Principles For Procedure System Management
Principles For Procedure System Management
NOT MEASUREMENT
SENSITIVE
DOE-STD-XXXX-YR
PROPOSED
DOE STANDARD
PRINCIPLES FOR PROCEDURE SYSTEM
MANAGEMENT
AREA MGMT
This document has been reproduced from the best available copy.
Available to DOE and DOE contractors from ES&H Technical Information
Services, U.S. Department of Energy, (800) 473-4375, fax: (301) 903-9823.
Available to the public from the U.S. Department of Commerce, Technology
Administration, National Technical Information Service, Springfield, VA 22161;
(703) 605-6000.
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Intentionally Blank
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Table of Contents
Topic
Page
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Foreword
1. This Department of Energy standard is approved for use by all DOE Components and
their contractors.
2. Beneficial comments (recommendations, additions, deletions) and any pertinent data
that may improve this document should be sent to the Office of Nuclear Safety Policy and
Standards (EH-53), U.S. Department of Energy, Washington, D.C. 20585, by letter or by using
the self-addressed Document Improvement Proposal form (DOE F 1300.3) appearing at the
end of this document.
3. DOE Technical Standards, such as this standard, do not establish requirements.
However, all or part of the provisions in a DOE standard can become requirements under the
following circumstances:
(1) they are explicitly stated to be requirements in a DOE requirements document; or
(2) the organization makes a commitment to meet a standard in a contract or in an
implementation plan or program plan required by a DOE requirements document.
Throughout this standard, the word "shall" is used to denote actions which must be performed if
the objectives of this standard are to be met. If the provisions in this standard are made
requirements through one of the two ways discussed above, then the "shall" statements would
become requirements. It is not appropriate to consider that "should" statements would
automatically be converted to "shall" statements as this action would violate the consensus
process used to approve this standard.
This Standard was prepared by the DOE Technical Standards Procedure Topical Committee. Members
include: Maggie Sturdivant - EH, Earl Carnes - EH, Charles Billups - SC, Joe King - DP, John Tseng EM, John Psaras - EM, Fred Carlson, consultant, Dick Nolan, DOE LBNL, Joyce Sylvester PWI, OR,
Peery Schaffer - Bechtel Jacobs, OR, Dan Plung - WSRC, Jacquie Lewis - BWXT INNEL, Steve Greene
UC, LANL, Susanne Guleke BWXT, PANTEX. The team wishes to acknowledge the assistance of
Dr. Daryl Grider and Mr. Bill Mullins for their assistance in the preparation of this Standard.
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Purpose
This Technical Standard (Standard) provides principles derived from lessons learned and best practices
from within the Department and industry for integrating management and technical knowledge,
requirements and standards into procedures that effectively support the missions of the Department of
Energy (DOE). These missions include scientific research and development, energy supply, nuclear
weapons stockpile stewardship, and cleanup of the environmental legacy from weapons production. This
Standard relies on principles rather than on prescription, and promotes reasoned adaptability in
recognition of the diversity of work, hazards, work environments, technical complexity, risks, knowledge,
and experience associated with accomplishing DOEs missions. Reliance on principle offers two
important benefits to providing a critical level of consistency in addressing this very diversity. First,
reliance on principle is intended and essential to retaining a consistent and recognized level of proven
performance excellence throughout DOE when it comes to codifying proven historical work practices and
newly developed work practices into approved procedures. Second, reliance on principle ensures the
direction is equally applicable to support all types of mission work: scientific, technical , operational,
maintenance, environmental, management and administrative work such as finance and personnel.
Introduction:
Over the past decade changes in DOEs missions have placed heightened attention on DOEs methods for
performing work. The result of this focus has been progress in matching work methods to missions. For
work where risk is understood, much collective experience has been codified. For work with
unconventional risks, good practices are being systematically and continuously learned by those working
at the edge of technology to develop standards and procedures for dealing prudently with the
unconventional.
Mission changes prompted the Department to establish a tailored standards-based approach for all DOE
work. This standards-based approach was developed in response to several factors: DOEs highly
specialized and experienced work force was aging and retiring; because of changing social expectations
new methods were needed to allow more open disclosure and discussion of how DOE work is performed;
new missions posed challenges that are on the edge of current knowledge. The government as a whole
was moving toward a system of regulation based on performance accountability. The Department of
Energy has responded by developing a body of performance-based policies, contracts, rules and
directives.
