DOE ORDER 450.3|
Use of Necessary and Sufficient Process
- OBJECTIVE. This Notice transmits DOE M 450.3-1, THE DEPARTMENT OF ENERGY
CLOSURE PROCESS FOR NECESSARY AND SUFFICIENT SETS OF STANDARDS (Necessary
and Sufficient Process), and provides requirements and guidance for
transition to widespread use of the Necessary and Sufficient Process. Use
of the Necessary and Sufficient Process is not mandatory; however, if the
Necessary and Sufficient Process is used, adherence to the Process described
in the Manual is mandatory. The Department of Energy (DOE) developed the
Necessary and Sufficient Process with an awareness that the relationship
among the Department's work, associated hazards, and requirements and
standards has not always been clear. By working across program lines and
using the Necessary and Sufficient Process to build agreements on standards
into the front end of work planning, DOE believes that Departmental Elements
can overcome this difficulty.
Standards-based work involves four activities:
- definition of work and hazards,
- identification of standards,
- performance of work in accordance with standards, and
- performance assessment.
The Necessary and Sufficient Process involves the first two of these
- APPLICABILITY. The Necessary and Sufficient Process is one example of the
Department's commitment to using integrated management systems to ensure
adequate protection for workers, the public, and the environment. Not every
activity, facility, or site must use the Necessary and Sufficient Process.
Where appropriate or required, Standards/Requirements Identification
Documents (SRID), Safety Analysis Reports (SAR), and equivalent approaches
may be used to meet this commitment. To avoid duplication of effort and
rework, many sites may "stay the course" with these other approaches.
- The Necessary and Sufficient Process can be used
to determine whether
any new nonregulatory Environment, Safety and Health (ES&H) standard
should be applied to a given work scope. This may be particularly
useful when deciding whether to include new DOE Orders in management
and operating (M&O) contracts.
- Contract reform initiatives are intended to provide a flexible
approach to how work is performed in the DOE complex. One approach
being considered is substituting the approved set of standards
developed using the Necessary and Sufficient Process for the ES&H
requirements contained in standard contract clauses.
- The Department remains committed to rulemaking for nuclear safety
requirements of general applicability. The Department intends to
propose revisions to its rule on exemption procedures to provide for
appropriate consideration of judgements, reached through the Necessary
and Sufficient Process, that particular DOE rule requirements do not
contribute to the achievement of adequate protection in particular
- In implementing the Necessary and Sufficient Process, a transition
period will be required to develop the expertise and program
infrastructure to ensure that the Necessary and Sufficient Process
will be properly applied. During this period, it will be necessary
for management to carefully choose high-value candidate projects and
provide priority management attention and support. Such choices must
be consistent with the priorities set by the Department in
implementing its integrated safety management program. The following
considerations should guide these choices.
(1) Optimize benefits to the entire Department. Focus on work where
significant safety benefits or high dollar cost
savings/avoidance can be achieved by developing new or revised
sets of standards. One way to accomplish this is to apply the
Necessary and Sufficient Process to work conducted at several
facilities or sites so that resulting knowledge and benefits can
be shared. The Necessary and Sufficient Process has not been
approved for privatization.
(2) Take advantage of current experience. As a result of the
Department Standards Committee (DSC) authorized pilot
demonstrations, pockets of experience have been developed.
Management teams should integrate the experience and lessons
learned into future applications of the Necessary and Sufficient
(3) Achieve near-term successes. Focus on those types of projects
that build on established infrastructure, expertise, experience,
and enthusiasm to achieve near-term successes. Such successes
would serve to further validate the robustness and effectiveness
of the Necessary and Sufficient Process and provide more case
studies for the benefit of the Department as a whole. This
would also serve to quickly increase the number of people
qualified to apply the Necessary and Sufficient Process and to
speed the learning process for the rest of the Department.
(4) Capitalize on additional learning opportunities. Early
application of the Necessary and Sufficient Process to
activities where higher levels of uncertainty or complexity
exist will give the Department the opportunity to gain
additional valuable experience. This will address Stakeholder
concerns, and provide significant return on the Department's
investment in the Necessary and Sufficient Process.
The criteria described below should be used to determine the
overall benefit that would accrue from applying the Necessary
and Sufficient Process when several potential candidate projects
compete for resources. The criteria are intended to be
considered as a set, not as individual decision points.
