doc_fn: draftord/252/g2521-1.html
DocType: Draft
ID: DOE G 252.1-1
Title: Technical Standards Program
Summary:
Org: EH
Date_Issue: 06/08/1998
Date_Close:
VdkVgwKey: draftord-21
Directive: 252.1
Text:
DOE G 252.1-1, Draft REV.4
IMPLEMENTATION GUIDE
for use with
DOE O 252.1
TECHNICAL STANDARDS PROGRAM
ASSISTANT SECRETARY FOR
ENVIRONMENT, SAFETY, AND HEALTH
DRAFT GUIDE - FOR COMMENT FOREWORD
This Department of Energy (DOE) Implementation Guide is approved for use by the Office of
Environment Safety and Health (EH), Office of Nuclear Safety Policy and Standards, and is
available to all DOE Elements and their contractors.
Comments (recommendations, additions, deletions, and any pertinent data) to improve this
document should be sent to the following address:
Richard J. Serbu, Manager
DOE Technical Standards Program
Office of Nuclear Safety Policy and Standards, EH-31
Office of Environment Safety and Health
U.S. Department of Energy/CXXI
19901 Germantown Road
Germantown, MD 20874
Phone: (301) 903-2856
Fax: (301) 903-6172
e-mail: richard.serbu@eh.doe.gov
DOE Implementation Guides are part of the DOE Directives System and are issued to provide
supplemental information regarding the Department's expectations for fulfilling its requirements as
contained in Rules, Orders, Notices, and regulatory standards. Implementation Guides may also
provide acceptable methods for implementing these requirements. Implementation Guides are not
substitutes for requirements, nor do they replace Technical Standards that are used to describe
established practices and procedures for implementing requirements.
Implementation Guides are used to identify methods that DOE finds acceptable for implementing
the Department's requirements. Applicable standards and procedures are included in a list
following each chapter of this Guide. In addition, each chapter includes a list of references which
provide other sources of information. CONTENTS
FOREWORD . . . . . . . . . . . . . . . . . . . . . . . . . . . .i
CHAPTER I, INTRODUCTION. . . . . . . . . . . . . . . . . . . . .1
1. PURPOSE . . . . . . . . . . . . . . . . . . . . . . . . . . .1
2. DESCRIPTION OF DOE O 252.1 SUPPORTED BY THIS GUIDE. . . . . .2
3. VALUE TO DOE. . . . . . . . . . . . . . . . . . . . . . . . .3
4. FEEDBACK. . . . . . . . . . . . . . . . . . . . . . . . . . .4
CHAPTER II, APPLICATION. . . . . . . . . . . . . . . . . . . . .1
CHAPTER III, GENERAL INFORMATION . . . . . . . . . . . . . . . .1
1. TECHNICAL STANDARDS . . . . . . . . . . . . . . . . . . . . .1
2. TAILORING (GRADED APPROACH) . . . . . . . . . . . . . . . . .1
CHAPTER IV, GUIDELINES . . . . . . . . . . . . . . . . . . . . .1
1. IMPLEMENTATION OF PUBLIC LAW 104-113 AND OMB A-119. . . . . .1
1.1 Introduction. . . . . . . . . . . . . . . . . . . . . . .1
1.2 Applicable Documents. . . . . . . . . . . . . . . . . . .2
2. TECHNICAL STANDARDS PROGRAM MANAGEMENT. . . . . . . . . . . .3
2.1 Introduction. . . . . . . . . . . . . . . . . . . . . . .3
2.2 Applicable Documents. . . . . . . . . . . . . . . . . . .5
3. SCREENING AND SELECTION OF TECHNICAL STANDARDS. . . . . . . .5
3.1 Introduction. . . . . . . . . . . . . . . . . . . . . . .5
3.2 Applicable Documents. . . . . . . . . . . . . . . . . . .6
4. USING TECHNICAL STANDARDS . . . . . . . . . . . . . . . . . .6
4.1 Introduction. . . . . . . . . . . . . . . . . . . . . . .6
4.2 Applicable Documents. . . . . . . . . . . . . . . . . . .7
5. PARTICIPATION ON NON-GOVERNMENT STANDARDS BODIES (NGSBs). . .7
5.1 Introduction. . . . . . . . . . . . . . . . . . . . . . .7
5.2 DOE Representation. . . . . . . . . . . . . . . . . . . .8
5.3 Applicable Documents. . . . . . . . . . . . . . . . . . .8
6. CONVERTING DOE TECHNICAL STANDARDS INTO NON-GOVERNMENT
STANDARDS. . . . . . . . . . . . . . . . . . . . . . . . . . . .8
6.1 Introduction. . . . . . . . . . . . . . . . . . . . . . .8
6.2 Applicable Documents. . . . . . . . . . . . . . . . . . .9
7. DEVELOPING AND MAINTAINING DOE TECHNICAL STANDARDS. . . . . .9
7.1 Introduction. . . . . . . . . . . . . . . . . . . . . . .9
7.2 Reasons to Develop and Maintain DOE Technical Standards 10
7.3 Applicable Documents. . . . . . . . . . . . . . . . . . 10 CONTENTS (continued)
8. ESTABLISHING AND PARTICIPATING IN DOE TOPICAL COMMITTEE . . 11
8.1 Introduction. . . . . . . . . . . . . . . . . . . . . . 11
8.2 Reasons for Topical Committees. . . . . . . . . . . . . 11
8.3 Applicable Documents. . . . . . . . . . . . . . . . . . 12
CHAPTER V, ADDITIONAL INFORMATION. . . . . . . . . . . . . . . .1
CHAPTER I
INTRODUCTION
1. PURPOSE
This Guide describes the management system and procedures by which DOE complies with
the requirements of Department of Energy (DOE) Order (O) 252.1, TECHNICAL
STANDARDS PROGRAM, and the Federal law and Federal policy the Order implements.
