Working Group # 3 – Subcontract Work

1. Working Group #3 – Subcontract Work Objectives (1 and 2 combined) Electrical Safety Compliance Resource web site Universal web-based tool for effective work planning Build and Share Best Practices Collection for 851 Compliance Proposal for Code and Standard updates to become the norm

2. The Dream Diehard Team • John Kruse-FNAL • Mauricio Burgos – ANL • Alan Tatum-ORNL • Jim Watson – LLNL • Jeff Williams – NNSA-Los Alamos

3. EFCOG Working Group #3 Objective 1.a Universal web-based tool for effective work planning

4. Vision of Objective 1.a • Web based tool(s) available for use by all M&O and subcontract work providers • Implement and build on best practices already in place • Enhance Electrical Safety Work Planning for consistently high performance • Quickly identify and provide the detailed hazards and controls for import to local integrated work management documents • Therefore independent of technology platforms in use at sites

5. Work Planning and Hazard Control Tool • This tool is for demonstration purposes, it is not vetted for use by DOE contractors. • http://apps.ctc.com/esafe-pro/

6. Example Use Cases for Online Tool • Laser Power Supply – Mode 2 TS&R • DC Hazards – 175 Volts, 3Amp • Hazard Class 2.2.c • Engineering Controls (Listed or Approved) • Admin Control (LOTO) • Arc Flash – N/A • 2 workers with SOP • PPE – Class 00 gloves • Capacitor Hazards (500 micro farad) • 3.2.b • Engineered Controls • Ground Hook

7. Example Use Cases for Online Tool • 480VAC 3-phase, 2000kVA transformer • Category 1.3.b • MCC, 25kA Short Circuit Current • Clearing time 120 mS • Mode 1 • Control – contact AHJ for PPE, 2-person, SOP

8. Strategy for 1.a • Identify a DOE or M&O host • Obtain the source code/platform for the DOD tool • Identify an EFCOG team to load desired material and validate functionality • Beta test resource at select sites, revise if needed • Prepare for full release – “press release” to sites, with POCs (AHJ or delegate) etc. • Garner high level support and visibility through execution of Objective 2 using the Lab Management Council, PSOs and other executive level communications • Long term management proposed as a NNSA “Corporate Behavior” activity.

9. EFCOG Working Group #3 Objective 1.b Build and Share Best Practices Collection for 851 Compliance

10. Vision of Objective 1.b Compilation of tools, techniques and processes to utilize for continuous improvement of 851 compliant electrical (both M&O and Subcontracted) work • Simple, “grab and go” type tools to aid ESOs, work planners, project planners and oversight personnel responsible for safe execution of electrical work • The “go to site” for electrical work

11. Vision of Objective 1.b cont. Examples • Corporate (DOE Complex) bin • Severity Index Tool • Handbook • Safety Practices (supply and location of AEDs) • Training Resources for Subs and others • General Tools for work execution • Smart Card (cheat sheet from JHA for field use) • Hazard class specific “cheat sheets” (class-specific guide or checklist for work scoping and planning) • Subcontract management tools • Training verification and validation tools • WSHP, LOTO, DOPs • Previous site/DOE experience of work provider • Equipment (Tools and PPE) validation for scope of work

12. Strategy for Achieving 1.b • Subgroup 3 will build the initial collection, host on same web site with the tool • Tools and other articles can be submitted to the subgroup, periodic updates • Subgroup will revisit and review use of the tool each year at the EFCOG committee meeting • All items will be provided with a short description and credits to the site/contractor that developed the item • Options for hosting this document server: • NTC – NNSA has a large IT contingency in ABQ and NTC already hosts the online training and reciprocity database • One of the NNSA labs, under the guise of the “corporate behavior incentive fee activities” • Other suggestions??

13. EFCOG Working Group #3 Objective 2 Proposal for Code and Standard updates to become the norm

14. Vision of Objective 2 • All DOE sites are implementing either the latest versions of NEC and 70E, or one revision back • Web based tool(s) available for use by all M&O and subcontract work providers • Implement and build on best practices already in place. • Streamline 851 compliance for consistently high performance • Establish a basis for continuous improvement and a model for other 851/WSHP segments • Decision paper to Lab Management Council and DOE PSO’s.

