Comment on FR Doc # E9-24929

October 24, 2009 Steven L. Krahn, Acting Deputy Assistant Secretary, Safety Management and Operations Environmental Management Office U.S. Department of Energy 1000 Independence Avenue, SW Washington, DC 20585-0121 RE: ID DOE-HQ-2009-0024-0001 Dear Mr. Krahn: In review of the above proposed rule from Hanford Challenge requesting the Department of Energy to initiate “Safety-Conscious Work Environment” guidelines in its nuclear facilities, it is prudent that beneficial feedback (recommendations and pertinent data) from the public address expectations, goals, accountability, sustainability and appropriate oversight. The current conflicts within the intra-groups of DOE bureaucracy and Hanford will continue to undermine any incoming written expectations and goals, especially without oversight and managerial transparent ethical practices. As with any strategic and innovative proposals, collaborative and harmonious partnerships should be sought through a core conceptual ethical decision-making oversight framework. To address high risk priorities in a safety-conscious work environment, collaborative oversight should include flow-down of accountability, increased management visibility, leadership training and increased management/employee communication through measurable increments. Additionally, the proposed rule did not address or assume that contractors already are aware of the compliance or its impact on occupational medicine coverage, liabilities, risks and compliance with Cal OSHA’s violations/amendments. A policy implementation should define the organization, its interpretations and applications in order to administer such a rule, during its language process. Without explicit language in the proposed rule for identifiable oversight tracking to trends, habitual or unreported incidents and program deficiencies and regulatory requirements typically found in a law or regulation into language that can ensure attainability of policy goals and objectives, there can be no reasonable expectation of achieving the stated goals of this rule. Developing resources for a self reporting and evaluation schematic system, multiple reporting requirements, tracking databases to support ongoing reporting and closeout requirements and facility upgrades to meet basic NFPA codes and health issues require mitigation and systems/equipment mechanisms to capture and manage risk findings in your organization. Designing core conceptual frameworks first can attract both internal and external factors and provide oversight to stay ahead of old frameworks that consistently display challenges in a technological 21st century. A core conceptual framework of these recommendations and comments would be an approach to move “out of the box” towards incremental re-examinations of strategic intervention measures. Respectfully Submitted, Diane Robinson University of La Verne, California Doctorate of Public Administration (A future scholarly student)