It does not create any new requirements.
The Guide also outlines the basic elements of the Technical Standards Program (TSP) and
how it functions in the areas of policy and program development, technical assistance, and
communications/outreach to (1) provide basic services and infrastructure necessary to DOE
and its contractors in the areas of Technical Standards management, and (2) provides basic
processes for developing or identifying Technical Standards for use by DOE Elements in
their operations, facilities, contracts, requirements identification documents, work smart
standards sets, safety analyses, and other authorization and safety analysis documents.
Documents managed under the TSP include DOE (technical) standards (both full
coordination and limited coordination), specifications, handbooks, Technical Standards lists,
and TSP procedures. The Guide does not describe a new program - the TSP described here
has been in existence for the past several years.
While the TSP provides management of one basic element of the four elements of the DOE
Directives System (Policy, requirements, Guides, Technical Standards), it is managed
separately from, but consistently with, the other Directives System elements. This Guide
describes this separate management system.
DOE O 252.1, covered by this Guide, provides the continuing basis for managing the
activities of the TSP, including
a. identifying existing voluntary, Government, and DOE Technical Standards for use in
DOE programs and activities;
b. screening proposed Technical Standards for need;
c. developing, coordinating, approving and issuing DOE Technical Standards;
d. printing, distributing, and providing Internet access to DOE Technical Standards;
e. converting, modifying, revising, canceling, and reaffirming DOE Technical Standards;
f. participating in Government and non-Government standards bodies (NGSBs) and
Technical Standards development activities on behalf of DOE, and reporting such
participation;
g. ensuring that Technical Standards-type documents are developed within the TSP and
unauthorized documents are controlled;
h. encouraging and supporting mission-related participation in DOE Technical Standards
activities by organizations and individuals;
i. supporting participation on DOE topical committees by DOE's subject matter experts,
and
j. managing program information and data bases.
2. DESCRIPTION OF DOE O 252.1 SUPPORTED BY THIS GUIDE
This Guide supports the implementation of DOE O 252.1, which accomplishes the
following:
a. Establishes the means and responsibilities for DOE to conform with the Federal
requirements related to Technical Standards as established in Public Law (PL) 104-113,
the National Technology Transfer and Advancement Act of 1995 (also called the
NTTAA), which codifies Federal Technical Standards policy contained in Office of
Management and Budget Circular A-119 (OMB A-119), "Federal Participation In the
Development and Use of Voluntary Consensus Standards and in Conformity
Assessment Activities," 2-10-98.
b. Establishes a Department-wide system for managing Technical Standards activities and
issues in a uniform, efficient and effective manner, for both DOE and contractor
elements.
c. Reorganizes and reduces the number of requirements in the TSP by eliminating those
requirements that are redundant with existing Public Law and Federal and DOE policy;
converting existing requirements to an outcome-oriented format; consolidating
essential requirements in a new format; and moving many of the "how" details from
DOE 1300.2A to a program guide and TSP procedures. In doing so, it also revises and
updates DOE organizations and responsibilities to reflect reorganization to the current
DOE structure and functions.
d. Establishes a key component of the infrastructure necessary for the Department to
conform with the "Criteria for the Department's Standards Program", with the
Technical Standards portion of the Department Directives System, and DOE's Safety
Management System.
e. Implements Departmental commitments made to the Defense Nuclear Facilities Safety
Board (DNFSB) in response to DNFSB Recommendation 91-1, "Strengthen Nuclear
Safety Standards Program."
f. Establishes the TSP as a principal path for the transfer of DOE's new and emerging
technologies to U.S. industries, and for making private sector technology available to
DOE.
3. VALUE TO DOE
In providing the means to implement the requirements of DOE O 252.1, this Guide also
provides for implementation of the Federal requirements related to Technical Standards
established in PL 104-113 and Federal policy and requirements contained in OMB A-119 for
DOE. The Guide also provides the means for conformance with the hierarchy of elements
and related requirements described in the DOE Directives System during the conduct of
Technical Standards activities.
In a DOE, Federal, national, or international venue, the DOE use of the private sector's
voluntary standards serves as a means to establish a common language of measurement,
enhance interoperability and ease of communications in commerce, make private sector
technology available within DOE, and reduce overall costs for the Government.
