Do all changes in the worker safety and health program require DOE approval before they can be implemented?
Response: No, Contractors must submit an update to their program to the Head of the DOE Field Element for approval whenever a significant change or addition to the program is made. In determining whether a change is significant and an update is warranted, contractors should consider whether the change is needed to ensure the program accurately reflects actual workplace activities and related hazards and controls or approved program roles and responsibilities. Such changes would be considered significant and would require program update and submittal. Changes should not be implemented until approved. Other changes to the program, that do not meet the significant criteria, can be included in the annual update. As general guidance the term significant change, which requires an update to the Worker Safety and Health Program (WSHP) submittal, means that if a hazard associated with a change in the worksite or processes, or any newly recognized hazards is not effectively controlled by the mea
