental Representative's staff must update the completion and closure status of the commitment in the Safety Issues Management System.

e. The Responsible Manager must retain commitment closure packages such that the closure packages can be retrieved, if necessary, within 2 hours of a request.

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