Virtually all major DOE Elements are routinely involved in Technical Standards activities
and need to devote resources to these activities to meet their business needs. The lack of a
DOE-wide Technical Standards Program would necessitate that each DOE and contractor
element develop and maintain individual programs or efforts to fulfill operational and
technical needs. The existence of multiple programs can certainly result in diverse and
sometimes incompatible processes for developing and approving Technical Standards within
the Department, and with this, the potential for developing Technical Standards that lack
credibility and technical acceptance by oversight organizations, industry, standards
development organizations, and other DOE Elements. Such proliferation, diversity and
inconsistency would also contribute to greatly increased management costs accompanied by
decreased efficiency and effectiveness in the management and coordination of various DOE
missions as well as Technical Standards activities. Legal liabilities are another concern
where inappropriately developed Technical Standards are employed by a contractor, or
mandated for use by a DOE program office.
Additionally, with Technical Standards activities and functions embedded among many
physically separate and separately managed Federal and contractor organizations, DOE
would still lack a central venue for assessing and verifying conformance with existing and
newly formulated public law and Federal Technical Standards policy, reporting overall DOE
activities in accordance with law and policy, and dealing with DOE-wide Technical
Standards issues. The TSP provides a centralized, yet cross-cutting program, that can
efficiently manage these matters in a manner acceptable to and agreed upon by the entire
Department.
The use of Technical Standards is a proven technique to maximize safety and efficiency in
the design, construction, and operation of facilities. Using Technical Standards also greatly
enhances technology transfer and standardizes work processes to produce consistent and
acceptable results with the greatest cost efficiency. Technical standards are a primary means
for industry and Government to introduce new technology and perform work more safely
and "faster, better, cheaper." Contractors can incorporate Technical Standards that reflect
technologies and management systems that best fit their technical needs and corporate
personality through such means as "Work Smart" standards sets.
The TSP's arrangement of topical committees also provides a venue for the Department's
subject matter experts to communicate and coordinate Technical Standards activities
independently of the organization of the Department's elements or its assignment of missions
and functions. This provides a cost effective and easily managed way to maintain a pool of
expertise across DOE and retain a DOE "corporate memory" for many of our technical
areas.
4. FEEDBACK
Users of this Guide should provide feedback to the Technical Standards Program Office
(TSPO) on the successes or difficulties encountered in the application of this Guide. (See
Chapter V for contacts.) CHAPTER II
APPLICATION
This Guide applies to all Technical Standards activities carried out on behalf of DOE or in support
of DOE missions and functions. In that the TSP reflects PL 104-113 and OMB A-119
requirements related to Federal Technical Standards activities, the TSP and the Guide serve DOE
Federal Technical Standards interests. The Guide does not apply to DOE contractors' internal
standards development processes where these purely serve contractor needs. However, since
many Technical Standards activities are carried out by DOE's contractors to meet DOE missions
and functions, many contractor activities related to the development of DOE Technical Standards
and the review of Technical Standards for DOE do fall under the TSP and this Guide. Some
Technical Standards activities are conducted solely on behalf of contractor organizations. Yet
others are conducted solely on behalf of individuals, and not related to their employment by DOE.
Where participations with SDOs do not involve expenditure of DOE resources (time, money,
effort), they are not covered by this Guide.
The intent of the TSP in standards development is that all DOE Technical Standards are
technically acceptable to the community of subject matter experts, and programmatically
acceptable to Departmental managers who use these Technical Standards. This is ensured by
developing DOE Technical Standards through a DOE-approved process, where procedures
ensure that openness, balance of interest, and due process are an integral part of the standards
development process, and DOE-wide coordination is the rule. Departmental directives and
standards policy requires the participation of all key stakeholders in Technical Standards
development - it is not acceptable for individual DOE organizations to develop and impose
standards that receive only very limited participation or outside technical review from other
Federal and contractor organizations. Nominal DOE "Technical Standards" developed outside of
approved DOE TSP processes (often called "rogue standards") may have inherent technical and
legal vulnerabilities for their sponsors and users. Inappropriately founded nuclear safety standards
may additionally be subject to challenge from the DNSFB and possibly intervention under the
Price-Anderson Act where technical inadequacies create safety problems.
The activities covered by the DOE TSP and discussed by this Guide include screening, selecting,
identifying, adopting, developing, reviewing, resolving comments for, approving, revising,
updating, converting and canceling Technical Standards. Also covered are participating in non-
Government standards development and on non-Government Technical Standards organizations
in the interests of DOE, and the tracking and reporting of: (1) the use and non-use of non-
Government standards by DOE, and (2) participation in non-Government standards development
activities.
The provisions of this Guide and the requirements in the Order are implemented through a central
TSPO and designated Technical Standards Managers (TSMs) participating as part of a DOE-wide
Technical Standards Managers' Committee (TSMC), as described below. The TSPO and TSMC
develop and approve a set of Technical Standards Program Procedures (TSPPs) that provide the
details for implementing PL 104-113, OMB A-119, DOE O 252.1, and general standards
management processes.
This Guide provides general information, methods, and TSPPs that DOE finds acceptable to meet
requirements applicable to the Department as defined in PL 104-113, OMB A-119, related DOE
policies, DOE O 252.1, and the Directives System. The Guide applies to all Technical Standards
development and reviews performed by DOE, and by its contractors in support of DOE missions
and functions. Using this Implementation Guide is not mandatory unless it is specifically stated in
a requirements document, contract, or DOE-approved implementation plan.
