With its wide range of nuclear facilities, DOE expends considerable resources in managing the safety of its nuclear operations. Yet in terms of lost-time injuries, fatalities, and associated costs, the department's historical losses have been skewed heavily toward those attributable to exposure to conventional hazards, with construction a primary contributor. Beyond the moral imperative to improve safety in its operations, DOE has a significant economic interest beyond that of most public sector owners or contracting agencies, because, in most cases, it fully reimburses its contractors for worker's compensation costs and other casualty losses.

With its environmental restoration and waste management mission and significant projects in program areas such as energy research and civilian radioactive waste management, DOE has become the largest construction owner in the nation. Thus, the obligation to review the construction safety management practices of the past and develop more effective policies for the future is created.

The discussion that follows reviews the primary features of DOE's recently developed construction safety and health management policy, the issues and considerations involved in the development of this policy, and how the program deals with these issues. This discussion may help in the development or revision of agency or corporate policies dealing with the management of safety and health during construction activities.

Department of Energy Policy

The departmental directive in place since 1980, DOE Order 5480.9, prescribed little more than that "contractors bidding on or selected for DOE construction contracts" shall submit a "descriptive outline" of an appropriate program with ''adequate provisions for emergency aid, ... training, inspections, reporting, and certifying the safe operating condition of ... equipment'' acceptable to the contracting officer. It provided little detail on what constituted an acceptable program and it did not establish a management framework for DOE or its construction manager to ensure the effectiveness of the program at the project work site. Further, its objective was weighted strongly toward compliance with applicable standards and not toward the identification and control of project hazards, whether or not they were adequately addressed within the standards.

This policy, along with DOE's legacy of limited oversight of its contractors, led to construction safety programs with widely ranging degrees of effectiveness across the DOE complex. DOE's greater emphasis on environment, safety, and health in recent years, however, has caused many of its contractors to develop construction safety programs that go far beyond the requirements of existing departmental policy and has led to outstanding safety records in many locations. Yet there are also a number of locations with less-than-

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