The standards-based approach is expressed in the DOE Safety Management System Policy, which
requires work in accordance with an Integrated Safety Management System (ISMS). This establishes a
formal framework to: (1) define work, (2) analyze hazards, (3) develop controls, (4) perform work and (5)
use feedback for correction and continuous improvement. These five functions are guided by seven
principles which address (1) line management responsibility for safety, (2) roles and responsibilities, (3)
personnel competence, (4) balanced priorities, (5) standards and requirements, (6) tailored hazards
controls, and (7) authorization of work. This framework is intended to apply in a tailored way to
technical work as well as the management and administrative work necessary to accomplish assigned
missions.
The ISM Policy is expressed through a hierarchy of agreements that take the form of mission, program,
and project descriptions and a variety of local work controls that individuals use to produce the outcomes
expected of their work. Work controls, particularly procedures, provide detailed expression of
management expectations for completing work tasks.
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Throughout DOE the maintained, written documents describing work performance may be referred to by
terms such as management controls, work instructions, operations aids, checklists, protocols,
administrative controls and standard operating procedures. This diversity of terminology has emerged
over time as part of the culture of individual DOE operations. Regardless of the terms used, local level
task work controls are considered the domain of procedures. Procedures serve to carry forward the
organizations collective knowledge of how to perform work, maintain design integrity, protect the health
and safety of people and the environment, and convey the management expectations for the degree of
autonomy of decisions and actions available to individual work performers. The value of procedures in
promoting the mutual goals of safety and quality is widely recognized by regulatory bodies and
professional associations such as the Occupational Safety and Health Agency, the Nuclear Regulatory
Commission, the Environmental Protection Agency, the Institute of Nuclear Power Operations, the
International Atomic Energy Agency, the Center for Chemical Process Safety, the American Society for
Quality and the International Organization for Standards. Just as these bodies do not all mandate the same
detailed methods for documenting procedures, so the set of Principles set forth in this Standard is
intended to accommodate a wide range of very different work realities.
What the agencies mentioned above do require is procedures that produce consistently high levels of safe,
efficient work results. The set of Principles established in this Standard also requires that work performed
according to written procedures achieve similar consistently high levels of safety and efficiency. In the
past, the Department of Energy has invested extensive effort and significant resources on procedures,
with uneven results. Procedures continue to be identified as principal causal factors in DOE accidents,
operating events, and lessons learned. Event reviews often specify a lack of management attention to
procedure development and procedure system management. To support implementation of Integrated
Safety Management at the task work control level, a DOE Procedures Topical Committee was chartered
as part of the DOE Technical Standards Program. The intent of this committee is to address procedures
from an enterprise view, that is, in a way applicable to all of the Departments work.
The members of the Topical Committee are managers, workers, operators, scientists, engineers and
technical specialists from both DOE and contractor organizations who have years of experience with
procedures and management systems. To support the ISM goal of doing work safely, the Committee has
focused attention on how procedures promote safe, efficient performance. The Committee has worked to
foster appropriate procedures that reduce the potential for human error. Members are mindful that
imposing inappropriate models of procedures would be counterproductive. The need to avoid the onesize fits all approach to procedures was felt to be an essential aspect of providing guidance that would be
productive, supported and used.
A comprehensive set of Principles for procedure system management and procedure development was
determined to provide the appropriate level of guidance. Establishing such a set of Principles was
deemed to be consistent with both the DOE need for an enterprise approach that respects the diversity of
DOE work and the management needs to communicate expectations and maintain awareness of procedure
systems and development activities. The guiding concept for these Principles is that the work, the hazards,
the environment in which the work occurs, and the skills, knowledge and experience that the work
demands give rise to the type of procedures to be used and how procedures will be used to aid in
performing work.
Applicability
This Standard can be applied to any DOE mission work. Contractors may use this Standard to tailor their specific
methods for managing the development, review, approval, distribution, use, maintenance and retirement of
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procedures. This Standard is consistent with and supports requirements and guidance found in 10 CFR Part 830
"Nuclear Safety Management," DOE Order 414.1A "Quality Assurance," DOE G 414.1-2 "Quality Assurance
Management System Guide," DOE Order 5480.19 "Conduct of Operations Requirements for DOE Facilities," and
DOE Order 440.1A "Worker Protection Management for DOE Federal and Contractor Employees."