CHAPTER III
GENERAL INFORMATION
1. TECHNICAL STANDARDS
As defined in PL 104-113, Technical Standards are "performance-based or design-specific
technical specifications and related management system practices" that are developed and
adopted by voluntary consensus standards bodies. OMB A-119 expands the PL 104-113
definition of standards (meaning Technical Standards) to include: (1) "common and repeated
use of rules, conditions, guidelines or characteristics for products or related processes and
production methods, and related management systems practices;" and (2) "the definition of
terms; classification of components; delineation of procedures; specification of dimensions,
materials, performance, designs, or operations; measurement of quality and quantity in
describing materials, processes, products, systems, services or practices; test methods and
sampling procedures; or descriptions of fit and measurements of size or strength." DOE
describes Technical Standards in a manner similar to OMB A-119 as a prescribed set of
criteria concerned with: classification of components; delineation of procedures;
specification of materials, products, performance, design, or operations; and definitions of
terms or measurements of quality and quantity in describing materials, products, systems,
services, or practices. It should be noted that the PL 104-113 definition is consistent with
and inclusive of the TSP use and definition of Technical Standards.
There are two categories of Technical Standards used by DOE: non-Government and
Government Technical Standards. Non-Government Technical Standards are also referred
to as voluntary consensus standards. Such standards are developed through consensus of
experts recognized by national and international professional and technical societies, using
structured and formal processes and procedures, and their technical adequacy has been
proven through years of use. These standards extend through technical, management, and
procurement areas. Examples include standards developed by non-Government standards
bodies such as the American Nuclear Society, the American Society of Mechanical
Engineers, the American Society for Testing and Materials, and the Institute of Electrical
and Electronics Engineers. Consistent with the policy in OMB A-119, voluntary consensus
standards are the Technical Standards of choice for DOE facilities, projects, and programs.
Government standards are those written and maintained by Government agencies like DOE
and the Department of Defense.
DOE Technical Standards include DOE (technical) Standards (Full Coordination and
Limited), Specifications, Handbooks, and Technical Standards Lists, as discussed in the
DOE TSPPs.
2. TAILORING (GRADED APPROACH)
A primary purpose of the TSP is to support the use of private sector technology through the
selection and use of voluntary standards developed by non-Government Standards
Development Organizations (SDOs). DOE and its contractors can tailor the selection of
Technical Standards to match identified work and hazards. This Guide identifies primary
resources and key processes available for DOE sites, facilities, and activities to select
Technical Standards graded to their needs (a "graded approach").
When there are no existing, technically adequate voluntary (or Government) standards to
meet the Department's needs, non-Government SDO's are available to work with DOE to
initiate a new standard or to convert a proposed DOE technical standard into a voluntary
standard. A further preference is to use existing Government standards in lieu of developing
another similar DOE Technical Standard. CHAPTER IV
GUIDELINES
1. IMPLEMENTATION OF PUBLIC LAW 104-113 AND OMB A-119
1.1 Introduction
Federal law and policy establish objectives and requirements for Federal agency use of
Technical Standards and involvement in Technical Standards activities. Their intent is
to establish common standards for Government and industry, promote interoperability,
and enhance U.S. competitiveness in world markets. Use of voluntary consensus
standards also serves to eliminate Federal standards development costs, serve broader
national needs versus limited agency needs, promote efficiency and competition
through harmonization, and encourage Government reliance on the private sector for
goods and services.
The DOE TSP is driven by Federal law and policy, implemented through a DOE Order,
conducted using TSP Procedures, and managed through EH's TSPO working in
conjunction with a DOE-wide Technical Standards Managers Committee (TSMC) and
topical committee chairs. The general structures and processes for program
management and information management are outlined in this and following chapters of
the Guide.
DOE's work involves operations, products and services that must meet established
standards. Many such standards, appropriate or adaptable for DOE's purposes, are
available from NGSBs. DOE participation in the standards-related activities of these
NGSBs provides incentives and opportunities to establish standards that serve national
needs. Use of voluntary standards and NGSBs also reduces the cost of DOE
developing its own standards.
a. PL 104-113. PL 104-113, approved on March 7, 1996, essentially codifies the
policy provisions of OMB A-119. It also imposes requirements and conditions
for the use of voluntary consensus standards by Federal agencies. The Law
directs Federal Technical Standards development efforts towards working SDOs
to develop or adopt non-Government standards, and away from internal
development of Technical Standards. It encompasses technical, management, and
procurement areas of standards use and development.
The processes and procedures described in this Guide establish the means by
which DOE can uniformly meet the requirements in PL 104-113 related to
screening and using Technical Standards, tracking and reporting participation in
NGSBs, and justifying the use of internal standards to OMB.
b. OMB A-119. OMB A-119 sets the policy codified in PL 104-113 for all Federal
agencies, including DOE, that must be implemented by these agencies. For DOE,
this includes such specific matters as: (1) establishing a preference for using
voluntary standards (non-Government standards) in lieu of DOE Technical
Standards when such voluntary standards are adequate and appropriate for the
intended application; (2) actively soliciting and working with NGSBs to develop
voluntary standards that will meet the needs of the DOE when such standards do
not exist; (3) actively working with appropriate NGSBs to convert DOE
Technical Standards into voluntary standards, and (4) reporting DOE
participation in non-Government standards activities and explaining (essentially
justifying) the use of Technical Standards developed internally by DOE to OMB.