Environment, Safety and Health
- The environment, safety and health basis for the work is
inadequate or non-existent.
- The Necessary and Sufficient Process can reduce confusion
stemming from multiple or conflicting standards.
Work Start-up or Restart
- Major business re-engineering.
- New design, construction, and/or activity.
- Excessive requirements.
- Business competitiveness.
- Tailored standards provide for equivalent performance.
- REQUIREMENTS. Management teamwork is essential in introducing the Necessary
and Sufficient Process across the Department. Therefore, during transition
to use of the Process, Secretarial Officers, Field Managers, and Contractor
Heads shall form line management teams to develop priorities for use of the
Necessary and Sufficient Process, to select initial Process applications in
accordance with these priorities, and to ensure that sufficient support is
available to conduct the Process properly. The DSC management training
course on the Necessary and Sufficient Process, "Necessary and Sufficient:
An Overview," is required for management team members.
Because the purpose of the management teams is to guide the transition, the
teams will not necessarily perform the same functions or consist of the same
individuals as the "Agreement Parties" or "Convened Groups" referenced in
DOE M 450.3-1. The Department Standards Committee (DSC) should be advised
of Necessary and Sufficient Process activities.
- Secretarial Officers, Field Managers, and Contractor Heads are
responsible for forming the line management teams.
- Management Teams.
(1) In guiding the transition to use of the Process, the management
teams are responsible for maintaining the correctness of the
Necessary and Sufficient Process and for (a) developing
priorities for use of the Necessary and Sufficient Process, (b)
selecting initial process applications in accordance with the
priorities, (c) ensuring that sufficient support is available to
conduct the Process properly, and (d) providing DSC approved
training on the Necessary and Sufficient Process.
(2) Management teams should deploy the Necessary and Sufficient
Process as follows:
(a) Communicate expectations to and provide training for those
involved in the Necessary and Sufficient Process to create
a common and accurate understanding of the Necessary and
(b) Redeploy existing resources to support application of the
Necessary and Sufficient Process.
(c) Consider resources devoted to the Necessary and Sufficient
Process an investment in the future. Improvements will be
realized in terms of both enhanced safety and operating
(d) Improve planning by applying available expertise and
developing the program infrastructure to ensure the
Necessary and Sufficient Process is properly executed.
(e) Initiate Necessary and Sufficient Process applications in
stages in accordance with deployment criteria and resource
(f) Optimize use of technical and management capabilities and
seek input from outside experts as appropriate. Input
from experts outside the Department is encouraged to
promote stakeholder confidence and build the available
(g) Establish mentoring programs across internal DOE
organizations to share Necessary and Sufficient Process
(h) Capitalize on similarities among activities across the DOE
complex while accounting for their differences. Maximize
information transfer regarding issues common to multiple
sites and Necessary and Sufficient Process lessons
learned. It may be helpful to use personnel from other
sites who have experience with the Necessary and
(3) Management teams should develop success indicators and
performance measures that provide DOE personnel, contractor
management, and other interested parties with objective indices
to determine the effectiveness of specific applications of the
Necessary and Sufficient Process. These success indicators and
performance measures should reflect the best knowledge of the
various elements of the Department and its contractors.
- The Department Standards Committee (DSC).
(1) The DSC will not have direct authority over application of the
Necessary and Sufficient Process. However, the DSC will
maintain and interpret the Necessary and Sufficient Process
description, which is contained in DOE M 450.3-1. The DSC will
also answer questions and help resolve problems regarding
application of the Necessary and Sufficient Process and will
remain involved in other aspects of standards management.
(2) The DSC owns and will maintain the training curriculum. In
addition, the DSC will provide training on the use of the
curriculum to those DOE and contractor personnel who are
responsible for training Necessary and Sufficient Process team
members. Mentoring and assistance are also available through
the DSC to assist with deploying any aspect of the Necessary and
Sufficient Process. Members of the management teams are
encouraged to participate in the mentoring program.
- CONTACT. Questions concerning this Notice should be addressed to the
Department Standards Committee at (301) 903-0077.
BY ORDER OF THE SECRETARY OF ENERGY:
ARCHER L. DURHAM
Assistant Secretary for
Human Resources and Administration
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Last modified Thursday, 28-Oct-1999 11:42:15 PDT