15. Road Map of Electrical Safety Requirements in 851 • 10 CFR 851 (2006) • NFPA 70 – 2005 (currently at 2014 – 2017 in process) • NFPA 70E – 2004 (currently at 2015 – 2018 in process) • 70E-2009 requires revision of maintenance program to include overcurrent devices, 70B is a guide • 70E-2015 adds further standards as guides • 29 CFR 1910 (S) (operations) • 29 CFR 1926 (K) (construction) • DOE G 440.1-1B (2011) • DOE HDBK-1092-2004 (superseded by 2013) • Each DOE prime contract WSHP

16. GOAL – Drive Consistent and Efficient 70 E Current DOE status of 70 E compliance 2004 – 8 sites: SRS, SLAC, ORP, PNNL, ANL, BNL, ORNL (partially on 2012), FNAL 2009 – 4 sites: JLAB, RL, INL, LLNL JLAB =>2012 2012 – 6 sites: NREL, PORTS, PTX, SNL, LBNL, PPPL NREL, PTX, LBNL, PPPL, LLNL => 2015 2015 – 5 sites in process (above)

17. GOAL – Provide existing data and business cases for efficient 70 E revision adoption Gather completed impact analyses from all sites on all revisions after 2004 Maintenance Program Status relative to 70E? Who does / does NOT have a documented maintenance program that is faithfully executed Who is using or transitioning to 70B(Current Version – 2016) ?? TBD for the Winter 2016/17 meeting Complex-wide metrics should be considered for this and other key program effectiveness.

18. GOAL – Drive Consistent and Efficient NEC Implementation NEC 2014 compliance status ?? TBD – follow on to Greg C. data call Maintenance Program Status relative to 70E? Who does / does NOT have a documented maintenance program that is faithfully executed Who is using or transitioning to 70B(Current Version – 2016) ?? TBD for the Winter 2016/17 meeting

19. 851 Requirements • 851.10   General requirements. • (a) With respect to a covered workplace for which a contractor is responsible, the contractor must: • (1) Provide a place of employment that is free from recognized hazards that are causing or have the potential to cause death or serious physical harm to workers; and • (2) Ensure that work is performed in accordance with: • (i) All applicable requirements of this part; and • (ii)The worker safety and health program for that workplace. • (b) The written worker safety and health program must describe how the contractor complies with the: • (1) Requirements set forth in subpart C of this part that are applicable to the hazards associated with the contractor's scope of work; and • (2) Any compliance order issued by the Secretary pursuant to §851.4. • [71 FR 6931, Feb. 9, 2006, as amended at 80 FR 5009, Jan. 30, 2015]

20. Strategy for 2 • Include in next DOE Electrical Safety Handbook revision, a recommendation to update code and standard revisions at all sites as timely as possible, but no more than one revision back from the most recently released version. • EFCOG leadership and DOE to garner high level support through NNSA/DOE and Office of Science federal and M&O staff engaged in EFCOG.

21. 851 Requirements cont. • 851.23   Safety and health standards. • (b) Nothing in this part must be construed as relieving a contractor from complying with any additional specific safety and health requirement that it determines to be necessary to protect the safety and health of workers. “What is more protective of the Worker?”

22. Message to Senior Leadership • DOE needs excellence not minimum compliance • Compliance with latest revisions drives excellence in worker safety • Implementing the latest versions shows due diligence and best-in-class • Compliance to latest versions supported by tools to simplify work planning • That was Easy....

23. Message to Senior DOE and M&O Leaders • This approach will simultaneously: • Reduce 851 compliance risk • Ensure implementation of electrical safety requirements only as they apply to the work being contracted • Streamlineexecution of subcontracted electrical work through consistent implementation of requirements • Create a safer work environment for electrical workers • Establish meaningfulelectrical safety metrics across DOE • This approach will NOT: • Require adoption of non-applicable requirements • Require costly changes to existing site M&O processes • Require lengthy implementation or training

24. Anecdote From Pirates of the Caribbean, Curse of the Black Pearl • Elizabeth: Wait! You have to take me to shore. According to the Code of the Order of the Brethren... • Barbossa: First, your return to shore was not part of our negotiations nor our agreement so I must do nothing. And secondly, you must be a pirate for the pirate's code to apply and you're not. And thirdlythecode is more what you'd call "guidelines" than actual rules. Welcome aboard the Black Pearl, Miss Turner.