By including contractor elements involved in DOE Technical Standards activities
under the TSP, DOE has established a common means of managing DOE
Technical Standards activities, avoiding the development of redundant, diverse
and inconsistent means for addressing Technical Standards activities and issues.
The TSP provides the means for the Department to meet the requirements of
OMB A-119 and to effectively manage its diverse Technical Standards functions.
c. Directives System. DOE's Directives System establishes the hierarchy of
requirements and guidance within DOE and recognizes that the Technical
Standards element is managed under Directives System policy through the TSP.
d. DOE O 252.1. The revised DOE O 252.1 (described in detail above) establishes
the DOE TSP as the central DOE function for managing Technical Standards
activities within the Directives System. It replaces DOE 1300.2A and its many
detailed requirements with a few generally performance-based requirements. The
accompanying Guide describes the TSP from a broader national and Federal
perspective, describes overall TSP management and processes (including
information management), and provides a link to the TSPPs.
e. Technical Standards Program Procedures. The TSPPs provide the specific
procedures used by the TSPO and TSMs to conduct routine business within DOE.
The TSPPs are initiated, developed, and approved by the TSPO and TSMs to
serve DOE needs.
1.2 Applicable Documents
1. Public Law 104-113, National Technology Transfer and Advancement Act of
1995.
2. OMB A-119, "Federal Participation in the Development and Use of Voluntary
Consensus Standards and in Conformity Assessment Activities," 2-10-98.
3. DOE O 252.1, Technical Standards Program
4. DOE-TSPP-1, DOE Technical Standards Program Responsibilities.
5. DOE-TSPP-2, Establishing the Need for a Technical Standard.
6. DOE-TSPP-3, Use of Non-Government Standards and Interaction with Non-
Government Standards Bodies.
7. DOE-TSPP-4, Registering a Technical Standards Project.
8. DOE-TSPP-5, Development of a New DOE Technical Standard.
9. DOE-TSPP-6, Coordination of DOE Technical Standards.
10. DOE-TSPP-7, DOE Technical Standards Comment Resolution.
11. DOE-TSPP-8, Approving and Issuing DOE Technical Standards.
12. DOE-TSPP-9, Maintenance of DOE Technical Standards.
13. DOE-TSPP-10, Conversion of DOE Technical Standards to Non-Government
Standards.
14. DOE-TSPP-11, Technical Standards Program Topical Committees.
2. TECHNICAL STANDARDS PROGRAM MANAGEMENT
2.1 Introduction
The DOE TSP is centrally organized as the TSPO and managed by the DOE TSP Manager
within EH. Individual TSMs are designated for each major DOE and contractor
organizational element. The TSP is coordinated with the Directives System and Department
Standards Committee through EH management, and with Federal activities via the DOE
Standards Executive. Program management and information management are directed
through three main functions: policy and program management; technical assistance; and
communications/outreach activities.
a. DOE Standards Executive. OMB A-119 requires that each Federal agency appoint a
Standards Executive (representing their Secretarial Officer) to provide a focus for
standards activities within each agency and represent that agency with the Interagency
Committee on Standards Policy (ICSP). The DOE Standards Executive is currently
appointed by the Assistant Secretary for Environment, Safety and Health, and supports
the TSP and Department Standards Committee in the conduct of their standards related
programs.
b. Technical Standards Program Office. The TSPO provides the overall management of
the TSP for DOE through EH. A DOE TSP Manager is assigned responsibility for the
overall conduct of the program and coordinates with appointed headquarters, field, and
contractor TSMs.
c. Technical Standards Managers. TSMs provide the field implementation network and
the communication network for the DOE TSP, enabling the transfer of relevant
program information to and from all DOE Elements and DOE contractors.
Each major DOE Element and DOE contractor organization can (and should) be
represented in the TSP by a designated TSM. It is recommended that the TSM (and
the designated alternate) be a senior staff member experienced in the application, use
and development of standards. It is important that the TSM have a working
knowledge of the pertinent activities conducted within DOE and its contractor
organizations (and of the pertinent disciplines required to conduct those activities), and
have a proven ability to effectively communicate.
In addition to a designated TSM, modest other resources are needed to properly satisfy
the responsibilities of the TSM functions. Within budgetary and mission constraints,
active participation by the TSM in all appropriate DOE TSP activities is encouraged.
Many organizations have consolidated their Directives System activities, Technical
Standards activities, and requirements development activities in a single point of
contact. Selecting an effective TSM is one of the most important actions that can be
taken to meet the requirements of DOE O 252.1 and to provide effective support for an
organization's Technical Standards activities.
d. Technical Standards Managers Committee. TSMs also participate in developing,
approving, and implementing TSPPs and processes, and identifying and resolving
Technical Standards issues by participating on the TSMC. The TSMC, consisting of
80-90 designated TSMs representing all major DOE and contractor elements, meets
routinely to discuss Technical Standards issues, conduct strategic and program
planning, and analyze program performance. The TSMC serves as a de facto DOE-
wide process action team for TSP program improvement and analyzing and resolving
DOE-wide Technical Standards issues. Participation in and ownership of the DOE
TSP for DOE and its contractors is achieved through the TSMs' involvement in the
TSP and TSMC.