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Hierarchy of Components
Safety Management
Objective
Safety Management
Principles
Safety Management
Functions
Safety Management
Mechanisms
Safety Management
Responsibilities
Safety Management
Implementation
Figure 1
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For most DOE work, implementation of work design, expectations, requirements and
standards are communicated through a set of interrelated documents. Depending upon the
work involved, risk, or safety implications, a document hierarchy may be needed to
express and achieve full implementation, for example, to communicate policy and
direction, support effective human performance, provide necessary information, establish
an organization's written intent to comply with applicable regulations and commitments,
and to direct task activities.
Figure 2 provides an example of a document hierarchy for capturing and implementing
expectations, requirements, commitments and direction.
Document Hierarchy
Source Documents
Laws, Regulations, Contract,
DOE Directives, Safety
Management System
Descriptions, Corporate Policy,
Corporate Standards
Bases Documents
Technical Bases, Design and
Authorization Bases,
Management Bases, Human
Performance Bases,
System/Program Descriptions
Work Instructions
Management Control
Procedures, Technical
Procedures, Emergency
Procedures
Supporting Documents
Lists, Guides, Templates
Figure 2
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Quality assurance
Configuration management
Personnel management
Emergency management
Fire protection
Human performance
Work planning
Safeguards and security
Lessons learned
Technical Procedures
conducting research
design
construction
testing,
starting up,
operating,
periodically surveilling the equipment, facilities, and processes,
maintaining,
shutting down,
transitioning to new missions
deactivation and decommissioning
Alarm response and emergency procedures delineate the steps to take when an abnormal
condition exists. Alarm response procedures signal when operations approach
established safety margins, allowing appropriate intervention prior to encountering
conditions that are more serious. Emergency procedures detail the responses when safety
margins have been breached or seriously jeopardized. Both alarm response and
emergency procedures are based upon systems design specifications, safety analyses,
hazards analyses, process flow diagrams, and vulnerability studies.
Summary
Procedures communicate direction for performing work when the consequences of that
work are important to safety, quality and regulatory compliance. For many types of
work, the use of procedures is required by regulation or corporate policy. To support
effective safe work, procedures must be based on the work to be done, hazards or
business vulnerabilities associated with that work, appropriate requirements, standards
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and expectations. The purpose of a procedures management system is to control the
development and maintenance of procedures so that individual procedures and the
collective set of procedures support effective, safe work throughout the organization.
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Principle 4: Authority and accountability for the procedure system and for
individual procedures are defined.
The procedure system includes development, review, approval, distribution, use,
maintenance and retirement of procedures. Authority and accountability should be
defined for each of these elements of the procedure system. In addition, authority and
accountability should be assigned for individual procedures to ensure procedure quality
and to promote procedure ownership. The organization should formally assign authority
for performing tasks associated with the procedure system and individual procedures.
Accountability is assigned to individuals deemed capable by experience, knowledge and
training to perform certain functions for an organization. They have demonstrated they
can perform assigned functions and that the organization and the individual(s) have
agreed that assigned functions will be performed as expected.
In some instances, authority and accountability may be assigned to different individuals
or organizations for each of the procedure types. This separation may be warranted
because of the differences in the development and administrative processes for the
procedure types, to afford greater attention on each type of procedure, or to support
organizational structures (e.g., assigning responsibility for technical procedures to an
operating division and management control procedures to an administrative function).
Procedure system accountability
Authority and accountability should be established for the procedure system. Although
the overall procedure system may have distributed elements, authority and accountability
should be clearly described. Assignment of authority and accountability is also important
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Process accountability
No single individual or organization can ensure that all needed procedures are generated
or that all procedures remain current, accurate, and complete. Management must ensure
that procedure-related operating experience information is directed into the procedure
system so that necessary revisions or improvements may be made. Collectively, all
designated procedure owners are held accountable for ensuring that procedures within
their purview are developed as necessary and updated:
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Technical reviewers share the responsibility for making sure that all elements of
procedures are true and accurate representations of the work, hazards, workplace, the
requirements, and work experience.
Validation personnel are responsible for ensuring procedures, in final form, are
usable in the actual environment where the work is to be accomplished.
The owning organization is responsible for the content, usability and final review.
The owning organization confirms that the procedure remains responsive to the
original purposes and to the requirements and standards being implemented.
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Principle 5: The procedure process begins with identifying the need for
procedures.
Not all work requires procedures, nor do procedures add value to the performance of all
work. Training or day-to-day supervision, for example, may be more appropriate and
effective for many work activities. Therefore, the first task in a procedure process is to
determine which activities need or would benefit from a procedure and to determine the
most efficient form of the procedure (for example, traditional 8 x 11 step-by-step, or
electronic procedures, job aids, operator aids, decision aids, checklists). This
determination is made considering such factors as risk, work experience, lessons learned,
informed judgments, capability and constraints (for example, available technology).
