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Advantages of Using External Assessors. Management system compliance audits represent organizational learning opportunities for management system ownersOne of the more effective processes for evaluating fundamental ISM implementationA significant investment is made in planning for, scheduling and
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1. Advantages of Using External Assessors C. Schaefer, BNL
H. Kahnhauser, BNL
2. Advantages of Using External Assessors Management system compliance audits represent organizational learning opportunities for management system owners
One of the more effective processes for evaluating fundamental ISM implementation
A significant investment is made in planning for, scheduling and conducting assessments
Assessments cross multiple organizational boundaries
Program owners are resource constrained and need to optimize assessments
3. Advantages of Using External Assessors Factors affecting assessment optimization include:
Assessment scope
Assessment duration
# of Assessors (i.e., do I need one person or a small team?)
Assessment Team composition (on-site SMEs, external SMEs or both?)
4. RCD’s Approach to its Triennial Assessment Program 10CFR835 issued in 1993; 1st amendment issued in 1999: requires each M&O Contractor to audit each functional element of its radiological protection plan (RPP) every 3 years
The BNL RPP covers a wide array of radiological operations and activities
5. RCD’s Approach to its Triennial Assessment Program Scope of BNL RPP
Multi-purpose Laboratory
Large and small accelerators (C-AD, NSLS, ATF, Cyclotrons)
Bench top applications
Radiation generating devices
Isotope Production and Synthesis
Waste operations
Environmental Restoration
6. BNL RPP Functional Elements Radiological Work Planning and Radiological Controls
Entry and Exit Controls
Posting and Labeling
Release of Materials and Equipment
Area Monitoring (Contamination, Airborne)
Sealed Source Control
Instrumentation and Calibration
Internal and External Dosimetry
ALARA
Radiological Training
Nuclear Accident Dosimetry and Emergency Response
Reports to Individuals, Records
7. RCD’s Initial Approach to its Triennial Assessment Program (pre-1999) Utilize team of 3 support staff
Massive checklists based on 10CFR835 requirements and implementing guides
No reliance on line organizations or external organizations to provide program assessment support
every 3rd year dedicate 3-4 months for team to assess each BNL facility
Nothing done during the intervening years
8. A Change in Approach 1998: HFBR Tritium leak discovered
During the investigation discovered a Lab-wide RPP problem: lack of uniformity of program implementation
Self assessment approach found to be inadequate: not helpful in understanding underlying issues regarding program improvement
BSA awarded the M&O contract
1st Task: Overhaul the BNL RPP
Huge expectations for immediate improvement
9. A Change in Approach Working group formed
Multi-year effort to rewrite the BNL Radiological Control Manual and author site-wide Radcon procedures to drive uniformity of implementation
Massive retraining effort
Issue: How to measure the progress being made and the adequacy of the newly structured program?
Decided to bring in SMEs from other Labs to review/benchmark specific functional elements
Help us understand where we needed to be
10. A Change in Approach External assessors brought in:
PNNL (Radiological Training)
PNNL (Radiation Generating Devices)
PNNL (Contamination Monitoring)
PNNL (Emergency Exposures)
Battelle (Records)
ORNL (Airborne Radioactivity Monitoring)
Consulting companies (Internal Dosimetry, Reports to Individuals)
11. The First Couple of Years Broke up the 3-month “Team Approach” into targeted topical assessments
Initial assessments very “painful”
External assessors exposed additional program weaknesses
Submitted several NTS Reports
Not even close to implementing “best practices”
Use of external assessors to benchmark progress enabled a dialogue on what other labs were doing and why
12. Additional Benefits BNL Program no longer “insular”
Avoid the temptation to believe that all is well; rely on an independent opinion based on program document reviews coupled with field verification
Began to understand how other sites were addressing the same requirements
Networking
Time saved in “borrowing” and implementing approaches developed by other Labs
More aware of DOE’s general expectations
13. Examples of What We have Learned/Adopted Restructured Sealed Source Program tracking thresholds
Need to balance professional judgment and procedural prescription
Requirements implementation matrix to better manage program documents
14. Current Approach Continue to rely on external SMEs to conduct assessments of functional elements where they have expertise (e.g., Dosimetry, Bioassay, Instrumentation, Radiological Work Controls, etc.)
Use in-house assessors for areas where assessment criteria are simple (e.g., Records, Reports to Individuals, etc.)
15. Current Approach Conduct 2-4 assessments each year
This allows Management to sample program performance/maturity on an on-going basis
Make it a part of the Division’s Business Plan (pay for travel expenses, housing, per diem)
Provide “Reciprocity”
16. Using External Assessors: Conclusion Keeps the Program from becoming insular (“theological inbreeding”)
Provides an independent opinion
Helps uncover more subtle program weaknesses
Provides networking opportunities
Faster identification of best practices ? faster program maturity
17. Questions?