e. Topical Committees. DOE Topical Committees are groups of DOE and contractor
subject matter experts recognized and chartered under the TSP. Groups from such
diverse areas as metrology, fire protection, quality assurance, construction safety, and
laboratory accreditation have organized under the TSP's Topical Committee
provisions. The process enables like-minded subject matter experts to cooperate on
Technical Standards activities on a DOE-wide basis, and provides a focus for technical
interaction. The Topical Committees function independently of but in support of line
organizations under the aegis of the TSP. These groups are formed "ad hoc" and from
existing DOE and contractor working groups, such as the TRADE Special Interest
Groups (SIGs), and focus on technically related standards activities (e.g., standards
reviews) within DOE and from national and international venues. The groups are
generally organized under a Chairperson in conjunction with a steering committee, and
are open to qualified DOE and contractor technical personnel.
2.2 Applicable Documents
1. DOE-TSPP-1, DOE Technical Standards Program Responsibilities.
2. DOE-TSPP-11, DOE Topical Committees.
3. SCREENING AND SELECTION OF TECHNICAL STANDARDS
3.1 Introduction
Technical standards are used for a variety of purposes, including establishing a "work
smart" (necessary and sufficient) set of requirements, establishing a uniform process for
conducting an activity, developing procedures, defining specifications, and conveying
technical knowledge. Technical standards have been developed in a wide range of
technical and programmatic areas by non-Government standards development
organizations, and are readily available for use within DOE. Their use enables DOE
contractors to apply the best and most appropriate private sector technologies to DOE
missions and hazards. The TSPO services include providing lists and information on
many of these standards for DOE users.
Consistent with PL 104-113 and the policy in OMB A-119, DOE processes and
procedures give preference to using voluntary standards (or working with NGSBs to
meet Department needs by modifying existing voluntary standards) in lieu of
developing its own standards. Because they represent a consensus within public and
private sector interests on acceptable work processes and methods, voluntary standards
will usually have a broader degree of acceptance than DOE Technical Standards.
To meet the intent of law and policy, DOE Element managers will need to carefully
screen each proposed technical standard topic before proceeding with a DOE internal
development effort. The TSP can help by providing lists of voluntary standards that
apply to a given topical area, and by putting staff members in touch with appropriate
NGSB topical committees. It is anticipated that there will be very few occasions that
DOE Elements and DOE contractors will be unable to find adequate voluntary
standards to satisfy their needs. In the event that this does occur, DOE Technical
Standards may be developed and used to address a Department need.
3.2 Applicable Documents
1. DOE-TSPP-2, Establishing the Need for a Technical Standard.
2. DOE-TSPP-3, Use of Non-Government Standards and Interaction with Non-
Government Standards Bodies.
4. USING TECHNICAL STANDARDS
4.1 Introduction
Using Technical Standards in the design, construction, testing, modification, operation,
decommissioning, decontamination, and remediation of DOE's facilities, programs, and
projects can save time and effort, reduce duplication of work, improve health and
safety, provide for standardization, and conserve resources, thereby increasing overall
Department efficiency. Pitfalls in using existing voluntary standards include subscribing
to "old" or very limited technology and generating a de facto "technology freeze" by
using only technology that is reflected in a voluntary standard. There may also be a
qualitative difference among voluntary standards, with quality ranges from "fair" or
"adequate" to "excellent" or "outstanding."
The DOE Technical Standards developed under the TSP are available through the TSP
home page on the Internet at the following URL:
http://apollo.osti.gov/html/techstds/techstds.html
where they can be viewed and printed, and in some cases, downloaded to a file. A
limited number of DOE Technical Standards are printed and available from the Office
of Scientific and Technical Information. Voluntary standards are generally not
available through DOE, except where DOE organizations have subscriptions services
with particular standards development organizations (SDOs) or commercial standards
information services. Access to data base lists of SDO standards is possible through
the TSP home page list of SDOs and "hot links" to their home pages. The National
Standards System Network (NSSN) provides links to many SDO lists of standards, and
with an appropriate subscription, can provide access to many voluntary consensus
standards. The TSP can also access its commercial services to provide lists of
Technical Standards relevant to a given topical area.
PL 104-113 and OMB A-119 require that DOE give preference to using voluntary
standards over Government Technical Standards unless their use would adversely affect
performance or cost, reduce competition, or have other significant disadvantages, such
as being inadequate for an agency regulatory role. Technical Standards are not
mandatory unless they are specifically invoked in a requirements document, such as a
DOE Order, or until a contractor commits to use them in an implementation plan, a
contract, or a set of "work smart" (necessary and sufficient) standards that are mutually
agreed upon with DOE. This provides the contractors with some flexibility in
determining "how to" implement DOE requirements by choosing Technical Standards
that are suitable for specific applications.
No matter how carefully conceived and developed, Technical Standards cannot address
all eventualities. Therefore, DOE and its contractors must critically assess the
Technical Standards in use at DOE facilities to ensure that they remain consistent with
the latest information arising from operational experience and developments in science
and technology.
4.2 Applicable Documents
1. DOE Technical Standards Program Procedures Overview.
2. DOE-TSPP-2, Establishing the Need for a Technical Standard.
3. DOE-TSPP-3, Use of Non-Government Standards and Interaction with Non-
Government Standards Bodies.