Procedures are warranted when any one of the following criteria is met:
TO REDUCE RISK: When work entails risk to the worker, public, environment or
the organization. This criterion is important when any of the following conditions
exist:
-
In addition, procedures may be warranted for reducing significant business risks, e.g.,
financial or legal liability, intellectual property loss, loss of company-sensitive
information.
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identifiable basis. However, the bases documents vary. For technical procedures,
documents such as hazards analyses and design specifications are principal information
sources. For management control procedures bases documents tend to be regulations,
standards, and best practices.
An essential step in the procedure process is to pull together or identify the need for
current, accurate, complete bases from which to write procedures. The bases may contain
any or all of the following based on the work:
Standards basis
Management control basis
Technical Basis
Design and Authorization bases
Work Process definition
Human Performance basis
Operating Experience
Procedure Interfaces
Standards basis
A goal of ISM is to have all DOE activities governed by sufficient sets of standards to
provide protection during the accomplishment of work. Standards bases are included in
approved ISM System Descriptions and listed by contract in Lists A and B. Contracts
typically identify requirements and standards that are important for management control,
technical and emergency procedures. The standards basis is derived from the work and
the hazards (or vulnerabilities) and furnishes essential input from which to develop
procedures.
Administrative programs,
Operational programs,
Technical support programs,
Contracts,
Memoranda of Agreement/Understanding.
Technical Basis
The technical basis for procedures includes the documents that establish the boundaries
within which normal and emergency operations can be performed safely. The Technical
Basis includes the design and authorization bases, work process definition, and operating
experience.
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The design and authorization bases for procedures include design and
construction criteria, materials, design engineering drawings and specifications,
hazards analyses, documented safety analysis reports, unidentified safety
questions (USQ) documents and vendor information. The Authorization Basis
may also include facility permits, emergency plans, waste management plans,
pollution prevention plans, quality management plans, conduct of operations
plans and, in cases of multiple user facilities, tenant agreements.
Operating Experience
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Procedure Interfaces
A new procedure or a change to an existing procedure may impact related procedures.
The development process should include identifying interfaces with existing procedures
and a means to determine if changes are needed to existing procedures to ensure that the
collective set of procedures is integrated.
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the procedure development process will ensure participation of all those needed to
provide a thorough knowledge of the work and its hazards and those to perform work and
human performance task analyses. This expertise must also involve those involved in the
performance and outcome of the work addressed by the procedure. In addition to
ensuring this primary expertise, the process must also ensure the development process
includes persons knowledgeable about the ISM system, the procedure system, the
development and use of bases, and the organization's documentation standards. Further,
guidelines should address how participants will be qualified on these related topics.
Development guides
The DOE has issued a DOE Technical Standard for developing technical procedures,
DOE-STD-1029-92 "Writers Guide for Technical Procedures." DOE and contractor
organizations can use this standard or tailor guides for their specific circumstances.
While the Writers Guide is oriented to technical procedures, the basic concepts presented
are useful for developing other types of procedures as long as the application of the
concepts is based on the nature of the work involved and the skills, knowledge and
experience of those who will perform the work. Tailored development guides should
define a procedure process, describe guidelines for presenting procedures (content,
format, and style) and include a plan for managing the records generated.
Document Structure
- Document layout (how to structure the document presentation to increase
comprehension and usability)
- Page layout (how to use headings, white space and typographic techniques to
increase performance and quality)
- Language (how to use terminology, reading levels and sentence structure to
enhance understanding and usability)
- Common error types (knowledge of common errors made when using procedures
and strategies for preventing these)
Use of alternative media to present procedures (e.g., electronic media, paper hard
copies),
Graphical presentations (the use of non-narrative formats such as tables, figures,
graphs, and forms) to better articulate required actions and documentation,
Alternative presentation structures (such as job performance aids) to optimize human
performance.
These design concepts, much like the management principles that define the procedures
program, are the fundamentals from which the development guides are built.
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For technical procedures, some level of simulation of the actual practice is used. At the
highest level of confidence validation involves use of a mock up or simulator in which
the actual steps are practiced. At the next confidence level is a walkdown, in which
personnel take the procedure to the location where the task is to be done and, without
actually performing the task, ensure that each step is correct and readily useable as
written. At the lowest level of confidence, validation is an analytical review that does not
simulate actual operation, but validates the procedure based on the knowledge and
experience of the reviewers.
