Compliance programs procedure development process

Compliance includes the development and implementation of policies, programs, and procedures used to ensure compliance with DOE Orders as well as implementation and verification, of compliance. Requests for CSAs shall follow the procedure in the January 18, 1990, memorandum (Reference 1) from SRRO to SRSPO vfor the preparation and processing of CSAs. 

Assessing clinical and quality requirements of the proposed program also means planning for how to comply with these standards. Compliance should be considered both on an initial basis and over the long term. Clinical and quality requirements may necessitate the hiring of certain (qualified) staff, the development of work processes to monitor quality, and the implementation of technology or procedures to ensure compliance. 

With the exception of a list of PINCs for renewable energy, BOEM s procedures and requirements for inspecting and auditing an offshore wind farm s SMS are not yet well developed. As formal policies of inspections and audits are developed, BOEM will need to ensure that its inspection process places the responsibility of safety compliance on the lessee and not on BOEM itself through a checklist of PINCs. Internal or operator audits help a company internalize a safety culture and encourage ownership of the company s safety program. BOEM can ensure that the lessee s internal audits are conducted appropriately through its own audits. The next section discusses the importance of properly trained personnel. 

WSRC shall require that all changes to plant operations be evaluated through the Unreviewed Safety Question (USQ) process to determine whether a change to the SAR is required. Administrative procedures shall be in place to ensure that the plant is operated in accordance with the SAR at all times. Procedures shall also be in place to restore the plant to SAR compliance and to fully report and analyze any operational incident outside the SAR. The requirements in this section must be developed and Implemented before restart. In the interim, the Reactor Issues Management Program (RIMP) may be used to evaluate whether a change affects the SAR until the USQ process is formally implemented. 

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