5. PARTICIPATION ON NON-GOVERNMENT STANDARDS BODIES (NGSBs)
5.1 Introduction
Participation by DOE and DOE contractor personnel on NGSBs (also called SDOs)
can be mutually beneficial to DOE, other elements of the public sector, and private
industry. Consistent with PL 104-113 and the policy in OMB A-119, DOE encourages
and supports the participation of DOE and DOE contractor employees in SDO
activities related to Departmental missions and functions. Such participation can help
the Department establish a uniform internal position on particular voluntary standards,
and can also help in establishing a uniform interagency position on particular Standards
and Standards issues, in accordance with OMB A-119. Participation in the Standards-
related activities of SDOs provides incentives and opportunities to establish standards
that serve national needs, and the adoption of voluntary standards eliminates the cost to
DOE of developing its own Technical Standards.
Within DOE, various topical interest groups are being recognized under the TSP as
topical committees. With modest cooperation and consolidation, these topical
committees are expected to provide the forum for linking DOE to SDO topical
committees.
5.2 DOE Representation
It is in the best interest of the DOE to have personnel participating on NGSBs where
the effort is related to DOE missions and functions, and they have appropriate expertise
or where they can be involved in the development or revision of Technical Standards of
relevance to Department operations. Official DOE representatives that work on
NGSBs are designated and serve as official spokespersons for the Department.
Participation in NGSB activities on behalf of DOE is tracked through the DOE TSP.
When questions arise over a perceived conflict of interest over DOE participation with
an SDO working group, committee or board, a senior DOE manager should evaluate
the situation and provide guidance.
It is important to recognize that there is a difference between official DOE
representation and other participation by DOE employees and contractors in NGSB
activities. Many DOE employees and contractors, because of personal or professional
interests, are members of technical or professional societies and associations. Such
participation does not constitute official DOE representation; however, this type of
participation is encouraged because it fosters good relationships and interaction
between Government and industry.
5.3 Applicable Documents
1. OMB A-119, "Federal Participation in the Development and Use of Voluntary
Consensus Standards and in Conformity Assessment Activities," 2-10-98.
2. DOE-TSPP-3, Use of Non-Government Standards and Interaction with Non-
Government Standards Bodies.
3. DOE-TSPP-11, DOE Topical Committees.
6. CONVERTING DOE TECHNICAL STANDARDS INTO NON-GOVERNMENT
STANDARDS
6.1 Introduction
Consistent with OMB A-119 policy, DOE and its contractors should strive to have
DOE Technical Standards converted by appropriate SDOs and published as non-
Government (voluntary) standards. The TSP establishes processes and procedures for
conversion of DOE Standards.
There are potential benefits of having DOE Technical Standards adopted by a NGSB.
The first benefit is the reduction of costs associated with the maintenance of Standards.
The second, and probably more significant benefit, is that truly excellent Standards are
developed over time, continuously improved from feedback provided by those
individuals using them. The conversion of a DOE Technical Standard to a voluntary
standard provides exposure for that standard to other public and private sector interests
that would otherwise be unaware of it. Extensive circulation of the standard
encourages valuable feedback, presenting more opportunities to improve the standard.
Once the expense of developing DOE Technical Standards is incurred, it is in the best
interest of DOE to have its Technical Standards accepted by NGSBs for development,
coordination, and publication as voluntary standards.
6.2 Applicable Documents
1. OMB A-119, "Federal Participation in the Development and Use of Voluntary
Consensus Standards and in Conformity Assessment Activities," 2-10-98.
2. DOE-TSPP-10, Conversion of DOE Technical Standards to Non-Government
Standards.
7. DEVELOPING AND MAINTAINING DOE TECHNICAL STANDARDS
7.1 Introduction
When the need for a technical standard exists within the DOE community, and when an
adequate non-Government (or Government) standard does not exist to satisfy that
need, then the development of a DOE technical standard can be initiated using the DOE
TSPPs.
An individual within DOE who foresees the need for a DOE technical standard should
consult with his or her organizational TSM, review the TSPPs for information, or
contact the TSPO for guidance. The TSPO will provide information on available
voluntary consensus standards already existing and available from SDOs in the
technical area of interest. The organizational TSM will work with that organization's
management to confirm that there is a need to develop a DOE technical standard. Each
organization may also have to provide justification for their effort if existing voluntary
consensus standards are not used (this is necessary to comply with PL 104-113). Each
proposed Technical Standards project is registered and administratively processed
through the TSP. The TSP provides electronic posting and access to draft and final
DOE Technical Standards via the Internet. The organization sponsoring and preparing
the proposed DOE technical standard (the Preparing Activity) is responsible for
soliciting comments and conducting an adequate comment resolution. Final approval
of DOE Technical Standards comes from senior management within the Preparing
Activity, once all TSP processes have been followed. Appeals on comment resolution
or final approvals can be processed through the DOE TSP Manager.
Technical standards that are developed and used by DOE are almost always the
product of a recognized standards development process, conducted through a
legitimate review and comment resolution process involving recognized subject matter
experts. The overall process involves openness, balance of interest, and due process.
