Oversight

To proceed with the topic of this section. Refs. 250 and 251 provide oversights of the application of contemporary surface science and bonding theory to catalytic situations. The development of bimetallic catalysts is discussed in Ref. 252. Finally, Weisz [253] discusses windows on reality the acceptable range of rates for a given type of catalyzed reaction is relatively narrow. The reaction becomes impractical if it is too slow, and if it is too fast, mass and heat transport problems become limiting. 

Quahty assurance must remain independent of manufacturing so that problems can be reported freely to upper management without fear of retribution. QA should have oversight responsibihty for QC. A reporting stmcture helps to ensure the independence of both quahty units and conforms to both Good Manufacturing Practice (GMP) and ISO 9000 requirements. 

Authorize states to manage the RCRA Subtitle C program, in whole or in part, within their respective borders, subject to EPA oversight... 

Equally important, the contractor s cost-estimation team will have established a sharply honed, systematic approach including all the correct checklists, forms, and report formats designed to preclude oversights. The team will have developed the discipline, as a result of competitive bidding, to produce the kind of final report that fits in correctly with any type of economic evaluation. 

For other CERCLA sites the proeess ean be very different from the typieal DOE site. The proeess may start with various phases of site assessments. The intermediate step may be a pilot study, followed by a pilot plant operation, or possibly a removal aetion or other alternative. The final steps may vary widely. However, just as in DOE sites, the appropriate rule or requirement depends on the site-speeifie faeility or operation, the assoeiated hazards, and the potential for worker exposure to the hazards. For the Army Corps of Engineers eleanup or oversight, the rules will most likely be even more stringent than for OSHA or DOE. 

Contractors and subcontractors are typically required by contract to be responsible for their own workers and should provide a level of oversight to meet all specifications. The primary contractor who is responsible for the worksite typically establishes the minimum requirements, controls access to the worksite, and verifies that subcontractors fulfill their health and safety duties and responsibilities. Wlien these specifications are defined, all contractors and subcontractors should meet or exceed these requirements, as appropriate. This could be based on the nature of the assigned tasks and associated hazards [2]. 

The responsibilities of contractors and subcontractors have been the subject of much debate. Therefore, it has become more commonplace for clients, who may have in-house personnel and resources adequate to perform cleanups, to hire subcontractors. These subcontractors could include all of those mentioned in the previous example, along with an oversight contractor. All of these subcontractors could bill the client directly for services or could bill the oversight contractor. Typically,... 

Let s take another example. Under DOE, when the M O contractor has oversight responsibility for other prime contractors, the M O... 

Other signatures may also be required. Eor example, if there are sub-eontraetors who will be performing site work, a representative from the subeontraeting firm should review and approve the plan. If the site has oversight eontraetors present, is eomplieated, large in size, or ineludes work that is projeeted to take plaee over a long period of time, there will likely be additional approvals required. 

The Site I subeontraetor also laeked a baekup safety and health supervisor fully trained in site safety and health management. The aeting health and safety speeialist (HSS) at Site E was a site worker who had held the position for one week. This individual stated to the audit team that he did not meet the eorporate or SSAHP qualiheations required to hold that position. Apparently, while the Site E eontraetor was waiting for the results of the LTEV performanee test and the unit was not in operation, site management determined that less health and safety oversight was needed. 

The audit team found that at Sites B and H, safety and health personnel had suflfieient authority in most eases to thoroughly implement the safety and health plans. To faeilitate safety and health eom-plianee, anyone who entered Site H, ineluding delivery personnel, was required to view a brief video that summarized the site history and remediation operations, identified the hazardous substanees monitored on site, and deseribed site evaeuation proeedures. Site B s SSAHP did not mention speeifie subeontraetors and their roles and responsibilities however, it did indieate that the prime eontraetor had oversight responsibility for all safety and health aetivities and the authority to diseontinue or modify site operations when unsafe eonditions were deteeted. 

The contractor at Site H had established area and personnel sampling consistent with HAZWOPER requirements. A photo ionization detector (PID) and a real-time aerosol monitor (RAM) were used on a daily basis to screen for potentially hazardous levels of contaminants. On a weekly basis, personal air samples were collected and submitted for laboratory analysis. PPE requirements, however, were often not based on this data because the oversight agency had established inflexible minimum PPE requirements. The audit team found many of the PPE requirements on Site H to be excessive in light of site monitoring data and hazard determinations. 

MORT Management Oversight and Risk Tree analysis lohnson, 197.1... 

The disa.ster brought an awareness for the potential hazards of the Kerr-McGec plant, just 0.7 mile from the center of town. Such was expressed at a hearing held by the Subcommittee on Investigations Oversight of the House Committee on Science, Space Technology... 

If an element has no system at all, it may indicate that the facility manager does not fully understand what the element requires, or is for some reason unable to cany his/her responsibilities. In addition, a weakness in corporate oversight, direction, or resource allocation may contribute to the problem. Either way, the plan you develop must take these gaps into account. 

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