Whereas all procedures are validated, the level of confidence needed differs with several
factors:
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Expedited revisions
In addition to supporting routine changes introduced as part of regular operations, the
revision process also includes an expedited process for reviewing and approving
procedure changes whose urgency demands immediate resolution. The ability to modify
procedures expediently is key to maintaining the highest standards for worker safety,
performance, and responsiveness to changing regulations or commitments.
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A process for canceling existing procedures is also established to provide a method for
ensuring that procedures that are no longer necessary or no longer used are effectively
removed from the system.
Make sure procedures are provided in a timely and disciplined manner to the users,
Maintain and ensure retrievability of records of the procedures development and use,
Match production resources to the numbers and complexity of procedures generated
and to the distribution needs,
Maintain an effective link between the procedure system and the training program.
Principle 12: A document control and delivery system ensures that the correct
and current versions of procedures are available for use.
An important part of the overall procedure system is controlled delivery to ensure that the
correct and current version of a procedure is available where and when needed. Control
of procedures should be an integral part of an organization's document control system.
Several elements are needed to properly control procedure distribution: a procedure
index, standardized distribution lists, a method for providing receipted control, and a
delivery system commensurate with the volume and types of procedures.
Procedure index
A procedure index lists all approved procedures, listing at a minimum the procedure
name, number, and revision. This list is maintained to ensure that the most current
version of the procedure is used to perform the task. Because selecting an outdated or
superseded procedure is a frequent cause of procedure-related human performance error,
the index is not only a basic administrative control but also allows procedure users to
locate the correct, current, and approved procedure.
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Each of these attributes carries specific requirements for reproduction activities, access
control, and delivery administration. Therefore, several factors - not only the number of
procedures or the number of procedure users - demonstrate why document control is
recognized as integral to the overall procedures system.
Delivery lists identify the location where controlled procedures are available. These lists
may be structured on a procedure-by-procedure basis or may be grouped in support of the
work (for example, by institution, facility or activity). These lists are maintained to
ensure that those who use the procedure receive the appropriate procedure and
subsequent revisions.
The receipt system - which is often accomplished by written receipts or computer records
from electronic distribution - records which version of the procedure has been issued,
identifies each controlled copy of a procedure, provides notifications and updates when
procedure changes are released, and logs the procedures back -if a mandatory return
program is used.
An index of procedures,
Controlled delivery lists for hard copy or electronic distribution,
Mechanisms for documenting and monitoring custodial assignments,
Production and distribution capabilities.
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procedure history files that document the bases and decisions made in the
development of the initial procedure and its revisions,
superseded versions of procedures,
feedback records generated following use of the procedures,
periodic reviews.
Identifies and collects designated procedure materials as part of the ongoing records
program.
Allows for retention and retrieval of interrelated procedure materials (superseded
revisions, development materials) as part of an overall effort to document the
historical integrity of operations.
Ensures personnel are knowledgeable of records requirements and deliver materials
to the records program in an appropriate and timely fashion.
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During all phases of the document life cycle, it is important that information is available
on the status of a document (whether in development, review, revision, etc.), the current
version of the document, the availability of the document (for example, where it can be
accessed), and who has ownership and custodial responsibility for the document. For
these reasons, allocation of appropriate information management support services is a
significant contributor to establishing and maintaining an effective procedures program.
Procedure production,
Tracking of commitments, requirements, and procedure bases documentation,
Document control and records activities,
Procedure duplication and distribution,
Continued technology reassessment and upgrades to the procedure management
program.
Managers training
Managers responsible for the work are trained on:
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Most importantly, the training emphasizes that procedures, as with systems, equipment
and tools, should be owned by managers and workers who are accountable for their
proper production and use.
operation by procedure,
how the procedure process works,
the employees obligation in ensuring the integrity of the procedure system.
Training on specific procedures is also provided and training logic and resources (for
example, simulators) made available, consistent with objectives of the procedure system.
Qualification
In addition to training, the organization should establish provisions to determine that
managers, procedure developers, procedure reviewers and procedure users are qualified
to perform their responsibilities. Qualification factors include knowledge and experience,
the level of supervision involved in assigned tasks and whether assigned tasks will be
performed individually or by a team.
Management,
Procedure users,
Procedure developers,
Procedure Reviewers.
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