DOE Technical Standards developed outside of such a recognized process may not
have technical or programmatic credibility or acceptability with the DOE and
contractor line organizations, internal and external oversight organizations, or the
office of primary interest designated for the technical subject matter within DOE.
Documents developed under another forum (such as a technical report) and intended
for use as a technical standard (or any directive) are treated as unauthorized documents
(e.g., "rogue" documents) under the Directives System. The DOE TSP establishes a
uniform system, based on those of successful Government and industry standards
development organizations, for the development of DOE Technical Standards.
Once a DOE technical standard has been developed, it is assigned to an individual
designated by the cognizant "Preparing Activity" that developed the standard. This
individual is responsible for maintaining the technical and administrative currency of the
standard, and serves as the point-of-contact for that standard. DOE Technical
Standards are automatically subject to review on a 5-year cycle, and on an "ad hoc"
basis when there are changes in requirements, technology, and applications. A project
list of all current and in-development Technical Standards and the point-of-contact for
that standards is maintained by the TSPO. DOE Technical Standards can be canceled,
reaffirmed, revised, modified, and may be converted to voluntary consensus standards.
7.2 Reasons to Develop and Maintain DOE Technical Standards
DOE Technical Standards should be developed to satisfy a DOE requirement when
there is no existing voluntary (or Government) standard which would satisfy the
Department's needs, and a NGSB (or Government standards organization) is unable to
develop a technical standard to meet the DOE needs. Cooperative Research and
Development Activities (CRADAs) often result in technical developments that are
licensed for limited applications with private industry. These are seldom taken the next
step and converted to a technical standard. In some instances, a DOE technical
standard may be the most practical means to disseminate a new technology developed
within DOE to U.S. industry.
DOE Technical Standards are maintained and periodically reviewed under the TSP to
help ensure their technical currency and usefulness to the DOE community. A DOE-
wide review of each standard's technical and functional content by DOE's subject
matter experts helps ensure that these standards reflect the latest technology and best
practices, and help meet DOE work and safety requirements.
7.3 Applicable Documents
1. OMB A-119, "Federal Participation in the Development and Use of Voluntary
Consensus Standards and in Conformity Assessment Activities," 2-10-98.
2. DOE-TSPP-4, Registering a Technical Standards Project.
3. DOE-TSPP-5, Development of a New DOE Technical Standard.
4. DOE-TSPP-6, Coordination of DOE Technical Standards.
5. DOE-TSPP-7, DOE Technical Standards Comment Resolution.
6. DOE-TSPP-8, Approving and Issuing DOE Technical Standards.
7. DOE-TSPP-9, Maintenance of DOE Technical Standards.
8. DOE-TSPP-10, Conversion of DOE Technical Standards to Non-Government
Standards.
8. ESTABLISHING AND PARTICIPATING IN DOE TOPICAL COMMITTEES
8.1 Introduction
The DOE TSP sponsors and recognizes selected topical committees where such groups
can support Technical Standards review and development activities directly related to
DOE missions and functions, and provide cooperative interaction with counterpart
representatives from SDOs and other Federal agencies in the interests of DOE.
Membership is open to DOE and contractor personnel with technical, programmatic,
and managerial interests in a given technical area. Each topical committee functions
under a TSP approved charter operating under the principles of openness, balance of
interest, and due process. General information on currently recognized topical
committees and contacts for these groups is available on the TSP home page.
Information on forming a DOE topical committee from an existing interest group or a
newly formed interest group is available from the TSPO. A "how-to" manual
(pamphlet) is referenced below.
8.2 Reasons for Topical Committees
DOE topical committees serve as a focus for DOE subject matter experts in a variety of
technical areas. The topical committees provide a "corporate memory" and a
cooperative venue that can maintain continuity through reorganizations and "right-
sizing" efforts. They function in concert with program offices with managerial
responsibilities in technical areas, and can serve as a ready technical resource for those
organizations. They primarily serve as a reviewing entity for DOE for Technical
Standards related to their area of expertise, and can serve as a preparing activity for
Technical Standards at the behest of a sponsoring DOE organization. DOE topical
committees can also serve as a link and contact point with their technical counterparts
in SDOs and in other Federal agencies. They also provide a means for DOE subject
matter experts to remain abreast of and participate in technical developments in their
areas of interest.
8.3 Applicable Documents
1. DOE-TSPP-11, DOE Topical Committees.
2. "Forming a DOE Topical Committee: A How-To Manual," Sandia National
Laboratories, 7-4-97.
3. DOE-TSPP-3, Use of Non-Government Standards and Interaction with Non-
Government Standards Bodies.
CHAPTER V
ADDITIONAL INFORMATION
For site-specific questions concerning the implementation of DOE O 252.1, contact your DOE or
DOE contractor organization TSM. You can find his or her name listed on the TSP home page
under Technical Standards Managers.
For additional information about the DOE TSP, contact the TSPO, managed by the Office of
Environmental Safety and Health, Office of Nuclear Safety Policy and Standards. The TSP
Procedures are also available through the TSP home page. For general questions concerning the
implementation of DOE O 252.1, or for questions concerning the contents of the Implementation
Guide, contact Rick Serbu 301-903-2856 or Jeff Feit 301-903-3927.
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