1. DOE’s Worker Safety and Health Enforcement Program Kevin Dressman, Director Office of Worker Safety and Health Enforcement Office of Enforcement Office of Enterprise Assessments U.S. Department of Energy

2. 2 4/6/15 Office of Resources, Communications and Congressional Affairs Eric G. Nicoll, Director Barbara R. Stone, Deputy Director Office of Resources, Communications and Congressional Affairs Eric G. Nicoll, Director Barbara R. Stone, Deputy Director Office of Enterprise Assessments (EA) Office of Enterprise Assessments Glenn S. Podonsky, Director William A. Eckroade, Deputy Director Office of Enforcement Steven C. Simonson Director Office of Cyber Assessments William F. West Director Office of Security Assessments Pernell B. Watson Director Office of Cyber and Security Assessments John S. Boulden, III Director Office of Environment, Safety and Health Assessments Thomas R. Staker Director Office of Worker Safety and Health Enforcement Kevin L. Dressman Director Office of Nuclear Safety Enforcement Jon H. Thompson Director Office of Security Enforcement Steven G. Crowe Director Office of Emergency Management Assessments Vacant Director Office of Nuclear Safety and Environmental Assessments William E. Miller Director Office of Worker Safety and Health Assessments Patricia Williams Director Office of Outreach and Analysis Mari-Josette Campagnone Director National Training Center Karen L. Boardman Director Office of Risk Analysis and Program Evaluation Vacant, Director Office of Risk Analysis and Program Evaluation Vacant, Director EA-1 EA-1.1 EA-1.2 EA-10EA-20 EA-11 EA-12 EA-13 EA-21 EA-22 EA-30 EA-31 EA-32 EA-33 EA-40 EA-50

3. 3 DOE’s Safety and Security Enforcement Program  DOE’s Regulatory Framework  Enforcement Philosophy  Approach and Process  Lessons Learned

4. Section 234C of the Atomic Energy Act established DOE’s regulatory authorities DOE’s Worker Safety and Health Program rule – 10 C.F.R. Part 851 DOE-approved WSHP before commencing work Invokes Title 29 and NFPA codes and standards as enforceable requirements DOE contractors (including subcontractors) are required to comply with the rule and are subject to enforcement actions and penalties ($80k per violation). DOE’s Worker Safety and Health Enforcement Program – Regulatory Framework

5. 5 DOE safety excellence starts with compliance with requirements. Contractors are expected to recognize and correct noncompliant conditions before worker injury or an event. Contractors perform critical self-evaluations and implement other proactive issue identification processes. Contractor causal analysis reflects the significance of the issue and corrective actions should prevent recurrence. DOE incentivizes these behaviors through discretion and mitigation. DOE’s enforcement process functions as a deterrent. DOE initiates enforcement activity for safety-significant violations. DOE’s enforcement process promotes learning from operating experiences. DOE’s Enforcement Philosophy

6. 6 DOE’s Safety and Security Enforcement Process Case SelectionNotice of Intent to InvestigateOnsite InvestigationInvestigation ReportEnforcement Conference Outcomes No action Enforcement Letter Notice of Violation Settlement Compliance Order

7. 7  Ensure work is performed within the defined scope  Use the hierarchy of controls  Engage Subject Matter Experts in work planning and control  Communicate DOE regulatory expectations to subcontractors  Use assessments to identify noncompliances before they result in events and worker injury/illness  Perform causal analyses to drive in-depth understanding of contributors and extent of conditions  Design corrective actions to prevent recurrence Lessons Learned from Enforcement Activities

8. 8 Additional Information Enforcement Program Regulations (10 CFR Part 851, Appendix B) Enforcement Process Overview (EPO) and Enforcement Coordinator Handbook (ECH) http://www.energy.gov/ea/services/enforcement/enforce ment-program-and-process-guidance-and-information DOE/NNSA Enforcement Outcomes http://www.energy.gov/ea/services/enforcement